DEVFY’s Privacy Policy was last updated in April 2022.
In order to protect the fundamental rights of freedom and privacy and the free development of the personality of the natural person, DEVFY has prepared this Privacy Policy, in compliance with the provisions of the Brazilian General Law for the Protection of Personal Data (LGPD) – Law No. 13,709/2018.
It’s critical that you take a moment to familiarize yourself with our privacy practices and contact us if you have questions.
It is important for us to be transparent about the processing of the personal data of Users who use the Services offered by DEVFY, pursuant to Article 9 of the LGPD. This Policy applies when the User uses our Services.
ACCURACY OF INFORMATION
Any and all information provided by the User to DEVFY, especially their personal data, must be truthful and cannot violate Brazilian legislation, especially the LGPD. If DEVFY verifies that the information provided is untrue, it may delete the personal data, as well as close the user’s account.
WHAT ARE PERSONAL DATA AND SENSITIVE DATA?
Let’s understand the object of protection of this Policy. Firstly, it is important to know that “PERSONAL DATA” is information that can be used to identify a natural person (natural person), therefore, data from companies (legal entities) such as corporate name and CNPJ are not covered by this policy.
“SENSITIVE PERSONAL DATA”, according to the LGPD, consists of information about racial or ethnic origin, religious conviction, political opinion, membership of a union or organization of a religious, philosophical or political nature, or even data regarding health or sexual life, genetic or biometric data, and are covered by this policy.
DEVFY AS CONTROLLER
It is important to inform that DEVFY is the Controller of the Personal Data collected. But what does it mean? According to the LGPD, DEVFY is responsible for making decisions regarding the processing of its Users’ Personal Data.
WHAT TYPES OF PERSONAL DATA DOES DEVFY COLLECT?
Considering that DEVFY offers its services through an application, it is necessary that the person interested in using the DEVFY Services, first of all, register. This initial registration is called User Registration.
The following Personal Data is collected in the User Registration:
full name;
email;
date of birth;
cell phone; It is
CPF;
Said Personal Data is collected in order to identify the User’s context in relation to our platform and the services offered, in order to allow DEVFY to be able to offer specific content and present Users with the same profile and the same needs.
The full name and CPF are important to identify the User; the email is how the user will login to the platform; the date of birth is used to screen the content of materials to be made available; the mobile phone is the primary mode of contact between the customer and their Devfy account manager.
It is important to inform that the Personal Data listed above are processed, solely and solely, for the purpose of identifying the user and optimizing their experience using the application.
WHY DOES DEVFY PROCESS USERS’ PERSONAL DATA?
The User Registration is subject to the legal hypothesis of execution of the Contract, that is, it is only possible for DEVFY to perform the contracted Services if the User completes the User Registration. In this scenario, item VI of Article 7 of the LGPD applies.
MAY DEVFY ALSO COLLECT SENSITIVE PERSONAL DATA?
Yes. As the object of DEVFY is to deliver a personalized service for the development and management of sites and applications, knowing in depth which user is important for DEVFY to be able to offer its services in the most appropriate way.
HOW DOES DEVFY STORE PERSONAL DATA?
DEVFY uses Bubble (bubble.io) and WordPress (https://www.hostgator.com.br) services to store and host its application and website, using the infrastructure of Amazon AWS and Hostgator. Bubble and Hostgator handle personal data pursuant to the GDPR as provided in their Privacy Policy available at https://bubble.io/privacy and https://newfold.com/privacy-center. For this reason, any international transfer of personal data by DEVFY to Hostgator and to Bubble complies with item I of article 33 of the LGPD.
CAN DEVFY PERFORM AUTOMATED PROCESSING?
DEVFY uses the information and data that the User has provided to make recommendations for connections, content and resources that may be useful to the User. For example, data and information about the User is used to recommend connections from other Users and recommend suitable content. Keeping your profile up to date and correct will help make these recommendations more accurate and relevant.
HOW LONG DOES DEVFY PROCESS PERSONAL DATA FOR?
The Personal Data and Sensitive Personal Data mentioned in this Policy will be processed during the execution of the Services offered by DEVFY. After the termination of the Services, for whatever reason, Personal Data will remain stored by DEVFY for a period of up to 3 years. Such period takes into account the statute of limitations provided for in item V of § 3 of Article 206 of the Civil Code. Therefore, the retention of Personal Data for such a period, even after the end of the processing period by DEVFY, observes the hypothesis provided for in item I of Article 16 of the LGPD. After said period, DEVFY will eliminate the User’s Personal Data from its repository.
HOW DOES DEVFY ENSURE INFORMATION SECURITY?
As provided for in items VII and VIII of Article 6 of the LGPD, which deal with the principle of security and prevention, respectively, DEVFY uses the most modern resources available in the area of information security for the internet environment, thus guaranteeing its access in a safe and secure manner. safe.
The information transmitted between the User and DEVFY undergoes an encryption process using SSL (Secure Sockets Layer), allowing the decoding of the data, in a readable form, only for the user and for our website and application.
Thus, with each access made, this security key cannot be deciphered by third parties, being for the exclusive use of the DEVFY website and application. This key is the guarantee that the user is operating in a secure system.
WHICH BROWSERS ARE COMPATIBLE WITH DEVFY’S INFORMATION SECURITY?
The use of certain browsers may create incompatibility with the security system and resources used by DEVFY. The most suitable browsers for browsing are always the most modern and well-known browsers (Google Chrome, Mozilla Firefox, Microsoft Edge).
Browsers must be purchased from authorized distributors, who can guarantee the authenticity of the software. Some distributors supply the browsers through the internet itself, by way of download.
All problems relating to the browser should be reported to their respective suppliers or distributors. DEVFY is not responsible for problems caused by the browser, or for problems arising from the use of a browser incompatible with safe navigation.
We are also not responsible for the failure to carry out operations that are due to facts, acts or omissions caused by other service providers contracted by the User, such as telecommunication service providers, including data transmission via cable or optical fibers, internet access providers Internet or, yet, due to failures of the User’s Internet access terminal, among others.
DOES DEVFY USE COOKIES?
DEVFY collects data that identifies your visit to the website or application to offer you a better and personalized experience, in addition to some information, such as browser type, screen resolution and access date, obtained through reports generated via logs, javascript routines and cookies, the latter also used in statistical reports to improve navigation, the services offered and to count the number of visitors and accesses, thus facilitating the definition of the technological park installed for the website.
If the User voluntarily fills in any form on our website, this information will only be used for the purpose for which it was filled out and which is clarified on the page of each registration. Under no circumstances will your data be provided or sold to third parties.
DOES DEVFY USE YOUR DATA FOR MARKETING PURPOSES?
The DEVFY website and app accept and advertise other brands and partners. The existing banners are to give more emphasis to the contents that deserve more attention from our Users and to promote contents and products that fit with the DEVFY guidelines and that we consider relevant to you and your interests.
DOES DEVFY SHARE COLLECTED DATA WITH THIRD PARTIES?
Subject to item V of Article 9 of the LGPD, DEVFY informs that it does not share, sell, rent or disclose any information of its Users.
It is made known that DEVFY uses Google Analytics, an internet data analysis tool (web analytics), to track the application’s audience data and understand how visitors interact and navigate through our pages.
Google Analytics collects information anonymously, that is, it reports website trends, such as pages visited, time spent on the website, among other information, without identifying individual visitors. Therefore, the personal data shared by Google Analytics with DEVFY is anonymized, pursuant to item III of Article 5 of the LGPD. In this sense, the LGPD does not apply, as provided for in its Article 12. It is worth mentioning that no personal information, such as name, email or telephone number, is collected by Google Analytics.
More details on the Google Analytics privacy policy can be found here http://www.google.com/intl/en_uk/analytics/privacyoverview.html.
DEVFY’s application and website were developed with the Bubble and WordPress platform, to host and store the developed applications, using the infrastructure of Amazon AWS and Hostgator. In this sense, both Bubble and Amazon AWS and Hostgator may have access to certain information entered in the DEVFY application. It is stated that such companies will only access the personal data entered in the DEVFY application, if necessary, and in the strict terms provided for in the LGPD.
THE RIGHT OF THE USER, AS HOLDER OF PERSONAL DATA
As provided for in Article 18 of the LGPD, the User is assured, at any time, upon request to DEVFY via email [email protected], to request:
- Confirmation of the existence of processing of Personal Data;
- Access to Personal Data processed by DEVFY;
- Correction of incomplete, inaccurate or outdated data;
- Anonymization, blocking or deletion of data that is unnecessary, excessive or treated in violation of the LGPD;
- Data portability to another provider;
- Elimination of Personal Data processed with the User’s consent, except in the cases provided for in Article 16 of the LGPD;
- Information from public and private entities with which DEVFY shared data;
- Information about the possibility of not providing consent and about the negative consequences; It is
- Revocation of consent, where applicable.
If the User wants confirmation of the existence or access to their Personal Data, DEVFY will provide, within 5 working days, counting from the date of the User’s request, such information in a simplified format; and within 15 days, counted from the date of the User’s request, a clear and complete statement, indicating the origin of the data, the lack of registration, the criteria used and the purpose of the treatment, observing commercial and industrial secrets.
CHANGES TO THIS PRIVACY POLICY
In the event of any change in relation to the specific purpose of processing Personal Data and Sensitive Personal Data envisaged, or in the form and duration of said treatment, in the identification of DEVFY as the controller of the data or in the information shared by DEVFY and its purpose, this undertakes to inform Users, with specific emphasis on the content of the changes, as provided for in § 6 of Article 8 of the LGPD
DEVFY MANAGER
If the User has any questions regarding the processing of their Personal Data or wants to exercise any of their rights as holder of the personal data, simply contact the person in charge of DEVFY, Mr. André Zampieri Grandino via email [email protected].
