Privacy policy
PRIVACY POLICY - SKEELO
1. INTRODUCTION
This Privacy Policy aims to clarify and inform, in a transparent manner, how the “SKEELO EDITORA, PRODUTOS E SERVIÇOS DIGITAIS LTDA.” (“Nós” ou “SKEELO”), treats the personal data of the people with whom it interacts as Users, (from now on also called “You”) and how such data is collected, used, stored, processed and protected in the context of Skeelo E-books (“SKEELO” or “PLATAFORM”).
For the purposes of this Privacy Policy, SKEELO will be considered the Data Controller. Contact details are provided at the end of this Policy.
By registering or otherwise using the SKEELO PLATFORM or website, as well as clicking “I ACCEPT”, you agree with this Privacy Policy, with all its terms and conditions.
We recommend and encourage YOU to read this Privacy Policy carefully, as well as to regularly check this page and review it to remind and stay abreast of any changes that may be made to this Policy..
2. PURPOSES OF THE PRIVACY POLICY
2.1.We hope that the above will help you understand our privacy commitments to your personal data. In any case, for further clarification on the terms used in this Policy, contact us by any of the means listed at the end of this Policy..
2.2. We remind you that, if you do not agree with the content of this Policy, you may choose not to use our services.
2.3. The purpose of this Policy is:
(i) Ensure you understand why we collect and use your personal data and how it is shared;
(ii) Explain and provide transparency to which personal data are processed by us, their purposes and the processing operations to which these personal data are subject, in order to provide you with the best experience in relation to our services; and
(iii) Explain your rights and choices regarding your personal data that we collect and process and how we preserve your privacy and take care of your personal data.
2.4. In order to meet the objectives described above, we must carry out several specific data processing operations, among which are those relating to the processing of personal data of our Users, as indicated in the table in item 5 below.
3. PERSONAL DATA
Data provided by the User
3.1. The personal data that we process about our Users is listed below the personal data collected from the User for the purposes of registration and identification on our PLATFORM:
i) Name
ii) CPF
iii) E-mail
iv) cell phone number
v) Birth Date/p>
3.2. In addition to these, the user may provide additional personal data for specific purposes as shown in the table below, being them:
i) RG
ii) Addre
iii) Photo (Selfie)
iv) Digital
v) Motor vehicle license plate
Data Created from Using the PLATFORM
3.3. From the use of the PLATFORM, statistical data and general information regarding the traffic models applicable to the PLATFORM are maintained by SKEELO, in addition to other specific technical information related to the Platform and obtained from tools such as Google Analytics®, without such data can be configured as personal data, as they are merely statistical and technical for general use.
3.4. Personal data related to User book reviews, main books consumed on the PLATFORM, frequency of use of the application are collected and, based on that, measures are implemented that aim to increment and improve the services offered by PLATFORM and present more appropriate reading recommendations for each User.
3.5. Identification information may be provided or checked with SKEELO partner companies, such procedure being necessary to verify and guarantee, when applicable, the User access to the PLATFORM.
4. COLLECTION OF PERSONAL DATA
4.1. The data obtained by Us are mainly provided by the User himself, through registration and use of our PLATFORM.
4.2. Evaluation information made public by Users on platforms such as Reclame Aqui and social networks such as Instagram® may be collected in order to serve the User himself and, in general, improve the services provided by SKEELO.
4.3. Positive ratings in text, images or videos made public by Users may also be collected for the purpose of recording feedback, without any illegitimate distortion of the purposes for which they were made public in principle by the User.
Third Party Collection
4.4. In specific cases, partner companies may provide the benefit of access to SKEELO. In these cases, these partner companies may provide simple identification data for the User, so that we can confirm the identity and even inform the holder of the benefit available.
4.5. Currently, SKEELO partners with companies:
i) Claro S.A.
ii) Oi S.A.
iii) Claro NXT
iv) Tim S.A.
v) Sercomtel
vi) Link Cariri
vii) Sem Parar
4.6. The collection and sharing of data by companies partnering with SKEELO is the responsibility of the companies themselves. We only use this data for the strict purpose of offering and verifying the User suitability in accordance with the contracting plan with partner companies.
4.7. More information about partnerships with companies and guaranteed benefits can be found in our website and in ours Terms of use.
5. TREATMENT OPERATIONS AND THEIR PURPOSES
5.1. As mentioned, for our services to be provided, it is necessary to carry out several operations with the personal data mentioned above, depending on the product used by the User.
5.2. Listed below are the processes in which we use our Users personal data:
Purpose: Registration
Treatment operations: User Registration / Proof together with partners that the user has access to the Platform
Personal Data: Name; Telephone; Email; CPF; License plate (only in case of benefit granted by a partner and linked to cars); Contracting plan (Customers associated with partners)
Legal Basis: Contract Execution
Purpose: Serving and assisting Users
Treatment operations: User service / Contacting users to answer questions, suggestions or complaints / Contacting to complement poorly rated service
Personal Data: Name; Email; Telephone; CPF
Legal Basis: Execution of Contract / Legitimate Interest
Purpose: Analysis of suggestions, complaints and comments about the Platform to improve services and meet User demands
Handling operations: User evaluations and complaints in external media / User evaluation of services performed / User complaint analysis when trying to access the Platform and negative evaluations in general / User service evaluation form submission
Personal Data: Name; Telephone; CPF; Email; Evaluation Content
Legal Basis: Legitimate Interest / Contract Execution / Legitimate Interest
Purpose: Improvement of the products offered
Handling operations: List of suggested books by users saved in spreadsheet / User review spreadsheet / Behavioral analysis
Personal Data: Name; Email; Suggested books; Content of assessments
Legal Basis: Consent / Legitimate Interest
Purpose: Marketing
Treatment operations: Campaigns targeted by SMS and Push / Launching marketing emails / Sending communications to users (email and SMS)
Personal Data: Name; Email; Telephone; CPF; Date of birth
Legal Basis: Legitimate Interest / Consent
Purpose: Operationalization of the Platform and Services
Processing operations: Creation of reports for operators / Request to change the user registration data for developers / Transfer of rights for works acquired through user request / User telephone change sent via partners (operators) / Drawings for gifts and prizes - Promotional campaigns / Collection of videos that people record about the application / User board change sent via partners (Without Stop)
Personal Data: Name; CPF; Telephone/Area Code; Email; Date of birth; RG; Address (only in case of sending gifts and prizes); Vehicle license plate (only in case of benefit granted by a partner and linked to cars); Image and voice (in case of video recorded by the User for the application)
Legal Basis: Consent; Legal obligation; Contract Execution; legitimate interest
5.3. In addition to the data processing operations mentioned in the table above, the purposes for which we may process personal data, subject to applicable law, include:
i) Prevent and verify cases of suspected fraud, violation of rights or other illegal activities committed by the user;
ii) Comply with court orders or orders from competent bodies; or
iii) Fulfill legal obligations imposed on SKEELO
6. SHARING DATA WITH THIRD PARTIES
6.1. For the sole purpose of providing our services, serving the User and complying with our legal obligations, we may share some of the data received with third parties..
6.2. We may also share information with third parties who provide us with services such as website hosting, data analysis, payment processing, ordering, product distribution, infrastructure provision, IT services, User support, e-mail delivery services. mail, payment processing, auditing services, security checks and other similar services. We undertake to demand from any company hired by us the same level of security and compliance with the applicable legal standards assumed by us throughout our service provision.
6.3. In addition, we may disclose your personal data to:
i) Legal and regulatory authorities, upon determination or for the purpose of reporting any actual or potential violation of applicable law or regulation;
ii) Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or effectiveness of legal rights;
iii) Any party relevant to the prevention, investigation, detection or prosecution of criminal offenses or the enforcement of criminal sanctions, including safeguarding and preventing threats to public security;
iv) Any relevant third party(ies) acquirer(s), in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any part of the business, assets or shares, including bankruptcy or similar proceedings.
v) Employees and group companies, investors, business partners, Partner Institutions, agents and/or SKEELO service providers; and
vi) Any other third parties to whom SKEELO is obliged to share the information due to legal, contractual and regulatory obligations and/or whose disclosure of information is necessary or advisable for the proper, effective and efficient operation of the PLATFORM.
7. INTERNATIONAL TRANSFER OF PERSONAL DATA
7.1. Due to our structure and contracted services, it may be necessary to transfer your Personal Data to third parties, which will always be done in accordance with the objectives defined in this Policy.
7.2. For this reason, it may be necessary to transfer your Personal Data to other countries that may have different data protection laws and compliance requirements than those that apply in the country in which you are located..
7.3. Currently, we only transfer data internationally when necessary for storage in a database located in the United States of America and when we transfer your personal data we always do so in accordance with the General Data Protection Act (Law 13.709/18), establishing consistent contractual obligations. with the protection of personal data guaranteed by this law and in accordance with the practices defined by the National Data Protection Authority.
8. SECURITY
8.1. We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure and access, and other illegal or unauthorized forms of processing, in accordance with applicable law and in accordance with good market practices.
8.2. However, we cannot be held responsible for the way in which You choose to make your Personal Data available to us, and You are responsible for ensuring that any Personal Data you send us is sent with due security..
8.3. It is important to note that no technology system is completely secure or safe from tampering or hacking, and SKEELO is not responsible for security incidents resulting from such actions..
8.4. SKEELO establishes a series of appropriate physical, electronic and management processes to ensure the security of the information that is collected, including data encryption, whenever possible and feasible, all covered by the concept of Privacy by Design implemented by SKEELO in its performance
8.5. Os Usuários deverão colaborar com a manutenção de um ambiente seguro para todos, além de adotar boas práticas de segurança com relação a sua conta e seus dados. Caso os Usuários identifiquem ou tomem conhecimento de algo que comprometa a segurança dos seus dados, deverão entrar em contato imediatamente com a SKEELO.
8.6. In the event that SKEELO verifies that the security of the Users personal information has been compromised, they will be informed about what has happened through the contact means provided, especially by email.
9. COOKIES
9.1. Cookies are text files that are downloaded to your device when you visit a website or access applications ("Cookies"). These files are useful as they allow efficient navigation between pages, remember preferences and, in general, improve the user experience.
9.2. SKEELO may use session Cookies (which will expire after the User leaves the PLATFORM) and persistent Cookies (which will remain on Users devices until they are deleted) to allow identification and improve the quality of information that will be offered to Users, as per applicable, as well as to allow SKEELO to recognize the hardware and software equipment used in your device to better adapt the services provided and, in general, improve your experience throughout the use of the PLATFORM.
9.3. This Policy does not cover the use of Cookies by third parties, so SKEELO will not be responsible for the privacy policies and practices arising from these third parties. It is important to note that Cookies inserted by third parties may eventually continue to monitor online activities, even after they have left the PLATFORM environment.
9.4. If you do not wish to receive Cookies, You can program your devices to do so, if they have the necessary resources. However, by preventing the receipt of Cookies, some PLATFORM services and solutions may not work correctly.
9.5. The PLATFORM and website may contain links or references to other digital platforms, websites or applications that are beyond SKEELO's control. In this way, Users are aware that this Privacy Policy does not apply to other digital platforms, websites or applications that may exist, and it is the User's responsibility to verify the policy of these digital platforms, websites or applications..
10. QUALITY OF PERSONAL DATA
10.1. Your personal data that we process will be kept accurate and, where necessary, updated. We take all reasonable steps to ensure that:
i) Your personal data that we process is accurate and, where necessary, kept up to date; and
ii) Any of your Personal Data that we process that is inaccurate (considering the purposes for which it is processed) will be deleted or rectified as soon as the inaccuracy is identified, which is why we may, from time to time, ask you to confirm the accuracy of your Data. Personal.
11. NEED AND ADEQUACY (MINIMIZATION) OF PERSONAL DATA
11.1. We take all reasonable steps to ensure that your personal data processed is limited to the personal data necessary to achieve the purposes mentioned in this Policy..
12. DATA RETENTION
12.1. We will keep copies of your Personal Data in a form that allows identification only for as long as is necessary in relation to the purposes set out in this Policy.
12.2. All personal data kept on our PLATFORM for the purposes for which they are intended, as mentioned here, for the period that the purpose justifies the storage and use of the data..
12.3. The criteria for determining the duration for which we will keep your personal data include the general purpose of using our services, for the period in which You authorize or as long as You do not request the interruption of the processing and deletion of Personal Data, when such request does not imply disobedience of legal obligation imposed on Us and the processing of data is not based on another legal basis that authorizes us to maintain it.
12.4. On the other hand, we clarify that data must be kept for a minimum period of 6 (six) months, for the sole and exclusive purpose of complying with the Civil Rights Framework for the Internet.
12.5. For purposes of auditing and preservation of rights, SKEELO may keep the registration history of User data for a longer period, in cases that the law or regulatory norm so establishes or for the preservation of rights. The data preserved in the indicated condition will have its use limited solely and exclusively for the preservation of the mentioned rights.
12.6. If you wish to withdraw any authorization granted, you may do so using the contact information provided in this Policy..
13. YOUR LEGAL RIGHTS
13.1. In addition to the other rights guaranteed in this Policy, and subject to applicable law, we guarantee you:
i) The right to request access to or copies of your personal data that we process or control;
ii) The right to request rectification of any inaccuracies in your Personal Data;
iii) The right to request, as the case may be, the elimination of the Personal Data that we process or the restriction of the Processing of your personal data that we process or control;
iv) The right to object to the processing of your personal data;
v) The right to have your Personal Data transferred to another Controller, as applicable (portability);
vi) Where we process your personal data on the basis of your consent, the right to withdraw that consent; and
vii) The right to file complaints about the processing of your Personal Data to the National Data Protection Authority.
13.2. To exercise one or more of these rights, to ask any questions about these rights or any other provision of this Policy or about the Processing of your Personal Data carried out by Us, please contact us using the information provided in this Policy.
14. YOUR OBLIGATIONS
14.1. We rely on You to provide us with complete and accurate Personal Data about you so that we can provide you with the appropriate services..
14.2. We also rely on You to ensure that You are legally able to disclose Personal Data to us as set out in this Policy.
15. CONTACT INFORMATION
15.1. If you have any comments, questions or concerns about any of the information in this Policy, or any other issues related to the Handling of Personal Data by SKEELO, please contact the Responsible Department through:
E-mail: [email protected]
Telefone: (11) 5645-1100
Endereço: Rua Cerro Corá, 2175 - Vila Romana, São Paulo - SP, 05061-450
16. UPDATES AND CHANGES
16.1. This Privacy Policy may be amended or updated from time to time to reflect changes in our practices regarding the Processing of Personal Data or changes in applicable laws..
16.2. All modifications will become valid for the User from the moment he agrees with the new conditions. The fact that you continue to use the PLATFORM after this Policy has been updated means that you have agreed to the changes to this Privacy Policy.
16.3. If you do not agree with any modification of this Policy, the PLATFORM User may reject it, without any charge. The rejection of the new version of the Policy, however, may imply the impossibility of offering services by SKEELO.
17. APPLICABLE LAW
17.1. This document is governed by and shall be interpreted in accordance with the laws of the Federative Republic of Brazil.