CWI Privacy Policy 

1. General information and definitions

CWI values ​​the privacy of its users and created this Privacy Policy to demonstrate its commitment to protecting your privacy and personal data, in accordance with the General Data Protection Law and other laws on the subject, as well as describing how your privacy is protected by CWI when collecting, processing and storing your personal information.

1.1 Definitions

Users: all natural persons who will use or visit the Website(s) and/or Application(s), over 16 (sixteen) years of age or emancipated and fully capable of carrying out acts of civil life or those absolutely or relatively disabled people duly represented or assisted.

Personal Data: means any information provided and/or collected by CWI, by any means, even if public, that: (I) identifies, or that, when used in combination with other information processed by CWI, identifies an individual; or (II) through which identification or contact information for a natural person can be derived. Personal Data may be in any media or format, including electronic or computerized records, as well as paper-based files. Personal Data, however, does not include business telephone number, business cell phone number, business address, business email.

Purpose: the objective, the purpose that CWI wishes to achieve from each act of processing personal information.

Necessity: justification why it is strictly necessary to collect personal data, to achieve the purpose, avoiding excessive collection.

Legal basis: legal basis that makes the processing of personal data for a certain prior purpose by CWI legitimate.

Consent: express and unequivocal authorization given by the User holding the personal data for CWI to process their personal data for a previously described purpose, in which the necessary legal basis for the act requires the holder's express authorization.

This policy applies, in general, to all Users and potential Users of services offered by CWI, including Users of websites or other means operated by CWI and summarizes how CWI may collect, produce, receive, classify, use, access, reproduce , transmit, distribute, process, archive, store, delete, evaluate or control information, modify, communicate, transfer, disseminate or extract collected data, including personally identifiable information, in accordance with applicable legal bases and all laws privacy and data protection regulations in force.

When accessing and/or using CWI's forms, applications or online service platforms, the User declares to be at least 16 (sixteen) years old and to have full and express capacity to accept the terms and conditions of this Privacy Policy and the Consent Form for all legal purposes.

If the User does not fit the description above and/or does not agree, even in part, with the terms and conditions contained in this Privacy Policy, he/she should not access and/or use the services offered by CWI, as well as the websites and services operated by it.

2. Collection and uses of personal information

The User is aware that he/she provides information knowingly and voluntarily through forms/etc, or through the websites/systems operated by CWI.

When the User registers and/or fills out forms offered by CWI, including on the websites/systems operated by it, certain Personal Data requested will be kept confidential and will only be used for the purpose that motivated the registration, according to the Table of Purposes.

3. Sharing and processing of personal information

CWI will not make Personal Data collected on its websites available to email list brokers without your express consent.

CWI may disclose the Personal Data collected to third parties, in the following situations and within the limits required and authorized by Law:

1. With companies and individuals contracted to carry out certain activities and services on behalf of CWI;

2. With suppliers and partners to provide services contracted with CWI (such as information technology, accounting, among others);

3. For administrative purposes such as: research, planning, service development, security and risk management;

4. When necessary as a result of legal obligation, determination of competent authority, or court decision.

In the event of sharing Personal Data with third parties, all subjects mentioned in items 1 to 4 must use the Personal Data shared in a consistent manner and in accordance with the purposes for which they were collected (or to which the User previously consented) and as determined by this Privacy Policy, other website or country privacy statements, and all applicable privacy and data protection laws.

4. Legal reasons for disclosing your data

In certain circumstances, CWI 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 a court order or judicial intimation, or in the good faith belief that such action is necessary to:

1. Comply with legislation that requires such disclosure;

2. Investigate, prevent, or take action regarding suspected or actual illegal activities or to cooperate with public agencies or to protect national security;

3. Execution of your contracts;

4. Investigate and defend against any third party claims or allegations;

5. Protect the security or integrity of the services (for example, sharing with companies that are experiencing similar threats);

6. Exercise or protect the rights, property and safety of CWI and its related companies;

7. Protect the rights and personal safety of its employees, users or the public;

8. In the event of sale, purchase, merger, reorganization, liquidation or dissolution of CWI.

CWI will inform the respective Users about any legal demands that result in the disclosure of personal information, in accordance with what was set out in item 4, unless such notification is prohibited by law or prohibited by court order or, even, if the request is emergency. CWI may challenge these demands if it finds the requests to be excessive, vague, or made by incompetent authorities.

5. Security of personal information

All Personal Data will be stored in the CWI database or in a database maintained “in the cloud” by service providers contracted by CWI, which are duly in accordance with current data legislation.

CWI and its suppliers use various security procedures to protect the confidentiality, security and integrity of your Personal Data, preventing the occurrence of possible damages due to the data processing.

Although CWI 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 are no guarantees that the information will not be accessed, disclosed , altered or destroyed by violation of any of the physical, technical or administrative protections.

6. Data retention 

CWI retains all data provided, including Personal Data, as long as the User's registration is active and as necessary to provide its services.

CWI will retain your Personal Data and keep your data stored until any request for deletion, or for a period of 2 (years).

CWI may keep your Personal Data after receiving your request for deletion or after a period of 2 (two) years if necessary to comply with legal obligations, resolve disputes, maintain security, prevent fraud and abuse and ensure compliance with contracts.

7. Legal basis for processing

CWI only processes Personal Data in situations where it is legally authorized or with the User's express and unequivocal consent.

As described in this Policy, CWI has legal bases to collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, eliminate, evaluate or control information, modify, communicate, transfer, disseminate or extract data about the User.

The legal bases include your consent (collected expressly and unequivocally in the Consent Form), contracts and preliminary contractual procedures (where processing is necessary to enter into a contract with the User) and legitimate interests, as long as such processing does not violate your rights and freedoms, as can be seen in the Table of Purposes.

Such interests include protecting the User and CWI from threats, complying with applicable legislation, the regular exercise of rights in judicial, administrative or arbitration proceedings, enabling the performance or administration of business, including quality control, reports and services offered, managing business transactions, understand and improve business and customer relationships, and enable users to find economic opportunities.

The User has the right to deny or withdraw the consent provided to CWI, when this is the legal basis for processing personal data, and CWI may end the provision of its services to this user in the event of such a request.

If you have questions about the legal bases for collecting, processing and storing your personal data, please contact CWI in accordance with item 10 of this document.

8. Right to access and control your personal data

CWI offers the User several options of what to do with their Personal Data collected, processed and stored, including its deletion and/or correction. The User can:

Delete data: the User may request the deletion of some of their Personal Data (for example, if it is no longer necessary to provide the services to them).

Change or correct data: the User can edit or request the editing of some of their Personal Data. The User may also request updates, changes or corrections to their data in certain cases, especially if they are incorrect.

Place objections, limits or restrictions on the use of data: the User may request that we stop using all or some of their Personal Data (for example, if we do not have the right to continue using it), or limit our use of such data (for example, if your Personal Data is incorrect or stored illegally), highlighting that CWI may process Personal Data in accordance with the legal bases listed in the Table of Purposes.

The User has the right to access or take his data: the User can request a copy of his Personal Data and the data that the User has provided in a readable format in printed or electronic form.

The User may make the requests listed above by contacting CWI, and these requests will be considered in accordance with applicable laws.

The execution period for requests made directly to CWI, as defined in item 10, will be up to 15 days, counting from the date of request made by the user.

9. Policy revisions

If CWI modifies this Privacy Policy, such changes will be visibly published on the CWI website. This Policy is valid from 01/08/2020. If the User has any questions regarding the website's privacy policies, please contact CWI, as described in item 10.

10. Contact 

The user may contact CWI via email at [email protected] (DPO: Edgar Fernandes), or via the CWI contact form.

11. Mediation and election forum

This policy is subject to the Law of the Federative Republic of Brazil and the Porto Alegre District Court is competent to resolve any dispute in relation to it, if direct conciliation between the parties is not possible, in accordance with the seventh paragraph of art. 52 of the Law.

CATEGORY OF PERSONAL DATA	FINALITY	LEGAL BASE	LEGAL BASIS
Full name, Email, CPF, Date of Birth, City, State, Telephone, Person with Disability (PWD) identification, PWD Category, Attached CV, Social Networks	To be able to apply for job opportunities, CWI will need the user to provide this data to participate in our selection processes.	Consent.	I agree to provide my Full Name, Email, CPF, Date of Birth, City, State, Personal telephone number, Person with Disability (PWD) identification, PWD Category, Attached CV and Social Networks to apply for job opportunities. I am aware that my data provided will be used internally for CWI professional evaluation. In specific cases, these Data may also be shared with third parties, as per item 3 above of this document.
Full name, Email and Company	To be able to receive promotional material from CWI, the user will need to provide their Full Name, Email and which Company they work for. CWI will send email marketing tousers who provide this information. The Personal Data collected will not be used to send any type of SPAM.	Consent.	I agree to provide my full name, Email and which Company I work for to access the material available on the website, in addition to receiving the CWI Newsletter and other marketing emails. I am aware that my data provided will be used internally for promotional purposes by CWI and I agree with receiving emails from CWI.
Full name, Email and Telephone	If the User wants to enter in contact with CWI through the “Contact Us” area available on the website, or wish to participate inevent feedback forms, CWI will need to collect Name, Email and Telephone of the user. The Personal Data collected will not be usedfor shipping any typeof SPAM.	Consent.	I agree to provide my Full name, Email and Telephone so that CWI can contact me, as well as I am aware that this data will be used by CWI's Marketing and Commercial areas for sending emails. Furthermore, I agree to provide feedback in online surveys, which CWI reserves the right to carry out the crossinguser data with our internal database of talents, for the purposes of interacting with potential candidates for job opportunities.
Full Name, Date of Birth, City, Email, Telephone, Social Networks, Educational Institution, Course, Completion forecast, What days are you studying, CV Attached	CWI will need the User to provide the data enteredin the personal data category. Collected data for selection processfor the CWI Crescer training program. The Personal Data collected will not be used to send any type of SPAM.	Consent.	I agree to provide my Full name, Date of Birth, City, Email, Telephone, Social Networks, Educational Institution, Course, Expected completion date, which days you are studying and Attached CV to apply for the Training ProgramCWI Crescer. I am aware that my data provided will be used internally for CWI's professional assessment.