(Websites: https://www.omeletecompany.com/; https://www.omelete.com.br/; https://www.theenemy.com.br/; https://www.gaules.gg/; https://www.baiano.tv/; https://www.ccxp.com.br/; https://conteudo.omeletecompany.com/geekpower-games)
General Information & Definitions.
User: all natural persons over 18 (eighteen) years of age or emancipated who will use or visit the Website(s) and/or Applications, capable of performing civil life acts or those who are absolutely or relatively incapable but duly represented or assisted.
Personal Data: any information provided and/or gathered by the Omelete Company and/or any of the group companies by any means, even public ones, that: (I) identifies or that, when used in combination with other processed information by the Omelete Company group, is able to identify an individual; or (II) through which an individual's identification or contact information may be derived. Personal Data can be stored in any medium or format, including digital files, as well as paper-based files. Personal Data, however, does not include business phone, business mobile number, business address or business e-mail.
Data Processing: any operation performed using personal data, such as those relating to the gathering, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, distribution, transfer, broadcast or extraction.
Purpose: the objective, the purpose that the Omelete Company group intends to achieve from each act of personal information processing.
Justification: justification as to why it is strictly necessary to gather personal data to achieve the purpose hereby stated, avoiding unnecessary gathering of information.
Legal Basis: legal basis on what makes the processing of personal data legitimate for a specific purpose stated by the Omelete Company group.
Consent: express and unambiguous authorization given by the User holder of the personal data for Omelete Company to process his/her personal data for a previously described purpose, in which the necessary legal basis for the act requires the express authorization of the holder.
This policy applies, in general, to all Users and potential Users of the services offered by the Omelete Company group, including Users of WEBSITES or other means operated by the Omelete Company group and summarizes how the Omelete Company, through such websites, may gather, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, delete, evaluate or control information, modify, communicate, transfer, disseminate or extract the gathered data, including the personally identifiable information, in accordance with applicable legal bases and all applicable privacy and data protection laws.
2. Gathering and use of personal information.
The User is aware that he/she provides information consciously and voluntarily by completing the registration, or through the websites operated by the Omelete Company group.
When the User registers and/or fills in forms made available by the Omelete Company group, or browses its platforms and Websites, certain Personal Data requested will be kept confidential and will be used only for the purpose that motivated the registration, as per the Purposes List below.
Personal Data Category
|Websites Homepage||In order to access content and receive information and/or promotional material, the Omelete Company will need the User to provide his/her e-mail. The Omelete Company group will send marketing e-mails to Users who provide this information. The Personal Data gathered will not be used to send any type of SPAM, only for targeted marketing.||Sole interests of the data holder.|
|Credit card details and confirmation of registration data||Data required to process payments. For this, payment data will be registered with the third-party company responsible for processing the payment.||Contract performance|
|Website browsing||Behavior data||There is the implementation of technological features by means of so-called cookies and pixels to gather browsing information from the user for the development of advertising aimed at the user's interest according to their browsing and profile. The tools used for this are Google Analytics and Facebook Pixels.||Sole interests of the data holder.|
|Prospecting of companies as clients for partnerships or service provision||Corporate email|
|For the prospecting of corporate clients (Companies), the Group uses research and tools to locate contacts provided by the company itself for the purpose of being contacted, especially emails or phone numbers without personal identification but rather specific sections of the company. However, companies may occasionally provide corporate emails for a responsible professional in the section or for receiving contacts from the company, or redirect contacts through automated messages. This data is processed solely for the purpose of establishing contacts with the company for the presentation of business opportunities linked to the Group.|
Controller's legitimate interest and article 7, §4 of the LGPD
Automatic Data Gathering: When accessing our website, some information is automatically gathered in order to improve the browsing and flow experience, perform market intelligence analysis, such as city of origin of access, system usage, visit origin, pages visits, time and duration of the visit, equipment used, among other information on the user behavior so that specific advertisements can be targeted according to the user's interest, as well as so that the quality of the event, areas of greatest interest and other data that enable the improvement of functionalities to be offered to users.
We emphasize that no personal data, that is, that which identifies or allows the identification of users, is gathered automatically or without the user's consent. The data gathered automatically does not allow the identification of the user present on the website and will not be used for this purpose. The information gathered automatically is usually stored in the user's browser in the form of cookies.
Blocking cookies can impair the user experience when using our website.
3. Sharing and handling personal information.
The Omelete Company group will not make Personal Data gathered on its websites available to mailing list agencies without the User’s consent.
The Omelete Company group may disclose the User’s Personal Data gathered to third parties in the following situations and within the limits required and authorized by law:
4. Legal reasons to release your data
In certain circumstances, the Omelete Company group may disclose Personal Data, to the extent necessary or appropriate, to government agencies, consultants and other third parties for the purpose of complying with applicable law or with a court order or subpoena, or if the Omelete Company group believes in good faith that such action is necessary to:
The Omelete Company group makes their Users aware of any legal demands that result in the disclosure of past personal information, in accordance with what has been set out in item 4, unless such awareness is prohibited by law or prohibited by court order, or, if the request is an emergency. CCXP and/or Omelete Company group may contest these claims if they deem the requests to be excessive, vague or made by incompetent authorities.
5. Security of personal information.
All Personal Data will be stored in the Omelete Company group database or in a cloud database handled solely by employees of specific departments and/or service providers hired by the Omelete Company group, which are duly in accordance with current data legislation.
The Omelete Company group and its suppliers use various security procedures to protect the confidentiality, security and integrity of your Personal Data, including through encryption of data in transit, preventing the occurrence of any damages arising from the processing of such data.
Although the Omelete Company group uses security measures and monitors its system to check for vulnerabilities and attacks to protect your personal data against unauthorized disclosure, misuse or alteration, the User understands and agrees that there is no guarantee that the information will not may be accessed, disclosed, altered or destroyed for breach of any of the physical, technical or administrative protections.
6. Data Retention
The Omelete Company group has a Personal Data retention policy in line with applicable law. Personal Data is stored only for as long as necessary to fulfill the purposes for which it was gathered, unless there is any other reason for its maintenance, such as, for example, compliance with any legal, regulatory, contractual, among others permitted under the law.
A technical analysis is always carried out to determine the appropriate retention period for each type of Personal Data gathered, considering its nature, gathering need and purpose for which it will be treated, as well as any retention needs to fulfill obligations or the protection of rights.
7. Legal basis for data processing.
The Omelete Company group only handles Personal Data in situations where it is legally authorized or with the express and unequivocal consent of the User.
Conforme descrito na presente Política, a Omelete Company tem bases legais para coletar, produzir, receptar, classificar, utilizar, acessar, reproduzir, transmitir, distribuir, processar, arquivar, armazenar, eliminar, avaliar ou controlar a informação, modificar, comunicar, transferir, difundir ou extrair dados sobre o Usuário.
As described in this Policy, the Omelete Company group has legal bases to gather, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, delete, evaluate or control information, modify , communicate, transfer, disseminate or extract data about the User.
The legal bases include your consent (expressly and unambiguously gathered in the Consent Form), contracts and preliminary contractual procedures (in which processing is necessary to enter into the contract with the User) and legitimate interests, provided that such processing does not violate your rights and freedoms, as shown in the Table of Purposes.
Such interests include protecting the User and the Omelete Company group from threats, complying with applicable law, regular exercise of rights in judicial, administrative or arbitration proceedings, enabling the execution or administration of business, including quality control, reporting and services offered, manage business transactions, understand and improve business and customer relationships, and enable users to find cost-effective opportunities.
The User has the right to deny or withdraw the consent provided to the Omelete Company group, when this is the legal basis for processing personal data, and the Omelete Company group may terminate the provision of its services for this user on hypothesis of such request.
If you have any questions about the legal bases for the gathering, processing and storage of your personal data, please contact the Omelete Company group and its Data Protection Officer via e-mail at firstname.lastname@example.org.
8. Right to access and control your personal data.
The Omelete Company group offers the User several options of what to do with his/her personal data gathered, processed and stored, including its deletion and/or correction. The User can:
The User may make the requests listed above by contacting our Data Protection Officer via e-mail on email@example.com and these requests will be considered in accordance with applicable laws.
In accordance with Article 16 of the LGPD (Brazilian General Data Protection Act), the Data Controller may retain the data and refuse to fully comply with requests for changes or deletions when there are reasons for retention, such as the need to comply with legal, contractual, regulatory obligations or even for statistical purposes or to protect the Data Controller's rights.
9. Policy Revisions.
10. Contacting Us.
The User may contact the Data Protection Officer (“DPO”) via the following physical address or e-mail firstname.lastname@example.org.
11. Mediation and Choice forum.
This policy is subject to the Law of the Federative Republic of Brazil and the Judicial District Court of São Paulo is competent to settle any dispute in connection therewith.
In the event of an incident with personal data, CCXP and/or Omelete Company group, from now on, reserve to appoint the company JUSPRO – Justiça Sem Processo Mediação e Conciliação S/S Ltda., as the Mediation Chamber able to resolve issues involving users data holders, pursuant to article 52, §7 of Brazil’s General Data Protection Law.