Privacy Policy

When accessing one of our websites and/or filling out any form to contact us, it may be necessary to collect certain personal data. Our company is committed to and processes all personal data of our users with the full rigor required by law.

We are SPUN MEDIA, and we declare that this Privacy Policy adheres to all provisions stipulated by the General Data Protection Law (LGPD) – (Federal Law No. 13.709/2018), the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the New York Stop Hacks and Improve Electronic Data Security Act (NY SHIELD), and other data protection laws.

To facilitate your understanding, whenever “Spun Media,” “website,” “we,” “us,” or “our” are mentioned herein, we are referring to the portals belonging to SPUN MEDIA. Conversely, when “user,” “you,” or “your,” or “customer” are used, we are referring to the data subject of the collected data.

To further simplify the understanding of our privacy policy, below is a summary of the key information:

  • Data Processor: SPUN MEDIA LTDA, a private legal entity registered under CNPJ No. 43.629.487/0001-89, headquartered at Rua 20 de Setembro, 334, room 03, Centro, Piratini – RS, CEP: 96.490-000.

  • Nature of Processed Data: Personal data provided by the user to contact Spun Media; and data automatically collected from the devices the user utilizes to access our websites.

  • Role in Processing: Predominantly the Controller of the collected personal data.

  • Purposes as Controller: To enable communication between us and the user, as well as to provide a better browsing experience on Spun Media platforms; to utilize users’ personal data to offer products and services; for advertising campaigns, sending information, products, discounts, coupons, promotions, invitations, greetings, and event publicity. Legal Basis: Based on the data subject’s consent.

  • Legal Compliance: Storing access log reports, complying with legal and/or tax requirements, among other legal obligations. Legal Basis: Fulfillment of a legal obligation.

  • Sharing: Spun Media does not share the data collected by us with third parties without the consent of the data subject. Data sharing occurs between companies belonging to Spun Media, operators, and service providers.

  • Data Protection: Internal technical measures implemented to ensure the security of the collected data.

  • Your Rights: The user may at any time, upon formal request, access, rectify, revoke consent, request anonymization, data portability, etc., regarding the information inherent to the collected data.

After this brief summary, we hope this privacy policy helps you to: (i) understand the reasons that lead us to collect your personal data; (ii) understand when this data will be shared; and (iii) know and understand your rights, options, and power of choice.

Spun Media is committed to always being transparent and indicating the purpose of processing your personal data and above all respecting and protecting your consent and privacy.

1 – Who does the Spun Media Privacy Policy apply to?

This privacy policy is applicable to everyone who accesses a website that belongs to Spun Media or companies that belong to this holding and/or uses the contact form, whether through a smartphone, tablet, notebook, computer or similar devices, regardless of whether they become patients or not.

2 – What data we collect and the purpose of processing

During your browsing on any Spun Media platform, some data may be collected. In this experience, various data are collected, in different ways, for different purposes, which will be detailed below.

2.1 – Personal Data

  • Username;
  • E-mail; and
  • Telephone.

Purpose of treatment: This data is collected to enable a response to the user who used our platform to contact us through the form, as well as to enable the execution of contracted services, correct identification of the user, getting in touch, advertising campaigns, sending information, products, discounts, coupons, promotions, invitations, congratulations and event announcements, etc.

2.2 –Usage data for our platform

  • Interactions with the Platform;
  • Date and time of sending information;
  • Demographic information
  • URL information;
  • Cookies data;
  • Technical Data;
  • Device type and attributes;
  • Type of connection to the computer network;
  • Language;
  • Browser;
  • Operational system.

Purpose of treatment: We collect and store this data to have records of the use of the platform, which can be used to identify the person responsible, in accordance with the Marco Civil da Internet and other legislation that entails obligations.

3 – Who can we share the collected data with?

To carry out all the services provided for in this Privacy Policy, it is necessary for data collected by us to be shared on some occasions, with companies that belong to Spun Media, employees and/or partner companies and/or contractors.

3.1 – Spun Media companies, employees, service providers and affiliates

In order for our services to be carried out with maximum effort, we need the support of our employees in various sectors that handle the personal data we collect. Furthermore, when carrying out any action on the website, when necessary, it will be shared with employees and/or service providers and our branches, so that they can carry out assistance, scheduling and other necessary services. Another possibility for sharing is with other websites and companies that belong to Spun Media.

3.1.1 –Companies that are part of Spun Media

The following companies are part of our company group and use our systems, configurations and other services and/or are direct partners of Spun Media:

JN Content Mídia Digital LTDA – CNPJ: 42.921.663/0001-99

ND Mídia Digital LTDA – CNPJ: 30.309.478/0001-69 

JR Mídia Digital LTDA – CNPJ: 44.211.659/0001-62

Matemática Genial Tecnologia da Informação LTDA – CNPJ: 33.399.553/0001-18

Hub Content Marketing LTDA – CNPJ: 34.199.504/0001-02

DM Network Midia Digital LTDA – CNPJ: 45.918.640/0001-13

Cleverson F. de Lima LTDA – CNPJ: 24.869.977/0001-08

3.2 – Judicial, governmental and/or police authorities

Spun Media behaves collaboratively towards the authorities of our country, complying with its legal or regulatory obligations, providing the personal data of platform users to these authorities in the event of a court order or administrative request.

3.3 – Marketing and remarketing operators

User data collected through the use of our websites may be processed in marketing and remarketing operations by Spun Media and its companies, or by third parties hired for this purpose.

3.4 – Potential buyers

In the event of transactions and/or corporate changes, we may share the personal data collected with third-party companies, whether this transaction involves all or part of Spun Media.

3.5 – Other ways

We may also share the data collected in other ways as long as this method requires new user consent to ensure adequacy.

4 – Security and storage of collected personal data

We are always committed to keeping all personal data collected from our users stored securely. This storage is carried out nationally, following all current legislation that deals with the subject.

Furthermore, Spun Media seeks to adopt and always keep up-to-date techniques for protecting personal data collected through our platform, to avoid unauthorized access, loss, fraud, etc. or any inappropriate form of data processing.

However, there is no 100% secure platform, therefore, we cannot fully guarantee the security and privacy of all data collected. If you have any suspicions or concerns that your data is at risk, contact us through our support channels to receive our support.

The personal data collected will be kept for as long as the user is active on our platform. After this phase, we may keep your data provided for the necessary period, respecting current legislation, to carry out audits, comply with legal requirements, regulations, etc.

5 – Cookies and other tracking technologies

We may use technologies such as Cookies, Pixels, Analytics, Web Beacon and other similar technologies on our platform to improve, facilitate and/or adapt the platform to the needs and interests of each user.

5.1 – Cookies: 

These are small files that are added to our users’ devices to personalize and improve their experience on the platform. Furthermore, these cookies are used to analyze traffic and allow us to know that the user has browsed certain websites. This technology does not give access to the user’s devices or collect information that the user chose not to inform, only what you chose to inform us is collected.

5.1.1 – Browser Settings

You can click on “help” within the browser settings you use to see how to prevent accepting cookies, as well as to be notified when you receive new cookies, deactivate existing ones, check their expiration date, etc.

Google Chrome | Mozilla Firefox | Safari | Internet Explorer | Microsoft Edge | Opera

5.2 – Pixels: 

These are JavaScript codes installed directly on the platform with the aim of collecting more information about user behavior, identifying access patterns, interests, products purchased, navigation, product targeting and more.

5.3 – Analytics tools:

This technology allows the mapping of the visiting public on web pages, to identify certain user behaviors on websites and servers on the web.

5.4 – Web beacon:

This technology allows the mapping of the visiting public on web pages, to identify certain user behaviors on websites and servers on the web.

6 – Third Party Ads

Spun Media uses third party advertising services such as Google AdSense and Google Ad Exchange (AdX), to serve these advertisements we use a DoubleClick cookie to serve more relevant ads across the web and limit the number of times a given ad is displayed for you.

For more information about these advertisements, please consult their official websites and their privacy policies.

Google 

7 – Rights of the holder of collected personal data

In accordance with current legislation, Spun Media’s priority is to guarantee all its users the following rights:

7.1 – confirmation of the existence of treatment;

7.2 – access to data;

7.3 – correction of incomplete, inaccurate or outdated data;

7.4 – anonymization, blocking or deletion of unnecessary, excessive or processed data that does not comply with the provisions of this Law;

7.5 – data portability to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;

7.6 – deletion of personal data processed with the holder’s consent;

7.7 – information on public and private entities with which the controller shared data;

7.8 – information about the possibility of not providing consent and the consequences of refusal;

7.9 – revocation of consent.

These may be required at any time, simply contact us using one of our contact methods available in item 11 of this Privacy Policy. Requests will all be handled free of charge and will undergo prior analysis of your identity and feasibility of the request.

8 – Children and teenagers

Our platform is not intended for people under 18 years of age. Must be used by adults.

The websites of Spun Media and its companies do not collect data from children and adolescents, therefore, they must refrain from informing and using our platform. If the collection of personal data from minors is detected, we will delete this data in accordance with the law.

9 – Retention and deletion of collected personal data

We will retain the collected data for as long as necessary to fulfill the purposes for which it was processed or for the period required to comply with legally mandated retention requirements. The duration for which personal data is kept depends on the specific purpose for which it was collected and used, in accordance with applicable laws. Upon request, we will appropriately delete personal data in a manner that ensures you are no longer identifiable, except in cases where its maintenance is legally permitted or mandatory, such as for legal, tax, or accounting audit obligations, among others.

10 – Changes to the Privacy Policy

We are always striving for the best for our users, clients, and patients; therefore, from time to time, Spun Media may update this Privacy Policy. However, we value transparency, so we will provide visible and appropriate communication whenever a change occurs in this policy, whether via email or any other similar or different means.

11 – Contact Us

You may speak with the person responsible for data processing via email at [email protected] or through our contact page whenever you have questions or need to reach our team. It is important to be aware of and verify if this Privacy Policy is the most up-to-date version while browsing our platform. It is a great pleasure for Spun Media to respond to all inquiries.

Last update: May 30, 2023 SPUN MEDIA