COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA is committed to comply with the laws protecting the privacy of customer and public data. This page is designed to provide information on how we are following data protection rules, what information we collect while you are browsing our communication channels, and how this information is collected, used, and protected by us, in compliance with Law No. 13.709/2018 (General Data Protection Law - "LGPD"). The use of our products and services, as well as of our platforms and other means of interaction made available, is conditioned to the acceptance of this Privacy Policy, including with regard to our associates.
I. Source of Personal Data
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will have access to personal data in the following situations:
• Through interaction with a client: When the Client provides and attributes personal data necessary for the provision of services and use of products provided by COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA
* Interaction with its associates: When its employees and associates of any nature use its systems and platforms to comply with the duties and obligations arising from their contractual relationship.
2. Types of personal data and sensitive personal data collected
Without prejudice to the data usually collected and processed from its associates for the purposes of the legal relationship they have, COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA may also collect the following personal data:
• Names and contact data, such as first and last name, e-mail address, postal address, telephone number, and other similar types of contact data, such as bank details;
• Device information, such as information about your device, IP address, location, or ISP;
• Use information and browsing history, such as information about how the User browses within our services, their browsing history, and which elements of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA services they use the most;
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The sensitive personal data eventually collected by COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will have its purpose separately informed to the User, who must consent that COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA uses them in a specific way, and in case of disagreement the data will be automatically deleted from COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA's databases.
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA does not collect data from minors, except with the authorization from parents or guardians. If data is collected without authorization, COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will immediately delete the data collected, according to the rules of the Terms of Use and this Privacy Policy.
3. Use of personal data collected
When collected, COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will use the personal data to:
• Provide and improve the contracted services;
• Comply with a legal or regulatory obligation;
• Manage the relationship with the Users;
• Set up and manage User accounts;
• Provide technical assistance, support, and training to the User;
• Contact Users;
• Internal research and development purposes and for improving, testing, and enhancing the features and functions of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA services;
• Provide Users with marketing, publicity, advertising, including from Partner companies of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA, as permitted by law;
• Meet internal and external audit requirements, including information security obligations of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA;
• Send messages by electronic mail to: (a) make confirmations or cancellations of requests using the platform; (b) communicate future changes that this policy may undergo; and (c) publicize updates, changes, additions of new data sources and improvements to the platform.
• Exercise the rights of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA, including, but not limited to, privacy, security, networks, systems, and property of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA and/or third parties;
• Comply with requests from courts, police authorities, regulatory bodies, and other public institutions and government authorities, including, but not limited to, any rules in effect outside the user's country of residence;
• The exercise of the rights of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA and to defend itself from any legal actions, as well as to comply with any legislation or regulation applicable to COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA or third parties with whom we work, as well as for the proper enforcement of any contracts entered into between COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA and its users;
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4. Sharing of personal data with third parties. The User accepts and agrees that COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA shares their personal data with the following recipient categories:
• Companies that provide access to or are responsible for the registry on which the user is dependent;
• Partner companies, such as third-party service providers and other companies that assist us in offering our services or who may act on our behalf to protect our rights, users, systems, and services;
• Third parties to whom COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA owes explanation to or is authorized to disclose information by law (Example: government bodies, regulatory agencies, judiciary, and other public authorities);
• Third parties in order to participate in the sale, merging, acquisition, restructuring, joint venture, assignment, transfer of part or all of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA's business, in which case the User's data will be considered an asset and transferred in an eventual negotiation;
* Third parties who need the data to protect the rights of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA;
• Any natural or legal person to whom the User requests the portability of their data.
5. International transfer of personal data
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA does not intend to perform the transfer of any personal data of the User collected outside of Brazil. If it is certain that the hypotheses below are not the case, the Users will be previously informed by e-mail, occasion on which the User may accept or not the transfer, and in case of disagreement, may have their access rights prevented by COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA.
The international transfer of data described in the General Data Protection Law (LGPD) requires the designation of guidelines to be established by the National Personal Data Protection Authority (ANPD). When defined, COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA undertakes to comply with them in their entirety.
6. Protection of personal data
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA uses proper technologies and procedures to protect any personal data collected (including administrative, technical, and physical protections) according to the level of risk and the service provided. It has a legally responsible team to handle the secure management of the data in line with legal provisions, regulatory requirements, changes in technology, among other relevant factors that may influence the way personal data is protected.
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COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA uses all reasonable efforts in the market to ensure the security of its systems and the data collected, using highly qualified and reputable Internet providers, database, and storage servers, in addition to security certificates (SSL) and software to protect against unauthorized access to the systems, as well as standard methods for encrypting and anonymizing the collected data.
This Policy represents the effort of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA to protect the User's information. However, due to the very nature of the Internet, it is not possible to ensure that malicious third parties fail in gaining unauthorized access to the information stored, which is why, if this occurs, COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will be responsible within the limits provided by law.
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA, within a reasonable period to be defined by the National Data Protection Authority ("ANPD"), shall communicate to the ANPD and the affected User the occurrence of a security incident that may cause relevant risk or damage to the affected User, mentioning, at least:
• a description of the nature of the personal data affected;
• the information about the holders involved;
• an indication of the technical and security measures used for data protection, observing commercial and industrial secrets;
• the risks related to the incident;
• the reasons for the delay, in case the communication was not immediate; and
• the measures that have been or will be taken to reverse or mitigate the effects of the damage.
7. Data processing and responsibility of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will handle its data processing responsibility as follows:
• When dealing with personal data provided directly by its Clients, COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will be the Operator, and will act without interference on the form of processing indicated by the Controller, but under the terms of the LGPD;
• COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will be the Controller of the Personal Data of its associates, processing them based on the Execution of Contracts, on the Fulfillment of legal or regulatory obligations, and also, in specific and determined situations, on the Consent.
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA may adopt different legal bases for different treatments of personal data.
8. Deadline for processing personal data
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COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA calculates the retention period for personal data according to the following criteria:
• Period necessary to fulfill the purpose of the collection;
• The moment the Client/User stops using the services of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA;
• The moment when there is withdrawal of consent or a request for deletion of the personal data by the Data Subject;
• The time required to demonstrate compliance with the duties and obligations of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA;
• The required period provided by Law, regulations, court decisions, etc.;
• Determination of the National Data Protection Authority;
• Compliance with legal or regulatory obligations by the Controller;
• Correct performance of the contract;
• Requirements for compliance with the legal system, as well as for any legal disputes;
• Transfer to a third party, provided the data processing requirements of the law are met; or
• Exclusive use by the controller, with forbidden access by third parties, provided the data is anonymized.
9. User Rights
According to the Brazilian General Data Protection Law, the User shall have the following rights concerning the treatment of their personal data:
• Right of Confirmation: The User may confirm if COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA processes any of their personal data;
• Right of Access: The User may make a written request to obtain details of how their information is being used, as well as to have a copy of said information;
• Right of Correction: The User may correct or remove any data that is incomplete, inaccurate, or outdated;
• Right of Anonymization, blocking or deletion: the User may request the anonymization, blocking or deletion of unnecessary, excessive data or data processed in disagreement with the purposes to which they gave their consent, observing, for such, other rules of the legal system;
• Right of Deletion: The User may request the deletion of some data, except those for which the law authorizes its retention;
• Right of Information: The User may request information from public and private entities with which COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA shared the use of their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data;
• Right to Refuse Marketing: The User may, at any time, request to unsubscribe from receiving advertisements and other materials through the available link [There appears illegible text] marketing sent.
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• Right of Portability: The User may request that their personal data be transferred to themselves or to a third party, except for those that have already been anonymized and deleted by COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA.
• Right to Withdraw Consent: The User may withdraw any consent previously granted to COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA to use their personal data. The User is aware that the cancellation will not affect the use or sharing of the data carried out prior to the request for withdrawal of consent.
The rights provided in this chapter are not absolute, and the User, whenever they wish to exercise them, shall contact COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA through the channel: This email address is being protected from spambots. You need JavaScript enabled to view it.
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA undertakes to answer such requests as soon as possible and without cost to the User, being limited to a maximum period of fifteen (15) days from the receipt of the request, unless a longer period is required to answer due to complexity, reasons in fact and in law, in which occasion the User will be informed.
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA will immediately notify the processing agents with whom it has shared the User's data about the correction, deletion, anonymization or blocking of the data, so that they repeat the same procedure.
The confirmation of the existence of or access to the User's personal data provided in this chapter will be provided, electronically or expressly, in a simplified format or by means of a clear and complete statement that indicates the origin of the data, the non-existence of a record, the criteria used, and the purpose of the processing, always respecting the commercial and industrial secrets of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA.
10. Cookies
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA and any partners may use cookies and other similar technologies to store and manage User preferences, offer targeted advertising, enable content, and collect analytical and use data, for example. The use of cookies and other tracking technologies is a standard on websites and platforms, through which information is collected about the User's activities on the platform, websites, or other services.
A cookie is a small text file, placed on a computer or other device, used to identify the User, device used and to collect information. Cookies can perform the following functions:
• Strictly Necessary Cookies: these are essential to allow the user to navigate on a platform and use its features.
• Performance Cookies: they collect information on how the User uses the COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA platform and are used to improve their navigation and enhance their experience. The information collected includes, for example, Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, the average duration of the visit, and the pages viewed.
• Functionality Cookies: these allow the platform to remember choices the User has made (such as their username or ID, language preference, or the area or region the User is in) and provide enhanced and more personal features.
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• Advertising Cookies: these track the User's browsing habits and are used to provide targeted advertising. These cookies also limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They also remember if the User has already visited a website and this information is shared with other organizations, such as advertisers.
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA uses both strictly necessary and performance cookies.
The User may disable Cookies through the browser settings at any time, by installing plug-ins available on the market, or even by using other technologies that they deem necessary.
In addition to cookies, COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA uses other tracking technologies such as:
Web Server and Platform Logs: The COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA servers automatically collect certain information to support, manage, and protect the services offered, as well as to analyze use and improve User experience. The information collected includes:
• IP address and browser type;
• Device information, including Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA) and similar identifiers assigned by us or third parties;
• Device's operating system and other technical data;
• The city, state, and country from which you are accessing BRASIL RISK's platform, including for the prevention of fraud;
• Typed information or text;
• Links and buttons clicked;
Social Network Connections: Some of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA's services may include social networking features, such as Facebook "Like" buttons and widgets; "Share" button and interactive mini-programs.
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA may allow the User to choose to use the logins of their own social networks to access some of the services offered, in which case COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA may receive and store authentication information from these services.
II. Contact information
Questions, comments, suggestions and/or complaints regarding this Privacy Policy, as well as any need for information, change or deletion of personal data, may be made by the User directly to COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA, by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
12. Changes
COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA constantly seeks updates and improvements, thus this Privacy Policy may be updated at any time always seeking a better provision of services and protection to users.
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In the event of changes affecting the purpose and duration of the processing of the User's personal data, the User will be informed through the e-mail registered in our services or through the platform itself with a thirty-day (30) notice. In case of disagreement with the changes, the User may withdraw the consent provided, being unable to use the services of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA.
If COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA changes its policy in the future in order to share data with third parties, it will send a thirty-day (30) notice to the user via e-mail. The user may disagree with the sharing of data and continue to use the services of COMEX SCIENCE CONSULTORIA E TREINAMENTOS LTDA.
The User is advised to read this policy periodically in order to keep up to date as to its content.
13. Applicable law and jurisdiction
This Policy will be governed, interpreted, and performed in accordance with the laws of the Federative Republic of Brazil, regardless of conflicts of these laws with laws of other states or countries, and the Jurisdiction of São Paulo is the one competent to settle any question arising from this instrument, with the waiver of any other, however privileged it may be.
All rights reserved.
