CROWD privacy policy

Hello! Welcome to Crowd's Privacy Policy ("Platform" or "Us"), a virtual platform owned by Crowd Agency Sistemas e Tecnologia Ltda - ME ("Crowd"), a legal entity governed by private law, registered with the CNPJ/MF under No. 18.134.801/0001-05, headquartered in the city of São Paulo, State of São Paulo, at Rua Cardeal Arcoverde, 2450, Sala 205, Pinheiros, CEP 05.408-003.

Crowd respects your privacy and understands that the Client, the Professional and/or the Company, collectively referred to as “Users”, and individually as a “User” care about how their information (“Information”) is used and shared , therefore, Crowd appreciates your trust and guarantees that it will do so carefully and sensibly, in compliance with the General Law for the Protection of Personal Data (Law nº 13.709/2018).

This privacy policy (“Privacy Policy”) was designed to be clear and objective, allowing our Users to understand in a simple way how Crowd works and how the User's personal information will be processed, provided that Crowd agrees to maintain the confidentiality and security of personal information provided by Platform Users. If you have any questions, we are available to listen to you. Your opinion is very important to Crowd.

This Privacy Policy explains how Crowd obtains, registers, uses, disposes, discloses, shares, stores and protects User Information and applies to any person who has access to the services offered by Crowd through the Platform, available from in accordance with the Terms of Use and this Privacy Policy.

The Privacy Policy is an integral part of Crowd's Terms of Use, which Users must review and accept. Before accessing and using the services offered by Crowd, Users declare that they have made the fully read and fully agree with all provisions of this Privacy Policy, expressly granting their consent for the processing of their personal data by Crowd, for each of the purposes described below and within the limits provided for in this instrument and by the applicable legislation, which may be revoked at any time by Users through Crowd's communication channels. If Users do not agree with the content of any of the provisions of these documents, we request that they do not use the Platform and/or the services offered.

2. Information Collected and Purpose of Personal Data Processing

Crowd collects Personal Information voluntarily provided by Users at the time of registration and during the use of the services offered by the Platform, observing the principles of good faith, purpose, suitability, necessity, free access, data quality, transparency, security, prevention and non-discrimination.

When accessing and browsing the Platform, Crowd may also collect information made available by internet browsers, such as information about the device used (mobile or computer), IP addresses, pages visited, date and time of connection, among others, as detailed below.

The processing of Users' personal data is carried out by Crowd so that it can improve and provide the services available on the Platform, to properly identify Users, as well as to comply with legal and regulatory obligations, and also, whenever necessary for the exercise regulate their rights.

Crowd collects the following types of information from Users:

2.1 Registration Information

When Users register on the Platform, Crowd collects the information provided, namely: full name, e-mail address (e-mail), telephone number and indication of an area of expertise. Next, the Professional and/or Company must fill in the information related to their professional experiences (Resume) and must create an access password.

Users declare and guarantee the veracity, accuracy, validity and authenticity of the entered data provided to Crowd and undertake to keep them up to date, as well as being responsible for all acts that are carried out using their access credentials, including login and passwords, exempting Crowd from any losses arising from improper use by third parties.

Crowd reserves the right to remove from the Platform any Users who do not observe this Privacy Policy or who have, during the registration phase or use of the Platform, adulterated, falsified or omitted essential data or information, or even, do not have kept updated. Crowd will not be responsible for the veracity, accuracy, validity and authenticity of data entered by Users.

Rights of the User holder of the Personal Data. Pursuant to article 18 of the General Data Protection Law, at any time and upon request via email [email protected], the User may (i) confirm the existence of treatment, (ii) access their personal data, (iii) review and update their registration and contact information, as well as correct incomplete and inaccurate data, (iv) request anonymization , blocking or deletion of unnecessary and excessive personal data for the purpose for which you consented or treated in breach of the law; (v) request the portability of data to another service or product provider, subject to commercial and industrial secrets, (vi) request the deletion of personal data processed with your consent, except in the cases provided for in article 16 of the said law, ( vii) revoke your consent in a free and simple way, (viii) request information from public and private entities with which Crowd performs shared use of data.

Users declare themselves aware that the exclusion of the Personal Information requested by Crowd, and essential for the use of the Platform, will imply in the impossibility of maintaining their registrations and in the impossibility of contracting our services.

THE INFORMATION COLLECTED IN THIS ITEM 2.1 WILL BE COLLECTED BY CROWD UPON SPECIFIC CONSENT FROM THE USER AND USED SO THAT CROWD CAN CORRECTLY AND DUELY IDENTIFY THE USER, IN ORDER TO ENSURE THE PREVENTION OF FRAUD AND THE SECURITY OF THE USER HOLDER OF THE PERSONAL DATA.

2.2 Cookies, Pixel Tags, Log Files, Web Beacons and Others

The Platform may use cookies and pixel tags, which enable the collection of information regarding your browsing history, date and time of access, facilitate User login (by storing username and password), assist in User interaction with the available services, align the general interests of the Users, in addition to adjusting the User's demographics to improve the performance of the Platform and provide a better experience to its Users. Users will be able to configure certain settings to block cookies, however, this may limit certain functionality of the Crowd Platform.

Cookies. Cookies are small text files that are transferred via server to your device (personal computer, hard drive, tablet, mobile phone, etc.). Crowd may use both session cookies and persistent cookies to better understand how the User interacts with the Platform and the services provided by Crowd, as well as to monitor aggregated usage by Users and redirection of web traffic, as well as to improve and personalize our services, manage sessions, navigations, accesses, User registrations, and identify User preferences. By deleting our cookies or disabling future cookies, Users declare themselves aware that they may not have access to certain areas or functionalities offered by the Platform.

Log File. The Platform may keep log files that record activities related to the use of the Platform, such as access to other websites, the type and quality of internet connection, hardware and/or software and the functionalities of a particular service that has been used. These log files may be used to monitor traffic on the Platform and troubleshoot technical issues.

Web Beacons. The Platform may also use web beacons (or pixels) that transmit information from your device to a server, similar to cookies. Web beacons can be inserted into online content, videos and emails, and are used to anonymously track Users' online usage patterns, such as which emails are opened and which links are clicked by the respective recipients. The information collected may identify popular sites, services, features and products, which will be used to customize the services offered by Crowd.

Crowd will also allow third parties to place cookies, web beacons and log files or similar technologies on the Platform, or in emails sent by Crowd, to measure traffic trends and other information that will help Crowd analyze and improve the services available to Users.

In addition, Crowd may collect information about the devices with which Users access the Platform, including the time, IP address, type of browser and device used, the web page visited before accessing the Platform and associated identifiers. to your devices.

THE INFORMATION COLLECTED IN THIS ITEM 2.2 WILL BE USED TO IMPROVE THE SERVICES OFFERED BY CROWD, AS WELL AS, EVENTUALLY, PROVIDE AND OFFER PERSONALIZED ADVERTISING, MONITOR THE EFFECTIVENESS OF THE SERVICES, THROUGH ANALYSIS OF THE NUMBER OF VISITORS, TRAFFIC, USE AND DEMOGRAPHIC PATTERNS AND TO FIX TECHNOLOGY PROBLEMS.

3. Use of Collected Information

3.1 Processing of Personal Data

To provide the Platform services, in addition to other functionalities, Crowd will store, process and transmit User data, files and the information contained therein. By agreeing to this Privacy Policy, Users expressly consent to the processing of their personal data by Crowd, which are essential for using the Platform.

Crowd may use the Information listed above for the following purposes specified below:

Create the necessary account and registrations to allow Users to interact with the Platform;
Provide the User with Crowd's services in an adequate and efficient manner;
Ensure proper identification, qualification and authentication of Users,
Analyze usage statistics and data in order to improve User experience;
Personalize Users' experience: provide Users with an experience compatible with their needs;
To improve our service to Users: your information helps us to respond more effectively to your User service requests and support needs.
Register access information so that the User does not have to complete it every time he connects to the Platform;
Improve, test and monitor the efficiency of the Platform;
Develop and test new products and tools that can be added to the services provided by the Platform;
Monitor information relevant to the Platform, such as the profile, data and information included therein, in order to verify any non-compliance with the rules established by Crowd;
Diagnose and correct any problems and imperfections in the Platform system;
Automatically update the Platform or any related software.
Offer promotions and discounts;
Send information about new products and/or services, offers, institutional news, and information related to the products and/or services purchased, by email;

3.2 Sharing and Confidentiality of User Information

Crowd will not make your Information available to other individuals or legal entities without the prior and express consent of the Users, except for the cases provided below:

For Crowd affiliates and for third parties that help Crowd to provide the Platform, which will have access to the Information and Content, in a manner reasonably necessary for the provision and improvement of the services offered to Users on the Platform;
For Third Parties responsible for publicity or advertisements transmitted through the Platform, considering that such information will be useful to direct and/or guide publicity and advertising especially in the best interest of Users;
For other Users, Professionals and/or Company, in a manner reasonably necessary for the correct provision of services, product delivery, individual identification of Users, etc.
To a credit protection agency, public or private databases, such as Serasa Experian, SPC, SCPC, or even, through any other legal means available to assist Crowd with the evaluation of the User's registration and in case of collection of some value due to the Crowd.

To protect Users, Crowd may remove all or part of data/information that may identify Users when providing data to Crowd's partners. Furthermore, Crowd will combine Users' Information and Contents, in order to make it difficult and protect the association of said information to any specific Users, not constituting such conduct, assumption of responsibility by Crowd.

Access to the Information collected is restricted to employees and persons authorized for this purpose. Employees and/or authorized persons who misuse this information, violating the Privacy Policy, will be subject to the penalties provided for in our disciplinary process, without excluding other applicable legal measures.

Crowd and authorized third parties will treat all Personal Information accessed in connection with the use of the Platform confidentially and will not disclose it to unauthorized third parties.

Crowd and authorized third parties will not be required to maintain the confidentiality of personal data obtained from unrestricted public access sources.

4. Legal Request by Competent Authorities and Prevention of Harm

Crowd may also access, monitor or share Users' Personal Information/Data if: (i) it is requested by a competent judicial or governmental authority for this purpose, including, without limitation, in the event of criminal, civil or commercial litigation; (ii) are necessary to detect, prevent fraud or other illegal activities or in violation of this Privacy Policy or the Terms of Use; and (iii) are harming the functioning of the Platform or in any way harming Crowd's image.

Users expressly accept and authorize Crowd to disclose Personal Data upon receipt of said requirements.

5. Change in Corporate Control

If Crowd decides to sell or transfer control or assets related to the Platform to third parties, Users' Personal Information, such as name, email address, telephone number and other information entered or made available on the Platform may be among the items sold or transferred to third parties, without remuneration or payment to Users. Notwithstanding, Crowd will endeavor to have the third party acquirer implement a Privacy Policy similar to this one.

6. Storage

The Personal Information provided by Users, as well as any other information related to Users, may be stored in databases duly registered with the competent authority, on any server and in any location.

The Personal Information provided is registered in our database or in the database of third parties contracted by Crowd in an automated way and stored in total security, without human intervention and kept in high security servers or magnetic means, both physical and technological.

Crowd will adopt all possible measures to maintain the confidentiality and security of confidential information, but will not be responsible for any damages arising from the disclosure of such information by third parties that use public networks or the internet, subverting the systems of security to access user information.

Crowd undertakes to adopt the best possible measures to (i) maintain the integrity and confidentiality of the Information provided by Users and; (ii) use the best protection systems and resources made available by digital technology to prevent access and/or misuse of such data by third parties, including, among other measures, firewalls and Secure Socket Layers (“SSL”).

Users are exclusively responsible for their user e-mail addresses and password, and should not provide them to anyone, keeping them secret, in order to prevent any undue access to their registration/profile, Information and/or Content by middle of the Platform. We remind you that Users must disconnect from their Accounts and close their browser window when they finish browsing the Internet in order to ensure that third parties do not have access to their Personal Information.

For User safety, Crowd does not request passwords/logins from its Users via email or any other service channel. If Users receive any communication in this regard, they must disregard it and not respond to it and, if possible, they must forward their report to [email protected], so that Crowd can take the necessary legal measures.

After the cancellation or deactivation of the Users' registration, Crowd may keep the Personal Information for the period provided for in Law 13.709, of August 14, 2018 and in Law 12.965 of April 23, 2014, for legal reasons or for a longer period if applicable. new regulation.

7. marketing

When registering at Crowd, Users will receive information about institutional news, new updates, products and services periodically by email. Receiving marketing material can be opted out at any time by simply clicking on the “Unsubscribe” link in any email they receive.

8. External Links

The advertisements available on the Platform may contain links to access external websites, whose contents and privacy policies are not the responsibility of Crowd. Therefore, Crowd recommends that, when redirected to external websites, Users always consult the respective privacy policies before consenting to the collection/processing of their data or information.

9. Changes and Modifications to this Privacy Policy

Crowd may change this Privacy Policy at any time or from time to time. In this case, the updated version of the Privacy Policy will be available on the Platform, with the new “Last Updated” date. If relevant changes are made that imply a new consent by the User, Crowd will require the User's acceptance in a prominent way on the Platform or will forward the updated Privacy Policy, by email, to the User.

10. To Contact Us

If Users have questions or comments about this Privacy Policy or our privacy practices, please contact us at [email protected].

11. Additional Considerations

This Privacy Policy supersedes all previous versions made available by Crowd.

If any provision of this Privacy Policy is considered illegal, invalid or unenforceable in whole or in part, by any legislation, that provision or part of it will be considered non-existent for the purposes of this Policy, but the legality, validity and enforceability of the other provisions contained in this document will not be affected.

The non-exercise of the right by either party cannot be interpreted as a waiver of the same, and precedents cannot be invoked as tacit novation.

This instrument does not matter in the creation of any labor or corporate bond between Crowd and Users.

All communications between Crowd and Users will be considered effective from the sending of emails to the addresses registered by Users, or through the Platform. Users must keep their email address up to date.

This Privacy Policy is governed by the laws of the Federal Constitution of Brazil and the Parties elect the Civil Court of the District of São Paulo, State of São Paulo, to resolve any disputes that may arise in relation to this Privacy Policy.

12. Consent

BY ACCEPTING THIS PRIVACY POLICY, THE USER DECLARES THAT THE USER HAS COMPLETELY READING AND FULLY AGREES WITH ALL THE PROVISIONS OF THIS PRIVACY POLICY, EXPRESSLY GRANTING HIS CONSENT TO THE TREATMENT OF HIS PERSONAL DATA BY CROWD, FOR EACH OF THE PURPOSES DESCRIBED AND IN LIMITS PROVIDED IN THIS INSTRUMENT AND BY THE APPLICABLE LAW, WHICH MAY BE revoked AT ANY TIME BY THE USER THROUGH CROWD'S COMMUNICATION CHANNELS. THE USER ACKNOWLEDGES THE IMPORTANCE OF PROCESSING AND SHARING SUCH INFORMATION, AIMING EXCLUSIVELY THE ADEQUATE PROVISION OF THE PLATFORM'S SERVICES, WHEREAS THE USER'S CONSENT REFERS TO THE ENTIRE DURATION OF THEIR RELATIONSHIP WITH CROWD.

Thank you for reading our Privacy Policy.

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