I. INTRODUCTION
I.1. This privacy policy (“Policy”) explains and regulates how the European Network of Research and Innovation Centres and Hubs in LAC – ENRICH IN LAC, a non-profit association, based in Brasília, Federal District, at Edifício Armando Monteiro Neto, 13th Floor, SBN, Quadra 01, Bloco I, Asa Norte, Zip Code 70040-900, in Brazil(“ENRICH”, “we”, “us” or “our”) collects, processes and shares information provided through its website (https://lac.enrichcentres.eu) (“Site”).
I.2. All information processing and sharing carried out by ENRICH is done in accordance with the laws of the Federative Republic of Brazil, notably Law No. 13,709/2018 (Brazilian General Data Protection Law, referred herein as “Lei Geral de Proteção de Dados” or “LGPD”) and seeks to secure the fundamental rights of liberty and privacy of those who access and navigate the Site (“User”, “you” or “your”).
I.3. In accessing and navigating the Site, you are at the same time registering your decision to accept and consent to the collecting, processing, sharing and transferring of the information you provide and have previously provided through the Site, under the terms set out in this Policy.
I.4. You have the right of not accepting and consenting to the collecting, processing, sharing and transferring of your information under this Policy, in which case you should not supply any information through the Site and be sure to customize your browser settings accordingly.
I.5. Please note that some functionalities or services of the Site may be partially or entirely unavailable as a result of your decision to not provide any information.
II. DEFINITIONS
II.1. Please consider the following definitions for the purpose of reading and interpreting the provisions set out in this Policy:
a. “User”, “you” or “your”: any individual aged over 18 (eighteen), or legal entity representative, who accesses and navigates the Site.
b. “Member”: any individual who has adhered to ENRICH’s membership in Brazil.
c. “Personal Information”: information related to an identified or identifiable individual, such as name, e-mail, phone number, residential address, etc.
d. “Sensitive Personal Information”: information such as racial or ethnic origin, political opinion, affiliation to a union or an organization of religious, philosophical or political character, when linked to an individual. Please note that any reference in this Policy to Personal Information also comprises Sensitive Personal Information.
e. “Processing”: any operation carried out with your information (including Personal Information and other information collected through the Site that does not allow us to identify you), such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, filing, storage, disposal, evaluation or control of information, modification, communication, transfer, diffusion or extraction.
f. “Anonymisation”: process by means of which an information loses the possibility of being associated, directly or indirectly, to an individual, using technical methods that are reasonable and available at the time in which the information is processed.
g. “Cookies”: small, often encrypted text files, located in browser directories, used by web developers to help users navigate their websites efficiently and perform certain functions (for more information please access: https://www.allaboutcookies.org/).
III. INFORMATION WE COLLECT, PROCESS AND SHARE
III.1. We may collect, process, and share, for the purposes set out in Chapter IV, the following information that you provide through the Site:
a. Personal Information provided when you:
i. purchase a product or subscribe to a service offered at the Site (such as name, e-mail, company, country);
ii. fill in the application form for ENRICH membership (such as name, e-mail, company, position, location, summary and specific company information);
iii. subscribe to our newsletter (such as name and e-mail);
iv. contact ENRICH for any purposes through the channels available on the Site (such as name, e-mail, company’s name);
v. respond to surveys and provide feedbacks through the Site (such as name, e-mail, and other information you chose to provide).
b. Information provided automatically (through the use of Cookies, as described in Chapter IX) when you access and navigate the Site, such as Internet Protocol address (IP address), location, browser type, operating system, date, time and duration of your visit, whether you reached the Site after searching, clickstream in advertisements or social media, or engaged in page interaction (scroll downs), etc.
III.2. Under the terms and conditions set out in ENRICH’s Terms of Use, Users are able to share content from the Site in public spaces, such as social media. In such cases, ENRICH may, for the purposes set out in Chapter IV, collect and process some of the Personal Information made publicly available by you.
III.3. ENRICH is committed to having authentic and complete information, and kindly asks you to provide information of this nature, as well as any updates or corrections that may be necessary, directly through the Site or using the channel provided in Chapter XI.
IV. OUR PURPOSES IN COLLECTING, PROCESSING AND SHARING YOUR INFORMATION
IV.1. ENRICH’S purposes in collecting, processing, and sharing information listed in Chapter III include:
a. Providing, operating, and maintaining the Site and the services available therein, and making necessary improvements;
b. Understanding how you interact with the Site, and customize your preferences and provide you with a better user experience;
c. Detecting and resolving technical issues;
d. Enabling you to interact with ENRICH’s associates, Members and supporters;
e. Promoting ENRICH’s activities and business operations (including, for example, ameliorating services offered by ENRICH, being able to market and sell services effectively, and connecting users for business and funding opportunities and other purposes);
f. Communicating with Users (including to notify Users about changes to our Site and/or to this Policy);
g. Complying with legal or regulatory obligations;
h. Carrying out studies, guaranteeing, whenever possible, the anonymization of Personal Information;
i. Executing a contract or preliminary procedures related to a contract to which you are a party, at your request;
j. Protecting ENRICH and Users through the regular exercise of rights in judicial, administrative or arbitral proceedings; and
k. Preventing fraud and guaranteeing Users’ security in identification and authentication procedures for registration in electronic systems.
V. SHARING AND TRANSFERRING INFORMATION
V.1. Based on this Policy, we are authorized to share and transfer the information listed in Chapter III with partner institutions, in or outside of Brazil, if necessary for the purposes listed in Chapter IV, and as long as the principles and guarantees set out in the LGPD are observed. This means that your information may be processed and maintained in other countries (especially European countries that are associates or partners of ENRICH in LAC), by ENRICH or its partner institutions.
V.2. The partner institutions mentioned in item V.1 may include, for example, ENRICH associates, Members and supporters, as well as suppliers and companies contracted by us to provide specific services to you and to support the Site’s operations and activities.
V.3. The partner institutions mentioned in items V.1 and V.2 are required to store and process all information with appropriate security and confidentiality, respecting the terms of this Policy and the rules set forth in the LGPD. Partner institutions can only process information according to the specific purpose and orientation designated by ENRICH under the applicable agreement.
V.4. The operations described in this chapter are conditional upon recipient institutions and countries offering a level of information security that is adequate to that of the LGPD.
V.5. If we need to transfer your information internationally for purposes that are incompatible with those set out in this Policy, we will only do so after previously notifying you and having your written consent for it.
VI. PROCESSING AND RETENTION PERIOD
VI.1. ENRICH may store and process your information for as long as it is relevant to reaching the purposes listed in Chapter IV. Anonymized Personal Information, which cannot be associated to an individual, may be retained for an indefinite period.
VI.2. ENRICH will terminate the processing of your information when (i) your information is no longer needed (as provided for in item VI.1), (ii) you expressly revoke the consent previously given for the processing of your information, or (iii) there is a legal obligation in this sense.
VI.3. Following the termination described in item VI.2, your Personal Information will be eliminated. However, such information may be kept for the following purposes:
a. Compliance with legal or regulatory obligations by ENRICH;
b. Carrying out studies, guaranteeing, whenever possible, the anonymization of Personal Information;
c. Sharing or transferring to a third party, as provided for in Chapter V; or
d. For ENRICH’s exclusive use, whereas access by third parties will be prohibited and the information will be anonymized.
VII. YOUR RIGHTS
VII.1. You have the right to obtain from ENRICH, with respect to your Personal Information, at any time and upon written request through the channel indicated in Chapter XI:
a. Confirmation on whether your information is being processed and/or transferred by ENRICH;
b. Access to your Personal Information;
c. Correction of incomplete, inaccurate or outdated Personal Information;
d. Anonymizing, blocking or deleting of information that is unnecessary, excessive or processed in violation of the LGPD;
e. Portability of your information to another service or product supplier, upon written request, in accordance with applicable regulation, and as long as commercial and industrial secrets are respected;
f. Elimination of Personal Information processed on the basis of consent given by you through the acceptance of this Policy, except in cases in which information retention is authorized by the LGPD;
g. Information about the institutions with which ENRICH has shared your information;
h. Revocation at any time of the consent you have given, under this Policy, for us to collect, process, share and transfer your information.
VII.2. The information listed in item VII.1 will be provided by ENRICH within 15 (fifteen) days, counting from the date in which you filed the request. However, ENRICH might not be able to provide you with such information immediately for legal reasons and will notify you about such reasons.
VIII. THIRD-PARTY LINKS
VIII.1. The Site may contain links to other websites that are not related to, controlled or managed by ENRICH. Such websites may have their own privacy policies, which are not connected to or endorsed by this Policy, and which we strongly recommend your read and understand before navigating through the websites and providing any information (including Personal Information and other information that may be collected).
VIII.2. ENRICH has no responsibility or control over your decision to click third-party links available at our Site, neither over the content you access through the websites or any information you provide therein.
IX. COOKIES
IX.1. We use Cookies and similar tracking technologies to collect information related to your navigation in the Site and improve the Site’s navigability and functionalities; analyse, understand, and customize your preferences; and for marketing purposes.
IX.2. We may use the following types of Cookies:
a. Analytics cookies, which enable the analysis and understanding of your activity in the Site, as well as the management of the Site. We currently use Google Analytics to collect information that allows us to improve your Site experience.
b. Technical cookies, which enable the provision of the Site and the services contained therein.
c. Functionality cookies, which enable the provision of content and recording your preferences.
d. Security cookies, which guarantee that information and data received by ENRICH is not corrupted.
IX.3. You can refuse Cookies on your computer, by disabling them through browser settings. However, this may prevent you from accessing all or part of the Site and its functionalities.
IX.4. With respect to our advertising and marketing activities, you may opt out.
X. SECURITY AND CONFIDENTIALITY
X.1 ENRICH will adopt appropriate security, technical and administrative measures (including but not limited to maintaining updated plug-ins; using appropriate tools for access control; firewalls; back-ups; protection against Cross Site Scripting and malicious codes), to protect your information from unauthorized accesses and accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate, unauthorized or illicit processing. However, please keep in mind that no system for transmission on the Internet or for electronic storage is 100% (one hundred percent) secure.
XI. CONTACTS
XI.1. In case you have any doubts, complaints or requests related to this Policy and/or to how we collect, process, and share your information, please contact us at contact@lac.enrichcentres.eu.
XII. FINAL PROVISIONS
XII.1 The Site is not addressed at and does not intentionally collect and process Personal Information from any person under the age of 18 (eighteen). If we find out that we have unintentionally and inadvertently collected information of this kind without the necessary, prior parent or guardian consent, we will adopt the necessary measures to eliminate such information from our system.
XII.2 In case there is an alteration of (i) our purpose in collecting, processing, and sharing your Personal Information, in a way that is incompatible with the original consent given by you through the acceptance of this Policy, (ii) the form and duration of the information processing, (iii) the entity responsible for taking decisions about the processing of your Personal Information (ENRICH), or (iv) the situations in which your information may be shared or transferred, you will be timely notified by ENRICH or through the Site, and may, where consent for information processing is needed, revoke such consent if you disagree with the alteration taken place.
XII.3 You may at any time revoke the consent given through this Policy for the collecting, processing, and sharing of your information, by sending a written request to contact@lac.enrichcentres.eu.
XII.4 This Policy explains how ENRICH currently collects, processes, and shares information. You will be notified through the Site about any significant alterations to the Policy, and we invite you to periodically visit and read the most updated version of it. By continuing to use and navigate the Site after such alterations are published, you are at the same time agreeing to the changes that have taken place.
XII.5 This Policy will be governed, interpreted and executed in accordance with the laws of the Federative Republic of Brazil, regardless of the conflicts between these laws and the laws of other states or countries, with the Jurisdiction of Brasília/DF, in Brazil, being competent to settle any doubt arising from this Policy. The User expressly consents to the competence of this jurisdiction, and waives, in this act, the competence of any other jurisdiction, however privileged it may be or may become.