We care about protecting the personal information of our customers and visitors who use our websites, products or services (collectively, our “Users”). This privacy policy provides details about how your personal information is collected, shared and used by us.

This privacy policy is effective from May 25, 2018

Responsible Person for all matters regarding the European Union’s General Data Protection Regulation 2016/679, or GDPR, is:

Almeida Dohrn Consultoria Ltda.
Av. Getúlio Vargas, 1492, Suite 200
Savassi
Belo Horizonte – MG, 30112-021
Brazil

Information Covered by this Privacy Policy

This privacy policy covers personal information, including any information we collect, use and share from you, as described further below. This privacy policy applies to our website, our services. This privacy policy does not cover how our Users may use or share data that they collect using our services.

When you purchase a Service from us, your personal information will be collected, used, and shared consistent with the provisions of this privacy policy.

Information We Collect From You

In the course of your use of the Services, we obtain the following information about you as described below.

Signing Up for Services; User Information

• Information you provide prior to any registration process, such as your email when you
  provide it to us;
• Information that you provide during any registration process such as your name, company name, email address, phone number, geographic location and industry, when you call or email us (for support or otherwise) or when you use our products or services;

Use of Services, Website Visits and Support

Data relating to your online activity on our websites with respect to our Services, including the following:

• IP address
• Browser type and version
• Geographic location
• Pages you view
• How you got to our Services and any links you click on to leave our Services
• When you update your information, communicate with us, or order new Services
• Metadata about your use and your contacts’ use of our Services and your emails you send (including clicks and opens)
• Your interactions with any videos we offer
• Issues you encounter requiring our support or assistance
• Any device or other method of communication you use to interact with the
  Services

We store this data we collect in a variety of places within our infrastructure, including
system log files, back end databases and analytics systems.

Social Media

• Information from third party social networking sites, including information that social
  networking sites provide to us if you use your credentials at such social networking sites
  to log into some of our Services (such as your name and email address to pre-populate
  our sign-up form).
• The information you allow us to access varies by social networking site, and depends on
  the level of privacy settings you have in place at the social networking site. You can
  control and find out more about these privacy settings at the applicable social networking
  site.

Other Sources

• Information you provide to us at seminars
• Information you provide to us in surveys;
• Information that is publicly available.

How We Use Your Information

We have a legitimate interest in running a successful and efficient business and in providing you with Services and useful content, and we use the information we collect, both on its own and combined with any other information we collect about you, for the following purposes:

• To provide the requested Services to you;
• To provide you with useful content;
• To ensure the proper functioning of our Services
• To offer and improve our Services;
• To provide you with requested information or technical support
• To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);
• To diagnose problems with our servers or our Services;
• In connection with our security and compliance programs;
• To administer our websites;
• To communicate with you;
• To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
• As otherwise described in this privacy policy.

Sharing of Information

We will only share certain personal information:

• With Partners of our network and only after requesting specific permission from our users
• With third party service providers so that they can assist us in servicing you (like IT
  services, tax consultant)
• For legal reasons. if legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, law enforcement authorities and other relevant third parties, such as internet service providers, to conduct an investigation, respond to a third party or law
  enforcement subpoena or court order, bring legal action, prevent harm to others or pursue
  other relief when you or a third party are or may be:
  • violating our terms and conditions of use;
  • causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or
  • violating federal, state, local, or other applicable law.

Further, our partners are prohibited from using your contact information for any purpose beyond those set forth above without your consent.

In the event we collect information from you in connection with an offer that is jointly presented by us and a partner, we will let you know who is collecting the information and whose privacy policy applies, as well as any options you may have regarding use of your information.

Security

The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

Tracking Technologies and Online Advertising

We do not use cookies, web beacons, pixels, tags, scripts and other similar technologies in the course of our business.

Choice/Opt-out

Marketing Communications from Us

EMAIL
You always have the opportunity to opt out of our marketing communications with you or
change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at info@radical-inclusion.com.

Information from Third Parties
To manage the information we receive about you from a social networking site or other third parties (if applicable), you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy policy and the information the third party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our Services.

Retention of Personal Information

We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than five years following the later of (i) the date on which you terminate your use of the Services or (ii) May 25, 2018, unless we are otherwise required by law or regulation to retain your personal information for longer.

Your Rights

Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies,
in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

Access

You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

Portability

You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent and a right to request that we transfer such personal information to another party. We are not responsible for the security of the personal information or its processing once received by the third party.

Correction

You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

Erasure

You may request that we erase the personal information we hold about you in the following
circumstances:

• Where you believe it is no longer necessary for us to hold the personal information;
• We are processing it on the basis of your consent and you wish to withdraw your consent;
• We are processing your data on the basis of our legitimate interest and you object to such processing;
• You no longer wish us to use your data to send you marketing; or
• You believe we are unlawfully processing your data.

Please provide as much detail as possible on your reasons for the request to assist us in
determining whether you have a valid basis for erasure.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:

• You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
• We wish to erase the personal information as the processing we are doing is unlawful but
  you want us to simply restrict the use of that data;
• We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
• You have objected to us processing personal information we hold about you on the basis
  of our legitimate interest and you wish us to stop processing the personal information
  while we determine whether there is an overriding interest in us retaining such personal
  information.

Objection

You have the right to object to our processing of data about you and we will consider your
request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

Third Party Links and Information Collection and Use by Our Users

Some of our Services may provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.

You may also log in to some of our Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you with the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form. For example, if you take advantage of certain of our social media features, such as the Facebook Like button, and widgets, such as the “Share This” button or interactive mini-programs that run on our site, the applicable social networking sites may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly.

Children

Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.

Data Transfer

In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in Dropbox, Mailchimp and Google Suite. All 3 services have are GDPR compliant.

Complaints

In the event that you wish to make a complaint about how we process your personal information, please contact our Data Protection Officer at info@radical-inclusion.comand we will try to deal with your request.

Notification of Changes

We reserve the right to modify this privacy policy at any time, so please review it frequently. If we decide to change this privacy policy in any material way, we will notify you here, by email, or by means of a notice on our website. In all cases, your continued use of any Services constitutes acceptance to any such changes.

Last Modified May 24, 2018

Responsible for content and updating of the Website:

Almeida Dohrn Consultoria Ltda.