(I) The solutions contained in the WINPULSE NETWORK PLATFORM (or simply "PLATFORM ") are made available by WINPULSE NETWORK PLATAFORMA DE SERVIÇOS LTDA, a legal entity of private law, registered with CNPJ/MF under number 39.694.123/0001-05, headquartered in Porto Xavier/RS - Brazil, at Rua Oswaldo Cruz, 596 - Centro – Zip Code 98.995-000;
(III) The official language of this POLITICS is the Portuguese. Any version in another language is a courtesy translation. In the event of a conflict due to interpretation, the Portuguese version shall prevail for the personal data processed by WINPULSE NETWORK.
Any person who accesses the PLATFORM is considered a USER, regardless of whether or not he / she has registered. However, registration and personal data are only requested from registered USERS, which may be PROPRIETARIES, VISUALIZERS, PARTICIPANTS or ACQUIRERS.
First, it is important to emphasize that to WINPULSE NETWORK is essential to collect, store and process the personal data obtained from USERS, to enable the provision of the services offered through its PLATFORM. By using the PLATFORM, the USER agreesto this POLICY expressly and unequivocally.
The USER is aware and agrees that it is his / her responsibility to provide true, accurate, current, and complete information when registering for access to the PLATFORM. We remind that the indication of incomplete or false data is a crime typified by law and may result in severe punishments to those who provide it.
The data collected by WINPULSE NETWORK will be stored in secure databases, within best practices, with restricted access only to employees and authorized persons with the appropriate credentials, who are obliged to maintain the confidentiality of the information and not use it improperly.
WINPULSE NETWORK may store and process the Personal Data collected and other information collected on a server located in Brazil or abroad.
Each USER has control over the Registration Data contained in the profile created on the PLATFORM, being able to access and change them using their login and password. We remind that the login and password are individual being the password known only by the USER himself, who should ensure the confidentiality of this data. WINPULSE NETWORK is not responsible for the way this data is used by the USER.
The WINPULSE NETWORK PLATFORM has the principle of collecting the minimum of mandatory information from the USER but allows the USER to provide other information that he deems relevant to make up his Personal Page, which will be accessible to other USERS, as detailed below.
The goal of having a Personal Page is to give credibility to the relationships between USERS through the PLATFORM, allowing to include relevant information, such as their skills and professional experiences, as well as other external means of contact and social networks. The Personal Page will be fully editable by the USER through the "Profile" menu and must contain minimum information for the maintenance of registration, such as Name, Username, and e-mail.
In addition to the Personal Page the USER will be able to create initiatives highlighting their professional services, which will be available on the Internet, will be fully responsible and fully editable by its PROPRIETARY
We only request registration and personal data of a person empowered to practice all acts of civil life (over 18 years of age, or regularly emancipated). If we become aware that we collected personal data of a minor under 18 years and not emancipated, we will block the respective account created on the PLATFORM and delete the personal data, only being able to keep personal data that aim to prevent further attempt to register.
Mandatory Registration Data:(a) Username; (b) Full name; (c) email; (d) Password; (e) Telephone; (f) CPF / CNPJ for Brazilians; (g) address for Brazilians;
Additional Non-Mandatory Data: (a) professional identity; (b) address for nonBrazilians; (c) presentation; (d) professional skills or products; (e) social networks (LinkedIn and Instagram); (f) website; (g) WhatsApp; (h) photo;
Payment Data: (a) PayPal API credentials; (b) current account number; (c) tax identification number for non-Brazilians; (d) other necessary information, such as for the case of international transfer, as requested by the contracted entity and regulatory bodies;
Activity Data: (a) sales made through the PLATFORM; (b) Receipts for sales of CONTENT and individual access to Initiatives;
Reviews: (a) USER reviews through their Personal Page; (b) evaluations of the Initiatives produced by the PROPRIETARY;
Additional Evidence: (a) proof of student regularity; (b) proof of majority; (c) other professional or student vouchers;
Mandatory Registration Data, Additional Non-Mandatory Data, and Payment Data make up the Registration Data.
The Personal Page comprises the Assessments, Mandatory Registration Data and Additional Non-Mandatory Data, except the telephone, address and CPF / CNPJ, which are not disclosed on the Personal Page.
Some payment data will only be requested for the specific action, such as transferring amounts to the USER's account and may be kept in the WINPULSE NETWORK database.
Retention Period: All USERS' personal data processed as provided in this POLICY will be kept by WINPULSE NETWORK for as long as necessary for their purposes. We may also retain information as required by law or regulation or for the regular exercise of rights, or in circumstances where there is a legitimate purpose of WINPULSE NETWORK or third parties.
Deletion Requests: The USER may delete at any time the personal data with the WINPULSE NETWORK PLATFORM, through the menu "Profile”, however, it is necessary to keep the name, account name, email, and telephone number, which will remain registered even if the account is inactive. This minimum information will be accessible to third parties (except the phone) with whom he / she has already been in contact via chat. If he / she does not want new USERS to have access to his / her Personal Page, the USER should also delete all his / her Initiatives on the PLATFORM.
WINPULSE NETWORK may share the USERS’ personal data with third parties, as described in the table below:
|Shared data||With whom?|
|Registration Data, Activity Data, Evaluations and Additional Vouchers||Companies and employees of the same economic group of WINPULSE NETWORK||➢ Provision of the services offered by PLATAFORM
➢ Improvement of the platform's functionalities and the services provided by WINPULSE NETWORK
|Mandatory Data and Address||PROPRIETARY of a Content or Initiative acquired individually||➢ Issuance of receipt and invoice
➢ Contact for support
|Mandatory data and payment data||Financial institutions and PayPal||➢ Process payments made through the PLATFORM
for the purchase of Content
➢ Sending confirmation of the purchase made via PLATFORM
➢ Allow payment to the USER who sold using the platform's credentials
|Registration data and Activity Data||Judicial or governmental authorities||➢ For compliance with requests made by judicial or governmental authorities, as provided by applicable law or regulations|
|Registration Data, and Activity Data||Service Providers||
|Personal Page||All registered USERS, through a created INITIATIVE, and USERS with whom he / she keep contact via chat||➢ Allow the identification of USERS from other
external means, reduce risks and give credibility
to relationships between USERS;
➢ Allow presentation, personal and professional introduction of the USER
➢ Allow communication and feedback between USERS
Rights and Warranties: the USER has rights and guarantees in relation to his / her personal data. We provide mechanisms, detailed below, so that USERS have clarity and transparency in the exercise of their rights. Whenever necessary, our team will be ready to evaluate any requests.
Rights Provided for in the LGPD:pursuant to the General Data Protection Act (Law
13.709/2018 –) ("LGPD"), the USER is entitled to:
Additional Information: Before we respond to a request to exercise the rights mentioned above, we may ask you to provide us with some information to confirm your identity.
Positioning: We are against any practice that promotes SPAM of any kind and we are committed to ensuring that the messages sent by the PLATFORM are always of interest or importance to the respective recipients.
Data Storage: The personal data collected by WINPULSE NETWORK will be stored in secure databases, within best practices, with restricted access only to employees with the appropriate credentials, who are obliged to maintain the confidentiality of the information and not use it improperly.
Questions about the POLICY or Your Personal Data: If after reading this POLICY the USER has any questions or want to submit any requests regarding his /her personal data, he / she can contact our data security team via email email@example.com
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