To enforce the Privacy Policy regarding personal data, or any other information provided by users when browsing, accessing and/or using our Platforms, as applicable.
For the purposes of this Privacy Policy, the following definitions apply: (1) “GJA Companies”: means the group of companies that make up what we call the José Alves Group, composed of the following companies: Bandeirantes, Rembal, Rebica, Unialfa, J&L Real Estate, Vitamedic, Sevla 3T, N&L Indústria, Colégio Alfa and Star Shop. For correspondence purposes, the address of the José Alves Group is Rua 02, Nº 255, Quadra 17, Setor Barcelos, Trindade-Go, CEP: 75.383-270, to the attention of the Legal Department; (II) “Platforms”: includes the websites, applications and social networks (such as Facebook, Instagram, LinkedIn, Twitter, TikTok and YouTube) of GJA; (III) “You”, “your”, “yours”: means anyone who uses the Platforms; (IV) “Personal Data”: means any information relating to an identified or identifiable natural person; (V) Sensitive Personal Data(s): means any personal data concerning racial or ethnic origin, religious beliefs, political opinions, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to a natural person. (VI) “Processing”: means any operation performed on Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction; (VII) “Data Subject”: means the natural person to whom the Personal Data being Processed refers; (VIII) “IP”: abbreviation for Internet Protocol. It is a set of numbers (and, in some cases, letters) that identifies the user's computer on the World Wide Web; (IX) “Logs”: means records of your activities performed on GJA websites and applications; (X) “Cookies”: are small text files sent by the website server to your computer, valid for a specific period. Cookies identify the user's computer and obtain data through the pages browsed (browser session) or links clicked, which allow: storing browsing history, user preferences, collecting statistical data, personalizing the use of the Platforms and targeting personalized marketing, according to the user's profile. In addition, some of our cookies are part of the technological solution and are inherent to the functioning of our platforms and applications, therefore, the choice to use or not use them is not optional. Cookies are secure, anonymous, private and are used only for your benefit, aiming to provide personalized content; (XI) “Session ID”: means identification of your session in the registration process or when using the Platforms in any way; and (XII) LGPD: stands for Law No. 13.709/18, General Data Protection Law.
GJA Companies are committed to the security of your Data throughout the entire process of browsing the Platforms, using the Services, and submitting requests through the communication channels available on the Platforms. Therefore, your Data will be kept strictly confidential and will not be sold, exchanged, or disclosed to third parties, except when permitted by applicable law.
4.1. By accepting the terms of this Agreement, you expressly agree to provide only true, current, and accurate Data and not to misrepresent your identity in any way when accessing and using the Platforms and/or Services. You will be solely responsible for any false or inaccurate information you provide through the Platforms and for any direct or indirect damages that this may cause to GJA Companies. 4.2. Data is collected when voluntarily entered or submitted by you: when registering on our Platforms to use the Services, when subscribing to receive our newsletters, when registering for our events, when using the Services through alternative channels also available on the Platforms (and other interactions), such as: Facebook, Twitter, YouTube, TikTok, LinkedIn, Instagram, customer service and ombudsman channels, email, or telephone available on the Platforms. 4.3. We also collect Data when you access our website and browse the items available on it through cookies. 4.4. When using our Platforms, GJA Companies only receive or collect the following types of information about you: (i) Before Registration: (a) Browsing data; and (ii) During and after registration: (a) Browsing data; (b) Registration data; (c) Billing data.
The GJA Companies website may use cookies, and it is up to you to configure your internet browser if you wish to block them. If you block cookies, some website functionalities may be impaired. We may collect the following data during your access to the Platforms, even if you are not registered and/or logged in: (i) Your IP address; (ii) Actions performed by you on the website; (iii) Pages accessed by you; (iv) Dates and times of each action and access to each website functionality; (v) Data about your location; and (vi) your Session ID, when applicable.
We may collect Data so that you can initiate and complete your registration, use our Platforms, and enjoy our Services. The Data collected for registration purposes includes, but is not limited to, name, username, password, date of birth, CPF (Brazilian tax identification number), email address, and/or phone number.
We may collect additional Data so that you can purchase courses, events, consulting services, and other services on our Platforms. When payment is made by credit card, the credit card and cardholder Data will be collected to process the payment.
We may collect data when you participate in any event promoted by GJA Companies: Bandeirantes, Rembal, Rebica, Unialfa, J&L Real Estate, Vitamedic, Sevla 3T, N&L Indústria, Colégio Alfa and Star Shop. The data collected at events will include, but are not limited to, name, email, job title, image and voice.
5.1. The data and information collected from Users may be used for the following purposes:
(i) To improve the use and experience of our Services; (ii) To carry out statistics, studies, research and surveys relevant to the activities and behaviors of users in the use of the Services, also aiming at the development of GJA Companies campaigns; (iii) To protect our rights and obligations related to the use of the Services, including in judicial and administrative measures; (iv) To collaborate with and/or comply with a court order or request by an administrative authority; (v) To recommend services or functionalities of the Platforms to you, including third-party services, that may interest you; and (vi) To redirect you to our profile on other websites.
(i) To complete your registration on our Platforms; (ii) To respond to any requests or questions you may have; (iii) To provide access to the restricted area of the site, upon prior identification and use of a personal and non-transferable password; (iv) To guarantee your security; (v) To keep your registration updated and enable any contact, by telephone (if necessary), in order to confirm registration data and avoid any damage or loss to our clients; and (vi) To recommend products and services to you, as well as send magazines, newsletters, or other services that may interest you.
(i) GJA uses the Billing Data only during the billing process, taking all necessary measures to ensure that this Data is protected against interception, misuse or tampering.
5.2.1. If we need to process data from minors, we guarantee that the processing of personal data has legitimate purposes and complies with the LGPD (Brazilian General Data Protection Law). 5.2.2. GJA only retains data from minors with the consent of their parents or guardians. 5.2.3. GJA does not intentionally request or collect personal data from children and adolescents without the consent of their parents or guardians. 5.2.4. If data from children and adolescents is detected in our database without their consent, it will be deleted as quickly as possible or whenever requested.
6.1. We may record your activities performed on the Services, creating, when possible and applicable, Logs that will contain: the IP address of the device used, access and actions performed by you on the Service provided, date and time of each action performed, and information about the device used, such as the operating system version, browser, and geolocation. 6.2. We may use certain technologies to monitor activities performed on the Platforms, such as: (i) Cookies: Cookies may be used for various purposes, including remembering you and your preferences and tracking your visits and activities related to the Platforms. The Platforms may also use locally stored objects to provide certain content. (ii) Web beacon: A web beacon is a technology that allows mapping who is visiting a particular web page, identifying their behavior with different websites or web servers. (iii) Analytics tools: These tools may collect information such as how you visit the Platforms, including which pages and when you visit those pages, as well as other websites that were visited before, among others. (iv) Redirecting tools: Our Platforms use redirecting technologies. This allows us to interact with you from our social networks. Redirecting technologies analyze the information we collect about your interactions with the Platforms. All technologies used by us will always respect the normative precepts of this term.
7.1. The database is our property and responsibility, and its use, access, and sharing, when necessary, will be carried out within the limits and purposes of our business and in accordance with applicable legislation. 7.2. We may share your Data in the following situations: (i) With GJA companies, to offer you the best possible experience in using our Services; (ii) With judicial, police, governmental authorities or other third parties with whom we are obliged by law, regulatory standard or court order; (iii) With Payment Providers, if you choose to carry out transactions related to payments, we will share the data with the relevant payment provider to facilitate this transaction; and (iv) With Service Providers, we provide information to service providers that support our business, such as cloud service providers.
8.1. Data is stored in a secure and controlled environment, accessible only to qualified individuals previously authorized by GJA Companies, for a minimum period of 12 (twelve) months, in accordance with the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet), considering the level of available technology. 8.2. Data may be stored on our own servers or those of a third party contracted for this purpose, whether located in Brazil or abroad, in accordance with applicable legislation. Data may also be stored using cloud computing technologies and/or other technologies that may emerge in the future, always aiming to improve and enhance our Services. In cases involving international transfer of personal data, we will adopt appropriate transfer mechanisms, as applicable. 8.3. Data is stored for the time necessary to provide the services. In cases where we no longer need your information to provide the services, we will only store your data as long as we have a valid legal basis. In some cases, we may retain your data for longer, particularly when necessary for the establishment, exercise, or defense of legal rights.
9.1. You have rights and guarantees regarding your Data, as provided for in the LGPD, which may not be applicable or may be subject to limitations in certain circumstances, namely: (i) Confirm and access your Data: You may request details and/or a copy of your Data stored by us; (ii) Change or correct your Data: If you wish to change your Data or if you have any reason to believe or suspect that any Data we hold about you is incorrect or incomplete; (iii) When applicable, you may revoke consent, delete, block, request anonymization and portability of your Data: Depending on the circumstances, you may (i) revoke your consent, whenever the processing of Data is based on consent, as per the LGPD; or (ii) request the deletion of your Data in the applicable cases provided for in the LGPD or deactivate your account, at any time, as per the law. Revocation of consent, as applicable, will result in your inability to use the Platforms and Services, as well as the interruption of the use of your Data, except for: (i) anonymized data; and (ii) Data necessary for GJA Companies and/or third parties involved in the provision of Services for purposes of judicial, arbitral or administrative defense, as well as for compliance with legal and regulatory obligations; and (iv) We store your history: You may contact us, as well as we are authorized to contact you, to access certain functionalities of our Services, ask questions about the Platforms, make complaints or suggestions, via email, telephone, Platform chat or social networks. The conversations will be stored by us and we may use their content as evidence in court, for the provision of our Services, or in other cases provided for by law. 9.2. To assess your request and, where applicable, enforce your rights, we may request proof of your identity as a security measure and to prevent fraud. In this case, any data and documents received will only be used for that purpose. 9.3. In certain situations, we may have legitimate reasons for not fulfilling some of your requests. For example, we may choose not to disclose certain information to you when disclosure could adversely affect our business, such as if there is a risk of violating our trade secrets or intellectual property rights. Furthermore, we may refrain from fulfilling a deletion request when it is not applicable due to the absence of the requirements stipulated in the LGPD (Brazilian General Data Protection Law), or if maintaining your personal data is necessary to comply with legal or regulatory obligations, or when such retention is necessary to protect our rights and interests in the event of a legal dispute. Whenever this is the case and we cannot fulfill a request you make, we will inform you of the reasons why we cannot fulfill your request. 9.4. To exercise your rights or ask questions, you can contact encarregadodedados@grupojosealves.com
10.1. For your security, we recommend that you do not share your access data with third parties, such as: website access emails, passwords (for personal and non-transferable use), CPF (Brazilian tax identification number), as well as other personal documents. Any problems arising from the sharing of access data will be duly investigated and those responsible will be held accountable. 10.2. We use the most advanced tools to prevent alteration, fraud, disclosure or destruction of the information we hold, such as encryption using SSL (Secure Socket Layers) and firewalls; however, we cannot guarantee the complete security of the data. Unauthorized access or use, hardware or software failure, and other factors may compromise the security of the Data. 10.3. We emphasize that the transmission of Data over the Internet is not completely secure due to several factors, including network and operational factors, and GJA Companies cannot guarantee the complete security of transmitted data. Although we do our best to protect your Data, we cannot guarantee the security of data transmitted to our Platform. Any transmission is your sole responsibility, and by agreeing to this GJA Sensitive Data Privacy Policy, you expressly acknowledge and assume such responsibility. 10.4. Once Data is received by the Platforms, we undertake to ensure that such Data will be secure. To prevent unauthorized access to or disclosure of your Data, we have implemented appropriate physical, electronic, and administrative procedures to secure and protect the Data we process.
From time to time our services may change. Therefore, we may unilaterally modify this Sensitive Data Privacy Policy at any time and communicate this through a simple notification on our Sites. After becoming aware of the informed modifications, by continuing to use these sites, the User automatically agrees to the changes in this Policy. If you do not agree with the changes, please stop accessing the GJA Companies' Sites. Hearing from you is always a great pleasure for the GJA Companies.
12.1. If you no longer wish to receive emails from GJA Companies, simply access the link at the bottom of all emails sent, indicating the possibility of canceling receipt. 12.2. By providing Data through the Platforms, you confirm that you are aware of the rules of use, protection and security established in this GJA Sensitive Data Privacy Policy. 12.3. The Platforms may contain links to partner websites. The mere availability of such links by GJA Companies does not imply agreement with or knowledge of their content, which is the sole responsibility of the Partner. 12.4. These guidelines come into effect on the date of their approval.
13.1. According to the LGPD (Brazilian General Data Protection Law), GJA Companies are considered the "Controller" of your Data. If, after reading this GJA Sensitive Data Privacy Policy, you still have any questions or need to contact us regarding matters involving your Data, please contact us by email: encarregadodedados@grupojosealves.com
To ensure compliance with the basic principles of the General Data Protection Law, No. 13.709/2018, establishing guidelines for the companies of the José Alves GJA Group, ensure integrated management in the processing of sensitive data, encompassing the particularities described in item “2” of this policy.
2.1 – Appoint a DPO for each GJA company;
2.2 Ensure the compatibility of GJA data processing with the purposes informed to the data subject, in accordance with the context of the processing (art. 6, II, LGPD);
2.3 Observe loyal, correct and honest behavior in carrying out the activities of processing personal data for GJA;
2.4 Process GJA data for legitimate, specific, explicit purposes, and as informed to the data subject, without the possibility of subsequent processing in an incompatible or distorted manner.
2.5 Guarantee to data subjects easy and free access to information about the form and duration of the processing, as well as the completeness of their personal data (Article 6, IV, LGPD).
2.6 Eliminate any impossibilities of carrying out the processing for illicit or abusive discriminatory purposes (art. 6, IX, LGPD).
2.7 Ensure resources for carrying out the minimum necessary processing, encompassing relevant data that is proportionate and not excessive in relation to the purposes of data processing (Article 6, III, LGPD).
2.8 Prevent the adoption of measures to prevent the occurrence of harm due to the processing of personal data (art. 6, VIII, LGPD).
2.9 Guarantee to data subjects the accuracy, clarity, relevance, and updating of data, according to the need and for the fulfillment of the purpose of its processing (art. 6º V, LGPD).
2.10 Demonstrate responsibility and account for the adoption of effective measures capable of proving compliance with personal data protection regulations, including the effectiveness of these measures (Article 6, X, LGPD).
2.11 Use technical and administrative measures capable of protecting personal data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication or dissemination (art. 6º VII, LGPD).
2.12 Ensure transparency for data subjects, providing clear, accurate, and easily accessible information about the processing and the respective data controllers, while respecting commercial and industrial secrets (Article 6, VI, LGPD).
José Alves Filho
President