This policy is effective from September 2022. This English version is a translation provided for convenience; if there is any difference, the Portuguese version prevails.
Cru Brasil, a private legal entity, takes your privacy seriously and protects the security of the data of all its customers, partners, suppliers and users of the cru.org.br domain and of any other website, store or application operated by the merchant.
This Privacy Policy explains how we use and disclose information collected during your visits to our store and in the messages we exchange with you.
This Privacy Policy applies only to information collected through the store.
BY ACCESSING THE WEBSITE, SENDING COMMUNICATIONS OR PROVIDING ANY KIND OF PERSONAL DATA, YOU CONFIRM THAT YOU ARE AWARE OF THE TERMS SET OUT HERE AND AGREE WITH THE PRIVACY POLICY, WHICH DESCRIBES THE PURPOSES AND WAYS IN WHICH THE PERSONAL DATA YOU MAKE AVAILABLE IN THE STORE IS PROCESSED.
This Privacy Policy gives an overview of our privacy practices and of the choices you can make, as well as the rights you can exercise regarding the Personal Data we process. If you have any questions about the use of Personal Data, please contact no-reply@cru.org.br.
In addition, the Privacy Policy does not apply to any third-party applications, products, services, websites or social media features that may be offered or accessed through the store. Following those links will take you away from our website and may result in third parties collecting or sharing information about you. We do not control, endorse or make any representations about third-party websites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any website you interact with before allowing your Personal Data to be collected and used.
If you send us Personal Data about other individuals, you confirm that you are entitled to do so and that you have obtained the consent needed to authorize the use of that information under this Privacy Policy.
Section 1 – Definitions
For the purposes of this Privacy Policy:
- “Personal Data”: any information that directly or indirectly identifies, or could identify, a natural person, such as name, CPF (Brazilian tax ID), date of birth, IP address, among others;
- “Sensitive Personal Data”: any information that reveals, about a natural person, racial or ethnic origin, religious belief, political opinion, membership of a trade union or of a religious, philosophical or political organization, data about health or sex life, or genetic or biometric data;
- “Processing of Personal Data”: any operation performed on Personal Data, by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Any other operation provided for under applicable law is also considered Processing of Personal Data;
- “Data Protection Laws”: all legal provisions that regulate the Processing of Personal Data, including but not limited to Law No. 13,709/18, the Brazilian General Data Protection Law (“LGPD”).
Section 2 – Use of Personal Data
We collect and use Personal Data to manage your relationship with us and to serve you better when you acquire products and/or services in the store, personalizing and improving your experience. Examples of how we use the data include:
- To enable you to acquire products and/or services in the store;
- To confirm or correct the information we hold about you;
- To send you information we believe is of interest to you;
- To personalize your experience of using the store;
- To contact you through a phone number and/or email address you provided. We may contact you in person, by voice message, through automatic dialing equipment, by text message (SMS), by email or by any other means of communication your device can receive, in accordance with the law and for reasonable business purposes.
In addition, the Personal Data provided may also be used in any way we consider necessary or appropriate: (a) under the Data Protection Laws; (b) to meet the requirements of legal proceedings; (c) to comply with court decisions, regulatory decisions or decisions of competent authorities, including authorities outside your country of residence; (d) to enforce our Terms and Conditions of Use; (e) to protect our operations; (f) to protect the rights, privacy and safety of us, you or third parties; (g) to detect and prevent fraud; (h) to allow us to pursue available remedies or limit damages we may suffer; and (i) in other ways permitted by law.
Section 3 – Not providing Personal Data
You are not required to share the Personal Data we ask for. However, if you choose not to share it, in some cases we may not be able to give you full access to the store or to some specialized features, provide the assistance you need, deliver the product or provide the service you contracted.
Section 4 – Data collected
The general public may browse the store without registering or sending any Personal Data. However, some features of the store may depend on registration and on sending Personal Data, such as completing a purchase or service contract and/or enabling us to deliver the product or provide the service.
When you contact the store, we may collect:
- Contact data: first name, last name, phone number, address, city, state and email address;
- Information you send: information you send through forms (questions, complaints, suggestions, criticism, compliments, etc.).
When you browse the store in general, we may collect:
- Location data: geolocation data when you access the store;
- Preferences: information about your preferences and interests regarding products/services (when you tell us what they are or when we infer them from what we know about you);
- Store browsing data: information about your visits and activities, including the content (and any advertisements) you view and interact with, information about the browser and device you are using, your IP address, your location and the address of the website you came from. Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons and embedded web links. To learn more, see how we use Automatic Data Collection Tools in section 7 below;
- Anonymous or aggregated data: anonymous answers to surveys or anonymous and aggregated information about how the store is used. In the course of our operations, in certain cases we apply a de-identification or pseudonymization process to your data so that it is reasonably unlikely that you could be identified through the use of that data with the available technology;
- Other information we may collect: information that does not specifically reveal your identity or is not directly related to an individual, such as browser and device information, store usage data, and information collected through cookies, pixel tags and other technologies.
We do not collect Sensitive Personal Data.
Section 5 – Sharing Personal Data with third parties
We may share your Personal Data:
- With the partner company or companies you select or choose to send your data, questions, queries, etc. to, as well as with service providers or partners who manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the United States, Argentina, Brazil or elsewhere in the world, and include, for example, servers for testing and production, providers of hosting and data storage, fraud management, customer support, sales on our behalf, order fulfillment, content personalization, advertising and marketing activities (including digital and personalized advertising) and IT services;
- With third parties, to help us manage the store;
- With third parties, if there is any reorganization, merger, sale, joint venture, assignment, transmission or transfer of all or part of our company, assets or capital (including in connection with bankruptcy or similar proceedings).
Section 6 – International data transfers
Personal Data and other information collected by us may be transferred to or accessed by entities belonging to the corporate group of the partner companies around the world, in accordance with this Privacy Policy.
Section 7 – Automatic collection of Personal Data
When you visit the store, it may store or retrieve information in your browser, mainly in the form of cookies, which are text files containing small amounts of information. This information may be about you, your preferences or your device, and is mainly used to make the store work as you expect. The information usually does not identify you directly, but it can give you a more personalized internet experience.
Under this Privacy Policy, we and our third-party service providers may, with your consent, collect your Personal Data in various ways, including but not limited to:
- Through the browser or device: some information is collected by most browsers or automatically by internet-connected devices, such as the type of computer, screen resolution, operating system name and version, device model and manufacturer, language, and the type and version of the internet browser you are using. We may use this information to make sure the store works properly.
- Use of cookies: information about your use of the store may be collected by third parties through cookies. Cookies are pieces of information stored directly on the computer you are using. Cookies allow the collection of information such as the type of browser, the time spent in the store, the pages visited, language preferences and other anonymous traffic data. We and our service providers use this information for security, to make navigation easier, to display information more efficiently and to personalize your experience when using the store, as well as for online tracking. We also collect statistical information about the use of the store to continually improve our design and functionality, to understand how the store is used and to help you solve issues related to the store. If you do not want your information to be collected through cookies, most browsers offer a simple way to reject cookies automatically, or give you the option to accept or reject the transfer of a specific cookie (or cookies) from a particular website to your computer. However, this may make the store less convenient to use. The settings you choose may affect your browsing experience and any features that require cookies. We therefore accept no responsibility for the consequences of the store working in a limited way because cookies are disabled on your device (inability to set or read a cookie).
- Use of pixel tags and other similar technologies: pixel tags (also known as web beacons and clear GIFs) may be used to track the actions of store users (including email recipients), measure the success of our marketing campaigns, collect statistical data about the use of the store and response rates, and for other unspecified purposes. We may hire behavioral advertising companies to obtain reports about the store’s advertisements across the internet. To do this, these companies use cookies, pixel tags and other technologies to collect information about your use, or other users’ use, of our store and of third-party websites. We are not responsible for pixel tags, cookies and other similar technologies used by third parties.
Section 8 – Categories of cookies
The cookies used in our store comply with legal requirements and fall into the following categories:
- Strictly necessary: these cookies let you browse the website and use essential features securely. One example is security cookies, which authenticate users, protect their data and prevent fraudulent logins.
- Performance: cookies in this category collect information in an encoded and anonymous way about our online store, such as the number of visitors to a specific page, where visits to the website come from and which pages the user accessed. All data collected is used only to improve the website and to measure how effective our communication is.
- Functionality: these cookies are used to remember the user’s preference settings in order to improve their visit to our website, such as settings applied to the website layout or your answers to sign-up pop-ups, so that we do not need to ask you repeatedly.
Section 9 – User rights
You may at any time request: (i) confirmation that your Personal Data is being processed; (ii) access to your Personal Data; (iii) correction of incomplete, inaccurate or out-of-date data; (iv) anonymization, blocking or deletion of unnecessary or excessive data, or of data processed in breach of the law; (v) portability of your Personal Data to another service provider, as long as this does not affect our industrial and trade secrets; (vi) deletion of Personal Data processed with your consent, to the extent permitted by law; (vii) information about the entities with which your Personal Data has been shared; (viii) information about the possibility of not giving consent and the consequences of refusing; and (ix) withdrawal of consent. Your requests will be handled with special care so that we can make sure your rights are effective. You may be asked to prove your identity to make sure that Personal Data is only shared with its owner.
Please keep in mind that in certain cases (for example, because of legal requirements) your request may not be met immediately, and that we may be unable to meet it because of legal obligations.
Section 10 – Security of Personal Data
We seek to adopt the technical and organizational measures required by the Data Protection Laws to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any of your accounts has been compromised), please notify us immediately.
Section 11 – Hypertext links to other websites and social networks
The Store may, from time to time, contain hypertext links that take you to websites of our partners, advertisers, suppliers and others. If you click one of these links, remember that each website has its own privacy practices and that we are not responsible for those policies. Please read those policies before sending any Personal Data to these websites.
We are not responsible for the policies and practices for collecting, using and disclosing data (including data protection practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other software developer or application provider, social media store, operating system, wireless internet service provider or device manufacturer, including any Personal Data you disclose to other organizations through or in connection with those applications, or that you publish on our social media pages. We recommend that you read the privacy policy of each website you visit and each service provider you use.
Section 12 – Updates to this Privacy Policy
If we change our Privacy Policy, we will publish the new text in the store with the updated revision date. We may change this Privacy Policy at any time. If there is a significant change to the terms of this Privacy Policy, we may inform you using the contact information we hold in our database or through a notice in our store.
We remind you that we are committed to not processing your Personal Data in a way that is incompatible with the purposes described above, unless otherwise required by law or court order.
Using the store after the changes means that you have accepted the revised Privacy Policy. If, after reading the revised version, you do not agree with its terms, please stop using the store.
Section 13 – Data Protection Officer
If you wish to exercise any of the rights set out in this Privacy Policy and/or in the Data Protection Laws, including withdrawing your consent, or to resolve any questions about the Processing of your Personal Data, please contact us at contato@cru.org.br.