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1.WHAT PERSONAL DATA DO WE COLLECT?
- Name, address with zip code, telephone, date of birth, gender, e-mail, ID, CPF;
- Complementary identification information, provided when You use a service (SAC), record an occurrence or participate in any of our promotional actions, surveys and/or events (such as, for example, profession and/or education level);
- Data related to your vehicle, such as your driver‘s license number, license plate;
- Financial and payment data, to the extent permitted and in accordance with criteria established by applicable law;
- Information about your consumption;
- Technical information collected from the device You use to access our website, applications, online platforms, wi-fi (IP, Mac Address, IMEI, Location, among others possible);
- Information We receive about You from third parties, including from publicly available databases, information You voluntarily make available to the general public (such as your profile, posts or information on social media);
- Your image, including video, sent by You through our website, applications and online platforms or captured through closed circuit systems in shopping malls.
Sensitive Data. According to the legal definition, sensitive personal data are those related to: racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data ("Sensitive Data"). In the event of capturing such data, it will be carried out following the criteria required by the applicable legislation.
Children and Adolescents Information. We collect information from children with the consent of a legal guardian or when collection is necessary for the protection of the child. We may collect information from teens only in their best interest, to fulfill requests or provide a requested product or service.
Update. From time to time, we may ask you to update your registration data.
2.HOW WE COLLECT YOUR PERSONAL DATA?
We collect your information in a variety of circumstances, including:
When creating your registration in one of our Activities, your registration may be associated with other information that we collect or that You provide to us;
When You visit a shopping center in which brMalls manages;
When You access, request or use one of brMalls‘ Activities, including, but not limited to, our websites, applications, online platforms, sales and delivery channels and Wi-Fi;
When You record a service request or an occurrence, such as compliments, complaints and suggestions to brMalls;
When we work with business partners who have information about You, collected independently and for the purposes described in Section 3, below.
Data collected online. As You access the Activities, especially our websites, applications and Wi-Fi, technical information regarding your device or connection may be obtained by brMalls, such as IP address, browser used, SSID and signal strength of nearby wireless networks, type and brand of mobile device, mobile device identifiers, operating system version, network information, Internet connection provider used, device configuration and software data.
You can manage these technologies through your device settings or web browser. The configuration of these technologies, however, may affect some features offered by our online platforms.
Information collected from third-party databases. brMalls may also obtain information about You from public and private databases, such as business partners, when You link your login to them, as well as from other service providers, provided that your information has been obtained in accordance with applicable law and can be shared with brMalls.
3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
Your personal data is used for the following purposes:
- Make available, provide, provide and maintain our Activities;
- Promote your safety, when you go to the malls in which brMalls manages;
- For purposes of recording and resolving incidents, such as lost ticket or return of lost and found;
- To get to know you better as a customer, providing promotions, offers, discounts and benefits, according to your information, profile and/or location;
- For advertising purposes and advertisements about brMalls and/or third party products and services, including targeted advertising, in the context of our Activities;
to allow the provision of services by third parties that are commercial partners of brMalls, such as, for example, services related to parking;
to communicate with You, including through service announcements, dissemination of events, news, newsletters, notifications, SMS, messages via apps such as WhatsApp, social networks and/or marketing related to our Activities;
to comply with requests made by You in connection with the Activities;
to conduct or support commercial promotions, contests or sweepstakes when You choose to participate in such activities;
to generate analysis and statistical reports on the functioning and operation of the Activities, for the benefit of brMalls and its business partners, aiming at improving the services provided/available to You;
customize, develop and improve our Activities and functionality by combining and using the information we have about You, such as the way You interact with the Activities, the resources You use the most, the content You interact with the most and your preferences in general;
carry out satisfaction surveys on the Activities;
to detect, identify, deter and defend against fraudulent, abusive or illegal activities;
comply with legal obligations to collect, retain and/or share data, including with government authorities, pursuant to applicable laws and regulations;
for the exercise of brMalls‘ rights in administrative, arbitration or judicial proceedings, in accordance with the law, and for the defense of brMalls, its rights, assets and legitimate interests.
4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
brMalls may share your information:
- in the event of an accident occurring on the premises of Shopping Centers in which BrMalls holds an interest, data relating to the vehicle‘s license plate may be shared with authorities;
- when You request or consent to sharing;
- to bodies, authorities and other entities of the Public Power, as well as to individuals or legal entities of a private nature, in compliance with a legal obligation or a court order;
- for the exercise and defense of any rights of brMalls, at its discretion, including within the scope of legal or administrative proceedings;
- in the event of a change in the ownership or control of brMalls or of a shopping center in which brMalls holds an interest and manages, due to a merger, acquisition, spin-off or sale of assets, and its information may be transferred to the new owner, at its discretion from brMalls.
brMalls does not sell or offer Users‘ personal data to companies, organizations or other individuals outside of brMalls.
International Transfer of Personal Data. brMalls has business partners and service providers in Brazil and abroad and, in this sense, uses a technical infrastructure on a global scale, with the objective of optimizing the efficiency, performance and safety of the Activities.
5. HOW AND HOW LONG DO WE KEEP YOUR PERSONAL DATA?
- The information collected by brMalls may be stored directly by brMalls and/or by brMalls service providers. brMalls will adopt security standards to protect the integrity, confidentiality and availability of the information stored as set out below.
How Long Do We Keep Your Information? Your information is processed and maintained for the period necessary to provide the Activities, while You remain using or linked to one of our Activities; to fulfill the purposes set forth in Section 3; and to handle any demands, as well as to comply with applicable legal, accounting or regulatory requirements. The minimum storage period will be of 5 (five) years, being, at brMalls‘ discretion, the reduction of this period, considering, among others, the engagement or connection of the data subject to our Activities.
Safety. brMalls adopts reasonable security, technical and administrative measures to prevent irregular or unlawful processing of Users‘ personal data, including unauthorized cases of access, destruction, loss, alteration or communication of data. These measures include physical, operational and technological protections, including the control of access to information, the use of security software and the training of our employees.
Security measures apply to your information only from the moment brMalls receives it and while it is in its custody. The operation and security of the device You use to access the Activities, as well as third-party networks through which the data travels, is not the responsibility of brMalls.
6. WHAT ARE YOUR RIGHTS AS A HOLDER OF PERSONAL DATA?
The following rights of the holder of personal data may be exercised as applicable, upon User‘s request:
- confirmation of the existence of processing of personal data;
- access to personal data;
- correction of incomplete, inaccurate or outdated personal data;
- anonymization, blocking or deletion of unnecessary, excessive or processed data in violation of the provisions of the LGPD;
- portability of personal data to another provider of a service or product, subject to national authority regulation;
- deletion of personal data processed on the basis of your consent, except when the law authorizes the maintenance of these data for another reason;
- information about public and private entities with which BrMalls has shared use of your personal data;
- information about the possibility of not giving consent to the processing of your personal data and about the consequences of such action; and
- revocation of its consent, when the processing has been carried out on the basis of the holder‘s consent.
7. HOW TO EXERCISE YOUR RIGHTS AS A HOLDER OF PERSONAL DATA?
We will be happy to clarify any doubts and/or respond to your request. Please note that under applicable law, we reserve the right to verify your identity before we respond to your request.
brMalls may keep certain personal data stored and/or anonymize them, after your request for deletion, as and to the extent authorized by applicable law.
If you request the deletion of your information, but still have an outstanding obligation to comply with brMalls, your information will not be deleted and will remain stored for the purpose of enabling the solution of the pending issue and the adoption of appropriate measures.
8. PRIVATE POLICY UPDATE
This Policy may be periodically updated.
All changes must be considered as applicable and effective immediately, unless otherwise communicated by brMalls to the data subjects.
DATA PROTECTION OFFICER
The GDPL (General Data Protection Law), Law No. 13.709/18, entered into force in September 2020 and establishes rules for the use, collection, storage, processing and sharing of users‘ personal data by public and private companies.
brMalls is committed to adapting the company‘s processes to comply with the law and, in this regard, we inform you that Marina Moreira, Deputy Director of Legal Affairs, has been designated brMalls Data Protection Officer (DPO - Data Protection Officer), responsible among others, through communication with ANPD, whose electronic contact is email@example.com
We remain available for any questions or further clarification, through the contact channels: firstname.lastname@example.org or email@example.com.