Mindo

Privacy Policy and General Data Protection Regulation

Privacy Notice

MINDO PUBLICIDADE LTDA. ("MINDO") is committed to protecting your privacy, in accordance with the rules governing the protection of privacy and personal data.

This Privacy Notice ("Policy") explains how and why we process your personal data, and what we do to ensure it is kept secure, in accordance with the General Data Protection Law ("LGPD") and any other applicable data protection and privacy laws ("Data Protection Laws").

For the purposes of this Privacy Policy, "Data Subjects" or "You" means any individual who, directly or indirectly, provides personal information to MINDO in the course of our business, such as clients, visitors, guarantors, sureties, and their respective legal representatives, employees, and/or agents.

This Policy should be read together with, and in accordance with, any other document, contract, or data processing clause that accompanies it, as the case may be. Other notices and information may be sent regarding data processing activities involving your personal data.

Through this Privacy Notice, Data Subjects are informed (i) what personal data is processed by MINDO, (ii) for what purposes and how long it is used, (iii) with whom it may be shared, and (iv) what rights Data Subjects have in relation to the processing of their personal data.

1. Data Collection and Storage

MINDO may collect the following personal data from Data Subjects:

  • Full name;
  • Date of birth;
  • Gender;
  • Nationality;
  • Phone number;
  • Marital status;
  • Full name of spouse, where applicable;
  • Marriage certificate, where applicable;
  • Full address and proof of address;
  • National identity card number (RG);
  • Individual taxpayer registration number (CPF/ME);
  • Copy or numbers of government-issued identification documents;
  • Personal data contained in articles of incorporation and powers of attorney;
  • Organization or company to which the person belongs or is associated, and related information;
  • Position, title, or role;
  • Contract information;
  • Communication preference information;
  • Publicly available information in third-party databases, including government agencies;
  • Verbal or written communication maintained between the User and MINDO;
  • Images collected for MINDO's security systems, such as registration photographs and footage from security cameras on MINDO's premises.

Note that in certain situations, such as prospecting for client relationships or in compliance with anti-corruption best practices and regulations, MINDO may also obtain your personal data from other sources, such as public websites or through background verification providers, in strict compliance with applicable data protection laws and regulations.

Data collected via website. MINDO may collect personal data from Data Subjects who access the website, particularly when the Data Subject chooses to provide such information when contacting us. Additionally, technical information such as your IP address, device identification, location data (based on your IP), and cookie information may also be collected when the User accesses the MINDO website or other electronic properties. MINDO also collects personal data that You voluntarily provide in lead forms published on social media or websites.

Links to other websites. The MINDO website may include links to third-party websites or other software applications or plug-ins. MINDO is not responsible for the content or functionality of any such external websites. If an external website requests your personal data, such information will be processed in accordance with that website's privacy policy, not this Policy.

Security system. MINDO uses a closed-circuit television (CCTV) security camera system on its premises to detect and prevent unlawful acts and to protect MINDO, as well as the safety of our employees and visitors. This means MINDO collects and stores, for a limited period, images of visitors to its premises via CCTV, and in the event of a security incident, MINDO may use such footage.

2. Purposes and Duration of Processing

MINDO carries out data processing activities in accordance with Data Protection Laws. Depending on the circumstances and the nature of our relationship with You, your personal data may be used for one or more of the following purposes:

  • To learn about your interest in our offerings and to be able to offer products suited to your profile and what You are looking for, including through targeted advertising;
  • For registration purposes and other preliminary contracting procedures;
  • For the performance of contractual obligations between MINDO and Data Subjects;
  • To establish contact between MINDO and Data Subjects, including to ensure compliance with contractual or legal obligations;
  • To provide assistance and ancillary services possibly related to contracts established with Data Subjects;
  • To combat and prevent fraud or unlawful acts of any kind, at any time in the context of the provision of products and services by MINDO;
  • To respond to authorities in the context of judicial or administrative proceedings, in compliance with legal, regulatory, or other lawfully required obligations, or in defense of MINDO's rights and legitimate interests;
  • Identification and registration for access to MINDO's physical premises and, where applicable, those of its business partners;
  • To enable your navigation on the MINDO website and other electronic properties, including analysis of your behavior on our website, identification of issues, personalization of features, and website security monitoring;
  • To address requests and contacts from Data Subjects, as well as to receive complaints, investigate reports, or respond to inquiries;
  • To conduct satisfaction surveys or surveys of another nature; and
  • For communication and relationship management purposes with Data Subjects, and so that we may contact Data Subjects, provide information, send notices, including advertising content such as direct marketing, advertising, and promotional activities.

MINDO undertakes to retain personal data only as necessary to fulfill the purposes set out above and to dispose of personal data whenever possible and as may be reasonably required, in compliance with Data Protection Laws. If the User has questions about MINDO's data retention and disposal practices, they may contact the personal data subject communication channel at contato@mindo.com.br.

3. Sharing of Personal Data

MINDO may share your personal data with third parties only when necessary for the purposes listed in this Privacy Notice and in accordance with one or more of the following scenarios:

  • Where the third party in question is one of MINDO's controllers, subsidiaries, or affiliates;
  • Where the third party in question is a service provider or business partner processing personal data on behalf of and in the interest of MINDO;
  • Where the third party in question is an official public body or entity, regulatory authority, law enforcement, or governmental authority, legitimately requesting information in the context of inspections, audits, regular legal proceedings or procedures that constitute legally binding obligations on MINDO, or where reasonably necessary to protect MINDO's rights;
  • When MINDO has obtained the User's free, unambiguous, and express consent for the sharing of data.

4. Security and Location of Processing

MINDO is responsible for adopting and maintaining reasonable technical and administrative security measures to prevent unauthorized, irregular, or unlawful processing of Data Subjects' personal data, including unauthorized access, destruction, loss, alteration, or disclosure of data.

All MINDO employees are subject to confidentiality obligations. In addition, MINDO updates and tests its security systems in accordance with best practices to protect your personal data.

PERSONAL DATA PROCESSING ACTIVITIES MAY BE CARRIED OUT OUTSIDE THE NATIONAL TERRITORY. ALTHOUGH THESE COUNTRIES MAY HAVE DIFFERENT LEVELS OF DATA PROTECTION THAN BRAZIL, MINDO WILL ADOPT SAFEGUARDS, INCLUDING CONTRACTUAL ONES, TO UPHOLD USERS' RIGHTS AND ENSURE THE CONFIDENTIALITY, INTEGRITY, AND SECURITY OF INFORMATION.

5. Rights of the Personal Data Subject

The following rights of personal data subjects may be exercised at any time, in accordance with applicable law, by Data Subjects upon request:

  • Confirmation of the existence of personal data processing;
  • Access to personal data;
  • Correction of incomplete, inaccurate, or outdated personal data;
  • Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
  • Portability of personal data to another service or product provider, subject to regulation by the national authority;
  • Request for deletion or anonymization of personal data processed based on consent, except where the law permits retention on other grounds;
  • Information about public and private entities with whom MINDO has shared your personal data;
  • Information about the possibility of withholding consent to the processing of your personal data and the consequences of doing so; and
  • Revocation of your consent, where processing was based on the data subject's consent.

6. Exercising Data Subject Rights

MINDO will facilitate the exercise of rights by data subjects whenever possible and as permitted by law. MINDO has a dedicated communication channel to manage communications with data subjects and enable the exercise of rights.

Data Subjects may submit any complaint, request, or inquiry related to the processing of their personal data, including to exercise the data subject rights set out in this Privacy Notice and guaranteed by national legislation, via email at contato@mindo.com.br or at the following address, to the attention of the Data Protection Officer:

Alameda Jaú, 1303, 7th floor, Jardim Paulista – São Paulo – SP. ZIP Code: 01420-005.

When the User contacts MINDO to exercise their data subject rights, MINDO may collect information for the purpose of verifying the data subject's identity, to the extent necessary for their interest and security.

Updates to the Privacy Notice

This Privacy Notice may be updated periodically. All changes shall be considered effective and applicable immediately, unless otherwise communicated by MINDO to Data Subjects. MINDO will take reasonable steps to notify Data Subjects of any updates to this Privacy Notice.