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We, Reclame AQUI ("Reclame AQUI" or "we"), are a company that offers various communication channels with the aim of improving the relationship between suppliers, Companies, and users, in a transparent and collaborative way. Reclame AQUI is the owner of the RA Reviews Platform, software that sends, collects, and moderates reviews and guarantees the veracity of the data received by the Licensee and consumer.
We have developed this document in the interest of privacy and data protection for our users ("You") who use the RA Reviews Platform. When you access or interact with our Platform, we may store some information about you ("Data" or "Personal Data"). We have prepared this Privacy Policy ("Policy") to clarify how your Personal Data may be collected, used, shared, and stored by us.
From the moment you access or interact with the Platform, you acknowledge the way your Personal Data is processed for each of the purposes described herein, as applicable. Therefore, you will be aware of and in full agreement with how we will use your information and your Personal Data. If you do not agree with this Policy, please do not continue using the RA Reviews Platform.
In order to facilitate understanding, we have divided the Policy as follows:
1. What types of data does Reclame AQUI collect? 2. How do we use cookies? 2.1 What is a cookie? 2.2 Why do we use cookies? 3. With whom does Reclame AQUI share your data? 4. What are the rights of data subjects? 5. How long will the data be stored? 6. How does information security work at Reclame AQUI? 7. Does Reclame AQUI transfer personal data internationally? 8. How to contact Reclame AQUI? 9. Updates to this Policy
1. What types of data does Reclame AQUI collect?
The amount and type of information collected by Reclame AQUI vary according to your use of the RA Reviews Platform.
If you are a user of our Platform and access it to make or manage reviews, we will use some of your Personal Data as presented below, based on the respective legal bases:
| Purpose | Personal Data | Legal Basis |
|---|---|---|
| Access to the website and/or platform | IP address, date and time of access, cookies, referral source, browser type, visit duration, and visited pages | Legal Obligation and Legitimate Interest |
| Submit a review (via email, WhatsApp, or push from the RA Reviews App) | Full name, email, phone number (WhatsApp), CPF, product image (optional), order number, estimated delivery date, product ID, product name, and tags included by customers | Contract Execution and Consent |
| Security and validation of collected data | Geolocation and browser and operating system identification information | Legitimate Interest |
| Support (via phone, social media, or contact form) | Full name, phone number, job position, and email | Legitimate Interest |
| Company registration on the platform | Name, email, and credit card details (exclusively for purchases via checkout) | Legal basis defined by the company |
| Sending transactional emails | Full name and email | Legitimate Interest |
| "Reliable Reviews" | Full name and email | Consent |
[1] It is important to mention that Reclame AQUI does not control how the information collected by Companies is handled. This data belongs to the Companies contracting RA Reviews, who disclose and protect it according to their respective privacy policies. In this sense, we recommend that the final consumer carefully read the Privacy Policy of the Company to which they are linked.
[2] If you have any questions about how your personal data will be handled, we recommend that you contact the Company that is offering the services to you.
[3] Regarding data processing for the "Reliable Reviews" process, Reclame AQUI will act as an independent Controller and may publish your review on its own website with reduced identification.
2. How do we use cookies?
2.1 What is a cookie?
Cookies are small text files stored in your browser or device. Cookies allow us to recognize your preferences to, for example, adapt our Platform to your specific needs.
It is through a cookie, for example, that we keep your account logged in for subsequent visits to our Platform, even when you close your browser.
Cookies generally have an expiration date. Some cookies are automatically deleted when you close your browser (session cookies), while others may be stored longer on your device until manually deleted (persistent cookies).
2.2 Why do we use cookies?
The RA Reviews platform uses the following types of cookies:
- Essential cookies: These are fundamental for our Platform to function correctly, authenticating logins, for example. Therefore, it is not possible to refuse these cookies if you want to visit our Platform.
- Advertising cookies: These are used on our Platform to monitor users' online activity. They record your interests and behaviors, allowing us to display targeted and personalized ads according to your interests.
- Analysis and personalization cookies: These improve the content of our Platform and your user experience. These cookies automatically collect certain Personal Data to provide us with information about how our Platform is being used, identifying, for example, how many times a certain page has been visited.
- Performance and functionality cookies: These aim to improve the performance and functionality of our Platform for the user. They can remember your preferences, such as chosen language and region, so you don't have to set them again.
You can set your preferences directly in your browser. For further explanations on how to configure the use of cookies in your browser, check the platform of the browser developer you use, such as:
It is important to clarify that Reclame AQUI is not responsible for the use of cookies by third parties.
Be aware that cookies placed by third parties may eventually continue to monitor your online activities even after you have left our Platform, so it is recommended that you clear your browsing data regularly.
3. With whom does Reclame AQUI share your data?
By offering online platforms, Reclame AQUI may operate in conjunction with other companies in a wide range of activities, including hosting, data storage, analytics, search engine indexing, among others. Therefore, we reserve the right to share your information, including Personal Data, as indicated below. We will adopt, whenever possible, mechanisms for anonymizing and pseudonymizing this Data and will establish strict clauses in our contracts, aiming to preserve your privacy as much as possible.
We may share your Personal Data in the following cases:
- Evaluated Companies: Whenever you carry out an evaluation of a product or company through the RA Reviews Platform, we will share the Data provided with the respective Company that originated the evaluation. The evaluation is part of the acquisition cycle of the products and/or services acquired by you, and we act as a supplier to this Company. We strive to protect the privacy of your Personal Data, but unfortunately we cannot guarantee the correct handling of Personal Data by third parties, who use, disclose, and protect Personal Data according to their respective privacy policies.
- Partners of the Evaluated Companies: It is possible that the Company chooses to share reviews with partners of its choice, such as, but not limited to: Reclame Aqui Website, Google Shopping, companies belonging to the same economic group, and/or other commercial partners, with the aim of disclosing the evaluations in other media.
- Our Suppliers: We have a number of suppliers that we need to hire to operate our Platform and offer our services, and some of them may process the Personal Data we collect on our behalf. For example, we use hosting and data storage services and hire market research services to improve your experience on our Platform. We strive to protect the privacy of your Personal Data, but unfortunately we cannot guarantee the correct handling of Personal Data by third parties, who use, disclose, and protect Personal Data according to their respective privacy policies.
- To safeguard and protect Reclame AQUI's rights: Reclame AQUI reserves the right to access, read, preserve, and provide any Data and information about you, including your interactions, if necessary to (i) comply with a legal obligation or court order, (ii) enforce or apply our Terms of Use and other agreements and/or contracts, or (iii) protect the rights, property, or safety of Reclame AQUI, as well as our employees and/or other users. For example, we may share certain information with the Public Ministry and/or the Civil Police when requested by these bodies, only to the extent expressly requested.
4. What are the rights of data subjects?
You can always choose not to disclose your Personal Data to us, but keep in mind that this Data may be necessary to enjoy some of the features available on our Platform.Regardless, you will always have rights regarding the privacy and protection of your Personal Data, and in addition to caring about the security of this Data, we also care that you have access to and knowledge of all your rights regarding the processing of your Personal Data.
In this sense, we present below a brief explanation and examples of some of these rights:
| Right | Concept |
|---|---|
| Request access to your Personal Data | This right allows you to request and receive a copy of your Personal Data that we hold about you. |
| Request rectification of your Personal Data | This right allows you, at any time, to request the correction and/or rectification of your Personal Data if you identify that some of it is incorrect. However, to effect this correction, we may need to check the validity of the Data you provide us. |
| Request deletion or cancellation of your Personal Data | This right allows you to request the deletion of your Personal Data from our database. All collected Data will be deleted from our servers when you request it or when it is no longer necessary or relevant to our services, unless there is any other reason for its maintenance, such as any legal obligation to retain Data or the need to preserve it to safeguard Reclame AQUI's rights. |
| Request portability | We will provide you, or third parties you choose, with your Personal Data in a structured and interoperable format. |
| Right to withdraw consent at any time | You have the right to withdraw your consent; however, this will not affect the legality of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services. If this is the case, we will notify you when this occurs. |
| Right to review automated decisions | You also have the right to request a review of decisions made solely based on automated processing of your Personal Data that affect your interests. |
We may need to request specific information from you to help us confirm your identity and guarantee your right to access your Personal Data (or exercise your other rights). This is a security measure to ensure that Personal Data is not disclosed to anyone who does not have the right to receive it. We may also contact you for more information regarding your request in order to expedite our response.
Confirmation of the existence of or access to your data will be made available:
- When you are the owner of the personal data, for a complete request or with multiple requests, the deadline for delivery of the declaration is 15 (fifteen) days from your request. - When you are the Company, the data is available for access in the logged-in area.
5. How long will the data be stored?
We will keep your Personal Data only for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of complying with any legal, contractual, accountability, or request obligations from competent authorities.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purpose of processing your Personal Data and whether we can achieve such purposes through other means, and the applicable legal requirements.
After all the purposes that justified the processing of Data about you on our Platform have ended, this Data will be deleted.
6. How does Reclame AQUI protect your data?
Reclame AQUI takes technical, administrative, and organizational measures to protect your Personal Data against unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication, or any form of inappropriate or unlawful processing.
In order to guarantee the security of your Personal Data on our Platform, we adopt the best information security practices available, including:
- Use of SSL certificate in the traffic of Personal Data via the internet. - Use of standard and market methods for the security of your collected Data, such as management and control of access to the database and password encryption. - Protection against unauthorized access to your systems. - Adoption of preventive procedures against information security incidents.
We strive to protect the privacy of your account and Personal Data that we keep in our records, but unfortunately we cannot guarantee complete security. Unauthorized entry or use of an account, hardware or software failure, and other factors may compromise the security of your Personal Data at any time, so please help us maintain a safe environment for everyone.
In addition to adopting good security practices in relation to your account and your Data, if you identify or become aware of something that compromises the security of your Data, please contact us.
7. Does Reclame AQUI transfer personal data internationally?
Reclame AQUI is headquartered in Brazil, and the Data we collect is governed by Brazilian law. It is hosted on servers of suppliers located mainly in the USA, Brazil, and Chile.
By accessing the RA Reviews Platform and sharing a review with us, we may share your review with the Companies being reviewed, including their affiliates, subsidiaries, companies of the same economic group, and/or other commercial partners that may be located outside Brazil.
Therefore, by accessing or using our Platform and providing Personal Data to us, you are aware of the processing and transfer of such Data to Brazil and other countries. This Data may be subject to local legislation and relevant rules.
8. How to contact Reclame AQUI?
If you have questions about how we use your Data, want to make comments or suggestions related to this Policy, or believe that your Personal Data has been used in a manner incompatible with this Privacy Policy or with your choices as the owner of this Personal Data, contact us through our Privacy Form..
In addition, we have appointed a Data Protection Officer (DPO) as described below:
- DPO (Encarregado): Baptista Luz Advogados
- Responsible: Fernando Bousso
- Address for correspondence: Praça General Gentil Falcão, 108, 16º andar, Cidade Monções, São Paulo/SP, CEP 04.571-150
You can ask our team your privacy questions through our Contact Us form.
9. Updates to this Policy
As we are always seeking to improve our Platform, this Policy may undergo updates, aiming to provide you with more security, convenience, and increasingly improve your experience. That is why we recommend that you access our Policy periodically so that you are aware of the changes. To make it easier, we indicate the date of the last update at the end of the document.
Last Updated: December 17, 2024.