1. PRIVACY POLICY
Carefully read the privacy policy below, because you are agreeing with it when you use our site.
Ellohub cares about the privacy of the personal data from the users and clients that access our website and/or hires our services. The present Privacy Policy contains information about the way we treat, totally or partially, in an automated way or not, your personal data. Our objective is to clarify to the interested parts about the kinds of data that are collected, the reasons for the collection and the way the user can update, manage or exclude these informations.
This Privacy Policy has been prepared in accordance with the Federal Law n. 12,965 from April 23rd 2014 (Marco Civil da Internet) and the Federal Law n. 13,709 from August 14th 2018 (Lei Geral de Proteção de Dados).
Our Privacy Policy only applies to the specific pages from the site https://www.ellohub.com/ and can be update due to any regulatory updates, reason which we invite the user to constantly visit this section.
2. DEFINITIONS
For the purposes of this Policy, the following definitions are understood:
Legal bases: are the predicted hypothesis in the LGPD that allows the organization to regulate the data processing, like consent, legal or regulatory obligation, contract execution, and others.
Controller: natural or legal person, private or public, who competes the decisions referring to the personal data (Ellohub).
Personal data: all the information related to a physical person that can identify itself or make itself identifiable.
Data protection officer: person indicated by the controller nominated to act as a communication channel between the controller, the users and the Autoridade Nacional de Proteção de Dados (National Data Protection Authority). Also know as, in other words, Data Protection Officer – DPO.
LGPD – Lei Geral de Proteção de Dados (Brazilian General Data Protection Law, in free translation).
Treatment: all the operations done by the organization with the personal data, including activities like: collection, production, reception, classification, using, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or information control, modification, communication, transfer, diffusion or extraction.
Holder: it’s the physical person to whom does refer the personal data that are subject of treatment (site user).
Operator: Person or entity, private or public, that does the treatment of the users’ personal data on behalf of the controller.
3. USERS’ RIGHT
The user can exercise his rights trough the email ellohub@ellohub.com specifying full name, email, phone and:
Confirmation and data access: the right to obtain the confirmation that the personal data that concern you are or are not subject to treatment by the organization and, if that’s the case, the right to access your personal data.
Data rectification: the right to request correction or update of the personal data that are incorrect or outdated that concern you.
Data elimination: the right of having your data excluded from the site, observing the rights of the organization.
Data anonymization: the right of having your data anonymized, which means unbound from every and any form of link with the Holder, making impossible its identification.
Data blocking: the right to temporary suspend the treatment of your personal data by the organization.
Limitation on the data treatment: the right to limit the treatment of your personal data, when inexact or used in an illicit way or without the observance of the proposed purposes or unnecessary ends.
Opposition: the right to oppose for reasons related with your situation, to the treatment of the personal data that relates to you, observing the rights of the organization.
Data portability: the right to ask the transfer of your personal data to other service or product provider website.
Obtain information regarding the data sharing: the right to obtain information about the public or private entities which the controller made use sharing your data.
Obtain information regarding consent: the right to obtain information about the possibility of not giving consent and its consequences.
Right of obtaining revision of automated decisions: the right of not being subject to any decision takes exclusively based on automated treatment (if any).
Right on evocation: the right to request the revocation of your consent for the realization of the treatment of your data by the controller.
4. RIGHT NOT TO PROVIDE THIRD PARTY DATA
While using the website, in order to cover (?) and protect the rights of third parties, the website user must provide only his personal data, not those of third parties.
5. COLLECTED INFORMATION
Data collection from the users will be done in accordance with the provisions in this Privacy Policy and will depend on the user’s consent, this being expendable only in the predicted hypothesis in article 11, item II, of the Lei de Proteção de Dados Pessoais (Personal Data Protection Law, in free translation).
5.1 – Types of data collected and its goa
User identification data used for the request of scheduling a demo.
The use, by the user, of certain functionalities of the website will depend on the register, which, in these cases, the following user data will be collected and stored with the following purposes as follows:
|
COLLECTED DATA TYPES |
GOAL OF THE COLLECTION AND TREATMENT |
|
FULL NAME |
For the identification and personalization of the user service. |
|
EMAIL ADDRESS |
Needed for the contact by the Ellohub team. |
|
COMPANY NAME |
For the identification and personalization of the user service requested by the user. |
|
PHONE NUMBER |
Needed for the contact by the Ellohub team. |
|
COUNTRY |
Needed for the validation of the acting region and service of Ellohub. |
|
PRODUCTS OF INTEREST |
For the customization of the service requested by the user. |
|
MONTHLY MEDIA AVERAGE |
For the customization of the service requested by the user. |
|
COMPANY AREA |
For the customization of the service requested by the user. |
5.2. Collection of not expressly provided data
Eventually, other types of data not expressly provided in this Privacy Policy can be collected, since they are provided with the consent from the holder, or, still, that the collection is allowed by law.
5.3. Sensitive Data
No sensitive data shall be collected from the user. Sensitive data are those defined in the article 5, item II of the Lei Geral de Proteção de Dados Pessoais (General Personal Data Protection Law, in free translation).
6. LEGAL FOUNDATIONS FOR THE TREATMENT OF PERSONAL DATA
TYPES OF DATA COLLECTED
|
TYPES OF DATA COLLECTED |
LEGAL BASE |
|
DATA FROM THE CONTACT FORM |
Consent (article 7, item I from the LGPD). Legitimate interest in service provision that benefits the user (article 7, item IX, and article 10, item II from the LGPD). |
|
PORTAL CLIENT DATA |
Client’s contract execution (article 7, item V from the LGPD). Legitimate interest in service provision that benefits the user (article 7, item IX, and article 10, item II from the LGPD). |
The user has the right to withdraw it’s consent at any time, not compromising the lawfulness of the treatment of its personal data before the withdraw. The withdraw of the consent can be made by e-mail: ellohub@ellohub.com.
The treatment of personal data without the user’s consent only will be done within the hypothesis provided for by law or in legitimate interest, among others, the following:
For the fulfillment of legal or regulatory obligation by the controller.
For the realization of studies by research bodies, granted, whenever possible, the anonymization of the personal data.
When needed for the execution of contracts or preliminary procedures related to contract which the user is part of, as requested by the holder of the data.
For the regular exercise of rights in a legal, administrative or arbitration process.
When needed to serve the legitimate interests of the controller or third parties, except in the case of prevailing rights and fundamental freedoms of the holder of the data that demands protection of personal data.
For the protection of credit, including regarding the provisions of the relevant legislation.
7. PERSONAL DATA CONSERVATION DEADLINE
Users personal data will be preserved por a period not bigger than the demanded to fulfill the objectives in account of which they are processed.
The data conservation period is defined by the following criteria:
Usage time based on the service chosen by the user on the website and/or the contract term stablished with the organization.
The data will be conserved by the organization after the end of the chosen service or the contract term in the following situations:
a) For the fulfillment of legal or regulatory obligation by the controller;
b) For studies by a research body, granted, whenever possible, the anonymization of the personal data;
c) For the transfer to third parties, once the data treatment requirements provided in the legislation are respected;
d) For the use by the controller, provided that third-party access is prohibited, and provided that the data is anonymized;
8. RECIPIENTS AND TRANSFER OF PERSONAL DATA
User’s personal data can be shared with third-party companies, convened and/or service or product providers for the organization, named as Data Operators, when needed for the realization of personal data treatment.
The organization can still share personal data from the user with public or private entities, in cases where there is legal or regulatory obligation or legal determination or from competent authority that requires the provision of personal data.
9. SAFETY IN USER’S PRESONAL DATA TREATMENT
Ellohub has suitable technical and organizational measures to protect user’s personal data from unauthorized access and destruction, loss, modification, communication or diffusion situation of such data.
To ensure safety, solutions are adopted that take in consideration: the adequate techniques; the costs of application; the nature; the scope, the context and the goals of the treatment; and the risks to rights and freedom of the users.
The website uses SSL certificate (Secure Socket Layer) that ensures that personal data is transmitted in a safe and confidential way, so that the data transmission between the server and the user, and in feedback, happens in a totally ciphered and encrypted way.
The violation of personal data happens when a security incident causes, in an accidental or illicit way, the destruction, the loss, the modification, the disclosure or the unauthorized access to personal data transferred, conserved or subjects to any other kind of treatment.
The organization will communicate the Holder of the data, in adequate time, if any kind of security incident happens, which deals with the previous item, related to its personal data, that may cause risks or relevant damage to your rights and individual freedoms.
Will not be considered as security incidents situations on which the damages are of exclusive fault of third parties, such as hackers or cracker attacks or exclusive fault of the data Holder, like in cases when itself transfer its data to third-parties.
Lastly, the organization commits to treat users’ personal data with confidentiality, within legal limits.
10. NAVIGATION DATA (COOKIES)
Cookies are little text files sent by the website to the user’s computer and in it are stored, with information related to the website navigation.
Through cookies, little amounts of information are stored by the user’s browser so that our server can read it afterwards. Can be stored, for instance, data regarding the device used by the user, as well as it’s place and time of the website access.
The cookies don’t allow any file or information be extracted from the user’s hard drive, not being possible, still, that, through them, have access to personal information that have not come from the user or the way he uses website resources.
It is important to highlight that not every cookie has information that allow the user’s identification, being that specific kids of cookies can be used simply for the site to load correctly or that its functions be executed in the expected way.
The information eventually stored in the cookies that allow users identification are considered personal data. That way, all the rules provided by this Privacy Policy are also appliable.
10.1. Website Cookies
Website cookies are those sent to user’s device or computer and administered exclusively by the website.
The information collected through these cookies are used to improve and personalize the user’s experience, provided that some cookies can, for instance, be used to remember the preferences or the choices from the user, as well as the offer or personalized content.
10.2. Third-party cookies
Some of our partners can configure cookies that access our site in user’s device.
These cookies, in general, aim to enable our partners to offer your content and their services to the user that access our site in a personalized manner, by obtaining navigation data extracted from the interaction with the site.
The entities in charge of these cookie collections can concede the information obtained to third parties.
10.3. Social network cookies
The website uses social networks plugins that allow them to be accessed from the website. So, by doing it, the cookies used by them can be stored in the user’s browser.
Each social network has its own privacy and data protection policy, being the natural or legal persons those who are responsible by the data collected and the privacy practices adopted.
The use can research, with the social networks, information on how their personal data is being treated. For information, we make available the following links, from which the privacy and cookies policies adopted by some of the main social media can be consulted:
Facebook: https://www.facebook.com/policies/cookies/
Twitter: https://twitter.com/pt/privacy
Instagram: https://help.instagram.com/1896641480634370?ref=ig
Youtube: https://policies.google.com/privacy?hl=pt-BR&gl=pt
Google+: https://policies.google.com/technologies/cookies?hl=pt
Pinterest: https://policy.pinterest.com/pt-br/privacy-policy
LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies
10.4. Cookie management and browser configuration
The user can oppose to the registry of cookies by the website, just deactivate this option in its own browser or device.
The deactivation of cookies, however, can affect the availability of some tools and features of the website, compromising its correct and expected operation. Other possible consequence is the removal of the user preferences that eventually are saved, harming its experience.
Below will be made available some links to help and support pages of the main browsers, that can be accessed by the user interested in obtaining more info on the cookie management by its browser.
- Internet Explorer: https://support.microsoft.com/pt-br/help/17442/windows-internet-explorer-delete-manage-cookies
11. COMPLAINT TO A CONTROL AUTHORITY
Without loss to any other way of administrative or legal resource, all holders of data have the right to present a complaint to a control authority. The complaint can me made to the authority from the website’s headquarters, the users’ habitual country of residence, his place of work and the place where allegedly the infringement was practiced.
12. OF THE CHANGES
The organization reserves the right to modify, at any given time and without prior notice, the terms of this policy, specially to adapt it to the evolutions of our website, either by providing new features, either by the suppression or modification of those that already exists.
In this way, we invite the Holder to periodically check this page to verify for any updates.
By using this service after possible modifications, the Holder of the data shows your accordance with the new standards. If he disagrees with any of the changes, he must interrupt, immediately, the access to the website or the area of the participant and present your caveat to costumer service, if he wishes so.
13. TO THE RIGHT TO THE APPLIABLE FORUM
For dispute settlement arising from this instrument, it will be fully applied the Brazilian law.
Any disputes should be presented in the forum of the County of São Paulo/SP where is the headquarters of Ellohub.
Last update: February 15th 2022
