OCTOBER /2023

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1. Glossary
Consumer: term used to designate people who purchase courses from FGPós.

Personal data controller: natural or legal person, governed by public or private law, who is responsible for decisions regarding the processing of personal data, in this case, FGPós.

Cookies: files that have the purpose of identifying a computer and obtaining access data, such as pages browsed or links clicked, thus allowing them to personalize their navigation, according to the user's profile.

Personal Data: information related to an identified or identifiable natural person.

Non-Personal Data: any information that does not relate to a person and/or cannot be used to identify a person.

Person in charge: Person appointed by FGPós to act as a communication channel between the controller, data subjects and the National Data Protection Authority (ANPD).

Personal data operator: natural or legal person, governed by public or private law, who processes personal data on behalf of the controller.
Partner: term used to designate people (individuals or legal entities) who offer courses in collaboration, cooperation or competition with FGPós.

Participants: term used to designate people who take advantage of the courses purchased by Consumers. If Consumers purchase courses in their own name, they will also be Participants. On the other hand, if the Consumer purchases courses for the benefit of third parties, they will only be considered Participants, and not Consumers.

Processing of personal data: any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction.

 

2. Obtaining personal and non-personal information
2.1. When registering on the FGPós website, some information will be collected, including personal data from all users whenever they provide it voluntarily to achieve the purposes set out in this Policy, which include, for example:
Data classification:

Registration data

Data description:

Information for user registration on the FGPós website to receive information

Data types:

Full name, email and cell phone (WhatsApp)

2.2. When registering on the FGPós website, the user is aware that FGPós may use access to data from their social networks, such as Facebook, Linkedin and Instagram, and the information that FGPós may obtain, in this case, depends on the configuration settings. privacy defined by the user with the social network service.
2.6. For the purposes of the provisions of Law No. 13,709/2018 (“General Personal Data Protection Law”), FGPós may act both as a controller of personal data, when it operates its own courses, and as an operator of personal data, when it collects personal data to one of your partners, depending on the circumstances and specific case.

 

3. Use of personal information
3.1. Personal data will be used in a manner compatible with the provisions of this Privacy Policy, with the aim of providing, developing and improving the services provided or products offered.
3.2. FGPós will use personal data to:
a) make contact with the holder and provide the information requested and create a profile for direct marketing.
b) send important notices and notifications, such as communications about courses and services offered. As this information is important for interacting with FGPós, the user will not be able to opt out of receiving this type of communication;
c) improve security and improve FGPós services and offers, as well as personalize the experience and product offerings of registered users;
d) recommend events and send advertising, as well as other promotional materials aimed at marketing our services and news to users, which includes digital campaigns such as targeted marketing on social networks and notifications;
e) internal and managerial purposes, such as auditing, data analysis and research to improve products, services and communications with customers and generating statistical analyzes regarding the use of our services, including consumer trends.
3.2.1. FGPós will process personal data based on the following legal hypotheses: compliance with legal obligations, execution of a contract, regular exercise of rights and fulfillment of legitimate interests. The legal basis for processing may vary depending on the activity carried out.
3.3. The Consumer is aware that, if they no longer wish to receive promotional emails, they must request to unsubscribe or block the email list.
3.4. If FGPós uses any personal data in a manner different from those established in this Privacy Policy, the user will be informed in advance about this new use, before or on the date on which the personal data is received.

 

4. Sharing of personal information
4.1. FGPós does not sell its users' personal data to third parties, however there are situations in which FGPós may disclose, transfer or share personal data with third parties, as provided in this document and Brazilian legislation.
4.2. FGPós may share personal data with operators, for the following purposes: (i) the development of new products and services; (ii) offering products and services that best meet users’ interests; (iii) generation of statistical and aggregated data about the use of products and services and user profiles.
4.3. FGPós may share its users' personal data with contractors and service providers who process such data on behalf of FGPós, in order to perform certain functions related to FGPós' activities, such as, but not limited to, marketing agencies, service providers of database services, disaster recovery and backup service providers.
4.5. Whenever requested, FGPós will share its users' information with police or judicial authorities, competent public authorities or other third parties, inside and outside Brazil, if required by applicable legislation, by court decision and by request from authorities, or if necessary to respond to legal processes or to participate in possible litigation or disputes of any nature.
4.5.1. In these situations, FGPós will cooperate with the competent authorities when necessary and appropriate in relation to any investigation of illicit acts, infringements of industrial or intellectual property rights, or other activity that is illegal or that may expose FGPós or its users to any legal liability. or impose risks on them, except in cases of confidentiality of information contained in applicable legislation.

 

5. Storage of personal information
5.1. Personal information collected by FGPós will be stored in reliable cloud services, provided by partners who may be located in Brazil or other countries, such as the United States of America (USA) and European Union countries.
5.2. FGPós stores user information only for the period necessary for the purposes presented in the Terms of Use and this Privacy Policy, always respecting the data retention period determined by applicable legislation.
5.3. FGPós uses its best efforts to respect and protect users' personal information against loss, theft or any type of misuse, as well as against unauthorized access, disclosure, alteration and destruction.
5.3.1. In the event of an information security incident that results in the destruction, loss, alteration, unauthorized access, or leakage of personal data, FGPós will immediately assess the risks to civil liberties and fundamental rights of holders of personal data. Communication to data subjects or the National Data Protection Authority will be carried out depending on the specific case, after evaluating the risks mentioned.

 

6. International Data Transfer
6.1. FGPós may not carry out international data transfers, except in the event that its partners are located in other countries, circumstances in which we will contractually establish that the partner has a standard of data protection and information security compatible with this Privacy Policy, in order to that data is always protected under these terms.

 

7. User rights
7.1. Users can request FGPós, in an easy and accessible way, through our web form on the Privacy Portal or by email dpo@fgpos.com.br, or through the FGPós portal, request from the holder:
(i) confirmation of the existence of personal data processing;
(ii) access to personal data;
(iii) correction of incomplete, inaccurate or outdated data;
(iv) anonymization, blocking or deletion of unnecessary or excessive data;
(v) data portability, within legal limits.
7.2. If a user initiates a request to delete data held by them, FGPós will be authorized to delete or anonymize the requestor's personal data, even if this means removing their availability for the proposed service.

 

8. Use of the FGPós website by minors and incapacitated people
8.1. When registering on the FGPós website, the user expressly guarantees that they are fully capable, in accordance with current legislation, to exercise and enjoy all Services. Furthermore, Users under the age of 18 (eighteen) must obtain the express consent of their parents, guardians or legal representatives to use the FGPós website and its features, in accordance with the provisions of the Terms of Use and the Privacy Policy.
8.2. Parents, guardians or legal representatives will also be fully responsible in the case of access to the FGPós website by children and adolescents, without obtaining prior authorization. They are fully responsible for monitoring the activities and conduct of the respective minors under their care, as well as being aware of the entirety of these Terms.

 

9. Cookies and other technologies
9.1. FGPós has its own policy on the use of cookies and other similar tracking technologies, called “Cookie Policy”.

 

10. General Provisions
10.1. When browsing the FGPós website and using its features, users accept all provisions of this Privacy Policy and other policies that are in force on the date of access, such as the Cookies Policy and Terms of Use. Therefore, it is recommended that users stay up to date.
10.2. This Privacy Policy is subject to constant improvement and improvement. Therefore, FGPós reserves the right to modify it at any time, according to the purpose of the FGPós website, such as for adequacy and legal compliance with a provision of law or standard that has equivalent legal force, and users are responsible for checking it whenever access the FGPós website. When there is a relevant change to the Privacy Policy, FGPós will inform users accordingly.
10.3. Any tolerance regarding any violation of the terms and conditions contained in this domain will be considered mere liberality and will not be interpreted as novation, invocable precedent, waiver of rights, tacit alteration of contractual terms, acquired right or contractual alteration.
10.4. If any provision of this Policy is deemed inapplicable or ineffective, the rest of the rules continue to be in force, without the need for a judicial measure declaring such assertion. The terms described here will be interpreted in accordance with Brazilian law.
10.5. Communication between FGPós and the user must be carried out through the service channels indicated and made available on the FGPós website, mainly through the Support email.dpo@fgpos.com.br, or via the web form – request from the holder to exercise rights
10.6. Whenever possible, potential disagreements between the user and FGPós will be resolved amicably. When all efforts in this regard have been exhausted, you hereby agree that the court of the district of São José do Rio Preto-SP is elected to resolve disputes or complaints arising from the use of our website or related to this Privacy Policy