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PRIVACY AND COOKIES POLICY

 

We, from Soulloop Desenvolvimento de Softwares Ltda. ("SOULLOP" or "we"), registered in the CNPJ/ME under no. CPF/CNPJ Inscrição Municipal 35.677.330/0001-09 and based in Rua Pedroso Alvarenga, 691 sala 104, Itaim Bibi - CEP: 04531-011 - São Paulo – SP, take your privacy and the protection of your data seriously. This document explains how we treat your personal data, what your rights are and how you can exercise them.

 

In addition to sharing universal knowledge through tools that allow a deeper knowledge of the soul, we also watch over your privacy, so before browsing or registering on our platform, read this Privacy Policy carefully.

 

In compliance with the Terms and Conditions of Use, this privacy policy describes how SOULLOOP treats and protects your personal data during the use of the platform. Here you ("User" and/or "You") will find clear and complete information about the ways of processing, as well as the controls used to protect your personal data, to demonstrate absolute transparency on this important matter.

 

SOULLOOP’s practices regarding data processing, as well as this Privacy Policy, are adequate to the requirements contained in Law nº 10.406/2002 (Brazilian Civil Code), Law nº 12.965/2014 (Marco Civil da Internet), Law nº 13.709/2018 (General Data Protection Law or LGPD) and other applicable laws.

 

SOULLOOP will take the necessary measures and care to safeguard all information and protect your personal data, using complete and effective information security mechanisms.

 

1.  Definitions


To simplify your reading of this document, we present some useful definitions for your interpretation.


 

  • Data Privacy: Data privacy focuses on the rights of individuals, the purpose of data collection and processing, privacy preferences, and how organizations control the personal data of data subjects.


 

  • Data Security: Data security concerns the means of protection that an organization is adopting to prevent unauthorized third parties from accessing your personal information. It focuses on protecting data from malicious attacks and prevents data exploitation (data breach or cyberattack). Includes access controls, encryption, and physical and logical network security, among others.

  • Owner or You: Natural person to whom the personal data that are processed refer.

  • Personal Data: Information relating to the identified or identifiable natural person. These are examples of personal data that allow your identification: name, CPF, RG, address, mobile phone, email, etc.

  • Sensitive Personal Data: Personal information about racial or ethnic origin, religious conviction, political opinion, affiliation to a trade union or organization of a religious, philosophical, or political character, data relating to health or sexual life, genetic or biometric data, when linked to a natural person. SOULLOOP also considers the importance of classifying the data of children and adolescents as sensitive data, always highlighting the importance of additional control measures involving the entire information life cycle, as well as applying best efforts to promote the use of existing security mechanisms to ensure that such information is stored securely and will be processed only by authorized persons
  • Purpose: Processing for legitimate, specific, explicit, and informed purposes to the owner, without the possibility of further processing in a manner incompatible with these purposes.

  • Necessity: Limitation of the processing to the minimum necessary for the accomplishment of its purposes, with the comprehensiveness of the pertinent data, proportional and not excessive in relation to the purposes of the data processing.

  • Processing: This is our use of your personal data, including, but not limited to, the following activities: collection, storage, consultation, sharing, transmission, classification, reproduction, deletion, inactivation, enrichment, and evaluation.

  • Anonymized Data: Data relating to the holder that cannot be identified, considering the use of reasonable and available technical means at the time of its treatment.

  • Legal Bases: These are the legal hypotheses that authorize us to process personal data for a particular purpose: it may be your consent, the need to fulfill a contract we have with you, or compliance with a legal obligation, for example.

  • Consent: It is the free, informed, and unequivocal manifestation by which the holder agrees to the processing of his personal data for a particular purpose.

  • Data Protection Officer (Data Protection Officer), who acts as a communication channel between SOULLOOP, the data subjects, and the National Data Protection Authority ("ANPD") when it comes to the protection of their personal data.

  • Policy: This is the Data Privacy Policy.

 

2.  How is your personal data collected and what types of personal data are collected?

 

a)  Registration data

 

We collect personal data when you create or change your SOULLOOP account. This data may include full name, date of birth, personal data of family members, friends, photo of the profiling, and other registration data requested on our platform.

 

We also collect personal data when you log in to Google, Instagram, and Facebook platforms. User contact details are provided on the platforms above. This information may be associated with other data that SOULLOOP collects about you and in the situations described in the section "Use and sharing of personal data. Information provided by third parties may be subject to their respective privacy policies.

 

b)  Details of payment

 

Data for payment: The SOULLOOP platform is integrated into the EBANX / STRIPE payment portal for the provision of our services. In this way, personal payment data such as your credit card details are collected.

 

Navigation information: We also collect information when you use our website. This information includes, but is not limited to:

 

-  Details on how you used our services;

-  Device information such as type and language of your browser;

-  Access schedules;

-  Pages viewed; and

-  IP address.

 

Identifiers associated with cookies or other technologies that can uniquely identify your device or browser; pages that you have visited before or after browsing our platform. We may use cookies and other technologies, such as web beacons, web storage, and advertising tags, to collect information about your activity, browser, and device.

 

Location Information: When you use our services, we may collect information about your location. With your permission, we collect information about your location, using your GPS, wireless connection, Wi-Fi access points, cell phone towers, among others.

 

3. For what purposes are your personal data collected?

 

The data is collected to provide resources and services in the Platform. SOULLOOP uses the personal data collected to provide, personalize, maintain, and improve its products and services. This includes using your data to:

 

a) Account creation and update:

 

Enable features that allow you to share information with others; perform internal operations necessary to provide our services, including software troubleshooting and operational issues; and conduct data analysis, tests and research, and monitor and analyze  of trends in the activity of use; Security: SOULLOOP uses your personal data to help maintain the security and integrity of our users and services. This includes, for example: Using device data, location, profiling, and usage, among others, to prevent, detect and combat fraud and dangerous activities. This includes processing this data in certain countries for identifying practices or standards that indicate fraud or risk of security-related incidents.

 

b) Customer support: 

 

SOULLOOP uses the data collected to provide assistance when you contact our customer support in the following circumstances:

 

• Forward your questions to the service; Investigate and solve the problems requested by the User.

• Monitor and improve our services.

•Legal procedures and requirements. We may use your data to investigate and resolve claims or disputes related to your use of the SOULLOOP services, as permitted by applicable laws, or in response to requests from regulatory agencies, government agencies, and official surveys.

 

4.  With whom does SOULLOP share your personal data?

 

(a) How we use your personal data

 

To improve the offer of products and services and to provide a service in a more agile and secure manner, SOULLOOP may use your personal information for the following purposes:

 

Administer, provide, supply, maintain, develop, improve, disseminate and expand services and fulfill the obligations arising from the use of the services and acquisition of SOULLOOP products.

 

We aim to adequately address your questions and requests;


 

  • Conducting scientific research and analysis;
  • Processing payments for our products and services;
  • Identify you and personalize your experience and use of the SOULLOOP platform and services, including providing promotions and financial incentives;
  • Develop internal studies on your interests and behaviors, anonymously, to better understand your needs and interests and to offer more interesting services to you;
  • Enable contacts that are needed by SOULLOOP due to their use of the platform;
  • Make available and improve the security and monitoring mechanisms of the SOULLOOP platform and services;
  • Detect and protect SOULLOOP and its users from fraud, abuse, or illegal acts;
  • Comply with legal obligations to collect and share data with the government, in accordance with applicable law.

 

SOULLOOP applies its best efforts to maintain the standards of security, privacy, and protection of personal data appropriate to its users. Internally, users' data are accessed only by authorized employees, respecting the principles of proportionality, necessity, and finality for the objectives of SOULLOOP, in addition to the commitment to the confidentiality and preservation of the privacy of Users.

 

Your financial data are used to make payments for our services and/or products. SOULLOOP may use other information about you from third-party sources and combine it with information collected directly from you in accordance with this privacy policy for all fins provided in this section.

 

(b) who do we share your personal data with

 

Payment platforms. We have an integration with EBANX/STRIPE payment gateway that will work as an intermediary of payments made in return for our services and/or products. In this sense, the user’s personal data may be shared for payment.

 

Partners who perform remote consultations via the platform.

 

Personal data can be shared with professional platform partners to perform remote queries as requested by the user.

 

Company of astrological maps. We may share personal data provided by you for the generation of astrological maps for the integration with Swiss Ephemeris from Astrochart.

 

We do not share users’ data with unauthorized third parties or authorize SOULLOOP to share.

 

To enable supply and operation of the SOULLOOP platform and services or work on behalf of the SOULLOOP platform and services appropriately and in the manner, you have contracted.

 

To commercial partners who provide services or work on behalf of SOULLOOP, in accordance with the specifications and guidelines determined by SOULLOOP, including contractual prediction of duty to maintain the confidentiality of information by Third parties.

 

Organizations, authorities, and other Government entities, to meet legislation and regulations applicable to the platform.

 

Organizations, authorities, and other Government entities individuals, or legal entities, in compliance with a legal or judicial order.

 

To the police authority or representative of the Public Prosecutor’s Office, when there is suspicion, flagrant violation, or investigation of crime with violence or serious threat involving users of the platform.

 

For exercising and defending any rights of SOULLOOP.

 

Please note the information shared with third parties is subject to the privacy policies of each of them.

 

5. Storing Personal Data

 

We keep your personal data only for as long as necessary. We guarantee that if we have no reason or legal need to process your personal data, we will delete your data. For your security, your data is stored in the cloud, according to the services provided by the company Amazon Web Services (AWS), with the aim of providing security and reliability in providing our services.

 

6. What are your rights as a data subject?

 

Personal data is yours and Brazilian law guarantees that You have a series of rights related to it. We are committed to enforcing these rights and, in this section, we will explain how You can exercise them with SOULLOOP. Brazilian law guarantees you the following rights:

 

 

Confirmation and Access

Allows You to check whether SOULLOOP processes personal data about You and, if so, to request a copy of the personal data we hold about You.

 

Correction

It allows You to request the correction of Your incomplete, inaccurate, or outdated personal data.

 

Anonymization, blocking, or deletion

It allows You to ask us to (a) anonymize Your data so that it can no longer be related to You and therefore ceases to be personal data; (b) block Your data, temporarily suspending its possibility for us to process it; and (c) delete Your data, in which case we will delete all Your data without the possibility of reversal, except as

provided by law.

 

Portability

You have the right to request, upon express request, that SOULLOOP provide You, or a third party You choose, with Your personal data in a structured and interoperable format, for transfer to another provider, provided that it does not violate the intellectual property or trade secrets of the

company.

 

Disposal

Where We process your Personal Data based on your consent, You may request deletion of the data.

 

Sharing information

You have the right to know the public and private entities with which SOULLOOP shares data. In any case, if you have doubts or want more details, you have the right to ask us for this information.

 

Information about the possibility of not consenting

Allows You to have clear and full information about the possibility and consequences of not providing consent. Your consent, when required, must be free and informed. Therefore, whenever we ask for your consent, You will be free to withhold it - although in such cases e may have to limit our deliveries to You.


 

 

 

Revocation of consent

You have the right to withdraw your consent about processing activities that are based on consent. However, this will not affect the lawfulness of any processing previously carried out. If You withdraw your consent, we may not be able to provide certain deliverables to You, but We will advise You when this

occurs.

 

Opposition

The law allows the processing of personal data even without your consent. If you do not agree to this processing, in some cases You can oppose it by requesting the interruption.

 

Whenever you exercise your rights, SOULLOOP may request some complementary information to prove your identity, in order to prevent fraud. We do this to ensure your security and privacy. Still, some requests may not be answered immediately, but SOULLOOP is committed to answering all requests in a reasonable time and always in compliance with the applicable legislation.

 

You may also ask us not to send you marketing communications and not to use your personal data for profiling for direct marketing purposes or any other benefit based on your consent. You may opt-out of receiving email newsletters and other marketing communications by following the unsubscribe instructions provided to you, in those emails. Messages from operational accounts will not be affected if you unsubscribe from marketing communications.

 

7. Safety Measures Adopted

 

We are continually deploying and updating administrative, technical, and physical security measures to protect your information from unauthorized access, accidental or unlawful situations of destruction, loss, alteration, communication, or any form of improper or illicit treatment.

 

Among the methods used are firewalls, data encryption, and information access controls. If you are aware or believe that your login information has been lost, stolen, diverted, or compromised, or in the event of an unauthorized use, please contact us immediately.

 

While we count on robust information security measures and controls, it is impossible to guarantee that malicious third parties will not have access to data, information, and communications. This is a risk inherent to the use of computerized systems, which affects any use of digital services.

 

8. How to contact SOULLOOP

 

If you believe that your personal information has been used in a manner inconsistent with this Policy or with your choices as a data subject, or if you have other questions, comments, or suggestions regarding this Policy, you may contact our team through our Site, under the Contact Us tab.

 

We have a person in charge ("DPO") who is available at the following contact addresses:

 

Foreman: Eric Serafim

Contact e-mail: soulloop@soulloop.com

 

9. Updates to this Policy

 

As we are always seeking to improve our Site, this Policy may be updated to provide the User with greater security and convenience and to further enhance the User's experience. For this reason, we recommend that the User periodically access our Policy in order to be aware of any modifications. To make things easier, we indicate at the end of the document the date of the last update. If relevant changes are made that require new consent from Users, we will publish this update and request new consent.

 

Date of last update: 10/16/2022.


 
 

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