HBR, a private legal entity registered with CNPJ under nº 58.766.353 / 0001-87, headquartered in São Paulo / SP, understands as sensitive and relevant the electronic records and personal data left by you “User” when using the HBR website and “Pages” of the services, serving this Privacy “Policy” to regulate, in a simple, transparent and objective way, which data and information will be obtained, as well as when they can be used. This Policy applies to pages related to any of HBR’s brands, being understood as such all those listed on HBR’s official website, www.hbr.net/, covering all of its products. This Policy may be updated, at any time, by HBR, by means of a notice on the website and / or by email, if the User has opted to receive communications from HBR. I. WHAT DATA DO WE USE HBR may collect the information actively entered by the User at the time of registration and also information collected automatically when using the pages and the network, such as, for example, identification of the commercial establishment used, IP with date and time of connection, between others. So, there is the treatment of two types of personal data: (i) those provided by the User himself; and (ii) those collected automatically. (i) Information provided by the User: HBR collects all the information actively entered by the User in the Pages, such as full name, e-mail, gender, date of birth, city and state, when filling out forms on the pages by the User. HBR will use this information to promote the dissemination of advertising material, promotions, discounts and events, as well as to conduct satisfaction surveys and NPS surveys. (ii) Data collected automatically: HBR also collects a series of information automatically, such as: characteristics of the access device, browser, IP (with date and time), origin of the IP, information on clicks, pages accessed, the following pages accessed after the Pages have left, or any search term entered on the sites or in reference to these, among others. For such collection, HBR will use some standard technologies, such as cookies, pixel tags, beacons and local shared objects, which are used for the purpose of improving the user’s browsing experience on the Pages, according to their habits and preferences. It is possible to disable, through the settings of your internet browser, the automatic collection of information through some technologies, such as cookies and caches, as well as on our own website, specifically regarding cookies. However, the User must be aware that, if these technologies are disabled, some resources offered by the website, which depend on the treatment of said data, may not work correctly. In addition, HBR may promote satisfaction and preference surveys when using the Wi-Fi Network, collecting this information to improve our services more and more, to better understand your preferences and to evaluate the quality and impressions of our products, as well as for statistical and advertising purposes. For this last hypothesis, HBR provides functionalities for the User to authorize (or not) the treatment of their data, being certain that such acceptance is not a condition for the User’s registration. The information collected may be shared by HBR with: (i) other partner companies, when necessary for the adequate provision of services that are the object of its activities; (ii) to protect HBR’s interests in any type of conflict; (iii) upon judicial decision or request from a competent authority.. We also clarify that your information may also be shared with companies that provide the technological and operational infrastructure necessary for HBR’s activities, such as payment intermediaries and information storage service providers. The User will be able to access, update and add his data, as well as be able to request the deletion of his data collected by HBR, through the form available in marketing@hbr.net. We will endeavor to respond to you in the shortest possible time, respecting the custody periods established by law. O Usuário poderá acessar, atualizar e adicionar seus dados, bem como poderá solicitar a exclusão dos seus dados coletados pela HBR, pelo formulário disponível em (inserir link). Iremos nos esforçar para respondê-lo no menor tempo possível, respeitando-se os prazos de guarda estabelecidos pela legislação. II. HOW WE USE THE DATA The information collected by HBR has the purpose of establishing a contractual link or the management, administration, provision, expansion and improvement of the Pages to the User, adapting them to their preferences and tastes, as well as the creation of new services and products to offered to Users. The information collected may also be used for advertising purposes, such as sending information about brands, HBR products, as well as the dissemination of events, or to conduct a satisfaction survey, with the consent of the holder to do so. HBR may centralize the information collected on the Pages, which may be used on Pages and services related to all HBR brands, respecting the purposes set forth herein and the User’s consent.
If the User no longer wishes to receive advertising information from HBR, at any time the User may contact HBR through the form available at marketing@hbr.net III. HOW WE KEEP DATA SECURE HBR will store the information collected on its Pages on its own servers or hired by it.
HBR uses reasonable market and legally required means to preserve the privacy of the data collected on its Pages. such as:
i. HBR uses standard and market methods to encrypt and anonymize the data collected; ii. HBR has protection against unauthorized access to its systems; iii. HBR only authorizes the access of previously established people to the place where the collected information is stored; iv. Those who contact the information must undertake to maintain absolute confidentiality. Breach of confidentiality will result in civil liability and the person responsible will be held responsible according to Brazilian law; and v. Maintenance of the inventory indicating the moment, duration, identity of the employee, or of the person responsible for access and the object file, based on the connection and application access records, according to legal provisions. IV. RETENTION OF COLLECTED INFORMATION The information collected by HBR through the Pages will be automatically deleted from its servers when they are no longer useful for the purposes for which they were collected, or when the user requests the deletion of their personal data. Without prejudice, the information may be kept for compliance with legal or regulatory obligation, transfer to a third party – as long as the data treatment requirements are respected – and exclusive use of HBR, being prohibited its access by a third party, as long as anonymized. Updated on October 01, 2020