Privacy Policy

This is a courtesy translation of a document originally written in Portuguese. In the event of any discrepancy, the Portuguese version of this Privacy Policy prevails.

NEDUCA TREINAMENTO EM INFORMÁTICA LTDA., a private legal entity registered with the Brazilian corporate taxpayer registry (CNPJ/MF) under no. 45.846.322/0001-94, headquartered at Rua Carlos de Almeida Prado, nº 76 A, Vila Nhocuné, ZIP code 03560-100, hereinafter referred to as MOOVI, is committed to data protection. This Privacy Policy exists mainly to provide information about how we process personal data, which legal bases we rely on for such processing, and for what purposes.

This privacy statement also serves to illustrate and clarify the several rights that you — as a personal data subject — have in relation to the processing of personal data described in this Privacy Policy.

This Privacy Policy is complementary to the Terms of Use of our website/app. Should there be any contradiction between this Policy and our Terms of Use, this Privacy Policy shall prevail on matters concerning the processing of personal data and privacy, and the Terms of Use shall prevail on other matters related to the website/app, jointly referred to as the PLATFORM.

What does this Privacy Policy cover?

This Policy applies to the processing of data that identifies or is capable of identifying visitors and users of our PLATFORM, including data related to their devices, which are considered personal data under the Brazilian General Data Protection Law (Law no. 13,709/2018).

If, after reading our Privacy Policy, you still have questions regarding the processing of your personal data, you may have them answered through the channels listed at the end of this Policy.

Which personal data will MOOVI process?

a) Browsing Data

Which browsing data will be processed?

General browsing and use of the PLATFORM does not require Users to identify themselves. However, when you access the PLATFORM — whether or not you log in — we collect data related to your browsing, such as your IP (Internet Protocol) address, browser type, device and mobile carrier, geographic location and other data related to users, in order to measure the performance of the PLATFORM, assess user needs, improve site functionality for users and customers, as well as to comply with the requirements set out in the Brazilian Internet Civil Framework (Law no. 12,965/2014).

In addition to this browsing data, the PLATFORM also uses "cookies". This technology helps us better understand user behaviour, tells us which parts of the PLATFORM people have visited, and enables and measures the effectiveness of advertising and web searches, among other functions.

You may disable the use of cookies through your internet browser. However, some functions and tools of our PLATFORM may be limited as a result.

The cookies used on the PLATFORM are essentially the cookies used by the RD Station Marketing and Google Analytics platforms.

What is browsing data used for?

Browsing data is analysed and used to improve your experience, to measure the performance of the PLATFORM, to assess user needs, to improve site functionality for users and consumers, as well as to increase the security of the platform and of the users who use the PLATFORM.

The processing of browsing data also aims to comply with the provisions of the Internet Civil Framework, which establishes that all administrators must retain the data of internet users recorded by application providers, in order to fight unlawful practices online by identifying those responsible for them. These data are retained per session.

b) Registration Data

Which registration data will be processed?

As stated in this Privacy Policy, using the PLATFORM does not require users to register; however, accessing the CONTENT does require the processing of some personal data.

Therefore, to ensure transparency in the processing of personal data carried out on our PLATFORM, we inform you which data is collected in order to register on the platform: e-mail and name. The same data and further details are requested in the event of a purchase on the website, such as: address, payment data, taxpayer number (CPF) and phone number, among others required for invoicing. Other professional data may be requested in specific campaigns, in order to deliver the best possible user experience.

What is registration data used for?

This data is collected to enable purchases on the digital platform, as well as to issue invoices, to comply with the provisions of the Internet Civil Framework (Law no. 12,965/2014), to allow us to contact you and to handle any requests you may have.

If, upon registration, you express interest in receiving marketing e-mails, your data will be used to send offers and run advertising campaigns. However, if you no longer wish to receive our offers in your inbox, you may request that we stop sending them through our communication channel, e-mail oi@moovi.education.

How is registration and browsing data shared?

Personal Data will only be shared in strict compliance with the purposes set out in this Privacy Policy. The main cases of data sharing are:

1. With public or delegated entities, to comply with legal or regulatory obligations;
2. With Processors, to offer third-party products or services related to MOOVI's core activities and to develop the activities of the PLATFORM;
3. Companies such as RIEVO, subsidiaries and parent companies belonging to the same economic group as MOOVI may have access to the personal data of MOOVI customers out of operational necessity, since the IT infrastructure is fully or partially shared by all of these companies;
4. We also share your browsing data with our advertising partners, who help us improve the ads and offers displayed to you according to your profile and interests.

c) Purchase Data

Which purchase data will be processed?

When you make a purchase on our PLATFORM, we collect information related to that purchase, including the total amount and the payment method.

What is purchase data used for?

We use your purchase data mainly so that we and our partners can complete the sale, process the payment and make the CONTENT available to you.

This data is collected to enable purchases on the digital platform, as well as to issue invoices, to comply with the provisions of the Internet Civil Framework (Law no. 12,965/2014) and to prevent fraud.

Likewise, bank and/or credit card data is collected in order to process payments and to carry out and complete the online purchase.

How is purchase data shared?

1. With public or delegated entities, to comply with legal or regulatory obligations;
2. With Processors, to offer third-party products or services related to MOOVI's core activities;
3. Companies such as RIEVO, subsidiaries and parent companies belonging to the same economic group as MOOVI may have access to shared personal data, where there are gains arising from operational needs, since the IT infrastructure is fully or partially shared by all of these companies;
4. With payment partners, possibly including an anti-fraud company, to protect you and to seek to prevent fraudulent transactions from being carried out in your name. Our anti-fraud partner belongs to the Locaweb group, which acts as a controller of personal data processing for the purposes described in this item;
5. With Processors acting as payment providers, collecting and processing the information related to the payment for the CONTENT purchased.

d) Newsletter

You may subscribe to our newsletter to receive promotions and advertising announcements in general, as well as exclusive offers. To do so, you must provide your e-mail address so that we are able to communicate with you.

e) Support Channels

You may contact us for general support through the channels made available on the PLATFORM, which may include, in the near future, the WhatsApp application. Each support interaction may involve the processing of different personal data; however, should any personal data be processed, we will observe the provisions of the LGPD and of this Policy.

We ask that you do not send us any personal data that we have not requested directly or that is unrelated to your request or contact. Should this happen, MOOVI reserves the right to permanently delete such data where legally possible.

What are the legal grounds for the processing described in this Policy?

For the processing of personal data, MOOVI relies on the following legal bases:

Do we share your data with third parties? Do we transfer your data internationally?

We do not sell your personal data to third parties under any circumstances.

We share your data with partners and service providers when necessary for any of the purposes described in this Privacy Policy, or when required by competent authorities and bodies. Whenever it takes place, data sharing is carried out in accordance with the provisions of the General Data Protection Law.

The main cases of sharing are described in the sections above.

What are your rights?

At any time, users have the right to:

• Confirmation that their personal data is being processed;
• Access to their personal data;
• Correction of incomplete, inaccurate or outdated data;
• Anonymisation, blocking or deletion of unnecessary or excessive data, or of data processed in breach of the General Data Protection Law;
• Portability of the data to another service or product provider, upon express request, in accordance with ANPD regulations;
• Withdrawal of consent and the consequent deletion of the personal data processed, except in the cases provided for in article 16 of the General Data Protection Law;
• Information about the public and private entities with which the controller has shared data;
• Information about the possibility of not giving consent and about the consequences of refusing it.

Should you wish to exercise any of these rights, please contact us through the means indicated at the end of this Privacy Policy. In that case, we may ask you for proof of identity before fulfilling your request. Once your identity is confirmed, we will respond to your request as soon as possible, in accordance with the provisions of Law no. 13,709/2018 (LGPD).

How do we protect your personal data?

We keep your personal data stored in secure environments, in accordance with our information security policy. All data collected during your interaction with our PLATFORM, from the first access onwards, travels protected by secure transfer protocols (HTTPS). Such data is then stored in the secure environment of our cloud storage services partner, in accordance with the highest information security standards.

For how long do we keep your personal data?

We will store your personal data only for as long as necessary for each of the purposes indicated in this Privacy Policy.

If your personal data is necessary for the performance of a contractual obligation we have undertaken towards you, we will only be able to delete your data after fulfilling such obligations.

When we need to keep your data solely to comply with our legal obligations, depending on the nature of the obligation, your data may be kept for a period of 5 years, renewable for a further 5 years.

In some cases, your personal data will be kept for an indefinite period, particularly where a legitimate interest of the Controller (in this case, MOOVI) or of third parties is demonstrated, in accordance with the provisions of the LGPD.

Changes to this Privacy Policy

We may change this Privacy Policy at any time. We therefore recommend that you check its most up-to-date version periodically.

Questions, comments and suggestions

If, after reading our Privacy Policy, you have any questions, comments or suggestions you would like to share with us regarding our privacy and personal data protection practices, or if you wish to exercise any of your rights concerning the processing of personal data, please contact our Data Protection Officer, GETGLOBAL INTERNATIONAL, at oi@moovi.education.