Global Dot Com SA  is committed to complying with laws that protect the privacy of customer and general public data.  This page is designed to provide information on how we are following data protection standards, what information we collect while you are browsing our communication channels, and how this information is collected, used and protected by us, in accordance with Law No. 13,709/2018 (General Data Protection Law – “LGPD”). The use of our products and services, as well as our platforms, and other means of interaction made available, is conditioned on the acceptance of this Privacy Policy, including with regard to our employees.

1. Source of Personal Data

Global Dot Com SA will have access to personal data in the following situations:

• Through interaction with a customer:   When the Customer provides and inputs personal data necessary for the provision of services and use of products provided by Global Dot Com SA
• Interaction with your employees:  When your employees and collaborators of any nature use your systems and platforms to fulfill the duties and obligations arising from the contractual relationship they have.

2. Types of personal data and sensitive personal data collected

Without prejudice to the data commonly collected and processed from its employees for the purposes of the legal relationship they have,  Global Dot Com SA  may still collect the following personal data:

• Names and contact details, such as first and last name, email address, postal address, telephone number and other similar types of contact details, such as bank details;
• Device information, such as information about your device, such as your IP address, location, or ISP;
• Usage information and browsing history, such as information about how the User navigates within our services, their browsing history and which elements of Global Dot Com SA services are most used;

Sensitive personal data that may be collected by Global Dot Com SA  will have their purpose separately informed to the User, who must consent to  Global Dot Com SA using them in a specific manner, and in case of disagreement, the data will be automatically deleted from the Global Dot Com SA databases. 

Global  Dot Com SA does not collect data from minors, except with the authorization of their parents or guardians. If they are collected without authorization, as soon as Global Dot Com SA becomes aware, it will immediately delete the data collected, in accordance with the rules of the Terms of Use and this Privacy Policy.

3. Use of personal data collected

When collected, Global Dot Com SA  will use personal data to:

• Provide and improve contracted services;
• Comply with a legal or regulatory obligation;
• Manage relationships with Users;
• Configure and manage User accounts;
• Provide technical assistance, support and training to the User;
• Contact Users;
• Internal research and development purposes and to improve, test and enhance the features and functions of  Global Dot Com SA services ;
• Provide Users with marketing, advertising, and publicity, including from  Global Dot Com SA Partner companies , as permitted by law;
• Meet internal and external audit requirements, including information security obligations of  Global Dot Com SA ;
• Send messages by email to: a) confirm or cancel requests through the use of the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, inclusions of new data sources and improvements to the platform.
• To exercise Global Dot Com SA ’s rights , including but not limited to privacy, security, networks, systems and properties of  Global Dot Com SA   and/or third parties; 
• Comply with requests from courts, law enforcement agencies, regulatory bodies and other public institutions and government authorities, including, but not limited to, any rules in force outside the user's country of residence;
• The exercise of the rights of Global Dot Com SA  and to defend itself against possible legal actions, as well as to comply with any legislation or regulation applicable to Global Dot Com SA or third parties with whom we work, as well as to exercise the proper fulfillment of contracts signed between  Global Dot Com SA  and its users;

4. Sharing personal data with third parties

The User accepts and agrees that Global Dot Com SA  shares his/her personal data with the following categories of recipients:

• Companies that provide access or are responsible for the registration on which the user is dependent; 
• Partner companies, such as third-party service providers and other companies that assist us in providing our services or that may take actions on our behalf to protect our rights, users, systems and services;
• Third parties to which Global Dot Com SA  owes satisfaction or is authorized to disclose information by law (Example: government agencies, regulatory agencies, judiciary and other public authorities);
• Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of  Global Dot Com SA 's business , in which case the User's data will be considered an asset and transferred in a possible negotiation;
• Third parties who need the data to protect the rights of  Global Dot Com SA ;
• Any natural or legal person to whom the User requests the portability of their data. 

5. International transfer of personal data 

Global  Dot Com SA does not intend to transfer any personal data collected by the User outside of Brazil, and if the situations listed below are not met, Users will be previously informed by email, at which time the user may accept or reject the transfer, and in the event of disagreement, may have their access rights prevented by Global Dot Com SA .  

The international transfer of data described in the General Data Protection Law (LGPD) requires the designation of guidelines to be established by the National Personal Data Protection Authority (ANPD), whereas, when defined,  Global Dot Com SA  will undertake to comply with them in their entirety.

6. Protection of personal data

Global  Dot Com SA uses appropriate technologies and procedures to protect any personal data collected (including administrative, technical and physical protections) according to the level of risk and the service provided, having a legally responsible team to deal with the secure management of data in line with legal provisions, regulatory requirements, changes in technology, among other relevant factors that may influence the way in which personal data is protected.

Global  Dot Com SA employs all reasonable market efforts to ensure the security of its systems and the data collected, using highly qualified and reputable Internet providers and database and storage servers, in addition to security certificates (SSL) and protection software against unauthorized access to systems, as well as standard methods to encrypt and anonymize the data collected.

This Policy represents  Global Dot Com SA 's effort  to protect User information. However, due to the very nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing stored information, which is why, should this occur, Global Dot Com SA will be held liable within the limits provided for by Law.

Global Dot Com SA, within a reasonable period to be defined by the National Data Protection Authority (“ANPD”), must notify the ANPD and the affected User of the occurrence of a security incident that may entail a risk or relevant damage to the affected User, mentioning, at least:

• a description of the nature of the personal data affected;
• information about the holders involved;
• the indication of the technical and security measures used to protect data, taking into account commercial and industrial secrets;
• the risks related to the incident;
• the reasons for the delay, if communication was not immediate; and
• the measures that have been or will be adopted to reverse or mitigate the effects of the loss.

7. Data processing and responsibility of Global Dot Com SA

Global Dot  Com SA will be responsible for processing as follows:

• When dealing with personal data provided directly by its Customers,  Global Dot Com SA  will be the Operator, and will act without interference in the form of processing indicated by the Controller, but under the terms of the LGPD;
• Global  Dot Com SA will be the Controller of the Personal Data of its employees, processing them based on the Execution of Contracts, Compliance with legal or regulatory obligations, and also, in specific and determined situations, on Consent. 

Global  Dot Com SA  may adopt different legal bases for different processing of personal data.

8. Period of processing of personal data

Global Dot Com SA  calculates the retention period of personal data according to the following criteria:

• Period necessary to fulfill the purpose of the collection;
• The moment in which the Customer/User stops using the services of  Global Dot Com SA ;
• The moment in which there is a revocation of consent or a request for the deletion of personal data by the Holder;
• The time required to demonstrate compliance with the duties and obligations of Global Dot Com SA ;
• The necessary period provided for by Law, regulations, court decisions, etc.;
• Determination of the National Data Protection Authority;
• Compliance with a legal or regulatory obligation by the Controller;
• Perfect execution of the contract;
• Needs relating to compliance with the legal system, as well as for possible legal disputes;
• Transfer to a third party, provided that the data processing requirements set out in law are respected; or
• Exclusive use by the controller, access by third parties is prohibited, and the data is anonymized.

9. User Rights

According to the Brazilian General Data Protection Law, the User will have the following rights regarding the processing of their personal data:

• Right of Confirmation: the User may confirm whether  Global Dot Com SA processes any of his/her personal data; 
• Right of Access: the User may make a written request to obtain details of how their information is being used, as well as to have a copy of said information;
• Right to Correction: the User may correct or remove any data that is incomplete, inaccurate or out of date;
• Right to Anonymization, Blocking or Deletion: the User may request the anonymization, blocking or deletion of unnecessary, excessive data or data processed in a manner that does not comply with the purposes for which they gave consent, observing, for this purpose, other rules of the legal system;
• Right to Deletion: the User may request the deletion of some data, except those in which the law authorizes their conservation;
• Right to Information: The User may request information from the public and private entities with which  Global Dot Com SA  shared their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data;
• Right to Refuse Marketing: The User may, at any time, request to cancel the receipt of advertisements and other materials through the link provided in the marketing email sent. 
• Right to Portability: The User may request that their personal data be transferred to themselves or third parties, except for those that have already been anonymized and deleted by  Global Dot Com SA.
• Right to Revoke Consent: The User may cancel any consent previously granted to  Global Dot Com SA  to use their personal data. The User is aware that cancellation will not affect the use or sharing of data made prior to the request for revocation of consent.

The rights provided for in this chapter are not absolute, and the User must, whenever he wishes to exercise them, contact  Global Dot Com SA  through the channel:This email address is being protected from spambots. You need JavaScript enabled to view it. 

Global  Dot Com SA undertakes to respond to such requests as soon as possible and at no cost to the User, limited to a maximum period of 15 (fifteen) days, counting from receipt of the request, unless a longer period is necessary to respond due to complexity, reasons of fact or law, at which time the User will be notified.

 Global  Dot Com SA  will immediately notify the processing agents with whom it has shared User data about the correction, deletion, anonymization or blocking of the data, so that they can repeat the same procedure.

Confirmation of the existence or access to the User's personal data provided for in this chapter will be provided, electronically or expressly, in a simplified format or by means of a clear and complete statement, indicating the origin of the data, the non-existence of registration, the criteria used and the purpose of the processing, always observing the commercial and industrial secrets of  Global Dot Com SA .

10. Cookies

Global  Dot Com SA  and potential partners may use cookies and other similar technologies to store and manage User preferences, offer targeted advertising, enable content and collect analytical and usage data, for example. The use of cookies and other tracking technologies is standard on websites and platforms, through which information is collected about User activities on the platform, websites or other services.

A cookie is a small text file, placed on a computer or other device, used to identify the User, device used and to collect information and may perform the following functions:

• Necessary Cookies: These are essential to allow the User to navigate a platform and use its resources. 
• Performance Cookies: These collect information about how the User uses the  Global Dot Com SA platform  and serve to improve their navigation and enhance their experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, the average duration of the visit and the pages viewed.
• Functional Cookies: these allow the platform to remember choices the User has made (such as their username or ID, language preference or the area or region where the User is located) and provide enhanced, more personal features.
• Advertising Cookies: These track the User’s browsing habits and are used to deliver targeted advertising. These cookies also limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They also remember that the User has previously visited a website and this information is shared with other organizations, such as advertisers.

Global Dot  Com SA  uses necessary and performance cookies. 

At any time, the User may disable Cookies through their browser settings, by installing plug-ins available on the market, or by using other technologies that they deem necessary.

In addition to cookies,  Global Dot Com SA  uses other tracking technologies, such as:

Web Server and Platform Logs:  Global Dot Com SA servers  automatically collect certain information to support, administer and protect the services offered, as well as to analyze usage and improve the User experience. The information collected includes:

• IP address and browser type;
• Device information, including Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA), and similar identifiers assigned by us or third parties;
• The device's operating system and other technical data;
• The city, state and country from which you are accessing the BRASIL RISK platform, including for fraud prevention;
• Typed information or text;
• Links and buttons clicked;

Social Media Connections: Some of Global Dot Com SA ’s services may include social media features, such as Facebook “Like” buttons and widgets; “Share” buttons and interactive mini-programs.

Global Dot Com SA may allow the User to choose to use their own social network logins to access some of the services offered, in which case Global Dot Com SA may receive and store authentication information for these services.

11. Contact information

Questions, comments, suggestions and/or complaints regarding this Privacy Policy, as well as any need for information, changes or deletion of personal data, may be made by the User directly to  Global Dot Com SA , by email:This email address is being protected from spambots. You need JavaScript enabled to view it. 

12. Changes

Global  Dot Com SA seeks constant updates and improvements, so this Privacy Policy may be updated at any time, always aiming at better service and protection for users. 

In the event of changes that affect the purpose and duration of the processing of the User's personal data, the User will be informed via the email registered in our services or via the platform itself 30 (thirty) days in advance. If the User disagrees with the changes, he/she may revoke the consent provided, being unable to use the services of Global Dot Com SA.

If in the future  Global Dot Com SA changes its policy regarding the sharing of data with third parties, it will send a notice 30 (thirty) days in advance to the user via the registered email, and the user may disagree with the sharing, in which case they will continue to use the services of  Global Dot Com SA .

The User is advised to read this policy periodically to stay up to date with its content.

13. Legislation and jurisdiction

This Policy will be governed, interpreted and executed in accordance with the laws of the Federative Republic of Brazil, regardless of conflicts between these laws and the laws of other states or countries, with the Court of São Paulo being competent to resolve any doubts arising from this instrument, waiving any other, however privileged it may be.

All rights reserved.