1. INTRODUCTION
1.1 Welcome to the Puji Service Website, managed by RJ Brazil LTDA (“Puji”), registered with CNPJ under nº 30117085000153, and its affiliates (individually and collectively, "Puji", "we", "we" or "our") . Puji takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of the Puji website and mobile application (the "Platform") (We refer to the Platform and the services we provide as described on our Platform collectively as the “Services”). The term “Users” refers to the user who has registered an account with Puji to use the Services, whether buyers or sellers (individually or collectively “Users”, “User”, “you” or “your”) We recognize the importance of data personal data you have entrusted to us and we believe it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy ("Privacy Policy" or "Policy") is designed to help you understand how we collect, use, disclose and/or process the personal data you have provided to us and/or we hold about you, now or in the future. future, as well as helping you make an informed decision before providing us with your personal data. 1.2 Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access. Common examples of Personal data may include name, identification number and contact information.
1.3 By using the Services, registering an account with us, visiting our Platform or accessing the Services, you acknowledge and agree that you accept the practices, requirements and/or policies described in this Privacy Policy and you hereby consent to our collection, use , disclose and/or process your personal data as described here. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will notify you by posting these changes or the amended Privacy Policy on our Platform. We reserve the right to change this Privacy Policy at any time. To the maximum extent permitted by applicable legislation, the act of continuing to use the Services or Platform, including placing purchase orders, will be considered your acknowledgment and agreement with the changes implemented in this Privacy Policy.
1.4 This Privacy Policy will be applied in conjunction with other regulations, notifications, contractual clauses, consent clauses applicable to the collection, storage and/or processing of your personal data by Puji and will not override said notifications, regulations or clauses unless expressly provided by Puji in this regard.
1.5 This Privacy Policy applies to all users of the Platform and services provided by Puji, including buyers and sellers, unless expressly provided otherwise by Puji.
2. WHEN WILL Puji COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
when you register and/or use our Services or Platform, or open an account with us;
when you submit any form, including, without limitation, registration forms or other forms relating to any of our products and services, whether online or via a physical form;
when you enter into any contract or provide other documentation or information regarding your interactions with us or when you use our products and services;
when you interact with us, such as telephone calls (which may be recorded), letters, faxes, in-person meetings, social media platforms and emails, including when you actively interact with our customer service and support services;
when you use our electronic services, or interact with us through our application or use services on our Platform. This includes, without limitation, through cookies that we may place when you interact with our application or website;
when you grant permission on your device to share information with our applications or Platform;
when you carry out transactions through our Services;
when you provide us with feedback or complaints;
when you enter a competition; or
when you submit your personal data to us for any reason.
The above is not intended to be exhaustive and sets out some common examples of when personal data may be collected about you.
3. WHAT PERSONAL DATA WILL Puji COLLECT?
3.1 The personal data that Puji may collect includes, among others:
name;
email address;
date of birth;
billing or shipping address;
bank account and payment information;
phone number;
Fri;
information sent to or associated with the device(s) used to access our Services or Platform;
Information about your internet network, as well as personal accounts and accounts with which you have interacted;
Recordings and files of photos, audios or videos;
Identification documents issued by competent public authorities and/or other information required due to our audits, know-your-customer process, verification and validation of user identity, as well as for fraud prevention and anti-money laundering processes;
advertising and communications data, such as your preferences regarding receiving advertising from us or third parties, your communication preferences, communication history with us, our service providers and other third parties;
service usage and transactional data, including details about your searches, requests, advertising and content with which you interact on the Platform and other products and services related to you;
locationdata;
any other information about you when you sign up to use our Services or Platform and when you use the Services or Platform, as well as information relating to how you use our Services or Platform; It is
aggregated data about the content the User engages with.
3.2 You agree not to submit any inaccurate or misleading information to us, and you agree to inform us of any inaccuracies or changes to that information. We reserve the right, in our sole discretion, to require additional documentation to verify the information you provide.
3.3 If you sign up as a user of our Platform using your social media account ("Social Media Account"), link your Puji account to your social media account, or use any social media feature of Puji, we may access information about you that you have voluntarily provided to the provider of your social media account in accordance with that provider's policies, and we will manage and use that personal data in accordance with this Policy at all times.
3.4 If you do not want us to collect the above-mentioned information/personal data, you can opt-out at any time by notifying our Data Protection Officer in writing. More information about opting out can be found in the section below titled "How can you withdraw consent, remove, request access to, or modify the information you have provided to us?" Please note, however, that deleting or withdrawing your consent to collect, use or process your personal data may affect your use of the Services and the Platform. For example, disabling the collection of location information will cause your location-based features to be disabled.
4. COLLECTION OF OTHER DATA
4.1 As with most websites and mobile applications, your device sends information that may include data about you that is recorded by a web server when you browse our Platform. This generally includes, without limitation, the device's IP address, computer/mobile device operating system and browser type, mobile device type, mobile device characteristics, unique device identifier (UDID) or device identifier. mobile equipment (MEID) of your mobile device, the address of a referring website (if any), the pages you visit on our website and mobile applications and the times of your visit, and sometimes a "cookie" ( which you can disable using your browser preferences) to help the website remember your last visit. If you are logged in, this information will be associated with your personal account. Information is also included in anonymous statistics to allow us to understand how visitors use our website.
4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi etc. We collect, use, disclose and/or process this information for one or more purposes, including, without limitation, the location-based services you request or to provide relevant content to you based on your location or to enable you to share your location with other Users as part of the services on our mobile applications. For most mobile devices, you can withdraw your permission for us to obtain this information about your location through your device settings. If you have questions about how to disable location services on your mobile device, contact your mobile device service provider or device manufacturer.
4.3 When you view pages on our website or mobile application, as well as when you watch content and advertisements, advertising and access some software on our Platform or through the use of our Services, most of the same information mentioned above is sent to Puji ( including, without limitation, IP address, operating system, etc.); however, instead of page views, your device will send us information about the content, advertisement viewed/or software installed through the Services and the Platform and the respective time they were accessed.
5. COOKIES
5.1 From time to time, Puji or its authorized service providers and partners may use "cookies" or other resources to allow third parties to collect or share information regarding your use of the Services or the Platform. It is precisely these features that will help us improve our Platform and the Services we offer, help us offer new services and resources and/or allow us, as well as our advertising and advertising partners to offer more relevant content to you, including through remarketing . "Cookies" are identifiers that we store on your computer or mobile device, record data about your computer or device, how and when the Services or Platform are used or visited, by how many people and other activities on our Platform. We may link cookie information to personal data. Cookies also link information about the items you select for purchase and the web pages you view. This information is used to track your shopping cart and to deliver content specific to your interest, to allow our advertising partners to serve advertisements on sites across the Internet, and to monitor and conduct analytics regarding the use of the Services.
5.2 You can refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do so, you may not be able to use the full functionality of our Platform or Services.
6. HOW DO WE USE THE INFORMATION YOU PROVIDE TO US?
6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
consider and/or process your application/transaction with us or your transactions or communications with third parties through the Services;
manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preferences), as well as your relationship and user account with us;
respond to, process, handle or complete a transaction and/or fulfill your requests for certain products and services and notify you about service issues and unusual account actions;
enforce our Terms of Service or any applicable end user license agreements;
protect personal safety and the rights, property or security of others;
for identification, verification, audits, “know your customer” processes, preventing and combating fraud and money laundering;
for analysis and decision-making related to your credit risk profile and verification of eligibility for credit products to be carried out by third parties who may eventually offer credit products to you;
maintain and administer any software updates and/or other updates and support that may be necessary from time to time to ensure the proper functioning of our Services;
to deal with or facilitate customer service, carry out your instructions, deal with or respond to any inquiries made by (or purported to be made by) you or on your behalf;
contact you or communicate with you by voice call, text message and/or fax, email and/or postal mail or otherwise for the purpose of administering and/or managing your relationship with us or the use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us may be by way of correspondence, documents or notices to you, which may involve the disclosure of certain personal data about you to provide for delivery thereof, as well as on the outer cover of envelopes/parcels mail;
to allow other users to interact, connect with you or view some of your activities on the Platform, including to inform you when another User sends you a private message or posts a comment to you on the Platform or in connection with your use of social interaction features on the Platform;
conduct research, analysis and development activities (including, without limitation, data analysis, surveys, product and service development and/or profiling), analyze how you use our Services, to recommend products and/or services of interest to you, improve our Services or products and/or enhance your customer experience;
enable audits and surveys to, among other things, validate the size and composition of our target audience and understand their experience with the Puji Services;
for marketing and advertising, in this sense, sending you through various channels and modes of marketing communications, promotional and product and/or service-related information and materials (including, without limitation, products and/or services of third parties with which the Puji may collaborate or associate) that Puji (and/or its affiliates or related companies) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function in the electronic marketing material. We may use your contact information to send you our newsletters or advertising material from our related companies;
respond to legal process or comply as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or when Puji, in good faith, believes that making such information available is necessary, including, without limitation, meeting the requirements for making disclosure under the requirements of any law binding on Puji or its related representatives or affiliates (including, where applicable, the presentation of your name, contacts and business details and of the respective legal entity);
prepare statistics and research for internal and regulatory reporting and/or record keeping requirements;
carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that have been implemented by us;
audit our services or Puji's business;
to prevent or investigate any suspected or actual violation of our Terms of Service, fraud, illegal activity, omission or misconduct, whether related to the use of our Services or any other matter arising from your relationship with us;
to respond to any threats and/or complaints made against Puji or other claims that any Content violates the rights of third parties;
to store, host, back up (whether for disaster recovery or otherwise) your personal data, whether within or outside your jurisdiction;
to handle and/or facilitate a business transaction or a potential business transaction, where such transaction involves the Buyer as a participant or involves only a corporation or affiliate related to the Buyer as a participant or involves the Buyer and/or any one or more Corporations or affiliates related to Buyer as participant(s), and there may be other third party organizations that participate in this transaction. A “business transaction” refers to the purchase, sale, lease, incorporation, merger or any other acquisition, disposition or financing of an organization or part of an organization or any business or assets of an organization; and/or
any other purposes of which we notify you at the time of obtaining your consent. (collectively, the “Objectives”).
6.2 You acknowledge, consent and agree that Puji may access, preserve and disclose your account information and Content if required to do so by law or court order or by any competent governmental or regulatory authority having jurisdiction over Puji or in good faith believe that preservation or disclosure of access is reasonably necessary to: (a) comply with due process and/or legal obligations; (b) respond to a request from any competent governmental or regulatory authority with jurisdiction over Puji; (c) enforce the Puji Terms of Service, this Privacy Policy and other Puji Policies and Regulations; (d) respond to any threat or actual complaint made against Puji or complaint that any Content violates the rights of third parties; (e) respond to your customer service requests; or (f) protect the rights, property or personal safety of Puji, its users and/or the public.
6.3 As the purposes for which we will collect, use, disclose or process your personal data depend on the circumstances in question, this purpose may not appear above. However, we will notify you of this other purpose at the time of obtaining your consent, unless processing the applicable data without your consent is permitted under Privacy Laws.
7. HOW DOES Puji PROTECT AND RETAIN CUSTOMER INFORMATION?
7.1 We implement a variety of security efforts and measures to ensure the security of your personal data on our systems. Your personal data is contained within protected networks and is only accessible by a limited number of employees who have special access rights to these systems. However, there is inevitably no way to provide guarantees of absolute security.
7.2 We will retain your personal information in accordance with Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which such personal data was collected is no longer being served by retaining such personal data; (ii) retention is no longer necessary for legal or business purposes; and (iii) no other legitimate interest that justifies the retention of such personal data. If you stop using the Platform, or if your permission to use it and/or the Services is terminated or withdrawn, we may continue to store, use and/or disclose your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without notice.
8. DOES Puji DISCLOSE THE INFORMATION COLLECTED FROM ITS VISITORS TO EXTERNAL ENTITIES?
8.1 In conducting our business, we will/may need to, use, process, disclose and/or transfer your personal data to our service providers, agents and/or our affiliates or related companies and/or other third parties, who may be located in Singapore or outside Singapore, for one or more of the above-mentioned purposes. These service providers, agents and/or affiliates or related companies and/or other third parties would be processing your personal data on our behalf or otherwise, for one or more of the aforementioned purposes. We use our best efforts to ensure that third parties and/or our affiliates keep your personal data secure from unauthorized access, collection, use, disclosure and processing, as well as similar risks, retaining such data only as long as necessary to fulfill the purposes mentioned above. These third parties include, without limitation:
our subsidiaries, affiliates and related companies;
buyers or sellers with whom you have interacted or transacted through the Platform or in connection with your use of the Services in relation to such purpose;
other users of our Platform for one or more of the purposes mentioned above;
contractors, agents, service providers and other third parties we use to support our business. This includes, but is not limited to, those parties that provide administrative or other services to us, such as postal distribution, logistics, general financial and payment processing services, advertising and marketing partners, telecommunications companies, information technology companies and data centers. date; government authorities and competent regulatory entities that have jurisdiction and control over Puji's activities, as permitted in item 6.2 above
a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Puji's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in that personal data held by Puji about our Service Users is among the transferred assets; or to a counterparty to a business asset transaction in which Puji or any of its affiliates or related companies is involved; It is
third parties to whom disclosure by us is for one or more Purposes and those third parties would in turn collect and process your personal data for one or more Purposes
8.2 Puji may share statistical and demographic information about our Users and information about your use of Services with advertising partners and third party providers of advertising, remarketing and/or other programming.
8.3 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws allow an organization like us to collect, use or disclose your personal data without your consent, this permission granted by the laws will continue to apply. Consistent with everything set out here and subject to applicable law, Puji may use your personal data on legitimate legal bases to comply with our legal obligations, to perform the contract with you, to achieve a legitimate interest and you acknowledge and You agree that our reasons for using it will not be a violation of your rights as a holder of personal data if we determine that it is necessary to use such data in connection with legal action.
8.4 Third parties may unlawfully intercept or access personal data transmitted to or contained on the Website, technologies may malfunction or not work as intended, or someone may access, abuse or misuse information through no fault of our own. However, we will implement reasonable security measures to protect your personal data as required by Privacy Laws; however, inevitably, there is no guarantee of absolute security, such as, without limitation, unauthorized disclosure by malicious and sophisticated hackers because they are unhappy, through no fault of our own.
8.5 If available in your territory, Puji may allow you to share YouTube videos on the Puji Livestream feature (“YouTube Content”). To facilitate this, Puji uses the YouTube API (system integration) services provided by YouTube. By using YouTube Content Sharing, you agree to be bound by the Google Privacy Policy (http://www.google.com/policies/privacy).
8.6 As set out in the Puji Terms of Service, Users (including any employees, agents, representatives or any other person acting for or on behalf of that User) in possession of another User's personal data through the use of the Services (the “Receiving Party”) agrees that, they will (i) comply with all applicable Privacy Laws with respect to such data, including any collection, processing, storage or transfer of such data; (ii) allow Puji or the User whose personal data the Receiving Party has collected (the "Disclosing Party") remove their collected data from the Receiving Party's database and (iii) allow Puji or the Disclosing Party to review what information has been collected about them by the Receiving Party; , in each case of (ii) and (iii) above, in accordance with applicable laws where necessary.
8.7 Notwithstanding any of the terms set out in this Policy, Sellers (including any employees, agents, representatives or any other person acting for such user or on behalf of such user) must comply with all applicable privacy laws and, in relation to any Buyer's personal data received from Puji, (i) is not authorized to use Buyer's personal data except as reasonably necessary to respond to Buyers' inquiries and to respond, process, negotiate or complete a transaction, always with the prior consent in writing from buyers and Puji ; (ii) you should avoid contacting buyers using such information outside of the Puji platform; (iii) are not authorized to disclose the buyer's personal data to unauthorized third parties without the prior written consent of the buyer and Puji; (iv) employ security measures sufficient to protect each Puji user's personal data in its possession, retain such data only for as long as necessary for the above purposes and in accordance with Privacy Laws, and to delete or return such data to Puji upon any request from Puji or as soon as reasonably practicable after completion of the transaction; and (v) to inform Puji's Personal Data Protection Officer at dpo.br@puji.com.br in the event of any potential data breach or other loss of data of such user.
9. INFORMATION ABOUT CHILDREN
9.1 The Services are not intended for children under 13 years of age. We do not knowingly collect or maintain personal data or non-personally identifiable information from children under 13 years of age nor is it part of our Platform or other Services directed to children under 13 years of age. Parents or legal guardians must not allow children under their responsibility to submit personal data to Puji. If personal data of children under 13 under your responsibility is shared with Puji, you, as the legal guardian, hereby consent to the processing of the personal data of the child in question and accept and agree to the provisions of this Policy on behalf of Puji . child. We will terminate any accounts used solely by such children and will remove and/or delete personal data that we believe has been submitted, without parental and/or legal guardian consent, by children under the age of 13.
10. INFORMATION COLLECTED BY THIRD PARTIES
10.1 Our platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyze how Users use the Platform. The information generated by the cookies about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating the use of the Platform, producing reports on website activity for operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties, whenever required by law or if Google delegates the processing of this information to third parties. Google will not associate your IP address with any other data held by Google.
10.2 We and third parties may from time to time make available downloads of software applications for your use through the Platform or through the Services. These applications may separately access and allow third parties to view your identifiable information, such as your name, your user ID, your device's IP address, or other information such as cookies that you may have previously installed or that were installed for you by an application or third-party software website. Additionally, these applications may ask you to provide additional information directly to third parties. Third-party products or services provided through these applications are not owned or controlled by Puji. You are encouraged to read the terms and other policies posted by third parties on their websites or otherwise.
11. DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES
11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION YOU PROVIDE ON THIRD-PARTY SITES. We implement a variety of security measures to maintain the security of your personal data that is in our possession or under our control. Your personal data is contained behind protected networks and is only accessible by a limited number of people who have special access rights to these systems and are obliged to keep personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. Any personal data or confidential information you provide is encrypted in our databases to be accessed only as indicated above.
11.2 In an attempt to provide greater value to you, we may choose various third party websites to link to and frame within the Platform. We may also enter into co-branding and other relationships to provide e-commerce and other services and resources to our visitors. These linked sites have separate and independent privacy policies and security agreements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independently of us. Data collected by our co-branded partners or third-party websites (even if offered on or through our Platform) may not be received by us.
11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are for your convenience only and you access them at your own risk. However, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback regarding such linked sites (including, without limitation, if a particular link does not work).
12. WILL Puji TRANSFER YOUR INFORMATION ABROAD?
12.1 Your personal data and/or information may be transferred, stored or processed outside your country for one or more purposes. In any case, Puji will only transfer your information abroad in accordance with applicable Privacy Laws and to (i) countries, jurisdictions and/or data centers that provide an adequate level of protection for personal data or; (ii) adopting the appropriate measures to provide the necessary protection for your personal data, which may involve the establishment of agreements with specific clauses aimed at establishing appropriate criteria and levels of security and exercising the rights of data subjects under the terms of LGPD.
13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS OR CORRECT THE INFORMATION YOU HAVE PROVIDED?
13.1 Withdrawal of Consent
13.1.1 You may withdraw your consent to the collection, use and/or disclosure of your personal data in our possession or under our control, as well as request that your personal data be deleted, by sending an Email email to our Personal Data Protection Officer at dpo.br@puji.com.br, and we will process the request in accordance with this Privacy Policy, as well as our obligations under privacy laws and other applicable laws. Withdrawal of consent may mean that we are unable to continue providing the Services to you and that we may need to terminate your existing relationship and/or the contract you have with us.
13.1.2 When You share YouTube Content, in addition to withdrawing your consent by sending us an email in accordance with Section 14.1, You may also revoke Puji's access to your personal data through the Puji security settings page. Google at https://security.google.com/settings/security/permissions.
13.2 Requesting Access to, or Correction of, Personal Data
13.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Platform. If you do not have an account with us, you may request access to and/or correction of your personal data currently in our possession or control by submitting a written request to us. We will need sufficient information about you to verify your identity and the nature of your request in order to be able to fulfill your request. Therefore, please submit your request in writing by emailing our Personal Data Protection Officer at dpo.br@puji.com.br.
13.2.2 We reserve the right to only execute users' requests with respect to their personal data in accordance with the provisions set out in applicable privacy and data protection legislation, including cases in which legislation eventually allows the controller and/or operator of personal data to refuse to comply with requests from personal data holders in certain circumstances and/or upon compliance with specific requirements by the data holders.
14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
14.1 If you have any questions or concerns about our privacy practices, please contact us at info@puji.com.br
Last modified: October 18, 2022