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PRIVACY POLICY

Version of June 5, 2024.

Welcome to Nuinalp

Hello, welcome to Nuinalp, first of all we would like to thank you for using our services and products. By using them you are trusting us with your personal information, and this is a big responsibility, so we work hard to protect it and put you in control.

For this reason, we have created this privacy policy to help you understand what information we collect, why we collect it and how you can update, manage, export and delete this information. This is a universal term that we use in all our services and products, however, there may be situations in which a particular product has additional and/or complementary terms, which means that these new terms will be part of our contract with you, if you decide to use them.

1. Privacy Policy

The Privacy Policy for the means of communication made available by Nuinalp is in accordance with current legislation and informs that it has implemented the necessary security measures, of a technical and organizational nature, to guarantee and protect the confidentiality, integrity and availability of the data entered.

We refer to Nuinalp through the use of terms such as “website”, “we”, “our”, “us”, words such as “you”, “your”, and similar expressions refer to our customers, or users of our products or services. By visiting and using our products and services, you automatically accept the conditions described below, which make up the Privacy Policy.

2. Personal Data

2.1. Information Collected by Nuinalp

We collect information to provide better services to all of our users. This information is used to find out basic things, such as the language you speak, browser you use, and even more complex scenarios such as the region you are currently in to optimize your access and provide greater speed. The information collected by Nuinalp and how this information is used depends on how you use our products and services and how you manage your privacy controls.

When you are not logged into a Nuinalp Account, we store the information we collect with unique identifiers linked to your browser, application or device that you are currently using. This allows us to maintain your preferences across browsing sessions; such as the language or theme you choose, as well as possible region suggestions or optimizations that we can make in order to deliver the best performance.

When you are logged in, we also collect information that we store with your Nuinalp Account and that we treat as personal information.

Explanation of what each item is, there will be a link to each highlighted term:

Unique Identifier

A unique identifier is a string of characters that can be used to uniquely identify a browser, application or device. They can be used in different ways and for different purposes, such as security, fraud detection, synchronization of services, such as the email inbox or even memorizing your preferences. In addition, there may be a variation in the sense of whether they are permanent or not, whether they can be reset by the user or not, in the way they can be accessed and the purpose for which they are used. On platforms other than browsers, unique identifiers can be used to personalize the experience on an Android device, such as enabling or disabling certain features.

Unique identifiers may be embedded in a device by the manufacturer (also called a universally unique code or UUID), such as the IMEI number of a cell phone. This allows us to customize our products and services for your device or to help us analyze related issues on the device.

Device

A device is a computer, smartphone, tablet, smartwatch or any type of device that has access to the internet and can be used to access Nuinalp's services and products.

Personal Information

This is information provided that identifies you personally, such as your name, email address or billing information, or other data that can be reasonably linked to this information by Nuinalp, such as the information we associate with your Nuinalp Account.

3. Information you create or provide to us

When you create a Nuinalp account, you provide us with some personal information such as your name and email address. In addition, you can also add other information to your Nuinalp account, such as your phone number, billing and email addresses, and additional phone numbers for monitoring and protection in Nuinalp ID Protection. Even if you do not have a Nuinalp account or are not logged in, you provide us with an email address to contact you, so that you can receive news and updates about Nuinalp products and services.

We also collect information that you view, upload, or receive from others when using our services. This includes email addresses, passwords, URLs, domains, and other information entered in Nuinalp Open Threats Platform, Nuinalp Labs, Nuinalp Cybersecurity Intelligence, and Nuinalp Fraud Prevention.

4. Personal information collected when using our services

When you use our products and services, we may collect information about the Apps, Services, browsers, and devices used to access our products and services. This information helps us provide specific features for each platform, provide automatic updates, identify problems, optimize access and data processing, marketing, payments, among others.

The information we collect includes:

  • The information you provide to us when filling out the contact form or any subscription form on our website, including your name, email, and other contact information, may be processed to analyze new business and service solutions;
  • Data collected from job candidates registered via our website, which will be sent and stored;
  • Communication log data, with or without subsequent storage, when accessing the Nuinalp Support channel “Contact Us”;
  • Information/data from questionnaires used for research purposes will be pseudonymized or de-identified whenever possible; * We also collect information about the interaction of apps, browsers and devices with our services, including IP address, error reports, system activity, as well as the date, time and URL of the request, online traffic data, the features you access;
  • Unique identifiers, browser name, type, version and settings, device name, type and settings, operating system, mobile network information, including carrier name and phone number and version number of the application or service.
  1. Refusal to Provide Personal Data

When we ask you to share your personal data with us, you can refuse. However, many of our services and products require certain personal information to be provided, and by choosing not to share the information necessary for the provision and operation of such services, you will not be able to use such products, services or features, and the use of some of them may also be limited.

6. Use of Data

Nuinalp will use this information to process and complete your access to the website and other products/services. Such data may be stored. Therefore, in accordance with current legislation, we may send messages.

Nuinalp is not responsible for the accuracy or lack thereof of the information provided by its users or for its outdated information, when it is the user's responsibility to update it.

Your personal data will only be used for the following purposes:

  • To register the user, possibly keeping specific records of the Transactions carried out in its system;

  • To allow the provision of services/products offered by the Platform, registration, facilitation of transactions, permission and feasibility of execution of contracts;

  • To transmit for payment and tax obligations purposes some registration data, such as: full name, CPF, e-mail address, authorization of the holder, among others;

  • To develop new products and services;

  • To offer personalized content;

  • To evaluate the performance of our services, Apps, infrastructure, database, among other resources;

  • Nuinalp reserves the right, at its sole discretion and according to its registration analysis parameters, to maintain the data for the Holder's registration;

  • Nuinalp reserves the right to block or cancel the Account due to the existence of indications of illegal acts, fraud, unauthorized automation (Bots), as well as registration discrepancies or other fraudulent means;

  • Carry out the necessary commercial and administrative procedures with the Users of the website;

  • Offer new products and services;

  • Notify you about news and updates of products and services;

  • Respond to queries and/or provide information requested by the User;

  • Provide services contracted or subscribed to by the User;

  • Notify the User of changes and amendments to our Privacy Policy;

  • Protect NUILNALP's rights and obligations related to the use of the content made available and interactions by its users;

  • Respond to authorities in the context of legal or administrative proceedings, in compliance with legal, regulatory or any other duties lawfully required of the Controller, or in defense of its rights and legitimate interests;

  • Carry out activities to prevent fraud and illegal activities, including measures to protect the Controller, Customers and/or third parties.

We will not process your data for any purpose other than those described above, except for compliance with a legal or regulatory obligation, shared processing of data necessary for the execution, by the public administration, of public policies provided for in laws or regulations, regular exercise of rights, protection of the life or physical safety of the holder or third parties, health protection, guarantee of fraud prevention and User security, court order or order from competent authorities.

Nuinalp will only make your personal information available, without prior notice, only in the event of: (a) applicable legislation, regulation, legal process or governmental request; (b) complying with investigation of possible violations; (c) fraud or for security; or (d) protecting against harm to the rights, property or safety of Nuinalp, our users or the public, as required or permitted by law.

7. Information We Share with Third Parties and Partners

The data collected and activities may be shared with regulatory, judicial, administrative or governmental authorities, as well as external auditors, whenever there is a legal determination or judicial request to do so or evidence of fraud.

Nuinalp will not pass on, rent or sell your email address or any other data. We will not share your personal information with other companies, in compliance with current legislation, except with your express authorization or in the event of a court order.

We are not responsible for the way in which third parties collect, use, protect or disclose the information you may provide to them.

Nuinalp provides a Consent Form for greater transparency regarding the purposes for collecting and processing personal data. This consent is intended for (i) Commercial relationships; (ii) Drafting commercial contracts and issuing charges against the Holder; (iii) Sending or providing the Holder with its products and services, whether paid or free of charge; (iv) Structure, test, promote and advertise products and services, whether or not customized to the Holder's profile.

This consent may be revoked by the Holder at any time, upon request via email or correspondence to the company, as long as it does not harm the Company's legitimate interest, the execution of a contract and the storage of data for legal compliance.

9. Minors under 18 years of age

By using our products and services, you confirm that you are of legal age in your state or province of residence and that you give us your consent to allow any of your minor dependents to use Nuinalp's products and services.

Nuinalp does not intentionally collect any identifiable information (such as name, address and telephone number, among others) from minors under 18 (eighteen) years of age.

Nuinalp specifically instructs minors under 18 (eighteen) years of age not to register and consequently not to send this information.

If the parents or guardians of a minor under 18 (eighteen) years of age believe that their child has provided us with personally identifiable information, they should contact us via email to possibly delete this information from our files.

10. We Keep Your Information Safe

All of our products and services are developed using solid tools and resources that continually protect your information. The insights we constantly receive as a result of maintaining our products and services help us automatically detect and block potential security threats that may reach you. And if we detect something dangerous or that requires action, we will notify you and assist you in every step to keep your Nuinalp account and your personal information safe.

We work hard to protect you and Nuinalp from unauthorized access, disclosure, alteration and/or destruction of the information we hold, including:

  • Offering several security features for your Nuinalp account, such as security verification and two-step verification.

  • Use of encryption to keep your data private while in transit;

  • Restrict access to information by contracted employees and Nuinalp representatives. Any person who needs to access information we hold is subject to strict contractual and procedural obligations and may be penalized and/or dismissed if they fail to comply with such obligations.

  • Compliance with integrity and security requirements and conditions established in the legislation in force in each country.

11. Exporting and Deleting Information

You can export a copy of your personal information or delete it at any time from your Nuinalp account.

To delete your personal information, you can:

  • Delete your entire Nuinalp account
  • Delete specific Nuinalp content or services, including personal information associated with these services
12. Retention of Your Information

We retain the information we collect for different periods, depending on what it is, the purposes, how we use it and how you have configured your settings:

  • Some data can be deleted at any time, such as your personal information from your Nuinalp account or content you create such as Nuinalp Bookmarks. This data will be kept until you remove it or decide to have it removed;

  • Other data is automatically deleted or anonymized after a period of time, such as shopping cart data;

  • Some data may be kept until your Nuinalp account is deleted, such as information about the frequency or country and device you use our services;

  • In addition, other information is kept for longer periods of time for legitimate commercial or legal purposes, such as security, fraud and abuse prevention, or financial record keeping.

13. Compliance with the Provisions of the General Data Protection Law

Nuinalp reaffirms its commitment to the privacy and protection of all personal data of its customers and employees. Thus, through the application of technologies and innovation, it always seeks to respect the privacy of our users and maximum transparency in the process of processing the data collected. Therefore, we reinforce our commitment, pledging to observe all provisions contained in the current legislation when processing personal data.

In addition, during the storage period by Nuinalp, there will be an exclusive person responsible for the data. This person will be responsible for the data, should it be necessary to present it to the competent authority. Contact details: [email protected]

14. Data Transfer

Nuinalp has servers in several countries in order to keep our services available worldwide, so your personal information may be processed on servers located outside of the country where you live. Data protection laws vary from country to country, and this means that some offer more protection and are stricter than others. However, regardless of the region where your data is processed, we will apply the same protections and care described in this policy. In addition, we work in compliance with the legal institutions of each country in order to follow their laws.

15. Changes to this Policy

We will change this policy periodically in order to better serve our customers. We will never reduce your rights without prior notice, for this reason, we will always indicate the date on which the last publications were published, and we will provide access to the archived versions for your analysis. If the changes are significant, we will send you a notice with more details, which may include, in some cases, email notifications of the changes to the Privacy Policy.

16. When This Policy Applies

This is a global Privacy Policy, and applies to all products and services offered by Nuinalp LTDA. This Privacy Policy does not apply to services that have separate privacy policies that do not incorporate this Privacy Policy.

This Privacy Policy does not apply to:

  • Information collection and processing practices of other companies and/or organizations that advertise our services and products;

  • Services offered by other companies or individuals, including products, websites or services that may include Nuinalp services;

17. Contact Data

If you have any questions about the conditions established in this Privacy Policy, contact Nuinalp, through “Contact Us”.