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FAZGAME PRIVACY POLICY

We, Zeltzer Tecnologias Educacionais Ltda. ("Company", "we" or "FazGame"), enrolled in the CNPJ/ME under no. 15.238.766/0001-86 and headquartered in the City of Rio de Janeiro/RJ, at Rua Lauro Muller, nº 86 - apto. 406 - Botafogo, we take your privacy and the protection of your data seriously. This document explains how we handle your personal data, what your rights are and how you can exercise them.

Why does FazGame handle your personal data?

In order to deliver our services, which are further detailed in the Terms of Use, we need to process information about you. FazGame only collects personal data that is essential for the execution and maintenance of our services. The processing of personal data are also indispensable for maintaining your access to the platform and personalization.

1. BASIC CONCEPTS:  WHAT DO YOU NEED TO KNOW TO UNDERSTAND THIS POLICY?

In order to uncomplicate your reading of this document, we present some useful definitions for its interpretation:

Term Concept
Personal Data It is information that relates to a natural person and that is able to identify the person or make it possible to identify the person.

Examples of personal data that can allow your identification are:  Name, CPF, telephone, e-mail, license plate number, etc.
Treatment It is any use we may make of your Personal Data, including but not limited to the following activities:  collection, storage, consultation, use, sharing, transmission, classification, reproduction, deletion, and evaluation.
Holder It is you, the natural person to whom the Personal Data refer.
Company That's us, FazGame
Policy It is this Privacy Policy.

2. WHAT KIND OF PERSONAL DATA DOES FAZGAME PROCESS?

The types of Personal Data and how we collect it depends on how you engage with the Company and why. For example, the Personal Data we collect will be different if you are a Free Login user or have Premium Login access to our site.

Listed below are some situations in which we may handle your Personal Data in the context of your relationship with FazGame:

Treatment Purposes Types of Personal Data Used
Registration/Free Login Name, e-mail and date of birth
Registration/access to the Extended Login Name, e-mail, birthday, institution, state, city.
Registration/access to the Premium and Corporate Login Name, e-mail, birthday, Institution you are connected to and whether it is public or not, state, city, country, cell phone number.
Registration/access to the Corporate Premium Login Name, e-mail, birthday, company, state, city, country, mobile number.
Filling out the form available on the site for those interested in obtaining premium access for their institution Name, e-mail, cell phone number (whatsApp), Skype, state, city, country, institution you are linked to, and whether it is public or not, and the segment you work in.

3. DATA PROCESSING OF CHILDREN AND ADOLESCENTS

For registration and access to Free, Extended or Premium Login, FazGame may collect personal data of children and adolescents directly from their parents or legal guardians, and with consent through acceptance of the Terms of Use, when the registration is done directly on our site, according to the rules of current legislation.

FazGame also collects the personal data of children and adolescents through schools and educational institutions that have a partnership with the Company in which the children are enrolled so that they can participate in the project. This collection may also occur through a partner company, when it comes to corporate login, provided it has the express consent of those responsible.

Depending on the type of access, minors participating in FazGame activities can create their own games within the platform, which will be available for other users to play. In these situations, no personal data of the child/teenager is shared with other users, since the games created are identified with an alias.

4. COOKIES

Within the FazGame website, we use cookies exclusively for storing and reading FazGame session data, such as session key and game information.

5. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

Personal Data is your data and Brazilian law grants you a number of rights related to it. We are committed to enabling you to exercise these rights, and in this section we will explain what these rights are and how you can exercise them. See below:

Your Rights Explanation
Confirmation and Access You may ask the Company to confirm the existence of the processing of your Personal Data so that, if so, you can access it, including by requesting copies of the records we have about you.
Correction You may request that we correct your Personal Data if it is incomplete, inaccurate or out of date.
Anonymization, blocking or deletion You may request that we (a) anonymize your Personal Data so that they can no longer be linked to you and are therefore no longer Personal Data; (b) block your Personal Data by temporarily suspending your ability to process them for certain purposes; and (c) delete your Personal Data, in which case we shall delete your Personal Data without possibility of reversal.
Portability You may request that the Company provide your Personal Data in a structured and interoperable format for transfer to a third party, provided that such transfer does not violate the Company's intellectual property or trade secrets.
Sharing Information You have the right to know the public and private entities with which the Company shares your Personal Data. If you have questions or want more details, you have the right to ask us for this information. Depending on the case, we may limit the information provided to you if its disclosure would violate the Company's intellectual property or trade secrets.
Information about the possibility of not consenting You have the right to receive clear and complete information about the possibility and consequences of not providing consent when it is requested by the Company. Your consent, when required, must be free and informed. Therefore, whenever we ask for your consent, you are free to deny it - in such cases, it is possible that some services cannot be provided.
Revocation of consent If you have consented to any purpose for processing your Personal Data, you may always choose to withdraw your consent. However, this will not affect the lawfulness of any Processing carried out prior to the withdrawal. If you withdraw your consent, it is possible that we may be unable to provide certain services to you, but we will notify you when this occurs.
Opposition If you do not agree with any processing of your Personal Data, you may express your disagreement by lodging an objection.


IMPORTANT NOTICES

To ensure your security and privacy, whenever a request for exercising the rights of data subjects is presented, the Company may request some additional information and/or documents so that we can verify your identity, seeking to prevent fraud.

In some cases, the Company may have legitimate reasons for not complying with a request to exercise rights. These situations include, for example, cases where disclosure of specific information could violate intellectual property rights or trade secrets of the Company or third parties, as well as cases where requests to delete data cannot be honored because the Company has an obligation to retain data, whether to comply with legal or regulatory obligations or to enable the Company or third parties to defend themselves in disputes of any kind.

Still, some requests may not be answered immediately, but the Company is committed to answering all requests within a reasonable time and always in compliance with applicable law.

If you have any questions about these issues or how you can exercise your rights, please feel free to contact us through the channels listed at the end of this Policy.

6. HOW DOES THE COMPANY STORE YOUR PERSONAL DATA?

All storage of personal data collected on the FazGame website is stored digitally. In addition to direct storage on the platform, we also store your data on internal, restricted access Drive (G-Suite) and in our Amazon Web Services (AWS) environment. Our server is located in the United States and our restricted access policy follows the Amazon Web Services guidelines.

7. FOR HOW LONG WILL PERSONAL DATA BE STORED?

The Company has a Personal Data retention policy in line with applicable law. Personal Data is stored only as long as necessary to fulfill the purposes for which it was collected, unless there is any other reason for its retention, such as compliance with any legal, regulatory, contractual or other obligations permitted under the law.

We perform a technical analysis to determine the appropriate retention period for each type of Personal Data collected, taking into account its nature, the need to collect it, and the purpose for which it will be processed, as well as any retention needs to fulfill obligations or protect rights.

8. HOW DOES THE COMPANY PROTECT YOUR PERSONAL DATA?

Our responsibility is to take care of your Personal Data and use it only for the purposes described in this Policy. To ensure your privacy and the protection of your Personal Data, we have adopted advanced technological resources to ensure the security of all data processed by the Company. Among the security measures implemented are access controls to systems and data treatment environments, encryption techniques and the installation of barriers against improper access to databases (including firewalls), as well as other information security controls.

We strive to protect the privacy of your Personal Data, but unfortunately we cannot guarantee complete security. Unauthorized entry and use of your information by third parties, hardware or software failures beyond the Company's control, and other external factors can compromise the security of your Personal Data. For this reason, your actions are fundamental to maintaining a secure environment for everyone. If you identify or become aware of any factor that compromises the security of your data in your relationship with the Company, please contact us using the contact information listed below.

9. HOW TO DISCUSS PERSONAL DATA WITH FAZGAME?

If you believe that your Personal Data have been treated in a manner inconsistent with this Policy or with your choices as a Data Subject, or if you have questions, comments or suggestions regarding this Policy and the way we treat your Personal Data, please contact us. We have a Data Protection Officer who is available at the following contact addresses:

In Charge:  Eduardo Sierra
E-mail for contact:  privacidade@fazgame.com.br

10. CHANGES TO PRIVACY POLICY

As we are always seeking to improve our services and the way we operate, this Privacy Policy may be updated to reflect the improvements made. Therefore, we recommend that you visit this page from time to time so that you are aware of any changes.

DATE OF LAST UPDATE:  03 March 2022.

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