Privacy policy

Privacy Policy

 

# Preamble

 

This Policy establishes the commitment of COLAB, COLAB TECNOLOGIA E SERVIÇOS DE INTERNET S/Aregistered with the CNPJ/MF under no. 19.381.604/0001-53, with registered office at Rua Pamplona, no. 1005, Jardim Paulista, São Paulo-SP, CEP 01.405-200, Federative Republic of Brazil, with your privacy. It is very important that any User reads and understands these rules, as well as other rules that may be applicable, including the General Terms of Use, Law No. 12.965/2014 ("Marco Civil da Internet"), Law No. 13.709/2018 ("General Law on the Protection of Personal Data in Brazil in Brazil") and REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

 

This Policy may be amended at any time, from time to time, in which case Users will be informed of the change when accessing the platform.

 

This Policy is a complementary document to COLAB's General Terms of Use and is inseparable from them.

 

In the event that Users do not agree with any of the changes made by COLAB, we recommend that their use be discontinued and/or that they close their User accounts, as appropriate.

 

If Users do not take the measures suggested and provided for above, the most up-to-date version of the Policy will be deemed to have been accepted.

 

COLAB ensures the confidentiality, privacy and protection of the personal data of its clients and visitors, protecting this information from loss, improper use, unauthorized access, alteration and destruction, thus maintaining the relationship of trust, respect and transparency built with its public in this project of engaging citizens to improve services to a community.

 

This Policy covers COLAB's treatment of information capable of identifying Users, whether collected directly on its Internet portal or application, or stored in its electronic databases by other means of collection, such as registrations filled out on physical media or consultations with customer service by telephone, e-mail, online messaging applications, SMS, among others.

 

Users who decide to provide their personal data in any COLAB environment declare that they know and accept the terms of this Policy.

 

The personal data processed by the platform and their respective justifications are listed below:


  • Mandatory registration data: Personal data strictly necessary for the fulfillment of COLAB.re's purpose provided by users to complete the registration process, including

both the app and web versions, the Name to identify the user; CPF/MF to validate the user's existence; E-mail for communication and operationalization of collaborative public management with the user; Date of birth for user engagement; City to route content directed at the user's possible interest; Password to guarantee the user's access to the platform's services;


  • Optional personal registration data: Photograph (does not need to be your facial biometrics) to identify your profile on our social network; Geographic location data to allow targeting of options for exercising citizenship in the place where the user is located; Gender, race, zip code and neighborhood, for statistical research; Bank details exclusively in the "Qualified, Won Program!Program" for the purposes of receiving credits in the event of being awarded; Gender to route targeted content and enable improvements to the platform through the generation of anonymized reports and statistical data; Neighborhood (exclusively in the web version) to route targeted content and enable improvements to the platform through the generation of anonymized reports and statistical data; Education level (exclusively in the web version) to route targeted content and make it possible to improve the platform by generating anonymized reports and statistical data; Real estate registration and/or sequence (exclusively in the app version) of the property in the event of interest in making or consulting IPTU payment methods; credit card number (exclusively in the app version) in the event of interest in making or consulting IPTU payment methods; credit card number (exclusively in the app version) in the event of interest in making or consulting IPTU payment methods.


For the purposes of this Policy, the following considerations must be observed:

 

#1 Data protection and privacy of COLAB as Controller of Users' Personal Data

  1. The information requested from Users is the minimum necessary for the development of COLAB's business and is used exclusively for the purpose indicated at the point of collection, always in accordance with the principles set forth in article 6 of Law No. 13.709/2018 ("General Law on the Protection of Personal Data in Brazil") and in REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016, being stored in our database, in a secure environment and in accordance with the precepts of the same legal provision already mentioned.

 

  1. COLAB, in the context of the use of its platform by its Users, reserves the right to process Personal Data and Sensitive Personal Data, all of which are in accordance with the definitions of Law No. 13.709/2018 ("General Law on the Protection of Personal Data in Brazil") and with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016, with the processing being provided in an anonymized form, whenever possible, in order to guarantee the confidentiality of users' data.

 

  1. Personal Data may be processed for the purpose of avoiding ideological falsehood and identity fraud and, where applicable, will be based on the User's consent, as defined in article 7 of Law No. 13,709/2018 ("General Law on the Protection of Personal Data in Brazil"), as well as in REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 or based on other legal bases provided for in said law, if applicable.
  2. The sharing of Sensitive Personal Data will only occur with the unequivocal and express authorization of the User and holder of such data and in compliance with article 11 of Law No. 13.709/2018 ("General Law on the Protection of Personal Data in Brazil") and with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016.



  1. Non-Sensitive Personal Data may be shared for the following purposes: individualized geolocation for grouping, mapping of Users contacted, social mixing, mobility and social networking standards.

 

At this point, it is necessary to clarify that location is a fundamental element, in times of Global Pandemic, for understanding how diseases behave. Understanding the proximity between the sick and the healthy can be the key to more accurate monitoring of the evolution of pandemics in your region. With this information, the User agrees to play an active, conscious and contributory role in participatory surveillance, offering data with a higher level of localization accuracy, so that Health Agencies can improve their actions in identifying possible pandemics and/or outbreaks of other diseases. In addition, with this type of data it will be possible to effectively monitor the stages of reopening of the economy, commerce and services.

 

The data may be shared with partner institutions in order to improve analyses that can help detect, monitor and control the existing and future situation of pandemics and/or other diseases, for the following purposes: a) Socio-demographic data (such as age, gender/sexual identity, income, zip code, address) to characterize variables that can directly help public agencies in search of a better understanding of populations at risk, with consent required for sharing gender/sexual identity; b) Facilitating contact by official services, if necessary, (such as State/Municipal Health Departments and Social Assistance agencies) for activities related to the diagnosis, monitoring and control of any pandemic and/or disease outbreak.

 

By agreeing to the terms, Users also agree to allow their data to be used for scientific research and/or scientific articles in an anonymized form.

 

  1. COLAB employees and its business partners involved in the processes are aware of this Policy and only qualified and authorized personnel are allowed to access the personal data collected, under penalty of disciplinary action in the event of violation of the rules set out in the policy.

 

  1. COLAB may share the data collected and the activities recorded: i) With competent judicial, administrative or governmental authorities, whenever there is a legal request from the authorities or a court order; ii) Automatically in the event of corporate movements, such as mergers, acquisitions or incorporations, and iii) Automatically, with the service providers contracted by COLAB to make the website/application and platform viable, together with all its functionalities and services made available.
    1. All third parties contracted for the purpose of item 1.6, "iii", above, undertake to treat the data confidentially and only for the purpose contracted, ensuring legal compliance in terms of privacy and data protection and using the best information security practices at all times.

 

  1. As seen in section 1.4, COLAB may share Sensitive Personal Data upon unequivocal and express authorization, when applicable, as well as Personal Data for the purposes set forth in section 1.6, always in compliance with the General Data Protection Law.

 

  1. It is the User's responsibility to safeguard their password and login. It is not appropriate to use obvious passwords, such as special dates, names or numerical sequences. If the user becomes aware or even just suspects that their password has been discovered, they must change it on their registration page immediatelyThe data and information processed under the terms of this Policy is stored under the strictest information security practices. All processing is strictly supervised and protected, so that only authorized COLLABORATORS have access, who are contractually obliged to preserve the secrecy and confidentiality of the information accessed and which makes up the Database.

 

  1. COLAB undertakes to always use its best efforts to ensure that information is always handled in accordance with the provisions of the General Terms of Use, as well as all applicable laws and regulations.



#2 Data protection and privacy of COLAB as Operator of Users' Personal Data

 

2.1 As stated in item 4.1 of COLAB's Terms of Use, when we are contracted by third parties, referred to as "Organization" in our Terms of Use, we offer some services that are optional to Users. When these Users decide to use them, from that moment on, COLAB will be the Operator of the User's Personal Data and the Organization contracting COLAB will be the controller of the User's personal data.

 

# Handling of COLAB data and information

 

3.1 COLAB, which specializes in the policy and management of services for a collectivity of users, acts as a hub to connect citizens, platforms, companies and governments and is committed to safeguarding the privacy and protecting the personal data of its data subjects, having as its guiding legislation the General Law on the Protection of Personal Data in Brazil, Law n. 13.709/2018, as well as REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016. 

Why does COLAB process personal data?

 

COLAB is a technology company applied to organizations, in particular service providers aimed at a collectivity of users, including members of the Public Administration. We use data as a source of intelligence to serve the Organization and help it make informed decisions. For COLAB to achieve its objectives, it is necessary to use technology to connect Organizations, including members of the Public Administration, to users and/or citizens to enable the execution of policies of interest to the community. COLAB's mission is to develop technological solutions aimed at enabling Organizations and users and/or citizens to connect with the demands of policies of interest to the community. In order to generate intelligence in the delivery of information, the solutions offered by COLAB depend on the collection and use of personal data from users and/or citizens using the platform. When COLAB refers to personal data, it takes into account not only its respect for and commitment to the security and privacy of data subjects, but also its commitment to guaranteeing everyone the right to choose how their personal data is used. In order to develop our solutions, COLAB uses personal data and information collected from COLAB.Social users, and in some cases it is possible to receive data from partners/suppliers and/or the Organization for some projects, guaranteeing transparency to the data subject about the processing carried out by COLAB. COLAB's premise of fostering development and stimulating innovation guides its activities and the way it handles personal data, and your privacy is taken seriously. If, after reading these Terms of Use and/or the privacy policy available on the web at www.colab.re, you still have questions, feel free to contact our Data Protection Officer by sending a message to dpo@colab.re.

 

Why and what is the purpose of this heading on the processing of COLAB data and information?

 

It serves to compile the main information on how COLAB processes personal data and information. As COLAB is responsible for various activities involving the processing of personal data and information, it always applies high levels of care to security controls and practices and the protection of the information that is part of its operations. With the protection of personal data as the cornerstone of its business, COLAB maintains its policies to establish the internal rules that define the standards for the processing of personal data in the context of its activities, in order to maintain effective governance over its internal processes and meet applicable legal requirements, including Law No. 13,709/2018 (the LGPD). To find out more about how COLAB interprets and applies the provisions of the LGPD and REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016, feel free to contact the Data Protection Officer by sending a message to dpo@colab.re.

What do you need to know to understand this title on data and information processing carried out by COLAB?

 

In order to make it easier to read, here are some useful definitions for interpreting them:

"Legal Bases" are the legal hypotheses that authorize COLAB and the Organization to process Personal Data. Any processing of Personal Data is considered valid if it is based on a legal basis.

 

"Personal data" means any information relating to an identified or identifiable individual, including identification numbers, location data, electronic identifiers or any data which, when combined with other information, is capable of identifying someone, making them identifiable or individualizing them.

 

"Processing" or "Processing" means COLAB's use of Personal Data, including, for example, the following activities: collection, recording, storage, organization, consultation, use, disclosure, sharing, transmission, classification, reproduction, processing and evaluation.

"Data Subject" means the natural person to whom the Personal Data relates.

 

In what situations does COLAB process personal data and what types of personal data are processed?

 

Through our users who register on the COLAB.Social platform; Through collaborating agents who register on the COLAB.Gov platform; From the receipt of data sets from COLAB's business partners, with whom it has an ongoing relationship ("Partners"), always with guarantees of lawfulness for the processing of Personal Data and the use of the necessary technical and organizational safeguards; From the receipt of data sets from COLAB's suppliers, responsible for specific data supplies ("Suppliers"), always with guarantees of lawfulness for the processing of Personal Data and the use of the necessary technical and organizational safeguards; From the open data platform of some government entity; When the Organization shares data controlled by it, so that COLAB can process it and generate intelligence to support decision-making by the Organization, in which case the Organization is responsible for defining the purposes, form and duration of the processing of personal data, as they are the controllers of such data.

 

What are the purposes for processing this data and information?

 

Engagement: Provision of gamification tools to engage the user and/or citizen, in order to bring them closer to public management and encourage them to be more participatory as co-creators of their organization or city, through caretaking.

public consultations, announcements, missions, etc., with the aim of developing triggers that encourage you to contribute to the management of your organization or your city.

 

Management: Management of user and/or citizen demands in a targeted manner with the competent leaders and/or secretariats, making the intersectoriality of the Organization's leaders and/or secretariats more expansive, as well as making it possible to improve the relationship, service and support to the citizen.

 

Assertiveness in decision-making: With COLAB.Gov technology it is possible for the Organization to gather and organize data and indicators generated from the requests received and registered on the platform, which allows for greater efficiency and assertiveness in decision-making and also in nurturing communication with users and/or citizens.

 

What rights do data subjects have and how can they exercise them?

 

Note: As COLAB obtains data from other controllers (whether customers, partners or suppliers), it is not possible to guarantee that every request to exercise rights addressed to COLAB will be met in full. However, in the event that COLAB is the controller of the data to which a request to exercise rights relates, all measures will be taken to fulfill that request, including with COLAB's contractors and subcontractors. For example: if you request the correction of part of your Personal Data, COLAB may update the databases controlled by COLAB itself, but this does not mean that the original databases from which your Personal Data was collected (such as an open data platform of some government entity) will also be affected by your request to exercise the right of correction. In such cases, it will be up to the Data Subject to submit a request to the original controller of their Personal Data to allow their rights to be fully exercised.

 

How do I know if COLAB has Personal Data about you, and how do I access it?

 

COLAB has tools that allow you to confirm whether we have personal data, as well as allowing you to access personal data on request. You can request this information by e-mailing dpo@COLAB.re.

 

How do I correct the Personal Data COLAB holds about you?

 

If you find that any of your Personal Data is incorrect or out of date, you can ask COLAB to correct your Personal Data directly by e-mailing dpo@COLAB.re. However, it is important to note that, as COLAB may receive data from other sources, such as partners, suppliers or customers, it is possible that, in addition to the version of your personal data corrected by your

You may also request that records be kept of the original version of your data, as provided by the original source. Data of this nature will be kept to guarantee the integrity and traceability of all data processed by COLAB, and you are guaranteed the right to have your personal data corrected when it is in bases controlled by COLAB, such as situations in which the source of the data was the user and/or citizen themselves.

 

How can I delete all or part of my Personal Data?

 

COLAB allows you to request the total or partial deletion of your personal data. All you have to do is send the request by e-mail to dpo@COLAB.re.

 

It is important to know that not all the personal data we have in our databases can be deleted, especially in cases of need to comply with legal obligations, but not limited to this. Even in these cases, we will maintain our commitment to secrecy and the protection of this data, keeping it only for the specific purposes related to the fulfillment of existing obligations.

 

Other information handled by COLAB

 

COLAB also handles information other than personal data, but it deserves the same degree of protection and confidentiality because it is content owned by the Organization generated through its technology, including through the use of the COLAB.Gov solution, which will only be shared with third parties with the express consent of the Organization, even if anonymized.

 

# Private use and public use of personal data at COLAB

 

  1. Private Use: This is for internal use to improve the user experience within the Platform, as well as for statistical analysis. The personal data that is not accessible by other users of the application is as follows: email, telephone, gender, date of birth, location, neighborhood, zip code, educational level and race.

 

  1. Public Use: This is personal data that can be seen by all users who interact and use the platform's social network. These are: name, profile picture and/or image, city and other interactions carried out on the social network (publication of demands, support and comments).

 

# 5 Obtaining and Using Navigational Information

 

5.1. COLAB also automatically receives and stores information on its servers about browser activity, including the IP address and page

accessed. The entry of personal data (IP) of the user on the COLAB portal through the acceptance of browsing cookies is not a requirement for browsing the portal and is optional, through configuration on the cookies platform on the site. However, some environments will be limited without this authorization.

 

# 6. Sending Announcements and Advertising Messages

 

  1. Notices and advertising messages sent by e-mail must include an option for COLAB to unsubscribe from sending that type of message. The request will be complied with in the minimum time necessary for this to be carried out.

 

  1. The opt-out is done via the User's e-mail address, so Users who have more than one registration may continue to receive communications or advertising messages at the e-mail address that has not been removed from the relevant registration.

 

  1. E-mail sending services are carried out by COLAB or by a contracted company, which will use its own servers to send the e-mails.

 

  1. The contracted company does not store or use in any way, and under no circumstances, the emails in the COLAB register for any purpose other than sending messages, in accordance with the preferences of each user registered with COLAB.

 

# 7. external links

 

7.1. The portal may have links to other external sites whose content and privacy policies are not the responsibility of COLAB. We therefore recommend that, when redirected to external sites, users always consult the respective privacy policies before providing their data or information.

 

# 8. Security

 

  1. COLAB treats personal data in accordance with the best information security practices and, in particular, stores it in the Amazon cloud, which applies the most advanced information security techniques available on the market, being certified and recertified in compliance with all the security requirements determined by ISO/IEC 27018:2019, as well as in accordance with the international code of best practices for the protection of personal data in the cloud (information and certificate available at: https://aws.amazon.com/pt/compliance/iso-27018-faqs/, accessed on 28/02/2023).
  2. COLAB itself also applies technical and administrative measures to protect personal data from unauthorized access and accidental or unlawful destruction, loss, alteration, communication or dissemination, taking into account the structure, scale and volume of its operations, as well as the sensitivity of the data processed and the likelihood and severity of damage to data subjects. These measures include the use of blowfish and md5 techniques for password encryption, data segregation by organization and data access control based on the need and permission granted by the USER.

 

# How to request the deletion of your personal data

 

9.1 In the event that you have previously consented to COLAB.re processing your personal data, you may exercise your right to revoke such consent and request the deletion of your data by sending an email to our Data Protection Officer (dpo@colab.re). COLAB will be subject to legal requirements for the retention of certain information and/or personal data, such as a legal obligation, compliance with a contract, legitimate interest, among other hypotheses provided for in Law 13.709/2018 (General Personal Data Protection Law in Brazil) and REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. 

 

# 10. Information on exercising data subject rights under the General Personal Data Protection Act in Brazil

 

  1. You can exercise your rights as a data subject under Law 13.709/2018 and REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 by contacting COLAB's Data Protection Officer (DPO) directly.

 

  1. In the event of any doubt regarding the provisions contained in this Privacy Policy or the need to contact the COLAB.re Data Protection Officer (DPO) for the purposes of exercising the rights of data subjects provided for in Chapter III of the General Law on the Protection of Personal Data in Brazil (Law No. 13,709/2018) and in REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016, the USER may contact the following e-mail address dpo@colab.re, replies to which will be sent between Monday and Friday, during business hours in the time zone of the city of São Paulo, except on public holidays.

# 11 Final provisions

 

  1. COLAB does not use any type of automated decision that impacts the USER.

 

  1. If third-party companies process any data collected by COLAB, they must comply with the conditions stipulated here and the best information security practices.

 

# 12. Changes to our Privacy Policy

 

  1. This Privacy Policy is subject to constant improvement and enhancement. We therefore recommend that you read it regularly.

 

  1. COLAB reserves the right to make changes at any time, with a view to continuous improvement, provided that the users of the service are given ample prior notice of such changes.

 

# 13. Channel for user questions and suggestions

 

13.1 If you have any questions or suggestions, please send an e-mail to contato@colab.re

 

Last updated: 28/02/2023.