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Privacy Policy

PERSONAL DATA PRIVACY POLICY

POLICY APPLICATION

This Privacy Policy (‘’Policy’’) establishes how CRT Adjusters collects and processes the Personal Data of people who access and use its services (“you”). We recommend that you read this Policy carefully and also consult it regularly to ensure any changes, in accordance with the terms of this instrument.

We emphasize that this Policy does not apply to the processing, by CRT Adjusters, of the Personal Data of its employees, in relation to the functions they perform for CRT Adjusters.

For the purposes of this Privacy Policy, Personal Data means any data that relates to an identified or identifiable natural person (“You”).

THIRD PARTY SERVICES AND APPLICATIONS

This Privacy Policy does not apply to third-party applications, products, services, websites or social media resources, which may be accessed through links we provide for your convenience and information. Accessing these links will cause You to leave our environment and may result in the collection or sharing of information about You by third parties. We do not control or make any representations about these third-party sites or their privacy practices, which may differ from ours.

COLLECTION OF PERSONAL DATA

You accept and agree that CRT Adjusters may collect your Personal Data in the following circumstances:

  • when you visit a CRT Adjusters website (each a “Site”) or use features or resources available on or through a Site. When you visit a Site, your device and browser automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to a Site and other technical communications information), some or all of which may constitute Personal Data.
  • when you download or use a CRT Adjusters mobile application (each an “Application”). CRT Adjusters Applications may record certain information (including Application usage statistics, device type, operating system, Application settings, IP address, language settings, dates and times of connection to the Application, location data and other information technical communications), some or all of which may constitute Personal Data.
  • when you register for any service provided by CRT Adjusters through a Site or an Application or when you start any session on a Site or an Application, including the following: registration details, username, email address .
  • when you contact CRT Adjusters, whether in person, by post, by telephone, online, by electronic communication or by any other means of communication.

RECEIPT OF PERSONAL DATA FROM THIRD PARTIES

You accept and agree that CRT Adjusters may receive your Personal Data from third parties in the following circumstances:

  • If you choose to make a payment directly to CRT Adjusters, it may receive your Personal Data from third parties such as information about payment service providers, for the purposes of that payment, including: purchase details, payment data, etc.
  • If a credit check is carried out by CRT Adjusters on your behalf in connection with a credit application, in accordance with Applicable Laws, CRT Adjusters may receive your Personal Data from credit checking agencies and other third parties for the purposes of checking credit, including: confirmation of whether or not the agency was able to verify your details and reference check results, including your credit rating.
  • Within the scope of its obligations and in accordance with Applicable Laws, CRT Adjusters may receive your Personal Data from public bodies.

DATA COLLECTED AUTOMATICALLY – COOKIES

Navigation cookies are text files containing small amounts of data that are transferred to a device, or more precisely, to the browser used on the device, when visiting a website. Cookies are used to make websites work fully, to monitor your movements on the website, and to remember user behavior since the beginning of a session. Placing cookies will help the website to recognize your device on your next visit.

We may use both cookies (which expire after you close your browser) and cookies without an expiration date (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website. We use two types of cookies: Firstly, cookies inserted by us on your computer or mobile device, which we use to recognize you when you return to visit our website; and third-party cookies that are from services provided by third parties on our website, and which can be used to recognize when your computer or mobile device visits our and other websites.

At any time, you can, through your internet browser, decide to be notified about the reception of cookies, as well as block their entry into your system.

Refusal to use cookies on the website may result in the impossibility of accessing some of its areas or receiving personalized information.

CATEGORIES OF PERSONAL DATA PROCESSED BY OR ON BEHALF OF CRT ADJUSTERS

The categories of Personal Data that may be processed by or on behalf of CRT Adjusters, to meet legal or contractual purposes arising from the relationship established, in accordance with this Policy (to the extent permitted by the General Data Protection Law), include:

  • Personal data: name; sex; photography; date of birth; profession; company or employer; sector;
  • Contact details: email address; Postal code; phone number; fax number; customer identification number;
  • Data related to Sites or Applications: technical data (as described above, including device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to a website, statistics usage of the Application, Application settings, dates and times of connection to the Application, location data and other technical communications information necessary for the operation of the Website or Application in question; username; password; security login details; usage data; aggregated statistical information;
  • Commercial data: financial details and payment information (including bank details or credit card details provided in connection with a purchase);
  • Marketing data: advertising interests; cookie data; clickstream data; browsing history; responses to direct marketing; and cancellation of direct marketing.
  • CRT Adjusters may collect or obtain personal data clearly made public by you, including through social media (for example, we may collect information from your profile(s) on social media if you make a public post about us ).

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

When processing your Personal Data for the purposes set out in this Policy, CRT Adjusters may, depending on the circumstances, rely on any of the following legal bases:

  • we have obtained your express consent before processing, including, but not limited to, when you are aware of any third-party content or advertising on a website or in an Application (including third-party plugins and cookies), CRT Adjusters receives your personal data from of the aforementioned third parties providing such content or advertising;
  • we have a legitimate interest in carrying out the processing (including our legitimate interests in operating our business, providing services to you, alerting you to other services that may be of interest to you and maintaining or improving our services) and we do not there is any undue risk to your rights, freedoms or interests;
  • the processing is necessary within the scope of the possible execution of a contract concluded with you or for your benefit or preliminary procedures related to this contract;
  • the processing is required by Applicable Laws;
  • the processing is necessary to protect the vital interests of any individual; or
  • any other legal basis available under Applicable Law.

PROCESSING OF YOUR SENSITIVE PERSONAL DATA

CRT Adjusters does not collect or process your Sensitive Personal Data, except when:

  • the processing is required or permitted by Applicable Laws;
  • processing is necessary to establish, exercise or defend legal claims;
  • CRT Adjusters has obtained your prior explicit consent before processing your Sensitive Personal Data; or

any other legal basis for the Processing of Sensitive Personal Data.

PURPOSES FOR WHICH CRT ADJUSTERS MAY PROCESS YOUR PERSONAL DATA

CRT Adjusters may process your Personal Data for the following purposes, in particular, to the extent permitted by the General Data Protection Law:

  • to display the content of a Site, Application or Device and any customizations you may select;
  • to monitor, adapt, update, protect and improve services we offer you;
  • For fulfillment and execution of a signed contract or preliminary procedures related to a contract;
  • to respond to your requests for assistance and support needs;
  • to administer content, promotions, questionnaires or other features of a Site, Application or Device;
  • to send you information relevant to previously contracted services, subject to compliance with Applicable Laws with regard to direct marketing;
  • to send you communications about the administration of your accounts and the functionality of a Site, Application or Device;
  • to give effect to your legal rights and your rights under this Policy;
  • to protect against fraud, identity theft and other illegal activities in compliance with the established relationship, whether commercial or contractual;
  • to establish or exercise CRT Adjusters’ legal rights or defend legal claims;
  • to comply with Applicable Laws and our other applicable policies.

DISCLOSURE OF YOUR PERSONAL DATA

CRT Adjusters will not sell, exchange or rent your Personal Data to third parties without your consent. We may, however, share or disclose your Personal Data to third parties in the following circumstances:

  • to CRT Adjusters employees, to the extent necessary to provide services and comply with legal obligations;
  • with CRT Adjusters recipients for the purposes of managing our business, operating the Sites, Applications or Devices, providing products or services selected by you or for the purposes set out in this Policy;
  • with recipients outside CRT Adjusters, for the purposes of managing our business, operating the Sites, Applications or Devices, providing services selected by you or for the purposes set out in this Policy;
  • through third-party service providers to help us operate our business, operate Sites, Applications or Devices, provide products or services selected by you, or administer activities on our behalf, such as sending newsletters or surveys. We may share your Personal Data with these third parties for the purposes set out in this Policy;
  • only with your consent, to share your Personal Data with our external marketing partners for direct marketing purposes, and you can withdraw your consent at any time or object to the processing of your Personal Data for the purposes of direct marketing;
  • in the event of a sale, merger or transfer of all or part of our business or assets (including in the event of reorganization, dissolution, liquidation or other corporate restructuring), we may disclose your Personal Data to the potential seller or buyer or their representatives, provided that we take appropriate measures to ensure the security and confidentiality of your Personal Data;

to the extent necessary to establish, exercise or defend legal claims; (ii) if required by applicable laws or regulations; (iii) in response to requests from government agencies and law enforcement authorities; (iv) when disclosure is necessary or appropriate to prevent physical harm or significant financial loss; and (v) for the purposes of investigating illegal activities.

INTERNATIONAL TRANSFER OF PERSONAL DATA

Specifically, the content and features of a Site, Application or Device may be provided through servers located outside of your jurisdiction (including, without limitation, servers located in the United States). Your Personal Data may be transferred and processed using these servers or other Processing Facilities, as part of the operation of a Website, Application or Device or in connection with any of the Processing purposes indicated in this Policy, always in accordance with the provisions of Applicable Laws. These transfers are necessary to provide you with our services efficiently and effectively.

By providing Personal Data to CRT Adjusters under this Privacy Policy, you acknowledge that your Personal Data may be transferred to locations outside your jurisdiction. If you do not want your Personal Data to be transferred to other jurisdictions, do not provide your Personal Data to CRT Adjusters or use the Sites, Applications or Devices.

However, we take security measures to require that your Personal Data remains protected in accordance with this Privacy Policy. This includes implementing standard contractual clauses for Personal Data transfers. We will also implement similar safeguards with our third-party service providers and partners.

PROTECTION OF YOUR PERSONAL DATA

CRT Adjusters is committed to processing your Personal Data securely and in accordance with the Personal Data Protection Law. We adopt appropriate data processing practices and appropriate technical and organizational security measures to protect Personal Data against unauthorized access, alteration, disclosure or destruction. The Internet is not, in itself, a secure environment and we cannot provide an absolute guarantee that your Personal Data transferred over the Internet will always be protected. The transmission of Personal Data over the Internet is your responsibility and you must only use secure systems to access Sites, Applications or Devices.

You are responsible for keeping your access credentials for each Site, Application and Device secure and confidential. You must frequently change your access credentials and you must notify CRT Adjusters immediately if you become aware of any misuse of your access credentials and change them immediately.

ADVERTISING AND MARKETING

We may collect, process and use your Personal Data from time to time by email, text message or other electronic or communication means for advertising or market research purposes and, in particular, to improve the services offered by CRT Adjusters, and to provide information about services that may be of interest to you. Alternatively, you can use the cancellation functions provided through our Sites and Applications or through our Manager.

CRT Adjusters may also allow third parties, such as analytics companies, advertisers and ad networks, to automatically collect information about You through our websites using cookies, web beacons and device identifiers, including Personal Data about your online activities over time and across different websites, devices, online channels and applications when You use our websites. Among other things, this may allow targeted advertising from CRT Adjusters or third parties to be shown to You when You are visiting other websites, for example advertising relevant to Your location or for services You have looked at, recommended or purchased. However, if You see advertising of this type, it does not mean that We provide advertisers with Personal Data such as your name, address and date of birth.

Please note that even if you opt out of marketing or advertising communications, we may still contact you to send you instructions, administer your account, or as otherwise required or permitted by Applicable Law.

CHILDREN AND ADOLESCENT DATA

Our website is not directed to children under 18 years of age. If a parent or guardian finds that his or her daughter has provided personal data on our website without their consent, they should contact us immediately. We will delete all this data as quickly as possible.

COMMUNICATIONS VIA EMAIL

We will only use your email address for the purposes for which You authorize it.

If You have expressly agreed to receive marketing emails or newsletters, You agree to receive communications from CRT Adjusters with content selected or prepared by us or advertising emails to the email address You have provided to us. Communications from CRT Adjusters may appear at regular or irregular intervals and, in addition to information belonging to CRT Adjusters, may contain offers from CRT Adjusters’ commercial partners or third parties. You can unsubscribe from CRT Adjusters communications at any time, using the link for this purpose, present in the messages themselves.

THE RIGHTS OF PERSONAL DATA SUBJECTS

It is your responsibility to ensure that your Personal Data stored by CRT Adjusters is complete, correct and up to date. Under Applicable Laws, you may have the following rights:

  • right to access your Personal Data processed by us;
  • right to correct and/or update your Personal Data;
  • right to anonymization of your Personal Data;
  • right to portability of your Personal Data to any other entity, in a structured manner;
  • right to erasure of your Personal Data processed by us;
  • right to information about the public and private entities to which the company shared your Personal Data;
  • right to object, for legitimate reasons, to the Processing of your Personal Data;
  • right to request, for legitimate reasons:
  • the deletion of your Personal Data processed by us; It is
  • the restriction of the Processing of your Personal Data processed by us;
  • if we process your Personal Data with your consent, the right to revoke that consent; It is
  • right to submit complaints regarding the Processing of your Personal Data to the National Data Protection Authority.
  • This does not affect your regulatory rights. You can exercise any of these rights using the contact details.

If you wish to exercise any of the above rights or have questions or concerns about how your personal data is being used by us, please contact i-lgpd@crtadjusters.com.br. Please note that these rights are not absolute and, in some circumstances, we may have the right to refuse your request, in whole or in part.

TERMINATION OF DATA PROCESSING

CRT Adjusters will terminate the processing of your Personal Data in the following cases:

  • when the purpose has been achieved or the data is no longer necessary in accordance with this Policy;
  • when the deadline required for processing has been reached;
  • when you request the deletion of Data;
  • by determination of the national data protection authority or other legally constituted authority.

You are aware that, even after the end of Data Processing, CRT Adjusters may keep Personal Data for the following purposes:

  • compliance with legal or regulatory obligations;
  • transfer to third parties, when applicable;
  • Anonymized use by CRT Adjusters

INFORMATION SECURITY AND CONFIDENTIALITY

CRT Adjusters takes precautions to protect your Personal Data from loss, misuse, unauthorized access, publication, alteration and distribution. We implement technical and organizational measures to protect your Personal Data and we contractually require our suppliers and service providers to protect your Personal Data with the same degree of care.

Additionally, CRT Adjusters makes every effort to maintain the confidentiality of the information it receives, processes and maintains. Information is revealed respecting this principle and is only revealed if legally substantiated and in accordance with this Data Privacy Policy.

ACCEPTANCE OF THIS POLICY

By using our services, any Website, Application or Device, you are deemed to have accepted this Policy. If you do not accept the terms set out in this Policy, you should not use our services, Sites, Applications or Devices.

POLICY CHANGES

CRT Adjusters may change, revise or update this Privacy Policy at any time, without providing you with any specific notice. We recommend that you check this Policy frequently to see if there are any changes and to stay informed about the ways in which your Personal Data is protected.

CONTACT

If You have any questions or concerns about this Privacy Policy, our practices for collecting and using Personal Data, or about a possible breach of Personal Data or privacy, please contact CRT Adjusters via the following email: i-lgpd@crtadjusters.com.br.

If you contact us, we will attempt to investigate and resolve each issue or complaint within 15 days or such other period as required by Applicable Law.

Keep in mind that email communications are not always secure. Therefore, please do not include sensitive information in your emails to us.

DEFINITIONS

In this Policy, the following terms shall have the meanings indicated below, unless expressly indicated otherwise:

“Personal Data(s)”: means any information that, directly or indirectly, alone or accompanied by other data, identifies or can identify a natural person. Examples of personal data are: name, CPF, CTPS number, Internet Protocol (IP) number, email address, bank account number, financial profile, taxpayer identification, professional registration, geolocation, among others. This concept includes Sensitive Personal Data, as defined below.

“Sensitive Personal Data(s)”: means any information that reveals, in relation to a natural person, racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious nature, philosophical or political data, data relating to health or sexual life, genetic or biometric data, when linked to a natural person, in addition to those Personal Data whose processing may reveal Sensitive Personal Data.

“Third party(s)”: means any Person, whether natural or legal, other than CRT Adjusters or affiliated companies or from the same economic group as CRT Adjusters, and includes CRT Adjusters subcontractors.

“Holder(s)”: means in relation to a given Personal Data, the natural person identified or who can be identified to whom that Personal Data refers.

“Processing”: means any and all operations carried out on Personal Data or Sensitive Personal Data, including, but not limited to, collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage , elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.