Official document
Privacy and Personal Data Protection Policy
We are The Seller, a company dedicated to protecting the security and integrity of the personal information entrusted to us. We are committed to handling the Personal Data of our customers, partners and other data subjects with responsibility and respect for privacy.
Purpose
This Policy aims to clearly present how The Seller handles the personal data entrusted to us, ensuring transparency and information security. We always seek to comply with data processing regulations, in particular Federal Law No. 13,709 (Brazilian General Data Protection Law – LGPD), Law No. 12,965/14 (Brazilian Internet Civil Rights Framework) and Constitutional Amendment No. 115.
Scope
This policy addresses how and why we process personal data, transparently explaining to data subjects what their rights are and how to exercise them. The policy applies to everyone who has any relationship with The Seller: customers, data subjects, directors, employees or service providers.
Definitions
- Brazilian General Data Protection Law (LGPD)
- Law No. 13,709, which addresses the protection of personal data in Brazil.
- Internet Civil Rights Framework (Marco Civil da Internet)
- Law No. 12,965, which sets out principles, rights, guarantees and duties related to the use of the internet in Brazil.
- Personal Data
- Any information relating to an identified or identifiable natural person.
- Identifiable Data
- Information that, when combined with other data, allows the identification of the data subject.
- Identified Data
- Data that, on its own, already allows identification of the data subject.
- Sensitive Personal Data
- Information about racial or ethnic origin, religious belief, political opinion, union membership or membership of a religious, philosophical or political organization, health, sex life, genetic or biometric data.
- Anonymization
- Technical process that irreversibly makes data impossible to associate with an individual.
- Data Subject
- Natural person to whom the personal data being processed belongs.
- Data Processing
- Any action carried out with personal data, including collection, storage, organization, use, access, reproduction, among others.
- Controller
- Individual or company responsible for making decisions on how personal data will be processed.
- Processor
- Individual or company that processes personal data following the controller's instructions.
- Sub-processor
- Individual or legal entity that assists the processor in processing the data.
- ANPD
- National Data Protection Authority, the body responsible for ensuring and enforcing compliance with the LGPD.
- Data Protection Officer (DPO)
- Professional appointed by the controller to act as the point of contact between the controller, data subjects, processors and the ANPD.
Positioning
Data protection is an essential responsibility for The Seller. This policy will serve as a reference to ensure that information security is integrated into our processes, products, services and organizational culture.
Guidelines
5.1. Compliance Rules
- Good faith: act with integrity, loyalty and ethical conduct.
- Purpose: use personal data only for legitimate and specific purposes.
- Adequacy: the use of data must be aligned with the purpose informed to the data subject.
- Necessity: collect and process only essential data.
- Free access: guarantee data subjects easy and free access to information about the processing.
- Data quality: ensure the accuracy and up-to-date status of the information.
- Transparency: maintain a clear and accessible stance with data subjects.
- Security: protect personal data across all products, services and processes.
- Prevention: act preventively to avoid possible harm.
- Non-discrimination: never use data for discriminatory, abusive or unlawful practices.
- Accountability: implement and demonstrate effective measures that ensure privacy and data protection.
5.2. Rules for the Processing of Personal Data
The LGPD establishes the legal bases that authorize The Seller to process personal data: the data subject's express consent; compliance with a legal or regulatory obligation; execution of a contract or preliminary procedures related to a contract; regular exercise of rights in judicial, administrative or arbitration proceedings; protection of the life or physical safety of the data subject or third parties; legitimate interest; and credit protection.
5.3. Personal Data Governance
To manage the data protection program, The Seller has a well-defined governance structure. The appointed Data Protection Officer (DPO) is Filipe Freitas Tozzo, responsible for receiving complaints and communications from the ANPD, guiding employees and maintaining the record of data processing operations.
5.9. Data Subject Rights
- Access their personal data
- Correct incomplete or outdated data
- Request deletion of data
- Withdraw consent
- Data portability
- Information about use and sharing
5.14. Privacy Incidents
A privacy incident is any occurrence that compromises the confidentiality, integrity or availability of data. The Seller adopts monitoring, control and response measures to effectively handle these events.
5.12. Sharing of Personal Data
For the proper execution of our services, personal data processed by The Seller may be shared as shown in the table below:
| Partner | Purpose |
|---|---|
| Technology partners, hosting providers | Secure storage and management of data |
| Business Partners | Offering of personalized products and services |
| Meta Platforms (Facebook/WhatsApp) | Sending communications |
Related Documents
Privacy Notice and Terms of Use.
Attributions and Responsibilities
The board of directors and partners are responsible for keeping The Seller's routine in compliance with the law, approving privacy and data protection policies, reviewing policies, providing internal consulting, overseeing compliance with internal rules, receiving requests from data subjects and the ANPD, preparing and maintaining data protection reports, and reporting incidents.
Disciplinary Measures
Failure to comply with the rules contained in this document will be subject to disciplinary measures, in accordance with the policy adopted by The Seller and applicable law.
Issuance and Update
This Policy is on Version 1.0 and may be updated periodically. The latest version was published on July 31, 2024. If any item of this Policy is deemed invalid by the ANPD, by our Terms of Use, by related legislation or by a court decision, the remaining clauses will remain in full force.
Questions about privacy?
For questions related to privacy and data protection, please contact our Data Protection Officer (DPO).