In accordance with the rules provided for in Law 13,709/18, which deals with data protection and other relevant legislation, we present the Privacy and Security Policy of Detroit Comunicações. 

​

This document is linked to and integrates the Conditions and Terms of Use of this website, being subject to change at any time to adapt to rules established by legislation that establish the mode of data processing. 

​

Access, visit and stay on this site/blog is free choice and happens according to the will/desire of the user, being his visit and continuation on the site, choice of this user. 

​

Becoming aware through this document that from the moment you maintain access and permanence on any of our pages, you are automatically demonstrating your agreement, explicitly with all the rules and terms brought in the Privacy and Security Policy described below . 

​

It is your right to contact us at any time for more information than has been described here, as well as clarification of any doubts that may exist. 

​

General information:

​

Our website undertakes to comply with and respect the principles set out in art. 6 of the General Data Protection Law, which are listed below and clarified according to the data processing carried out by this website/blog:

​

I – Principle of Purpose: This website/blog complies with the principle of purpose set forth in the aforementioned legislation, carrying out the treatment with a legitimate and specific purpose, informing through this Privacy and Security Policy explicitly, the holders of the data that the reason for the treatment will be treated.   No treatment will be carried out in a way that is incompatible with the purposes that will be informed in this document. 

​

II – Principle of Necessity: We collect and process only the data necessary to carry out the explicit purposes of our website, with the commitment to collect and process the minimum amount of information from our website user. We only use relevant information/data, proportional to the activity performed by us, without exceeding any limit in the relationship between the user and our website/blog, and any and all data is collected and treated in accordance with the purposes established on our pages.

​

III – Principle of Adequacy: All treatment carried out on our pages is compatible with the purposes informed to the user/client, respective data subject, and no type of action or mechanism is carried out that is inconsistent and disrespects the context of necessary treatment.  

​

IV – Non-discrimination: The data that we collect, store and that we carry out any type of treatment are not used for any discriminatory, harassing, illicit or abusive purpose. 

​

V - Principle of Data Quality: We guarantee data subjects clarity and relevance at the time of data collection and processing, in addition to the possibility of updating, as necessary to fulfill the purpose of the treatment, depending on the activity that is carried out. performed by the user/customer on our website. 

​

VI - Principle of Free Access: We clarify through this Privacy and Security Policy that we guarantee to all data holders that we carry out the treatment, the consultation in a free and easy way, at any time they wish, through a specific channel , about the treatment carried out with your data, as well as any information regarding the data collected, and the holder's personal data may even be updated, without the need for any request by our website.

​

VII – Principle of Prevention: We adopt and ensure the prevention of any and all acts that may cause damage to data collected from users/customers, with measures implemented in order to prevent any uncomfortable, illegal situation, or that generates any kind of loss/damage to the personal data that we process. 

​

VIII – Principle of Transparency: We work with clarity, precision, accuracy and veracity in all the information brought about the processing of data, with its easy and available access to the user/client in this Privacy Policy, as well as in the Terms of Use in our website/blog. The information regarding the treatment agents follows the same transparency criteria listed above. All information provided about the treatment and treatment agents respect commercial and industrial secrets. 

​

IX – Principle of Security: We inform you that we use all appropriate and possible measures in the technical and administrative area, aiming at greater protection of personal data, from the moment we have access to them. The techniques used seek to protect personal data from any and all unauthorized access, as well as from situations that may cause damage to the data subject, even if accidental or unlawful. The techniques we use seek to bring security and protection to the holder of the data that we carry out the treatment, since they are taken in order to prevent and protect the information collected from any illicit situation of loss, destruction, sharing, communication or unauthorized dissemination.

​

X – Principle of responsibility and accountability: The agent will demonstrate and prove that it complies with and respects all applicable rules for the Protection of Personal Data, effectively adopting appropriate measures for this purpose. Our website carries out all the steps related to the processing of personal data of users/clients who access it, without disrespecting any rule or principle present in Law 13.709/2018, clearly and objectively stating the purpose for processing each information collected personnel. 

​

About Our website/blog

​

Our website/blog has texts, videos, images, audios, e-books, as well as other content that you can view when accessing our tabs, all without any discriminatory, illicit or defamatory content. 

​

We draw up plans and goals to be followed in order to present valuable content, with relevant information regarding the topic addressed here. 

​

Through this document, we are committed to providing the best result when browsing our user/client, committing ourselves to act and work with complete security and respecting the privacy of the personal data processed. 

​

Pay attention to all the information made available on this page, as it is through it that we clearly and directly show how all the stages of processing the personal information collected take place, including making clear the sharing and disclosure that we carry out with partners.

​

This Privacy and Security Policy may be modified at any time, according to regulatory updates or changes to our Internal Policy, which is why we invite our user/customer to consult this document periodically so that they are aware immediately of any changes that may occur. 

​

Information about the controller and Data Controller

​

As provided for in art. 5 of the General Data Protection Law, we bring here information about the controller defined by the “in verbis” legislation:

​

Art. 5, VI – controller: natural or legal person, public or private, who is responsible for decisions regarding the processing of personal data;

​

Detroit Comunicações is the CONTROLLER and is responsible for defining and making any decision regarding the processing of data carried out by us and our team. 

​

The CONTROLLER is a professional/company of our full trust, who is aware of all the norms brought in the legislation that carries out data protection, in addition to being fully aware and aware of the norms established in our Internal Policy.

​

Information about the Content of the site/blog and Indicative Rating:

​

The content brought is directed to people who are interested, curious or looking for information about the content of our website.

​

All content covered on our pages is produced by our team or by partners, respecting national legislation, as well as ethical and human values, in addition to moral principles, ensuring transparency and truthfulness in all information provided. Our content can be found on Google, Yahoo or other search engines.

​

About data processing:

​

Our website works with certain operations and functionalities which are necessary for the processing of personal data, from the collection stage to its elimination or storage, as will be discussed below:

​

From data collection:

​

We collect data from users/visitors/clients of our website not only to carry out the services we provide, but also for security purposes, since any irregular or unlawful act practiced by it may be subject to specific consequences for the person responsible.

​

The use of certain functions on our website expressly depends on the collection of user data such as: name, contact telephone number, e-mail, as well as other applicable data for the purpose presented on the website.

​

Data Collection can take place in all areas of our website/blog, as it happens by filling out forms, FAQ, sending questions, chatting or registering. 

​

We are also aware that when filling out the form/FAQ/Registration or any type of area regarding the return of contact or doubts on our website, as well as the ACCEPTANCE of the COOKIES we use, THE USER /CUSTOMER demonstrates THE AGREEMENT in an objective, clear and express way of the collection and processing of your data that will be carried out by the site/site team/site partners respecting all personal data protection rules. 

​

It is also essential to inform that we work with a data analysis tool (analytics or similar) to monitor the results of accesses, comments, among other information about the performance of our website/blog. 

​

Other data

​

Our website also collects and processes data relating to the device and linked to the access record. 

​

• Device data: We collect data linked to the device that accesses our website, mainly for security reasons – data such as: hardware model, operating system, device identifiers (location and etc.). 

• Access Records: We collect and handle actions related to the use of data, from its inclusion to the deletion of data, user/client IP, date (day/month/year), time of access performed.

• Browsing data: We collect and process data related to browsing, so we can provide a better experience for the user/client - browser where the user accessed and pages accessed. 

​

​

Data collection method

​

The collection of data from our users/clients takes place respecting all the principles and norms set out in the General Data Protection Law, with the express condition of the user's free and spontaneous consent for this, since we do not carry out any treatment without the permission of the user/client. customer or the person in charge. 

​

We do not use any coercive, authoritarian, oppressive, repressive or abusive means in order to obtain user consent for the processing of their data. 

​

* User's personal data: Collected through forms, FAQs, Contact Us, etc.

* Device Data: Collected/Transmitted/Transferred by accessing the service via the internet

* Access Log: Collected/Transmitted/Transferred by accessing the service via the internet

* Browsing data: Collected through cookies while browsing the site. 

​

The collection of personal data can take place in different places, pages and tabs of our website, by filling out forms, FAQs, chat and registrations necessary for sending materials, making purchases or sending information.

​

Access logs and device data are collected for the safety of the user/client as well as the owner of the site and his entire team through access to the service we provide, which happens when accessing our page.

​

As we seek to get to know our public better, we work with some mechanisms and platforms that automatically collect data from our users/clients directly through the system, respecting all the rules of the LGPD, as well as the user's privacy, providing all the technical and security administrators.

Browsing data is collected by our cookies from the moment you start browsing our website/blog. 

​

Purpose of processing personal data

​

All data that we process are used in compliance with the principles of the General Data Protection Law, especially that of purpose, suitability and necessity, and are only kept in our system until the moment their purpose continues to exist.

​

User/client data: Identify the user/client for the purpose of registering/sending materials/answering questions/sending news and etc. 

​

Device data: Bring better access to the user, because through the collected data we can better adapt the site/blog to the device/browser of the user/client.

​

Access Record: Through this data we provide greater security to the site owners and users, as this way we can identify any act that takes place within our site/blog.

​

Browsing Information: Through this information we know our user better, being able to pass on content that he is interested in, as well as indicating service from our partners that he shows preference, which will be found through the pages that he most accessed.

​

User data is collected and treated solely for the purpose for which they are provided, being explicit in each part of our website/blog for what the data provided will be used, whether through registration, FAQ, submission of forms, submission of news and etc. 

​

Device data is processed so that we can provide the best experience when accessing the website, since it is through it that we can adapt the website/blog view to the device/browser used.

​

Access records are essential items when collecting and processing our website/blog, as it is through them that we can provide greater security for users and our team, since through this data you can identify information such as IP address, date, time, activity performed, etc., in any area of our website/blog, which may target any illicit act that may occur. 

​

Navigation information is the best way to bring our content and that of our partners to you, as it is through navigation information that we share news, advertisements and other materials of your choice for each user. This preference is objectified by data found on pages most accessed by the user/client. 

​

Treatment performed on the data

​

The processing of data carried out on our website / blog respects all the rules provided for in data protection legislation, having a legal basis to be carried out, happening only with the user's consent. All processed data is available for alteration and updating at any time, including throughout its storage. 

​

All data collected will be stored and may be changed according to the need for the service provided, or due to any provision that may exist. 

​

Personal Data: Collection, storage, sharing, communication.

​

Device Data: Collecting, storing, processing, sharing, communicating information from devices that visit our website/blog.

​

Browsing Data: Collection, storage, processing, sharing, communication of information linked to preferences and behavior of the user/visitor who accesses our website/blog.

​

data not collected

​

Respecting the principles contained at the beginning of this Privacy and Security Policy, we do not collect any data that is not necessary for the services we provide, or that has a purpose other than those informed. 

​

We do not collect sensitive data, except in cases where there is a legal determination to do so, the user being expressly informed of the need for treatment, if any, as well as the treatment that will be carried out with him. 

​

Sharing/disclosure/publication of collected data

​

We respect all the limits set forth in the General Data Protection Law regarding the sharing/dissemination or publication of data collected by us, acting in good faith and morally without any intention of causing harm to our user/client.

​

The data will only be shared with partners, if necessary, the user being aware that he grants the sharing of his data by accepting to fill out forms on our website/blog in exchange for free materials.

 

The data collected and shared according to the information mentioned above can generate monetary return to the owner and the team of the site/blog, since when filling out forms in exchange for materials, it becomes the right of this site/blog to share the information provided in order to generate income for keep this project. 

 

In cases provided for by law, bulletin, or if we receive any type of determination from a public authority or through some regulatory determination, data is shared, published or disclosed. 

 

The holder has the right to allow the sharing and access of his data to a third party, provided that he expressly informs the permission he has given to the holder. 

 

In situations where we are informed that there is a criminal investigation when cooperation is requested from our website, we make our users/customers aware that we cooperate as requested. 

​

About our partners

​

All partners who work with us respect the rules set forth in the General Data Protection Act, as well as other legislation dealing with this subject. 

​

We inform you that our website contains links and hyperlinks from our partners, when clicking on any of these links or hyperlinks you are directed to an external website, which has no connection with our website, having Privacy and Security Policy, Internal Policy and Terms of Use different from ours. 

​

We have no power or information to discuss how data is processed by our partners, so make sure you are familiar with the Privacy Policy, Terms of Use, as well as other documents that deal with their data processing._cc781905-5cde -3194-bb3b-136bad5cf58d_

​

About our Team

​

Our team is aware of all the technical and administrative mechanisms that must be used in the processing of data, as we inform in our Internal Policy, known by all our employees, the way in which all stages of data processing must take place, respecting privacy and all rules brought in Law 13.709/18. 

 

NOTE: Every team that works with us is aware of all the practices and techniques that must be used in the treatment of the data we collect, as everyone has had and continues to have access to our Internal Policy and Governance Policy, as well as specific training for this , and any act considered illicit or harmful to the data subject will generate direct liability and will be reasonable grounds for dismissal with just cause.

​

Security in Data Processing

​

Our website is committed to taking any and all technical, administrative and institutional measures regarding the protection of personal data. The security techniques used protect user/customer data from access by unauthorized third parties, as well as from any occasion that may bring about any type of modification, destruction, diffusion, sharing, disclosure, communication of data without authorization and disrespecting the General Law Data Protection. 

All protection and security measures are taken specifically for the data collected, respecting the context and purpose that this information has. 

​

Our site applies encryption and/or firewall, thus providing the transmission in a safe, private and confidential way. The transmissions that take place between the transmitter and the user/clients are fully encrypted, in an effort to protect the collected data. 

​

We undertake to notify the data subject of any violation or suspicious access that may cause any risk of damage to the personal rights and freedoms of the subject. We provide the communication channel at the end of this text so that our user/client can report any situation that identifies failure, security vulnerability or defect in the processing of collected data. 

​

Cookies and Newsletter

​

Cookies are files that have small sizes and are sent by our website to your computer, so that we can store navigation information and user/customer data necessary for the service we perform. 

​

Cookies are the means by which we quickly record data and preferences of our users/clients so that we can provide an adequate experience when accessing our page, including services related to the searches you make on our website. /blog. 

​

We also inform you that not all cookies brought on this site/blog collect and store personal data, as some of the cookies brought are used to perform some of the services we provide. 

  “newlestter” is the means by which we notify and inform our users/customers of any updates we make. 

​

The data informed to “newlestter” is used only for this purpose, without any contrary destination or that violates Data Protection legislation. 

​

You are not obliged to accept the "cookies" or the "newlestter", it is your free choice whether or not to register the "cookies", if you do not want it to happen, use the option in your browser/device to deactivate the registration of cookies.

 

We inform you that deactivating cookies may bring you an incomplete experience or failures in your visit to our website/blog, in addition to not bringing the correct performance of the tools and functions that we make available on our pages. 

 

Disabling cookies may also cause damage to the provision of our end service, as well as, in some cases, we will not be able to provide you with an experience that is more adequate to your preferences because we will not have access to them. 

​

Data processing for other purposes

​

Respecting the provisions of the General Data Protection Law, we inform our users/customers that we can process their data for different purposes later, without this causing any damage or disrespect to the data subject, informing below the purpose of subsequent use of the information collected. 

​

The information we collect about the holder, device, navigation, location, etc., may continue to be used so that we develop the provision of better services and a better experience for the user/customer on our page.

​

If the data subject requests the deletion of his data, he can contact us by the email informed in this Privacy Policy. 

​

After the holder's request for deletion of his data happens, we will anonymize the data, and these will remain in our files in anonymized form, and may be used in the future for the purpose of research, generation of statistics, dissemination of specific information, and also, in publications. 

​

User Consent

​

The user/customer, when accessing our website/blog, demonstrates that he/she agrees with all the information contained in our Privacy Policy and Terms of Use, as well as freely and spontaneously granting that his/her data be treated by our team, respecting the principles of purpose, need and suitability. 

​

User/customer consent is free, since we do not use any means of coercion, obligation, inducement, constraint, threat or imposition for the user/customer to grant and allow the processing of their data.

​

data deletion

​

If the user/customer does not allow the storage of their data, they can contact us through the contact channels below:

E-mail: contato@detroitcomunicacao.com

Phone: +55 (54) 992222772

​

After the data deletion request, we have a period of 90 days for the data to be deleted or anonymized.

​

Contact Channels and person in charge

​

We provide contact channels for our user/customer in order to have a clear and cordial relationship, making us available to clarify any doubts about our website, as well as about the way we carry out the treatment of their data.

Through this professional, we seek to have better and more direct communication with our users/clients.

Below are Service Channels for you to contact our data controller:

​

• E-mail: contato@detroitcomunicacao.com

• Phone: +55 (54) 992222772

​

This Privacy and Security Policy will be valid from January 4, 2023 with indefinite validity.