data privacy policy

Please read this Personal Data Protection and Privacy Policy carefully to understand our policies and practices regarding your Personal Data and how we will treat it. This Policy applies to individuals who interact with HSI Institute services as consumers (“you”). This Policy explains how your Personal Data is collected, used and disclosed by HSI Institute (referred to in this policy as “HSI Institute“, “We”, “With Us”). It also tells you how you can access and update your Personal Data and make certain decisions about how your Personal Data is used.

This Policy covers our data collection activities both online and offline, covering the Personal Data We collect through our various channels, including – but not limited to – Websites, Applications, Third Party Social Networks, Customer Service Consumer, Points of Sale, Research and Events. Please note that We may aggregate combined Personal Data from different sources (for example, our website and offline events). As part of this, We combine Personal Data that was originally collected by different entities of the HSI Institute or partners of the HSI Institute. You can consult the section “About your rights regarding Personal Data” for more information on how to oppose this.

In some specific cases, if you decide not to provide us with your Personal Data identified as necessary (We will indicate when this is the case, for example, by explicitly placing that information on our registration forms), We may not be able to provide you with our products and / or services.

PERSONAL DATA SOURCES

We collect your Personal Data from the following sources:

  • HSI Institute Sites: All of our sites can be used to collect personal data. This includes both websites that we operate directly through our domains and IP addresses, as well as websites or pages that We establish in third party services, such as Facebook, Linkedin, and other third parties that offer this type of service.

  • Electronic Mail and instant messaging systems: Services used to maintain electronic communications between you and the HSI Institute, including those made available directly by Us, or third party services such as WhatsApp, Telegram or SMS.

  • HSI Institute mobile applications: Mobile applications provided directly by the HSI Institute or through third party services such as Google or Apple.

  • Customer services and Sales Center: Communications made with you through our sales and service centers.

  • Ads, advertisements and online forms: Interactions with any type of ads, advertisements and online forms from the HSI Institute.

  • Offline records: Records completed offline, distributed during events and other interactions with the HSI Institute.

  • Data received from third parties: Including, but not limited to, social networks and third party sites such as Facebook, Instagram, Linkedin, and the like, data aggregator services, HSI Institute partners, public sources and data received during acquisition from other companies.

WHAT PERSONAL INFORMATION WE COLLECT AND HOW IT IS COLLECTED

During your interaction with the HSI Institute, using one of the collection sources previously mentioned, we may collect various types of personal data about you, as set out below:

  • Contact Information : Includes any type of information that may facilitate our contact with you, including your physical mailing address, telephone numbers, e-mail addresses, websites and profiles on social networks.
  • Login information: Includes information to identify and authenticate to services provided by the HSI Institute, including your registration name (login), password in unrecoverable (encrypted) format, and security questions.
  • Demographic information and your interests: Any information that can describe your demographic data, habits or behavioral characteristics, including items such as your birthday, date of birth, age or age group, gender, geographic location, favorite products, hobbies and hobbies, other family interests and information or about your lifestyle.
  • Technical information about your computer equipment or mobile devices : Details about your computer or other portable device that was used to access one of our websites, services or applications, including the record of the IP address used to connect your computer or device to the internet, including its geographic location, the type and version of the operating system, and the type and version of the web browser. If you access a HSI Institute website or application using a mobile device, such as a smart phone or tablet, the information collected will also include, where permitted, your phone’s unique device ID, advertising ID, geographic location and other similar data from the mobile device.
  • Information about how you use our sites and services. During your interaction with our sites and services, we use automatic data collection technologies to capture information about the actions you have taken. This can include details such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and duration of visits to certain pages. This information is captured using automated technologies, such as Cookies (Browser Cookies, Flash Cookies and the like) and web beacons, as well as via third-party tracking. You have complete freedom to oppose the use of such technologies, for this see the details, in the section “About your rights regarding Personal Data”.
  • Market research and consumer feedback : This is information that you voluntarily share with the HSI Institute about your experience of using our products and services.
  • Consumer generated content : Including any content that you create and share with the HSI Institute on third party social networks or by uploading to one of our websites, applications and other online and offline services, including the use of social networking applications from third parties, such as Facebook, Instagram, Linkedin and the like. This data includes texts, comments, articles, photos, videos, personal stories or other similar content and media. Whenever permitted, We collect and publish consumer-generated content in connection with a variety of activities, including dissemination of the HSI Institute products and services, contests, awards and other promotions, website community resources, consumer engagement and social networks. the 3rd.
  • Third-party social media information: This is any data that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as Facebook, Instagram, Linkedin and the like) and that you allow the social network share with us. This data can include details such as your basic account information (name, email address, gender, date of birth, current city, profile photo, user ID, friends list, etc.) and any other information or activities you allow the third party’s social network to share with us. We receive your social media profile information from third parties (or parts of them) whenever you download an item or interact with a HSI Institute application or web service on a third party social network, whenever you use a social networking feature that is integrated with a HSI Institute website or whenever you interact with Us through a third party social network. To learn more about how your information from a third party social network is obtained by the HSI Institute or to choose not to share that social network information, visit the specific third party social network website.
  • Financial and payment information: Any data that the HSI Institute needs to fulfill an order, or that you use to make a purchase, such as your debit or credit card details (cardholder name, card number, date expiry date, etc.) or other forms of payment used. The HSI Institute or our payment processing service providers handles your financial and payment information in accordance with applicable laws, rules and security standards, such as the PCI DSS (“Payment Card Industry Secutiry Standards Council”).
  • Contacts with our Customer Service and Sales Center : Your interactions with our Customer Service and Sales Center can be recorded or heard, in accordance with applicable laws, for the operational needs of the HSI Institute. Details of financial and payment information are not recorded. When required by law, you will be informed of such recording at the beginning of your call.
  • Sensitive Personal Data: The HSI Institute does not normally deal with Personal Data considered sensitive according to current legislation, so we do not intend to collect or process sensitive personal data in the normal course of its interactions with our products or services. When there is a legitimate interest or it is necessary to process your sensitive personal data, for whatever reason, we will obtain your prior, express and formal consent for any processing that is voluntary (for example, for marketing purposes). If we process your sensitive personal data for other purposes, we rely on the following legal bases: (i) detection and prevention of crime; and (ii) compliance with applicable law.

ON PERSONAL DATA OF CHILDREN AND ADOLESCENTS

The HSI Institute does not knowingly request, collect, process, store or share personal data of minors and children. If we discover the occurrence of any type of handling of said data, unintentionally, we will remove that child’s or adolescent’s personal data from our records quickly. However, the HSI Institute may collect personal data from children and adolescents directly from their parents or legal guardians, and with explicit consent, and in accordance with the rules of current legislation.

ABOUT THE USE OF COOKIES, LOG FILES AND THE LIKE

Cookies are small text files that can be placed on your computer or portable device by websites or services on the web that you use. They are used to ensure the smooth functioning of websites and other online services, as well as to provide information to the owners of the website or online service.

Cookies are used to improve the use and functionality of the HSI Institute websites and other compatible web services and to better understand how our visitors use our websites and online services, as well as the tools and services they offer. Cookies facilitate the process of adapting the websites of the HSI Institute to your personal needs, facilitating whenever possible their use, receiving feedback on the satisfaction of our consumers.

The HSI Institute uses the following types of Cookies on its compatible websites and services:

  • Session cookies : These are temporary use cookies, which are deleted the moment you close your browser. When you restart your browser and return to the website that created the cookie, that website treats you as a new visitor.
  • Persistent cookies: These are cookies that remain in your browser until you delete them manually or until your browser deletes them according to the period of time established by the cookie. These Cookies will recognize your return as a visitor to a website or service of the HSI Institute.
  • Necessary cookies : Cookies are strictly necessary for the operation of a HSI Institute compatible website or service. They allow you to browse the site and use our resources.

  • Cookies that send us information about you: We place this type of Cookies on a compatible website or service of the HSI Institute and this type of Cookie can only be read by our compatible websites and services.
  • Cookies in HSI Institute advertisements : We place Cookies in advertisements and advertisements that are displayed on compatible third party websites and services. We obtain information through these Cookies when you click on or interact with the advertisement or advertisement. In this case, the HSI Institute is placing a “third party” cookie. We may use this data obtained by third-party cookies to send you other advertisements that we believe are relevant or of interest to you based on your past behavior.
  • Cookies that share your information with third parties: These are cookies placed on a HSI Institute website by our partner companies, such as online advertising services. They may use the data collected by these Cookies to anonymously send you targeted advertisements from other websites, based on your visit to compatible websites or services of the HSI Institute.

The HSI Institute compatible websites and services may also use other tracking technologies similar to Cookies, which may collect information such as IP addresses, log files and web beacons, among others. This data is also used to help us adapt HSI Institute websites and other compatible services to your personal needs.

See more details below:

  • IP addresses : An IP address is a number used on the internet or on a network to identify your computer. Every time you connect to the internet your computer receives an IP assigned by your internet service provider. We can register IP addresses for the following purposes: 
    • Treatment of technical problems;
    • Maintenance of the protection and security of our websites and other online services;
    • Get a better understanding of how our websites and other online services are used;
    • Adapt our content to your needs, depending on your geographic location.
  • Log Files: The HSI Institute or a third party working on our behalf, may collect information in the form of log files (logs) that detail the activities of the site and collect statistics on the user’s browsing habits. These records are usually generated anonymously and help us understand details such as:
    • The type of browser and system used by users of our websites or online services;
    • Details about the user’s session, including the source URL, the date, time and what pages the user visited on our compatible sites and services, and how long the user spent using them;
    • Other details of navigation or click count including website traffic reports, unique visitor count and similar data.
  • Web beacons: We can use web beacons (or transparent GIFs) on the websites of the HSI Institute. Web beacons (also known as webbugs or web beacons) are small strings of code that allow the delivery of a graphic image on a web page in order to transfer data back to us. We use information from web beacons for a variety of purposes, including:
    • Understand how a user responds to email campaigns;
    • Traffic reports for our compatible sites and services;
    • Perform unique visitor counting, auditing and advertising and email reporting, and personalization on our websites and other compatible services.

It is important to remember that it is up to you to ensure that the settings on your computer or portable device reflect whether you consent to accept Cookies or not. 

Most browsers allow you to establish rules to warn you before accepting Cookies or simply refusing them. You do not need to have Cookies enabled to use or browse most of the HSI Institute websites and online services, however in this case we cannot guarantee that you will be able to access all of its resources. We recommend that you see the “help” button on your browser as to how to perform this type of configuration. 

Remember that if you use different browsers, or even computers and / or portable devices in different locations, you will need to ensure that each device and browser is adjusted to your personal cookie preferences.

As our web beacons can be part of a web page, it is not possible to exclude (“opt-out”) this type of feature, but you can make it completely non-functional by activating the “opt” feature -out ”for Cookies placed by that flag.

ABOUT THE USE OF YOUR PERSONAL DATA

The following items describe the purposes for which the HSI Institute collects your Personal Data, and the different types of Personal Data we collect for each purpose. Please note that not all uses below will be relevant to all individuals and may only apply to specific situations.

  • Consumer services : Your Personal Data is used for the purpose of providing consumer services, including answering your questions, inquiries and suggestions. This usually requires certain personal contact information and information about the reason for your question, question or suggestion, for example, what was your request, if there is a technical problem, question or complaint about product, question in general.
    • Reason for using your personal data in this situation :
      • Comply with contractual obligations;
      • Comply with legal obligations;
      • Our legitimate interests.
    • Our legitimate interests in this situation :
      • Continuously improve HSI Institute products and services;
      • Continuously improve the effectiveness of our customer service.
  • Competitions, promotions and other marketing actions: With your consent (when necessary under current legislation), the HSI Institute uses your Personal Data to provide information about products or services, such as marketing communications, advertising campaigns or promotions. This can be done by various means of communication, including e-mail, advertisements, sending SMS messages, telephone calls and postal correspondence (as permitted by current legislation), in addition to our own websites and / or websites and social networks. the 3rd. In this situation, the use of your Personal Data is completely voluntary, which means that you can object, or even withdraw your consent at any time, to the processing of your Personal Data for these purposes. For more details on changing your marketing communications preferences, see the section “About your rights regarding Personal Data” in this policy. For more information about our contests and other Promotions, see the regulations or details posted about each contest / promotion.
    • Reason for using your personal data in this situation :
      • Comply with contractual obligations;
      • Our legitimate interests;
      • We obtained your consent (when necessary).
    • Our legitimate interests in this situation :
      • Understand which of our products and services may interest you and provide information about them; 
      • Define consumers for new products or services.
  • Social networks and third party websites : We use your Personal Data when you interact with functions of social networks and third party websites, such as “like”, to provide advertisements and interact with you on third party social networks. The way these interactions work, the profile data that the HSI Institute obtains about you, and how to cancel them (“opt-out”) can be understood by reviewing the privacy policies directly on the respective social networks and third party websites.
    • Reason for using your personal data in this situation :
      • Our legitimate interests;
      • We obtained your consent (when necessary).
    • Our legitimate interests in this situation :
      • Understand which of our products and services may interest you and provide information about them; 
      • Define consumers for new products or services.
  • Personalization (offline and online): Based on your consent (when required under current legislation), the HSI Institute uses your Personal Data (i) to understand your preferences and habits, (ii) to anticipate your needs, based on our understanding of your profile, (iii) to improve and personalize your experience on our websites and applications; (iv) to ensure that the content of our websites and applications is optimized for you and your computer or device; (v) to send you targeted advertising and content, and (vi) to allow you to participate in interactive functions, whenever you decide to do so. In this situation, the use of your Personal Data is completely voluntary, which means that you can object, or even withdraw your consent at any time, to the processing of your Personal Data for these purposes. 
    • Reason for using your personal data in this situation :
      • Our legitimate interests;
      • We obtained your consent (when necessary).
    • Our legitimate interests in this situation :
      • Understand which of our products and services may interest you and provide information about them; 
      • Define consumers for new products or services. 
  • Service to your orders : We use your Personal Data to process and send your orders, in addition to informing you about the status of your orders, correcting addresses and conducting identity verification and other fraud verification activities. This involves the use of certain Personal Data and, in certain situations, payment information.
    • Reason for using your personal data in this situation :
      • Comply with contractual obligations; 
      • Legal obligations; 
      • Our legitimate interests;
      • We obtained your consent (when necessary).
    • Our legitimate interests in this situation :
      • Improve and develop new products and services; 
      • Be more efficient in meeting your requests; 
      • Protect our systems, networks and employees; 
      • Fully comply with legal obligations.
  • Legal reasons or merger / acquisition : If the HSI Institute or its assets are acquired by, or merged with, another company, including due to bankruptcy, we will share your Personal Data with our legal successors, respecting the requirements of the current legislation. We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from the competent legal authority; (iv) to protect our rights, privacy, security or property; or (v) to enforce the terms of any agreement or the terms of our website, products and services, in accordance with current legislation.
    • Reason for using your personal data in this situation :
      • Legal obligations; 
      • Our legitimate interests;
    • Our legitimate interests in this situation :
      • Fully comply with legal obligations;
      • Protect our systems, assets and employees.
  • Other purposes and situations in general : According to current legislation, the HSI Institute uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research and measuring the effectiveness of our advertising campaigns. We reserve the right, if you have HSI Institute accounts, to integrate these accounts into a single account. We also use your Personal Data to manage and operate our communications, IT and security and data protection systems.
    • Reason for using your personal data in this situation :
      • Comply with contractual obligations; 
      • Legal obligations; 
      • Our legitimate interests;
      • We obtained your consent (when necessary).
    • Our legitimate interests in this situation :
      • Improve and develop new products and services; 
      • Be more efficient in meeting your requests; 
      • Protect our systems, networks and employees; 
      • Fully comply with legal obligations.

ABOUT THE DISCLOSURE OF YOUR PERSONAL DATA

In addition to the entities that are part of the HSI Institute, we may share your Personal Data with the following types of third party organizations:

  • Service providers : Include external companies that are used by the HSI Institute to help operate our business. Service providers and their selected employees are only authorized to access your Personal Data on behalf of the HSI Institute for the specific tasks that are requested of them based on our direct instructions. Our service providers are contractually obliged to keep your Personal Data confidential and safe, and in cases of violation respond jointly and severally in accordance with current legislation.
  • Credit analysis, debt collection and financial services  agencies : As permitted by applicable law, credit analysis and / or debt collection agencies are external companies that the HSI Institute can use to help us check your credit status or to collect past due payments.
  • Third parties that use Personal Data for their own marketing purposes : Except for situations where you have given your specific consent, the HSI Institute does not license or sell your Personal Data to third parties for their own marketing purposes. In cases where this type of sharing occurs, the identity of these third parties will be revealed before obtaining their consent.
  • Third parties using your Personal Data for legal reasons or due to merger / acquisition : We will disclose your Personal Data to third parties for legal reasons or in the context of a merger or acquisition in the HSI Institute.

ABOUT THE RETENTION AND TERMINATION OF THE TREATMENT OF YOUR PERSONAL DATA

In accordance with current legislation, the HSI Institute uses your Personal Data for as long as is necessary to satisfy the purposes for which your Personal Data was collected, as described in this policy, or to comply with applicable legal requirements. 

Personal data used to provide you with a personalized experience will be kept exclusively for the time allowed, in accordance with current legislation.

You can obtain more details about the retention of your Personal Data through the communication channels detailed in this policy.

When, at the end of the processing of your Personal Data, these will be eliminated within the scope and technical limits of the activities, conservation is authorized in the situations provided for in the current legislation.

ABOUT THE DISCLOSURE, STORAGE OR TRANSFER OF YOUR PERSONAL DATA

The HSI Institute takes appropriate measures to ensure that your Personal Data is kept confidential and secure. However, that these protections do not apply to information that you have chosen to share in public areas, such as third party social networks.

  • People who can access your Personal Data: Your Personal Data will be processed by our employees or authorized agents, as long as they need access to such information, depending on the specific purposes for which your Personal Data has been collected.
  • Measures taken in operational environments : We store your Personal Data in operating environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data.
  • Measures that the HSI Institute expects you to take: It is important that you also have a role in keeping your Personal Data safe. When creating an online account, please be sure to choose a password that is strong to prevent unauthorized parties from guessing it. We recommend that you never reveal or share your password with others. You are solely responsible for keeping this password confidential and for any action taken through your account on the HSI Institute compatible sites and services. 

If you use a shared or public computer, never choose the option to remember your login name, email address or password, and make sure that you log out of your account (logged out) whenever you leave the computer. You must also use any privacy settings or controls that the HSI Institute provides on our website, services or applications, including those considered optional.

Transfer of your Personal Data : Given the nature of our business, we may have to transfer your Personal Data stored within the HSI Institute to third parties, in accordance with the purposes set out in this Privacy Policy. For this reason, we may transfer your Personal Data to other countries, as long as they have laws and regulations compatible with those in force in Brazil.

ABOUT YOUR RIGHTS REGARDING PERSONAL DATA

You have the right to confirm the existence, access, review, modify and / or request an electronic copy of the information in your Personal Data that is processed by the HSI Institute

You are also entitled to request details about the origin of your Personal Data or the sharing of this data with third parties.

At any time, you may also limit the use and disclosure, or revoke consent to any of our activities for processing your Personal Data, except in situations provided for in current legislation.

These rights can be exercised through the communication channels detailed in this policy, and it is necessary to validate your identity by providing a copy of your RG or equivalent means of identification, in accordance with current legislation. 

Whenever an application is submitted without providing the necessary evidence to prove the legitimacy of the data subject, the application will be automatically rejected. We emphasize that any identifying information provided to the HSI Institute will only be processed in accordance with, and to the extent permitted by, the applicable laws.

We emphasize that in certain cases, we cannot delete your Personal Data without also deleting your user account. In addition, some situations require the retention of your Personal Data after you request its deletion, in order to satisfy legal or contractual obligations. 

When available, our websites, applications and online services may have a dedicated function and you will be able to review and edit your Personal Data. We emphasize that the HSI Institute requests the validation of your identity using, for example, a login system with access password or similar resource, before allowing access or modification of your Personal Data, thus ensuring that there is no unauthorized access to your account and associated personal data.

The HSI Institute does its best to be able to answer any questions you may have about how we process your Personal Data. However, if you have unresolved concerns, you have the right to complain to the relevant data protection authorities.

WHAT ARE YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA

The HSI Institute does its utmost to give you freedom of choice over the Personal Data you provide to us. The following mechanisms give you control over the treatment of your Personal Data:

  • Cookies / Similar Technologies : You can manage your consent using: 
    • Our consent management solutions;
    • Your browser settings to refuse some or all Cookies and similar technologies, or to alert you when they are being used. 
  • Advertising, marketing and promotions : You can consent to your Personal Data being used by the HSI Institute to promote our products or services through checkboxes located on the registration forms or by answering questions presented by our representatives. 

If you decide that you no longer wish to receive such communications, you can cancel your subscription to receive marketing-related communications at any time by following the instructions provided in such communications.

To unsubscribe from marketing communications sent by any means, including third party social networks, you can opt out at any time, canceling your subscription, through the links available in our communications, logging into our websites, applications, compatible online services or third-party social networks, and adjusting your user preferences or calling our customer service directly.

It is important to remember that, even with your unsubscription to our marketing communications, you will continue to receive administrative communications from the HSI Institute, such as orders, transaction confirmations, notifications about your account activities on our compatible sites and services, and others important non-marketing ads.

  • Personalization (offline and online): Whenever permitted by law, if you want your Personal Data to be used by the HSI Institute to provide you with a personalized experience or targeted advertising and content, you can indicate this through the relevant check boxes located on the registration form or by answering questions from our representatives.

If you decide that you no longer want to benefit from this customization, you can opt out at any time by logging into our compatible sites, applications and services, and selecting user preferences in your account profile or calling our service directly. customer service.

  • Targeted advertising: The HSI Institute may enter into partnerships with ad networks and other service or ad providers, which display advertisements and other advertisements on our behalf or on behalf of other companies not affiliated with the HSI Institute. Some of these advertisements may be adjusted to your interests, based on information collected on the websites and other compatible services of the HSI Institute or on the websites of organizations not affiliated with the HSI Institute

You can contact us using the communication channels detailed in this policy for more information on how to manage or cancel your participation in targeted advertising.

CHANGES TO OUR PRIVACY POLICY

Whenever the HSI Institute decides to change the way we treat your Personal Data, this Policy will be updated. We reserve the right to make changes to our practices and this Policy at any time, as long as compliance with current legislation is maintained. 

We recommend that you visit it frequently, or whenever you have questions, to see any updates or changes to our Privacy Policy.

CONTACT

You can contact:

  • Ask questions or comments about this Policy and our personal data protection and privacy practices;

  • Complain;

  • Confirmation of the existence of treatment of your Personal Data;

  • Get information on how to access your Personal Data;

  • Correct incomplete, inaccurate or outdated personal data;

  • Obtain information on the anonymization, blocking or elimination of unnecessary, excessive or treated data in non-compliance with the provisions of current legislation;

  • Obtain information about the portability of your personal data to another service or product provider, upon express request, in accordance with current legislation;

  • Request the elimination of personal data processed with your consent, except for the cases provided for in the current legislation;

  • Request details of public and private entities with which we share your Personal Data;

  • Obtain information about the possibility of not providing consent and the consequences of this denial;

  • To revoke consent for the treatment of your Personal Data, except for the cases provided for in the current legislation;

  • Other rights of the holder of personal data, according to current legislation.

For this, we request that you contact us using the following channels:

  • Sending an email to [email protected]

  • Making a telephone call to the number 55 11 3285-6539

  • In person or by conventional mail at Av. Paulista 967 – 8º andar Bela Vista – São Paulo – SP, CEP: 01311-918

The HSI Institute will receive, investigate and respond, within a reasonable time, to any request or complaint about the way We treat your Personal Data, including complaints about breach of your rights under the current Personal Data protection and privacy laws.