Privacy Policy
Last updated on 02/04/2025
1. Purpose
Bella Club understands that privacy policies are crucial instruments to demonstrate transparency and establish trust with users when it comes to the collection, use and sharing of their personal data. Our policy is the legal document that describes how the organization Bella Entretenimento LTDA collects, stores, processes and protects users personal information.
Below are some reasons why we believe privacy policies are important:
Transparency: In our view, privacy policies allow users to know what personal information is being collected, why it is being collected and how it will be used. This helps to establish a relationship of trust between the organization and its users, demonstrating that the company is transparent about its data collection practices.
Legal compliance: In Brazil, data protection and privacy laws require organizations to inform users about their personal data collection and use practices. This privacy policy allows companies to comply with these legal obligations.
User rights: This privacy policy aims to inform users of their rights in relation to the personal data they share. This includes the right to access, correct and delete their data, as well as the right to withdraw consent for the processing of their data.
Informed decisions: By reading our privacy policy, users can make informed decisions about whether or not to share their information with us. This is especially important when it comes to sensitive or confidential information.
Security and data protection: This privacy policy also aims to detail the security measures implemented to protect user data from unauthorized access, misuse and leaks. This, we believe, is intended to reassure our users about the security of their information.
Trust and reputation: We believe that demonstrating our commitment to the privacy and security of user data tends to maintain a good reputation and the trust of our customers.
Please read this Policy carefully, as it sets out the activities we carry out, as well as your rights as a “Personal Data Subject”.
2. Assumptions
Bella Club is committed to complying with the provisions of the General Data Protection Law, known as Law No. 13,709/2018. To this end, we place great importance on respecting the rights of our consumers and all people whose information we collect.
This Privacy Policy is part of a broader Personal Data Protection Governance program. Its purpose is to provide all essential information in a clear manner. We want you to know exactly what data we collect, for what purposes we use it, and how we process it.
If you have any questions or requests, we are providing a direct channel for you to communicate with our Personal Data Protection Officer. This person is prepared to provide clarifications and guidance, if necessary.
In short, we are adopting strict measures to ensure the protection of the information we collect and process. Everything is explained in a transparent and accessible manner for you. If there is anything you would like to know more about, our team is here to help.
3. Scope of Application
This Privacy Policy applies to all of our integrated platforms and activities where personal data is processed.
a. Collection of Personal Data
As a consumer of our products and services, you will provide us with personal data so that we can provide you with quality service, fulfill contracts and provide secure services. We also use this data to provide you with offers, suggestions and promotions that align with your interests.
b. Broad Coverage
This policy covers a variety of activities in which we process personal data. This includes online activities, such as browsing our website (using cookies and registration forms), as well as offline activities, such as: Loyalty programs, Marketing initiatives, Customer registrations, Social media interactions, Our website, Data protection service, Experience Improvement. In order to provide services and improve your experience with us, we may combine personal data from different sources, both online and offline. We will always ensure that you are aware of and informed of, or can give your consent to, the processing carried out.
c. Rights and Options
As the data subject, you have the right to object to certain processing activities. However, in some cases, your decision to object or not to provide necessary personal data may limit our ability to offer you specific offers, promotions or services.
d. Transparency and Justification
We always base our responses to your inquiries related to your personal data on solid grounds. We are committed to providing transparent and justified information in all situations.
4. Collected Data and Processing
The personal data we process about you may be collected through the following sources:
Offline records: When you fill out a satisfaction survey, a coupon for promotions, product and improvement suggestions, sweepstakes, or interact with any advertisement or action on the website;
Participation in sweepstakes and/or donations: When you participate in a sweepstake or donation and provide personal data to receive confirmation or a thank-you message;
Third-party data: When, from external sources, we correlate information you have provided to us with other repositories or any other website belonging to the Bella group;
Online activities: When you interact with our websites, applications, and online services, we may collect personal data automatically transmitted by your browser or mobile device.
5. Data collected and its purpose
When using our services, whether online or offline, we may collect and process information that is necessary to carry out activities related to the platforms provided by Bella Entretenimento.
We value and respect the purposes for which you provided or were informed about the collection of your personal data. We are committed to using your personal data only for the purposes that have been clearly informed to you. At no time will we use your personal data for purposes other than those that have been expressly communicated in a transparent and specific manner.
Within this Policy, we present in detail the purposes and needs underlying the processing of your personal data. Our goal is to ensure that you fully understand how and why your data is being collected and processed in relation to the operations of the Bella Entretenimento platforms.
Occasionally, in the event of an interest or need to process sensitive personal data, we will wait for your informed, free, express, specific, unambiguous and highlighted consent or we will process based on legal bases involving the detection and prevention of crime and compliance with the law, after preparing and evaluating a data protection impact report.
6. Online activities and cookies
Use of Cookies and Tracking Services
On some occasions, during our online activities, we may use Cookies and other tracking services, such as web beacons, records and logs. These are text files that may be collected on your device. Our intention is to ensure the proper functioning of our online services, to better understand how you use our services and, sometimes, for advertising purposes.
Importance of Some Services
Some of these services are really important. Therefore, it is not possible to disable them without compromising the security and functionality of our online services. Others, such as cookies used for advertising or that share information with third-party websites and services, can be blocked.
Control and Notice
Before you start using the service, you will receive a notice. This way, you can enable the cookies you deem necessary. However, it is important to mention that essential cookies, those essential for the operation, will be enabled and cannot be removed.
Questions and Support
If you have any questions about cookies, you can contact our Data Protection Officer. We are here to help and clarify any questions.
Device Settings
It is also recommended that, to ensure your privacy, you always check whether your device settings are adjusted restrictively in relation to cookies and beacons.
7. How we collect and handle data
Responsible Collection of Personal Data
Personal data is collected through the specific data sources described in this Privacy Policy, or when you voluntarily choose to provide your data directly to us.
Compliance with Data Protection Principles
All collection of personal data is carried out in full compliance with data protection principles. We act transparently and collect only the information strictly necessary to perform our activities and provide benefits to you.
Proactive Security
We have implemented an Information Privacy Management System, reinforced by physical, technical and organizational measures. This system is designed to safeguard your data against third-party interventions, breaches and leaks, ensuring the preservation of its security. At any time, you have the right to consult the details of the security measures and controls that we employ to protect your personal data.
Comprehensive Protection
We use organizational, administrative and technical approaches to ensure adequate protection of your data. Administrative and organizational measures include employee awareness, strict access policies and contracts established with our third-party partners and personal data operators.
Technical and Innovative Measures
Technical measures include, but are not limited to, database encryption, implementation of robust passwords for access and, whenever possible, pseudonymization of personal data. At any time, you can seek more information about our information security practices, details of the measures adopted and techniques employed, by contacting our Personal Data Protection Officer.
8. Questions or concerns about the purpose of processing the data subjects data
Clarifications and Questions
You are always free to question at any time any purpose that has been specified here or whether personal data is really necessary to achieve that purpose. Through our Data Protection Officer, we will be ready to answer your questions and, if necessary, meet your requests.
Transparency and Understanding
In situations where we are unable to accommodate a request, you will receive a detailed and reasoned explanation of the reasons for the refusal. We are committed to ensuring that you fully understand the situation.
9. Sharing of personal data
To ensure the accurate, safe and satisfactory execution of our activities, as well as to offer high quality products and services, Bella Entretenimento LTDA may share your personal data with affiliated companies. We emphasize that all personal data sharing operations are in compliance with current legislation and regulations on data privacy.
Purposes and Recipients of Data Sharing:
Marketing and Advertising: We share information such as your name, email address and telephone number with third-party platforms (operators) so that they can send you our content. This process involves technology service providers, SMS messaging services, WhatsApp, telephone service, authentication, email marketing automation tools, among others. The personal data provided by you is used to present products, promotions and services that we believe may be of interest to you. The operating companies that may be used by us to send data and advertising are accessible to you at any time, through the Data Subject Portal.
Affiliated Companies in the Same Economic Group: With your consent or to meet a legitimate interest of our organization, we may share your information with other companies in the same Economic Group. Your consent may be revoked at any time or you may choose not to have your data processed. For details on the data shared, purposes and companies that are part of our group, please contact our Data Protection Officer.
Court Order, Authorities or Legal Obligations: Whenever necessary to comply with legal obligations or requests from competent authorities, after judicial approval, we will share your personal data.
Corporate Changes: In cases of merger, acquisition or incorporation of our company, we may share your data. We undertake to ensure compliance with data processing standards with all parties involved and you will be duly informed.
Social Networks: When you register on our websites on social networks, such as Instagram, Google and Facebook, your personal information may be shared with these companies. The decision whether or not to share this information is yours. It is important to note that we have no control or influence over the Privacy Policies of third parties regarding personal data.
10. Commitment of operators and subcontractors
Responsible Partnership with Data Operators and Processors: Commitment to Data Protection
The operators or data processors of Bella Entretenimento LTDA are fully aware of the commitment established by the companys Data Protection Policy. They undertake to adopt strict technical and organizational measures to protect data and respect the rights of data subjects. Our approach includes the use of contractual clauses, amendments, criminal provisions and possible fines.
Security and Transparency in Our Approach
Despite our ongoing efforts, it is important to mention that we cannot absolutely guarantee the security of information within the structures of controllers, operators and third parties. Should any incident involving your personal data be identified, we will take the necessary precautions to notify you promptly. In addition, we will adopt the appropriate procedures to investigate and resolve the incident. This notification will include details about the incident identified and what occurred within the framework of the controller, processor or third party with whom we shared the data.
We are committed to maintaining the integrity and security of your personal data as a fundamental priority. If you have any further questions or require further clarification, please do not hesitate to contact us. We are here to ensure transparency and the protection of your data.
11. You may question and object to the sharing
Total Control Over Your Personal Data
We ensure that you always maintain the right to revoke your consent for any data processing action that has been based on it, including marketing activities carried out on our behalf or any data sharing processes. This prerogative is under your complete authority.
Exercising Your Rights in an Easy and Accessible Way
To exercise this right, we provide the Personal Data Holder Portal, a secure and accessible channel for you. Through it, you may withdraw consent, ensuring full compliance with your wishes. We are committed to putting you in control of your personal information and providing effective means for you to exercise your rights in a convenient manner. If there is any further information you require, feel free to contact us.
12. International data transfer
Scope of the General Data Protection Law and International Data Transfer
The General Data Protection Law (Law No. 13,709/2018) applies to Bella da Semana, a company headquartered in Brazil that processes personal data of individuals located in Brazil and offers products and services aimed at people located in the national territory. However, in order to ensure the adequate provision of our services, it is possible that the personal data collected may be transferred to countries such as the United States and countries of the European Union. These transfers frequently occur when we use cloud storage and hosting services or when we contract software and systems from international companies.
In these situations, our priority is to ensure that the destination countries have a level of data protection equivalent to that required by the LGPD. In addition, we seek to ensure the protection of your data against unauthorized access, as well as against possible accidental or unlawful incidents, such as destruction, loss, alteration, communication or any form of inadequate or illegal processing.
To achieve this level of protection, we use Standard Contractual Clauses whenever applicable. These clauses are intended to regulate the transfer of data and ensure the security of your data, even internationally.
We are committed to ensuring that your personal data remains protected and in compliance with applicable laws. Should you have any questions regarding this international transfer of data, please do not hesitate to contact us. We are available to provide further information and clarifications if necessary.
13. Your rights under the LGPD
Your Rights as Data Owner:
Access, Correction and Control
We want to make it clear that you are the owner of the data you have entrusted to us. Within the rules established by the Law, you have certain important rights. These are rights provided for in the General Personal Data Protection Law, in article 18.
Information at Your Disposal
One of the things we guarantee is that you can always know how your data is being processed. At any time, you can ask to see what information we are using and how we are using it.
Accurate Data Maintenance
You can also ask us to correct information that is incorrect, missing or out of date. In addition, if any data is extra or considered unnecessary, you have the right to ask for it to be anonymized, blocked or even deleted.
Consent Control
If you have given consent for us to use your data, you can change your mind at any time. Just tell us that you no longer want us to use it and we will stop using it, unless the law says otherwise.
Transparency in Partnerships
You have the right to know which companies, whether public or private, we share your data with.
Important Decisions
When we ask to use your data in specific situations, we will tell you what happens if you do not want to provide that data. It is good to know the consequences before you decide.
Your Opinion Matters
Even though we do not always need your consent to process your data, if you think we do not need it, you can question it. At any time, if you feel that the reason we used your data was not really necessary, you can ask us.We aim to make these rights easy to understand and exercise. If you have any further questions or require clarification, please feel free to contact us. We are here to help.
14. How long do we keep your data?
Understanding the Retention Period of Your Personal Data
You have the right to know how long we keep your personal data. In accordance with the General Data Protection Regulation, we keep your information for as long as necessary to fulfill the purposes for which the personal data was collected.
It is important to note that different categories of personal data may have different retention periods.
When we have finished processing your personal data and we no longer have a legitimate interest or legal obligation to keep it, we proceed to delete it from our databases.
In cases where we use your data based on your consent, you have the right – unless the law provides otherwise – to request the deletion of this data. In such cases, we inform everyone with whom we have shared this data so that they can also perform the deletion.
In addition, you can initiate a request through our Personal Data Subject Portal. This will allow you to request the deletion of your personal data, as well as information about when the processing has ended and the time for which it will be retained.
It is important to mention that in some situations, we are legally authorized or obliged to retain the data.
To exercise any of the rights mentioned above, feel free to contact us through the contacts that are explicitly established in this Policy.
15. Complementary and specific policies
For some specific products and services, we may detail, present specific guidelines and standards. To this end, we recommend that you analyze the specific Policies for a given platform or service.
16. Requests, applications and doubts
If you have any questions, doubts, requests for rights, criticism, opposition or clarification about our Privacy Policy, the data we collect, how we process it or how to exercise your rights, please contact us through the “Data Holder Portal” or contact Bellas Data Protection Officer.
We may request minimum personal data to check its authenticity, before proceeding with due diligence regarding personal data.
17. Deadline and format for response
We will respond to your requests within the deadlines determined by law. However, when there is no specified deadline, you will receive a reasonable estimate of the response whenever you make a request to our Data Protection Officer or on the “Data Subject Portal”.
18. Versioning and changes to the policy
We will be committed to updating our Policy whenever necessary to ensure full respect for personal data, in our processes and services. Changes will, logically, be in full compliance with the data protection legislation in force and users will be notified by email or when accessing our platform. However, we recommend that you review the latest version of the Policy whenever possible via the link.
Att.
Data Control Team
Bella Entretenimento LTDA
1. Purpose
Bella Club understands that privacy policies are crucial instruments to demonstrate transparency and establish trust with users when it comes to the collection, use and sharing of their personal data. Our policy is the legal document that describes how the organization Bella Entretenimento LTDA collects, stores, processes and protects users personal information.
Below are some reasons why we believe privacy policies are important:
Transparency: In our view, privacy policies allow users to know what personal information is being collected, why it is being collected and how it will be used. This helps to establish a relationship of trust between the organization and its users, demonstrating that the company is transparent about its data collection practices.
Legal compliance: In Brazil, data protection and privacy laws require organizations to inform users about their personal data collection and use practices. This privacy policy allows companies to comply with these legal obligations.
User rights: This privacy policy aims to inform users of their rights in relation to the personal data they share. This includes the right to access, correct and delete their data, as well as the right to withdraw consent for the processing of their data.
Informed decisions: By reading our privacy policy, users can make informed decisions about whether or not to share their information with us. This is especially important when it comes to sensitive or confidential information.
Security and data protection: This privacy policy also aims to detail the security measures implemented to protect user data from unauthorized access, misuse and leaks. This, we believe, is intended to reassure our users about the security of their information.
Trust and reputation: We believe that demonstrating our commitment to the privacy and security of user data tends to maintain a good reputation and the trust of our customers.
Please read this Policy carefully, as it sets out the activities we carry out, as well as your rights as a “Personal Data Subject”.
2. Assumptions
Bella Club is committed to complying with the provisions of the General Data Protection Law, known as Law No. 13,709/2018. To this end, we place great importance on respecting the rights of our consumers and all people whose information we collect.
This Privacy Policy is part of a broader Personal Data Protection Governance program. Its purpose is to provide all essential information in a clear manner. We want you to know exactly what data we collect, for what purposes we use it, and how we process it.
If you have any questions or requests, we are providing a direct channel for you to communicate with our Personal Data Protection Officer. This person is prepared to provide clarifications and guidance, if necessary.
In short, we are adopting strict measures to ensure the protection of the information we collect and process. Everything is explained in a transparent and accessible manner for you. If there is anything you would like to know more about, our team is here to help.
3. Scope of Application
This Privacy Policy applies to all of our integrated platforms and activities where personal data is processed.
a. Collection of Personal Data
As a consumer of our products and services, you will provide us with personal data so that we can provide you with quality service, fulfill contracts and provide secure services. We also use this data to provide you with offers, suggestions and promotions that align with your interests.
b. Broad Coverage
This policy covers a variety of activities in which we process personal data. This includes online activities, such as browsing our website (using cookies and registration forms), as well as offline activities, such as: Loyalty programs, Marketing initiatives, Customer registrations, Social media interactions, Our website, Data protection service, Experience Improvement. In order to provide services and improve your experience with us, we may combine personal data from different sources, both online and offline. We will always ensure that you are aware of and informed of, or can give your consent to, the processing carried out.
c. Rights and Options
As the data subject, you have the right to object to certain processing activities. However, in some cases, your decision to object or not to provide necessary personal data may limit our ability to offer you specific offers, promotions or services.
d. Transparency and Justification
We always base our responses to your inquiries related to your personal data on solid grounds. We are committed to providing transparent and justified information in all situations.
4. Collected Data and Processing
The personal data we process about you may be collected through the following sources:
Offline records: When you fill out a satisfaction survey, a coupon for promotions, product and improvement suggestions, sweepstakes, or interact with any advertisement or action on the website;
Participation in sweepstakes and/or donations: When you participate in a sweepstake or donation and provide personal data to receive confirmation or a thank-you message;
Third-party data: When, from external sources, we correlate information you have provided to us with other repositories or any other website belonging to the Bella group;
Online activities: When you interact with our websites, applications, and online services, we may collect personal data automatically transmitted by your browser or mobile device.
5. Data collected and its purpose
When using our services, whether online or offline, we may collect and process information that is necessary to carry out activities related to the platforms provided by Bella Entretenimento.
We value and respect the purposes for which you provided or were informed about the collection of your personal data. We are committed to using your personal data only for the purposes that have been clearly informed to you. At no time will we use your personal data for purposes other than those that have been expressly communicated in a transparent and specific manner.
Within this Policy, we present in detail the purposes and needs underlying the processing of your personal data. Our goal is to ensure that you fully understand how and why your data is being collected and processed in relation to the operations of the Bella Entretenimento platforms.
Occasionally, in the event of an interest or need to process sensitive personal data, we will wait for your informed, free, express, specific, unambiguous and highlighted consent or we will process based on legal bases involving the detection and prevention of crime and compliance with the law, after preparing and evaluating a data protection impact report.
6. Online activities and cookies
Use of Cookies and Tracking Services
On some occasions, during our online activities, we may use Cookies and other tracking services, such as web beacons, records and logs. These are text files that may be collected on your device. Our intention is to ensure the proper functioning of our online services, to better understand how you use our services and, sometimes, for advertising purposes.
Importance of Some Services
Some of these services are really important. Therefore, it is not possible to disable them without compromising the security and functionality of our online services. Others, such as cookies used for advertising or that share information with third-party websites and services, can be blocked.
Control and Notice
Before you start using the service, you will receive a notice. This way, you can enable the cookies you deem necessary. However, it is important to mention that essential cookies, those essential for the operation, will be enabled and cannot be removed.
Questions and Support
If you have any questions about cookies, you can contact our Data Protection Officer. We are here to help and clarify any questions.
Device Settings
It is also recommended that, to ensure your privacy, you always check whether your device settings are adjusted restrictively in relation to cookies and beacons.
7. How we collect and handle data
Responsible Collection of Personal Data
Personal data is collected through the specific data sources described in this Privacy Policy, or when you voluntarily choose to provide your data directly to us.
Compliance with Data Protection Principles
All collection of personal data is carried out in full compliance with data protection principles. We act transparently and collect only the information strictly necessary to perform our activities and provide benefits to you.
Proactive Security
We have implemented an Information Privacy Management System, reinforced by physical, technical and organizational measures. This system is designed to safeguard your data against third-party interventions, breaches and leaks, ensuring the preservation of its security. At any time, you have the right to consult the details of the security measures and controls that we employ to protect your personal data.
Comprehensive Protection
We use organizational, administrative and technical approaches to ensure adequate protection of your data. Administrative and organizational measures include employee awareness, strict access policies and contracts established with our third-party partners and personal data operators.
Technical and Innovative Measures
Technical measures include, but are not limited to, database encryption, implementation of robust passwords for access and, whenever possible, pseudonymization of personal data. At any time, you can seek more information about our information security practices, details of the measures adopted and techniques employed, by contacting our Personal Data Protection Officer.
8. Questions or concerns about the purpose of processing the data subjects data
Clarifications and Questions
You are always free to question at any time any purpose that has been specified here or whether personal data is really necessary to achieve that purpose. Through our Data Protection Officer, we will be ready to answer your questions and, if necessary, meet your requests.
Transparency and Understanding
In situations where we are unable to accommodate a request, you will receive a detailed and reasoned explanation of the reasons for the refusal. We are committed to ensuring that you fully understand the situation.
9. Sharing of personal data
To ensure the accurate, safe and satisfactory execution of our activities, as well as to offer high quality products and services, Bella Entretenimento LTDA may share your personal data with affiliated companies. We emphasize that all personal data sharing operations are in compliance with current legislation and regulations on data privacy.
Purposes and Recipients of Data Sharing:
Marketing and Advertising: We share information such as your name, email address and telephone number with third-party platforms (operators) so that they can send you our content. This process involves technology service providers, SMS messaging services, WhatsApp, telephone service, authentication, email marketing automation tools, among others. The personal data provided by you is used to present products, promotions and services that we believe may be of interest to you. The operating companies that may be used by us to send data and advertising are accessible to you at any time, through the Data Subject Portal.
Affiliated Companies in the Same Economic Group: With your consent or to meet a legitimate interest of our organization, we may share your information with other companies in the same Economic Group. Your consent may be revoked at any time or you may choose not to have your data processed. For details on the data shared, purposes and companies that are part of our group, please contact our Data Protection Officer.
Court Order, Authorities or Legal Obligations: Whenever necessary to comply with legal obligations or requests from competent authorities, after judicial approval, we will share your personal data.
Corporate Changes: In cases of merger, acquisition or incorporation of our company, we may share your data. We undertake to ensure compliance with data processing standards with all parties involved and you will be duly informed.
Social Networks: When you register on our websites on social networks, such as Instagram, Google and Facebook, your personal information may be shared with these companies. The decision whether or not to share this information is yours. It is important to note that we have no control or influence over the Privacy Policies of third parties regarding personal data.
10. Commitment of operators and subcontractors
Responsible Partnership with Data Operators and Processors: Commitment to Data Protection
The operators or data processors of Bella Entretenimento LTDA are fully aware of the commitment established by the companys Data Protection Policy. They undertake to adopt strict technical and organizational measures to protect data and respect the rights of data subjects. Our approach includes the use of contractual clauses, amendments, criminal provisions and possible fines.
Security and Transparency in Our Approach
Despite our ongoing efforts, it is important to mention that we cannot absolutely guarantee the security of information within the structures of controllers, operators and third parties. Should any incident involving your personal data be identified, we will take the necessary precautions to notify you promptly. In addition, we will adopt the appropriate procedures to investigate and resolve the incident. This notification will include details about the incident identified and what occurred within the framework of the controller, processor or third party with whom we shared the data.
We are committed to maintaining the integrity and security of your personal data as a fundamental priority. If you have any further questions or require further clarification, please do not hesitate to contact us. We are here to ensure transparency and the protection of your data.
11. You may question and object to the sharing
Total Control Over Your Personal Data
We ensure that you always maintain the right to revoke your consent for any data processing action that has been based on it, including marketing activities carried out on our behalf or any data sharing processes. This prerogative is under your complete authority.
Exercising Your Rights in an Easy and Accessible Way
To exercise this right, we provide the Personal Data Holder Portal, a secure and accessible channel for you. Through it, you may withdraw consent, ensuring full compliance with your wishes. We are committed to putting you in control of your personal information and providing effective means for you to exercise your rights in a convenient manner. If there is any further information you require, feel free to contact us.
12. International data transfer
Scope of the General Data Protection Law and International Data Transfer
The General Data Protection Law (Law No. 13,709/2018) applies to Bella da Semana, a company headquartered in Brazil that processes personal data of individuals located in Brazil and offers products and services aimed at people located in the national territory. However, in order to ensure the adequate provision of our services, it is possible that the personal data collected may be transferred to countries such as the United States and countries of the European Union. These transfers frequently occur when we use cloud storage and hosting services or when we contract software and systems from international companies.
In these situations, our priority is to ensure that the destination countries have a level of data protection equivalent to that required by the LGPD. In addition, we seek to ensure the protection of your data against unauthorized access, as well as against possible accidental or unlawful incidents, such as destruction, loss, alteration, communication or any form of inadequate or illegal processing.
To achieve this level of protection, we use Standard Contractual Clauses whenever applicable. These clauses are intended to regulate the transfer of data and ensure the security of your data, even internationally.
We are committed to ensuring that your personal data remains protected and in compliance with applicable laws. Should you have any questions regarding this international transfer of data, please do not hesitate to contact us. We are available to provide further information and clarifications if necessary.
13. Your rights under the LGPD
Your Rights as Data Owner:
Access, Correction and Control
We want to make it clear that you are the owner of the data you have entrusted to us. Within the rules established by the Law, you have certain important rights. These are rights provided for in the General Personal Data Protection Law, in article 18.
Information at Your Disposal
One of the things we guarantee is that you can always know how your data is being processed. At any time, you can ask to see what information we are using and how we are using it.
Accurate Data Maintenance
You can also ask us to correct information that is incorrect, missing or out of date. In addition, if any data is extra or considered unnecessary, you have the right to ask for it to be anonymized, blocked or even deleted.
Consent Control
If you have given consent for us to use your data, you can change your mind at any time. Just tell us that you no longer want us to use it and we will stop using it, unless the law says otherwise.
Transparency in Partnerships
You have the right to know which companies, whether public or private, we share your data with.
Important Decisions
When we ask to use your data in specific situations, we will tell you what happens if you do not want to provide that data. It is good to know the consequences before you decide.
Your Opinion Matters
Even though we do not always need your consent to process your data, if you think we do not need it, you can question it. At any time, if you feel that the reason we used your data was not really necessary, you can ask us.We aim to make these rights easy to understand and exercise. If you have any further questions or require clarification, please feel free to contact us. We are here to help.
14. How long do we keep your data?
Understanding the Retention Period of Your Personal Data
You have the right to know how long we keep your personal data. In accordance with the General Data Protection Regulation, we keep your information for as long as necessary to fulfill the purposes for which the personal data was collected.
It is important to note that different categories of personal data may have different retention periods.
When we have finished processing your personal data and we no longer have a legitimate interest or legal obligation to keep it, we proceed to delete it from our databases.
In cases where we use your data based on your consent, you have the right – unless the law provides otherwise – to request the deletion of this data. In such cases, we inform everyone with whom we have shared this data so that they can also perform the deletion.
In addition, you can initiate a request through our Personal Data Subject Portal. This will allow you to request the deletion of your personal data, as well as information about when the processing has ended and the time for which it will be retained.
It is important to mention that in some situations, we are legally authorized or obliged to retain the data.
To exercise any of the rights mentioned above, feel free to contact us through the contacts that are explicitly established in this Policy.
15. Complementary and specific policies
For some specific products and services, we may detail, present specific guidelines and standards. To this end, we recommend that you analyze the specific Policies for a given platform or service.
16. Requests, applications and doubts
If you have any questions, doubts, requests for rights, criticism, opposition or clarification about our Privacy Policy, the data we collect, how we process it or how to exercise your rights, please contact us through the “Data Holder Portal” or contact Bellas Data Protection Officer.
We may request minimum personal data to check its authenticity, before proceeding with due diligence regarding personal data.
17. Deadline and format for response
We will respond to your requests within the deadlines determined by law. However, when there is no specified deadline, you will receive a reasonable estimate of the response whenever you make a request to our Data Protection Officer or on the “Data Subject Portal”.
18. Versioning and changes to the policy
We will be committed to updating our Policy whenever necessary to ensure full respect for personal data, in our processes and services. Changes will, logically, be in full compliance with the data protection legislation in force and users will be notified by email or when accessing our platform. However, we recommend that you review the latest version of the Policy whenever possible via the link.
Att.
Data Control Team
Bella Entretenimento LTDA