It was last updated on May 13, 2020
This document was written and made available on May 13, 2020.
Below are the meanings of the technical nomenclatures and terms in the English language:
Cookies: Small text files that are recorded on the Internet user’s computer and can be retrieved by the website that sent him during browsing. They are mainly used to identify and store information about visitors.
Cryptography: Set of principles and techniques for encrypting writing, making it unintelligible for those who do not have access to combined conventions.
Person in Charge: Person appointed by the controller and operator to act as a communication channel between the controller, data holders and the Brazilian National Data Protection Authority (ANPD).
IP (or Internet Protocol): Unique identification for each computer connected to a network.
Student User: Individuals who access the platform in search of courses and mentoring session on the subject of their interest.
Mentor User: Individual or legal entity that participates in a selection process carried out by the platform in order to offer mentoring to Student Users.
3.1. Protecting your privacy is very important to us. Your data is transferred in encrypted form and stored on Digital Ocean servers, whose access is restricted. In addition, we use firewalls and security certificates, offering a variety of security technologies and procedures to help protect Users’ information.
3.2. The servers used by AWARI are equipped with mechanisms capable of ensuring the security of your data that are located outside of Brazil but are kept in countries that provide an adequate degree of personal data protection, according to article 33, I of Law no. 13709/18.
3.3. All access records, set of information regarding the date and time of use of a given internet application from a given IP address, will be kept by AWARI, under confidentiality, in a controlled and safe environment, for a minimum period of 06 (six) months, under the terms of Law no. 12,965 / 2014, and article 7, II, of Law 13709/18.
3.4. The User must be responsible and declare himself exclusively responsible for all actions, as well as for all information and the veracity of the content that he inserts on the platform.
4.1. Data provided by both Student and Mentor Users: Full Name, e-mail, ID Number, birthdate, full address and telephone.
4.2. Information we collect indirectly: We collect information indirectly through cookies, such as IP address used, location and visit times. We collect the following personal data indirectly through Facebook Pixel and Google Analytics in order to promote the platform’s marketing campaigns: Pages Visited, Session Time, HTTP Headers, Clicked Buttons and Form Inputs.
4.3. Contact historical: AWARI stores information about all interactions already carried out between Users through the platform, such as messages in emails, telephone contacts and file uploads, as this will improve your service and make you more efficient. Without this history, probably every time you used the platform, you would have to repeat what has already happened to us before.
|Personal Data Type||Legal Basis||Goal|
|Full Name||Necessary for the execution of a contract or preliminary procedures related to a contract to which the holder belongs, at the request of the data holder (Art. 7, V, Law No. 13.709 / 2018).||User identification. This is essential personal data so that it is possible to contact the User, to attend to their requests and provide targeted responses.|
|E-mail and telefone number||Necessary for the execution of a contract or preliminary procedures related to a contract to which the holder belongs, at the request of the data holder (Art. 7, V, Law No. 13.709 / 2018).||Used for login and validation of registration on the platform, sending invoices, as well as means of communication with the User, for contacts and interactions throughout the journey of using the platform.|
|Birthdate||Necessary to meet the legitimate interests of the controller or third party (Art. 7, IX, Law No. 13,709 / 2018).||Required to confirm the minimum age for using the platform, and to complete the service provision contract.|
|ID Number and Full Address||Compliance with legal or regulatory obligation by the controller (Art. 7, II, Law No. 13,709 / 2018).||It is necessary to issue an invoice to the User regarding the platform subscription.|
|Visited Pages, Session Time, HTTP Headers, Buttons, Clicked, Forms Inputs||Necessary to meet the legitimate interests of the controller or third party (Art. 7, IX, Law No. 13,709 / 2018).||Used for marketing campaigns on the platform.|
|IP (Internet Protocol),|
|Compliance with legal or regulatory obligation by the controller (Art. 7, II, Law No. 13,709 / 2018).||Compliance with article 15 of Law no. 12,965 / 2014, which imposes the duty of AWARI to keep the respective records of access to internet applications, under confidentiality, in a controlled and security environment, for a period of 6 (six) months.|
6.1. Only persons strictly necessary for the provision of the service may have internal access to the Users’ information.
6.2. Student User data will be shared with Pagar.me partners, for processing payments made for access to courses and Provi, for those who choose Student Financing. In addition, Student User data may be shared with Mentors, as well as that of mentors with students. This sharing is necessary to enable the provision of our service.
6.3. AWARI will not share Users’ confidential data with third parties not described in these policies, except under law or a court order.
7.1. Access accounts cancelling by AWARI: AWARI may, in its sole discretion, block, restrict, disable or prevent any User from accessing the platform whenever improper conduct is detected.
7.2. Access accounts cancelling by the User: Users who want to cancel their accounts (login) can directly request it by the means described in item 12 of these policies.
7.3. Data Exclusion: At the time of account cancellation, when the purpose of data processing ends or upon request, the User will have all his / her data deleted immediately and permanently from the platform, except for the data whose maintenance is mandatory by law or regulation, the data necessary for the regular exercise of rights in judicial, administrative or arbitral proceedings, such as access records (set of information regarding the date and time of use of a given internet application from a given IP address), which will be kept confidential , in a controlled and safe environment, for a period of 6 (six) months, pursuant to Law no. 12,965 / 2014 and with the legal basis of art. 7, II, of the Brazilian General Personal Data Protection Law.
8.1. The holder of personal data is entitled to obtain from AWARI, in relation to the data processed by it, at any time and upon request:
8.1.1. The confirmation of a data treatment existance;
8.1.2. Access to the data;
8.1.3. Incomplete, inaccurate or outdated data correcting;
8.1.4. Anonymizing, blocking or deleting unnecessary, excessive or treated data in non-compliance with the provisions of Law 13.709 / 2018;
8.1.5. Portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, subject to commercial and industrial secrets;
8.1.6. Elimination of data processed with the consent of the holder, except in the cases provided for in Law 13.709 / 2018;
8.1.7. Information from public and private entities with which AWARI has made shared use of data;
8.1.8. Information on the possibility of not providing consent and on the consequences of the denial;
8.1.9. Consent revocation.
9.1. AWARI is committed to preserving the platform’s stability, security and functionality, through technical measures compatible with international standards and by encouraging the use of good practices. However, no service available on the Internet is fully guaranteed against illegal invasions. In cases where unauthorized third parties invade the system illicitly, AWARI will do its best to find the person responsible for the illegal act but is not responsible for the damages caused by them.
10.2. If the change made requires the User’s consent, the option will be presented to be accepted the new text freely, unambiguously and informed or to refuse it.
10.3. If the User does not agree with the change, the User should not provide consent to specific acts or you may terminate your relationship with AWARI entirely. Such termination will not, however, exempt the User from complying with all obligations assumed under the preceding versions of the Privacy Policies.
11.1. AWARI appoints in charge Mr. Fabio Willian Leme Muniz, of the CPF under number 433.166.488-01, with electronic address email@example.com, under the terms of art. 41 of the General Data Protection Law, to accept complaints and communications from holders and the National Data Protection Authority, provide clarifications and act when needed.
12.1. AWARI provides the following channels to receive all communications that Users wish to make: e-mail firstname.lastname@example.org.