2.1 Methods of processing

We take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of your data. The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In some cases, the data may be accessible to certain types of persons in charge, involved with the operation of Sala (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors. These are natural or legal persons, authorities, institutions or other bodies that we contracted with necessary confidentiality requirements and they process personal data on behalf of us, the data controller. The updated list of these parties may be requested from us at any time.

2.2 Legal basis of processing

We may process personal data relating to Users while providing our services, if one of the following applies:

• Users have given their consent for one or more specific purposes;
• Provision of data is necessary for the performance of the contract with the User and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which we are subject to;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

2.3 Place

The data is processed at our operating offices and in any other places where the parties involved in the processing are located. In any case we and our data receivers measure up to these highest requirements of the applicable data protection regulation. Depending on the User's location, data transfers may involve transferring the User's data to a country other than their own. To find out more about the place of processing of such transferred data, Users are welcomed to check the section containing details about the processing of personal data.

2.4 Retention time

Personal data shall be retained as long as it is necessary to fulfill the purposes of collecting. (i.e. saving your address in order to provide you the bill for the services purchased.)

Therefore:

• Personal data collected for purposes related to the performance of a contract between Sala and the User shall be retained until such contract has been fully performed.
• Personal data collected for the purposes of Sala’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by us within the relevant sections of this document or by contacting us.

We may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Legal action

The User's personal data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of this Sala or the related Services. The User’s personal data may be revealed upon request of public authorities.

Additional information about User's personal data

In addition to the information contained in this privacy policy, Sala may provide the User with additional and contextual information concerning particular Services or the collection and processing of personal data upon request.

System logs and maintenance

For operation and maintenance purposes, Sala and any third-party services may collect files that record interaction with this Sala (System logs) use other Personal data (such as the IP Address) for this purpose.

Children’s Privacy

Protecting the privacy of young children is for us especially important. For that reason, Sala does not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from persons under 13 years-of-age. If Sala learns that personal information of persons under 13 has been collected on or through the Sala Services, Sala will take appropriate steps to delete this information soon as possible. If you are the parent or legal guardian of a child under 13 who has become a Sala Services member, then please contact us to have that child’s account terminated and personal information deleted.

Information not contained in this policy

More details concerning the collection or processing of personal data may be requested at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by notifying Users on this page and within - as far as technically and legally feasible - sending a notice to Users via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, We shall collect new consent from the User, where required.

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Sala. For example, you directly provide your personal information when you submit requests via any forms on this website. You also provide personal information indirectly when you navigate this website, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this webpage and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such a third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement. We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service. To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen whenever an Sala runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by Sala, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of services and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of personal data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

• The categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• In case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • For sales, the personal information categories purchased by each category of recipient; and
  • For disclosures for a business purpose, the personal information categories obtained by each category of recipient.

  The disclosure described above will be limited to the personal information collected or used over the past 12 months.
  If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Sala, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request. We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period. Should we deny your request, we will explain to you the reasons behind our denial. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

• Your consent to the relevant processing activities;
• Compliance with a legal or regulatory obligation that lies with us;
• The carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• The carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• The exercising of our rights in judicial, administrative or arbitration procedures;
• Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of personal data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal data” and “The purposes of processing” within this document.

Your Brazilian privacy rights

You have the right to:

• Obtain confirmation of the existence of processing activities on your personal information;
• Access to your personal information;
• Have incomplete, inaccurate or outdated personal information rectified;
• Obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• Obtain information on the possibility to provide or deny your consent and the consequences thereof;
• Obtain information about the third parties with whom we share your personal information;
• Obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• Revoke your consent at any time;
• Lodge a complaint related to your personal information with the ANPD (the National data Protection Authority) or with consumer protection bodies;
• Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• Request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• Request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

• When the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• When the transfer is authorized by the ANPD;
• When the transfer results from a commitment undertaken in an international cooperation agreement;
• When the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.