Privacy Policy

When you access one of our websites and/or complete any form to contact us, it may be necessary to collect some personal data. Our company cares for and treats all personal data of our users with the full rigor required by law.

We are SPUN MEDIA, and we declare that we follow in this privacy policy everything stipulated by the General Data Protection Law (LGPD) – (Federal Law No. 13.709/2018), General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), the New York Stop Hacks and Improve Electronic Data Security Act (NY SHIELD), and other data protection laws.

To facilitate your understanding, whenever “Spun Media,” “website,” “we,” “us,” or “our” is mentioned here, we refer to the portals belonging to SPUN MEDIA. On the other hand, when “user,” “you,” “your,” or “customer” is used, we refer to the holder of the collected data.

To further facilitate the understanding of our privacy policy, below is a summary of the main information.

Data Processing Agent: SPUN MEDIA LTDA, a private legal entity registered under CNPJ No. 43.629.487/0001-89, with registered office at Rua 20 de Setembro, 334, room 03, Centro, Piratini – RS, CEP: 96.490-000.

Nature of Processed Data: Personal data provided by the user to contact Spun Media; and data automatically collected from the devices the user uses to access one of our websites.

Role in Processing: Predominantly the Controller of the collected personal data.

Purposes as Controller: To enable contact between us and the user, as well as a better browsing experience through Spun Media platforms; to use users’ personal data to offer products and services; for advertising campaigns, sending information, products, discounts, coupons, promotions, invitations, greetings, and event advertisements.

Legal Basis: Based on the data subject’s consent.

Compliance: Storing access log reports, meeting legal and/or tax requirements, among other legal obligations. Legal Basis: Compliance with a legal obligation.

Sharing: Spun Media does not share the data collected by us with third parties without the consent of the data subject. Data sharing occurs between companies belonging to Spun Media, operators, and service providers.

Data Protection: Internal technical measures to ensure the security of the collected data.

Your Rights: The user may at any time, upon formal request, access, rectify, revoke consent, request anonymization, portability, etc., regarding information inherent to the collected data.

After this brief summary, we hope this privacy policy helps you to: (i) understand the reasons that lead us to collect your personal data; (ii) understand when this data will be shared; and (iii) know and understand your rights, options, and power of choice.

Spun Media is committed to always being transparent and indicating the purpose of processing your personal data and, above all, respecting and protecting your consent and privacy.

1 – To whom does the Spun Media Privacy Policy apply?

This privacy policy applies to any person who accesses a Spun Media website or companies belonging to this holding and/or uses the contact form, whether via smartphone, tablet, notebook, computer, or similar devices, regardless of whether they become patients or not.

2 – What data we collect and the purpose of processing

During your navigation on any Spun Media platform, some data may be collected. In this experience, various data are collected in different ways and for different purposes, as detailed below.

2.1 – Personal Data

Username;

E-mail; and

Phone number.

Purpose of processing: This data is collected to respond to the user who used our platform to contact us through the form, as well as to enable the execution of contracted services, correct identification of the user, contact, advertising campaigns, sending information, products, discounts, coupons, promotions, invitations, greetings, and event announcements, etc.

2.2 – Platform Usage Data

Interactions with the Platform;

Date and time of information submission;

Demographic information;

URL information;

Cookie data;

Technical data;

Device type and attributes;

Network connection type;

Language;

Browser;

Operating system.

Purpose of processing: We collect and store this data to maintain records of platform use, which may be used to identify the responsible party, in accordance with the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet) and other legislation involving obligations.

 

3 – With whom can we share the collected data?

To carry out all services provided for in this Privacy Policy, it is necessary for the data collected by us to be shared, on some occasions, with companies belonging to Spun Media, employees and/or partner companies and/or contractors.

3.1 – Spun Media Companies, Employees, Service Providers, and Affiliates

For our services to be performed with maximum effort, we need the support of our employees in various sectors who handle the personal data we collect. Furthermore, when performing any action on the website, when necessary, it will be shared with employees and/or service providers and our branches so they can perform assistance, scheduling, and other necessary services. Another possibility of sharing is with other websites and companies belonging to Spun Media.

3.1.1 – Companies that are part of Spun Media The following companies are part of our business group and use our systems, configurations, and other services and/or are direct partners of Spun Media:

JN Content Mídia Digital LTDA – CNPJ: 42.921.663/0001-99

ND Mídia Digital LTDA – CNPJ: 30.309.478/0001-69

JR Mídia Digital LTDA – CNPJ: 44.211.659/0001-62

Matemática Genial Tecnologia da Informação LTDA – CNPJ: 33.399.553/0001-18

Hub Content Marketing LTDA – CNPJ: 34.199.504/0001-02

DM Network Midia Digital LTDA – CNPJ: 45.918.640/0001-13

Cleverson F. de Lima LTDA – CNPJ: 24.869.977/0001-08

3.2 – Judicial, Governmental, and/or Police Authorities

Spun Media acts collaboratively with the authorities of our country, complying with its legal or regulatory obligations, providing the personal data of platform users to such authorities in the event of a court order or administrative request.

3.3 – Marketing and Remarketing Operators

User data collected through the use of our websites may be processed in marketing and remarketing operations by Spun Media and its companies, or by third parties contracted for this purpose.

3.4 – Potential Buyers

In the event of transactions and/or corporate changes, we may share collected personal data with third-party companies, whether this transaction involves all or part of Spun Media.

3.5 – Other Methods

We may also share collected data in other ways, provided that this method requires the consent of the user to ensure its suitability.

4 – Security and Storage of Collected Personal Data

We are committed to keeping all collected personal data of our users stored securely. This storage is carried out nationally, following all current legislation dealing with the subject.

Furthermore, Spun Media seeks to adopt and always keep up-to-date techniques for protecting the personal data collected through our platform to prevent unauthorized access, loss, fraud, etc., or any inappropriate form of data processing.

However, no platform is 100% secure; therefore, we cannot completely guarantee the security and privacy of all collected data. If you have any suspicion or concern that your data is at risk, please contact us through our support channels for assistance.

Collected personal data will be kept as long as the user is active on our platform. Once this phase is over, we may retain your provided data for the necessary period, respecting current legislation, to conduct audits, comply with legal requirements, regulations, etc.

5 – Cookies and Other Tracking Technologies

We may use technologies such as Cookies, Pixels, Analytics, Web Beacons, and other similar technologies on our platform to improve, facilitate, and/or adapt the platform to the needs and interests of each user.

5.1 – Cookies:

These are small files added to our users’ devices to personalize and improve their experience on the platform. Additionally, these cookies are used to analyze traffic and let us know that the user has browsed certain websites. This technology does not grant access to the user’s devices or collect information that the user decided not to report; only what you chose to inform us is collected.

5.1.1 – Browser Settings You can click “help” within your browser settings to see how to prevent the acceptance of cookies, as well as how to receive notifications when you receive new cookies, disable existing ones, check their expiration date, etc.

Google Chrome | Mozilla Firefox | Safari | Internet Explorer | Microsoft Edge | Opera

5.2 – Pixels:

These are JavaScript codes installed directly on the platform with the aim of collecting more information about user behavior, identifying access patterns, interests, purchased products, navigation, product targeting, and more.

5.3 – Analysis Tools:

This technology allows mapping the visiting audience on web pages to identify certain user behaviors on websites and web servers.

5.4 – Web Beacon:

This technology allows mapping the visiting audience on web pages to identify certain user behaviors on websites and web servers.

6 – Third-Party Advertisements

Spun Media uses third-party advertising services, such as Google AdSense and Google Ad Exchange (AdX). To serve these ads, we use a DoubleClick cookie to show more relevant ads on the web and limit the number of times a certain ad is shown. For more information about these ads, please refer to their official websites and privacy policies

Google

7 – Rights of the Holder of Collected Personal Data

In accordance with current legislation, Spun Media’s priority is to guarantee all its users the following rights:

7.1 – Confirmation of the existence of processing;

7.2 – Access to data;

7.3 – Correction of incomplete, inaccurate, or outdated data;

7.4 – Anonymization, blocking, or deletion of unnecessary, excessive, or processed data that does not comply with the provisions of the Law;

7.5 – Portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;

7.6 – Deletion of personal data processed with the consent of the holder;

7.7 – Information about public and private entities with which the controller shared data;

7.8 – Information about the possibility of not providing consent and the consequences of refusal;

7.9 – Revocation of consent.

These can be requested at any time; simply contact us using one of our contact methods available in point 11 of this Privacy Policy. All requests will be managed free of charge and will be subject to a prior analysis of your identity and the feasibility of the request.

8 – Children and Adolescents

Our platform is not intended for persons under 18 years of age. It must be used by adults. The websites of Spun Media and its companies do not collect data from children and adolescents; therefore, they must refrain from providing information and using our platform. If the collection of personal data from minors is detected, we will delete this data in accordance with the law.

9 – Retention and Deletion of Collected Personal Data

We will retain the collected data for the time necessary to complete the purposes for which they are processed or for the period necessary to satisfy legally required retention requirements. The retention period for collected personal data depends on the purpose for which they were collected and used in accordance with current laws. If requested, we will delete personal data in a timely manner, without identifying you, except in cases where retention is legally permitted or mandatory, such as legal, tax, or accounting audit obligations, among others.

10 – Changes to the Privacy Policy

We always seek the best for our users, customers, and patients; therefore, from time to time, Spun Media may change the Privacy Policy. However, we value transparency, so we will make visible and appropriate communication when there is any change in this policy, whether by e-mail or any other similar or different means.

11 – Contact Us

You can speak with the party responsible for data processing via e-mail: [email protected] or our contact page whenever you have any questions or need to contact our team.

It is important to note and check that this Privacy Policy is the most up-to-date while browsing our platform. It is a great pleasure for Spun Media to respond to all contacts.

Last update: May 30, 2023 SPUN MEDIA