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Data protection
according to GDPR 

As of: October 29, 2020

Introduction

We Luenya Santiago dos Santos Change & Transform take the protection of the data of users of our website and/or our mobile app http://www.luenyasantiago.online very seriously and we are committed to protecting the information that users provide to us in connection with the use of our website and/or our mobile -App provide to protect. We are further committed to protecting and using your data in accordance with applicable law.

This Privacy Policy explains our practices regarding the collection, use and disclosure of your information through the use of our digital assets or services when you access the Services through your devices.

Please read the Privacy Policy carefully and make sure you fully understand our practices regarding your information before using our Services. If you have read this policy, fully understand it and do not agree with our practices, you must stop using our digital assets and services. By using our Services, you accept the terms of this Privacy Policy. Continued use of the Services constitutes your acceptance of this Privacy Policy and any changes thereto.

In this privacy policy you will learn:

  • How we collect data

  • What data we collect

  • Why we collect this data

  • Who we pass on the data to

  • Where the data is stored

  • How long the data is retained

  • How we protect the data

  • How we deal with minors

  • Updates or Changes to the Privacy Policy

What data do we collect?

Category: Always

Below is an overview of the data we may collect:

 

  • De-identified and non-identifiable information that you provide during the registration process or that is collected through the use of our Services (“Non-Personal Information”). Non-personal data does not allow any conclusions to be drawn as to who collected it. Non-personal information that we collect consists primarily of technical and aggregate usage information.

  • Individually identifiable information, i.e. H. all those through which you can be identified or could reasonably be identified (“personal data”). The personal information we collect through our Services may include information requested from time to time, such as names, email addresses, addresses, phone numbers, IP addresses and more. If we combine personal information with non-personal information, we will treat it as personal information as long as it is in combination.

How do we collect data?

Category: Always

Below are the main methods we use to collect data:

 

  • We collect data when you use our services. This means that when you visit our Digital Assets and use Services, we may collect, record and store usage, sessions and related information.

  • We collect data that you provide to us, for example when you contact us directly via a communication channel (e.g. an email with a comment or feedback).

  • We may collect information from third-party sources as described below.

  • We collect information that you provide to us when you log in to our Services through a third party such as Facebook or Google.

Why do we collect this data?

Category: Always

We may use your data for the following purposes:

 

  • to provide and operate our services;

  • to develop, customize and improve our Services;

  • to respond to your feedback, inquiries and requests and to offer assistance;

  • to analyze demand and usage patterns;

  • for other internal, statistical and research purposes;

  • to improve our data security and fraud prevention capabilities;

  • to investigate violations and enforce our terms and policies and to comply with applicable law, regulation or governmental request;

  • to provide you with updates, news, promotional materials and other information related to our Services. For promotional emails, you can decide for yourself whether you would like to continue to receive them. If not, simply click on the unsubscribe link in these emails.

Who do we share this data with?

Category: Always

We may share your information with our service providers to operate our services (e.g. storing data through third party hosting services, providing technical support, etc.).

 

We may also disclose your information in the following circumstances: (i) to investigate, detect, prevent, or take action against unlawful activities or other wrongdoing; (ii) to establish or exercise our rights of defense; (iii) to protect our rights, property or personal safety, or the safety of our users or the public; (iv) in the event of a change of control of us or one of our affiliates (by way of a merger, acquisition or purchase of (substantially) all of the assets, among other things); (v) to collect, maintain and/or manage your information through authorized third parties (e.g. cloud service providers) as appropriate for business purposes; (vi) to work with third parties to improve your user experience. To avoid any misunderstandings, we would like to point out that we may transmit, pass on or otherwise use non-personal data to third parties at our own discretion.

Category: User has a blog or forum

Please note that our Services enable social interactions (e.g. publicly posting content, information and comments and chatting with other users). Please be aware that any content or data you provide in these areas may be read, collected and used by other people. We advise against posting or sharing information that you do not wish to be made public. If you upload content to our Digital Assets or otherwise make it available as part of using a Service, you do so at your own risk. We cannot control the actions of other users or members of the public who have access to your data or content. You acknowledge and hereby acknowledge that copies of your data may remain accessible on cached and archived pages even after they have been deleted or after a copy/storage of your content has been created by a third party.

Cookies and similar technologies

When you visit or access our Services, we authorize third parties to use web beacons, cookies, pixel tags, scripts and other technologies and analytics services (“Tracking Technologies”). These tracking technologies may allow third parties to automatically collect your data to improve the navigation experience on our digital assets, optimize their performance and ensure a tailored user experience, as well as for security and fraud prevention purposes.

 

To find out more, please read our Cookie Policy.

Category: The user is NOT affiliated with an advertising service

We will not share your email address or other personal information with advertising companies or advertising networks without your consent.

Category: The user is connected to an advertising service, a campaign manager or Facebook Ads

We may provide advertising across our Services and our digital assets (including websites and applications that use our Services), which may also be tailored to you, such as: B. Ads based on your recent browsing behavior across websites, devices or browsers.

 

To deliver these advertisements to you, we may use cookies and/or JavaScript and/or web beacons (including transparent GIFs) and/or HTML5 local storage and/or other technologies. We may also use third parties, such as: B. Network advertisers (i.e. third parties that display advertisements based on your website visits) to serve targeted advertisements. Third-party advertising network providers, advertisers, sponsors and/or website traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including transparent GIFs) and/or Flash cookies and/or other technologies to improve effectiveness measure your ads and tailor advertising content for you. These third-party cookies and other technologies are subject to the specific privacy policy of the relevant third party and not this one.

Where do we store the data?

Category: Always

Non-Personal Information

 

Please note that our companies and our trusted partners and service providers are located around the world. For the purposes explained in this Privacy Policy, we store and process any non-personal data that we collect in different jurisdictions.

Category: User collects personal data

Personal Data

Personal data may be maintained, processed and stored in the United States, Ireland, South Korea, Taiwan, Israel and to the extent required for the proper provision of our Services and/or by law (as further explained below) in other jurisdictions.

How long is the data retained?

Category: Always

Please note that we retain collected information for as long as necessary to provide our services, comply with our legal and contractual obligations to you, resolve disputes, and enforce our agreements.

We may correct, supplement or delete inaccurate or incomplete data at any time at our sole discretion.

How do we protect the data?

Category: Always

The hosting service for our digital assets provides us with the online platform through which we can offer our services to you. Your data may be stored through our hosting provider's data storage, databases and general applications. It stores your data on secure servers behind a firewall and it offers secure HTTPS access to most areas of its services.

Category: User accepts payments/eCom

All payment options offered by us and our hosting provider for our digital assets comply with the PCI-DSS (credit card industry data security standard) regulations of the PCI Security Standards Council. This involves collaboration between brands such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information (including physical, electronic and procedural measures) by our store and service providers.

Category: Always

Regardless of the measures and efforts taken by us and our hosting provider, we cannot and do not guarantee absolute protection or security of the data that you upload, post or otherwise share with us or others.

For this reason, we ask that you set strong passwords and, if possible, not provide us or others with any confidential information that you believe, if disclosed, could cause you significant or lasting harm. Additionally, because email and instant messaging are not considered secure forms of communication, we ask that you do not share any confidential information through any of these communication channels.

How do we deal with minors?

Category: User does NOT collect data from minors

The Services are not intended for users who have not yet reached the legal age of majority. We will not knowingly collect data from children. If you are under the age of majority, you should not download or use the Services or provide any information to us.

 

We reserve the right to request proof of age at any time so that we can check whether minors are using our services. If we become aware that a minor is using our Services, we may prohibit or block such user's access to our Services and we may delete any data we maintain about that user. If you have reason to believe that a minor has provided information to us, please contact us as explained below.

Category: User collects data from minors

Children can use our services. However, if you want access to certain features, you may be required to provide certain information. Some data collection (including data collected through cookies, web beacons and other similar technologies) may occur automatically. If we knowingly collect, use or disclose information collected from a child, we will provide notice and obtain parental consent in accordance with applicable law. We do not condition a child's participation in an online activity on the child providing more contact information than is reasonably necessary to participate in that activity. We only use the information we collect in connection with the services the child has requested.

 

We may also use a parent's contact information to communicate about the child's activities on the Services. Parents can view information we have collected from their child, prohibit us from collecting any additional information from your child, and request that any information we have collected be deleted from our records.

 

Please contact us to view, update or delete your child's information. To protect your child, we may ask you to provide proof of your identity. We may deny you access to the information if we believe your identity is questionable. Please note that certain data cannot be deleted due to other legal obligations.

Category: Always

We will only use your personal data for the purposes set out in the Privacy Policy and only if we are satisfied that:

 

  • the use of your personal data is necessary to perform or enter into a contract (e.g. to provide you with the Services themselves or customer service or technical support);

  • the use of your personal data is necessary to comply with relevant legal or regulatory obligations, or

  • the use of your personal information is necessary to support our legitimate business interests (provided that we do so at all times in a manner that is proportionate and respects your privacy rights).

As an EU resident you can:

 

  • request confirmation as to whether or not personal data concerning you is being processed and request access to your stored personal data and certain additional information;

  • request to receive personal data that you have provided to us in a structured, commonly used and machine-readable format;

  • request correction of your personal data held by us;

  • request the deletion of your personal data;

  • object to our processing of your personal data;

  • request the restriction of the processing of your personal data, or

  • lodge a complaint with a supervisory authority.

Please note, however, that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal information we collect and how we use it, please contact us as indicated below.

In the course of providing the Services, we may transfer data across borders to affiliates or other third parties and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the Services, you consent to the transfer of your data outside the EEA.

 

If you are based in the EEA, your personal data will only be transferred to locations outside the EEA if we are satisfied that an adequate or comparable level of protection of personal data exists. We will take appropriate steps to ensure that we have appropriate contractual arrangements in place with our third parties to ensure that appropriate security measures are in place so that the risk of unlawful use, alteration, deletion, loss or theft of your personal data is minimized and that such third parties will at all times act in accordance with applicable laws.

Rights under the California Consumer Privacy Act

 

If you use the Services as a California resident, you may have the right to request access to and deletion of your information under the California Consumer Privacy Act (“CCPA”).

 

To exercise your right to access and delete your data, please read below how to contact us.

Category: The website does not sell any data about its users

We do not sell users' personal information for the purposes of the CCPA.

Category: Websites with a blog or forum

Users of the Services who are California residents and under 18 years of age may request and obtain removal of their posted content by sending an email to the address provided in the “Contact Us” section below. These requests must all be marked “California Removal Request.” All requests must include a description of the content that you request to be removed and sufficient information to permit us to locate the material. We will not accept communications that are unlabeled or improperly delivered, and we may not be able to respond if you do not provide sufficient information. Please note that your request does not ensure that the material will be completely or comprehensively deleted. For example, material you post may be republished or reposted by other users or third parties.

Updates or Changes to the Privacy Policy

Category: Always

We may revise this Privacy Policy from time to time in our sole discretion, the version posted on the Site will always be current (see “As of” statement). We encourage you to periodically review this Privacy Policy for any changes. If there are any significant changes, we will post a notice on our website. Your continued use of the Services following notification of changes on our website will constitute your acknowledgment and agreement to the changes to the Privacy Policy and your agreement to be bound by the terms and conditions of such changes.

Contact

Category: Always

If you have general questions about the Services or the information we collect about you and how we use it, please contact us at:

 

Name: Luenya Santiago dos Santos

Email address: contact@luenyasantiago.online

DISCLAIMER

The information contained herein is not a substitute for legal advice and you should not rely solely on it. Specific requirements regarding legal terms and guidelines may vary from state to state and/or from jurisdiction to jurisdiction. As set out in our Terms of Use, you are responsible for ensuring that your Services are permitted by, and comply with, the law applicable to you.

To ensure that you fully comply with your legal obligations, we strongly recommend that you seek professional advice to better understand which requirements apply specifically to you.

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