Na Wooba, privacy and security are priorities and we are committed to the transparency of the processing of personal data of our users/clients. Therefore, this Privacy Policy sets out how information is collected, used, and transferred from customers or other people who access or use our site. By using our services, you understand that we will collect and use your personal information in the ways described in this Policy, under the Data Protection regulations (LGPD, Federal Law 13,709/2018), the consumer provisions of Federal Law 8078/1990 and other applicable Brazilian legal regulations.

In this way, the WOOBA INFORMATION SYSTEMS S.A., henceforth referred to simply as”Wooba”, registered with the CNPJ/MF under number CNPJ: 07.480,136/0001-95, in the role of Data Controller, is bound by the provisions of this Privacy Policy.

1. What data do we collect about you and for what purpose?

Our site collects and uses some of your personal data, in order to enable the provision of services and improve the user experience.

1.1. Personal data provided by the owner

1.2. Personal data collected automatically

2. How do we collect your data?
‍
In this sense, the collection of your personal data takes place as follows:

2.1. Consent

It is based on your consent that we process your personal data. Consent is the free, informed and unambiguous expression by which you authorize Wooba to process your data.

Thus, in line with the General Data Protection Law, your data will only be collected, processed and stored with prior and express consent.

Your consent will be obtained specifically for each purpose described above, evidencing Wooba's commitment to transparency and good faith towards its users/clients, following the relevant legislative regulations.

By using Wooba's services and providing your personal data, you are aware of and consenting to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

At any time and at no cost, you can revoke your consent.

It should be noted that the revocation of consent to the processing of data may imply the impossibility of the adequate performance of some functionality of the site that depends on the operation. Such consequences will be informed in advance.

3. What are your rights?

A Wooba assures its users/customers their rights as a holder provided for in article 18 of the General Data Protection Law. That way, you can, for free and at any time:

4. How can you exercise your rights as an owner?

To exercise your rights as an owner, you must contact Wooba through the following available means:

In order to guarantee your correct identification as the subject of the personal data subject to the request, we may request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by Wooba will be used and stored for the time necessary to provide the service or for the purposes listed in this Privacy Policy to be achieved, considering the rights of data subjects and controllers.

In general, your data will be kept for as long as the contractual relationship between you and Wooba lasts. At the end of the storage period of personal data, they will be deleted from our databases or anonymized, subject to the hypotheses legally provided for in article 16 of the general data protection law, namely:

I — compliance with a legal or regulatory obligation by the controller;

II — study by a research body, guaranteed, whenever possible, the anonymization of personal data;

III - transfer to a third party, provided that the data processing requirements set out in this Law are respected; or

IV — exclusive use of the controller, with no access by a third party, and provided that the data is anonymized.

That is, personal information about you that is essential for the fulfillment of legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be kept, despite the deletion of other data.

The storage of data collected by Wooba reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions to guarantee the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and access control to the stored information.

6. What do we do to keep your data safe?

To keep your personal information secure, we use physical, electronic, and managerial tools aimed at protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the treatment, and the risks that possible violations would pose to the rights and freedoms of the owner of the data collected and processed.

Among the measures we adopted, we highlight the following:

A (simplified business name) undertakes to adopt the best postures to avoid security incidents. However, it should be noted that no virtual page is completely secure and risk-free. It is possible that, despite all our security protocols, problems of exclusively third-party fault occur, such as cyberattacks by hackers, or also as a result of the negligence or recklessness of the user/client himself.

In the event of security incidents that may generate a relevant risk or damage for you or any of our users/clients, we will notify those affected and the National Data Protection Authority about what has happened, in accordance with the provisions of the General Data Protection Law.

7. Who can your data be shared with?

In order to preserve your privacy, Wooba will not share your personal data with any unauthorized third party.

Your data may be shared with our business partners.

They receive your data only to the extent necessary for the provision of the contracted services and our contracts are guided by the data protection regulations of the Brazilian legal system.

However, our partners have their own Privacy Policies, which may differ from this one. We recommend reading these documents, which you can access here:​

In addition, there are also other hypotheses in which your data may be shared, which are:

I — Legal determination, request, requisition, or court order, with competent judicial, administrative, or governmental authorities.

II — Case of corporate movements, such as mergers, acquisitions and mergers, automatically

III — Protection of Wooba's rights in any type of conflict, including those of a judicial nature.

7.1. International data transfer

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. Under these conditions, in any case, your personal data will be subject to the General Data Protection Law and other Brazilian data protection laws

In this regard, Wooba is committed to always adopting efficient cybersecurity and data protection standards, in the best efforts to guarantee and comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will take place for the purposes described in this instrument.

8. Cookies or browsing data

Wooba makes use of Cookies, which are text files sent by the platform to your computer and stored there, containing information related to site navigation. In short, Cookies are used to improve the user experience.

By accessing our site and consenting to the use of Cookies, you indicate that you know and accept the use of a navigation data collection system with the use of Cookies on your device.


Wooba uses the following Cookies:

* Marketing Cookies: Cookies are used to provide more relevant content and of interest to users. They can be used to present advertising with greater targeting or to limit the number that it is displayed, on the pages of Wooba and its products. They also allow the measurement of the effectiveness of a launched advertising campaign.

*Performance cookies: Cookies help understand how visitors interact with Wooba sites, providing information about the places visited, the time spent visiting the site, and any problems identified during navigation, such as error messages.
* Functionality cookies: These are used to remember the settings you previously selected, providing improved functionality and personalization.
* Necessary cookies: Cookies are essential for the site to load properly and allow the user to navigate correctly, as well as to make the most of the available features.

You can, at any time and at no cost, change permissions, block or refuse Cookies. However, the revocation of consent to certain Cookies may prevent the correct functioning of some features of the platform.

To manage your browser's cookies, simply do so directly in the browser settings, in the Cookie management area. You can access tutorials on the topic directly from the links below:

If you use Internet Explorer: Access


If you use Firefox: Access


If you use Safari: Access


If you use Google Chrome: Access


If you use Microsoft Edge: Access


If you use Opera: Access


You can get more information about the Cookies we use and how they work in our Cookie Policy, available at this link.

9. Amendment to this Privacy Policy

The current version of the Privacy Policy was formulated and last updated on: 22/10/2021.

We reserve the right to modify this Privacy Policy at any time, mainly because it is appropriate to any changes made to our site or in the legislative framework. We recommend that you review it frequently.

Any changes will take effect as soon as they are published on our site and we will always notify you about the changes that have occurred.

By using our services and providing your personal data after such modifications, you consent to them.

10. Responsibility

Wooba provides for the liability of the agents who act in data processing processes, in accordance with articles 42 to 45 of the General Data Protection Law.

We are committed to keeping this Privacy Policy up to date, observing its provisions and ensuring compliance.

In addition, we are also committed to seeking technical and organizational conditions that are securely able to protect the entire data processing process.

If the National Data Protection Authority requires the adoption of measures in relation to the data processing carried out by Wooba, we undertake to follow them.

10.1 Disclaimer

As mentioned in Topic 6, although we adopt high security standards to prevent incidents, no virtual page is completely risk-free. In this sense, Wooba is not responsible for:

I — Any consequences resulting from the negligence, recklessness, or imexpertise of users in relation to their individual data. We guarantee and are responsible only for the security of the data processing processes and for the fulfillment of the purposes described in this instrument.

We emphasize that the user is responsible for the confidentiality of the access data.

II — Malicious actions by third parties, such as hacker attacks, unless proven guilty or deliberate conduct by Wooba.

We emphasize that in the event of security incidents that may generate a relevant risk or damage for you or any of our users/clients, we will notify those affected and the National Data Protection Authority about the incident and we will comply with the necessary measures.

III — Inveracity of the information entered by the user/client in the records necessary for the use of Wooba services; any consequences resulting from false information or entered in bad faith are the sole responsibility of the user/client.

11. Data Protection Officer

Wooba provides the following means for you to contact us to exercise your rights as an owner.

If you have questions about this Privacy Policy or about the personal data we process, you can contact our Personal Data Protection Officer, through the following channels:

Gustavo Faria — gustavo.faria@wooba.com.br