v.18.10.2019
Page 1 of 7
OBVIA METHOD APPLICATION PRIVACY POLICY
OBVIA EDITORA LTDA (hereinafter “OBVIA PUBLISHERS” or “Obvia Method” or “we” or “us”),
registered with CNPJ/MF under nº 15.699.096/0001-03, operator of Obvia Method Application
(“APP”). This Privacy Policy applies solely to information collected by us in our APP and describes our
privacy practices, including those relating to users of our APP ("you"). This Privacy Policy also
describes the options available to you regarding the use of your information collected in this APP and
your choices regarding the collection and use of such information.
1. INFORMATION COLLECTED
We collect information when you visit the APP, including information about navigation, usage, and
interactions. The information we collect about you: the type of Internet browser, browser language,
and operating system you use; the Internet Protocol (“IP”) address of your device; access dates and
times; unique device identifiers as well as hardware or operating system device identifiers (for
example, IDFA for iOS and AAID for Android); connection type (wired or Wi-Fi); the region where
your device is located; network to which your device is connected; longitude/latitude of a device
(mobile); SDK data; engagement data; geo-IP data; the mobile carrier (if available); the APP you
came before and visited after; We also collect personal information, such as your name, address,
phone number, and email address.
By providing this information, you consent to OBVIA PUBLISHERS Method contacting you to answer
your questions and as permitted by this Privacy Policy. You may also submit personal information,
such as name and email address, to subscribe to one of our newsletters.
Some sections of the APP (including certain password protected sections) are accessible only by
employees or representatives of corporate customers. Each of our agreements with Business
Customers may contain terms that establish OBVIA PUBLISHERS more specific obligations and rights
with respect to the use and disclosure of information we collect from a specific Business Customer. In
addition, employees or representatives of current or prospective Business Customers must submit
certain portions of their personal information so that we may be contacted in connection with (or to
enable us to provide) one or more of our Services. Such personal information may include, without
limitation, the name, telephone and email of an entity or any employee or representative.
v.18.10.2019
Page 2 of 7
2. THE USE OF COOKIES AND SIMILAR TECHNOLOGIES
Cookies are information that may be placed on your computer by an APP to facilitate and improve
your communication and interaction with the APP. We and certain third-party business partners,
suppliers and advertisers may use cookies (or clear gifs, web beacons or similar devices, including
mobile devices) to collect information and other behavioral data from you for purposes such as
advertising targeting services and better understand the effectiveness of our ads. We use different
types of cookies and some cookies are placed in the following categories (note that some cookies may
be used differently by different business customers):
v.18.10.2019
Page 3 of 7
Analytical/performance cookies. They allow us to recognize a returning visitor to the APP from a
OBVIA PUBLISHERS Marketing Business Client.
Cookies of functionality. They are used to recognize you when you return to the APP from some
OBVIA PUBLISHERS Business Customer. This allows us to customize advertising content for you
and remember your preferences (for example, your choice of language or region).
Cookies of segmentation. These cookies record your visit to the APP from some OBVIA
PUBLISHERS Business Customer, the pages you visit, and the links you follow. We use this
information to make display advertising more relevant to your interests.
2.1. Cookie Disable Request
We collect your consent to process your personal information at the time of your registration on the
page. You may set your browser to refuse cookies, or to alert you when sent in this case, some parts
of the Service may not function properly. To withdraw your consent or to learn more about your
rights as a data subject, see below.
2.2. Web browser
You can stop or restrict the placement of cookies on your computer or remove them from your
browser by adjusting your browser preferences. There are also many programs that allow you to
manually delete your cookies.
The online advertising industry also provides webAPPs from which you may opt out of receiving
interest-targeted advertising/advertising from OBVIA PUBLISHERS, our data partners, and our other
advertising partners participating in self-regulatory programs. To make it clear, targeted ads should
be deleted on each device and browser you want to disable. For example, if you turned off your
computer browser, this cancellation will not be effective on your mobile device. You must disable
each device separately. However, once you have disabled a device ("Device Disabled"), we will not
use any new data from the device you withdraw to identify it on another device for interest-based
advertising, and we will not use data from another device for advertising with interest based on the
Default Device.
v.18.10.2019
Page 4 of 7
If you delete or change your cookie/device settings (including updating certain browsers or devices),
you may need to perform each deactivation process again unless we can match the device as
described above. Even if you disable cookie-based targeted ads, you may still see ads based on other
general factors, such as web page context or browser type.
2.3. Disabling third party marketing
If you do not want your personal information to be shared with third parties who may use this
information for direct marketing purposes, you may cancel such disclosures by sending an email to
privacy@obviapublishers.com. However, we are not responsible for the removal of your personal
information from third party lists that were previously provided with your information in accordance
with this Privacy Policy.
v.18.10.2019
Page 5 of 7
3. USE AND DISCLOSURE OF INFORMATION
We may use and disclose your information, which may include your personal information, as follows:
We use your information, as provided by you through the APP, to contact and correspond with you
and/or answer your questions, as well as for other business purposes, such as adding you to our
marketing lists and reviewing your application to become a customer.
If you are a Business Customer, we use and disclose your personal information as necessary to
provide the Contracted Services.
We also use your information to analyze your interactions and performance of our APP,
determine how much time visitors spent on the APP, improve our APP and our Services, our
research activities, and collect demographic information about our user base as a whole.
We may share your information with other companies in our economic group to conduct internal
reviews to improve our services and the services of our other companies.
We disclose your information to third parties providing services on our behalf. For example, and
without limitation: (a) integrated companies required to provide the services in accordance with
the contracted offer; (b) we may also share Commercial Customer credit card information with
our third party payment and banking portal for the purpose of collecting payments due to us or
to facilitate payment to a Commercial Customer; (c) we may share information relating to any
sweepstakes, contests or other promotions that you enter or intend to enter for the purpose of
facilitating your participation in that sweepstakes, content or other promotion.
In the event of a disclosure to third parties to perform services on our behalf, such third parties
will have access to your information for the purpose of performing services for us and for use in
a manner directed by us, the use of which will be consistent with this Policy. Privacy and any
consents you provide.
We may disclose your information upon (a) requests from local, state or federal authorities or law
enforcement officials; (b) any judicial, administrative or similar proceeding or order, such as
intimation; (c) if required by law; or (d) investigate suspected fraud, harassment, physical
v.18.10.2019
Page 6 of 7
threats, or other violations of any law, rule or regulation, this Privacy Policy, or the rights of third
parties or investigate any suspicious conduct that we deem inappropriate.
We do not sell your personal information to third parties or to mass marketers.
Finally, please note that if you specifically agree to additional uses or disclosures of your
information, we may use your information in a manner consistent with that consent.
To be clear, we may, to the extent permitted by applicable law, collect or create information other
than personal information, such as aggregate data sets and other generalized information, including
information about navigation, use and interactions, and unidentified personal information that does
not disclose your identity. We retain the right to use and disclose non-personal information in any
manner permitted by law.
4. USERS RIGHTS
Brazilian data protection law applies to the processing of your information, we provide the controls
described in this policy so that you can exercise your right to request access, update, removal and
restriction of the processing of your information. You also have the right to object to the processing
of your information or to export your information to another service. When you first visit an APP or
app, we read cookies and similar technologies in your device's web browser or in connection with the
apps you use, allowing us to identify browsers and devices that have already interacted with our
Services or Business Clients. This initial reading of cookies and similar technologies allows us to
determine whether you or your device user (s) have previously consented to the use of “personal
data” as defined by applicable law. References in this privacy policy to the collection and use of your
personal data will occur only after we determine the appropriate legal basis for processing such
information: (i) consent, (ii) legitimate interest (as described below), (iii) performance of a contract
or (iii) our compliance with a legal obligation. References to the exclusion possibilities set forth above
will apply to you if you have first given consent to the use of your personal data. They will also watch
the rights listed below:
Access, Correction, Restriction, Deletion and Portability: You have the right to (i) access your
personal data that we may have on our system (s); (ii) request the correction of your personal
data that we have in or system (s); (iii) contest or request to restrict the processing of your
personal data under certain circumstances; (iv) request the deletion of your personal data from
our system (s) under certain circumstances; and (v) request the transfer of your personal data
out of our system (s) in a commonly used format. To exercise the rights of access, correction,
restriction, deletion and portability, please contact us on the channels indicated in this Policy.
v.18.10.2019
Page 7 of 7
Withdrawal of consent: When we are relying on consent to process your personal data, you have
the right to withdraw your consent at any time. However, it will not affect the legality of any
processing performed before you withdraw your consent. To withdraw your consent, please
submit a request through the channels indicated in this Policy.
Right to file a complaint: Please contact us in the first instance with any complaints you may have
by sending an email to privacy@obviapublishers.com
OBVIA PUBLISHERS will make all reasonable efforts to facilitate the exercise of the above rights in
accordance with applicable data protection laws. Please note that in order to claim these rights, we
need to verify your identity to confirm your rights. This is a security measure to ensure that personal
data is not disclosed to anyone who is not entitled to receive it. To verify your identity, we may need
to collect more personal information from you than we currently have.
4.1. Legal basis for the use of personal data:
There are different legal bases on which we rely to use your personal data, namely: - Legitimate
interest: We may process your personal data for our legitimate interests. For example, to provide or
improve our Services, manage relationships with Corporate Customers, or for security and fraud
prevention purposes. When we process personal information to serve our legitimate interests, we
create safeguards to ensure that your privacy is protected and to ensure that our legitimate interests
are not undone by your interests or fundamental rights and freedoms.
v.18.10.2019
Page 8 of 7
Consent: We will rely on your consent to use your personal data (including, without limitation,
technical data, cookie data, usage information, and geolocation data), for the purposes of
personalized or interest-based advertising. You may choose not to use your data usage at any time
by using this subject access request page or by using the tools described above.
Agreement Compliance: We will process your business contact information you provide when you
sign up for our services to provide the Services and manage relationships. We will also contact you
about additional opportunities on our Services to make sure you are aware of all available options. In
addition to other rights, users also have the right to be informed of the following:
Data Sharing: Direct recipients of your personal data include our corporate partners as well as
business customers. There may also be indirect recipients of a limited amount of personal data
based on your access to the Service.
Duration of processing: OBVIA PUBLISHERS may actively process your personal data for two
years from the time of your last interaction with our Services or our Commercial Clients' APPs or
applications (“Interaction Date”). We may, however, store your data in a pseudonymized or
anonymized form for up to seven (7) years after the Interaction Date in order to comply with
other legal requirements. After this time, we will delete your personal data from our system (s).
Personal Data Transfers: OBVIA PUBLISHERS and our Business Customers may be located in
various countries of the world. As a result, personal data may also be transferred from the EU to
the United States and other jurisdictions whose laws may differ from those of the EU. Obvia relies
on OBVIA PUBLISHERS Binding Corporate Rules for data transfers to entities outside OBVIA
PUBLISHERS Group in countries that have not been deemed to provide an adequate level of
protection by the European Commission, we may use specific agreements promulgated by the
European Commission, such as the Standard Contractual Clauses.
5. SAFETY
We take appropriate security measures to protect against unauthorized access or unauthorized
alteration, disclosure or destruction of personal information. This includes the physical, electronic,
and administrative procedures necessary to protect the integrity, access, and use of data. Please
note that no internet transmission method or electronic storage method is 100% secure. As a result,
we strive to protect your personal information, but we cannot guarantee or guarantee the security of
your information against any potential loss or unauthorized access.
v.18.10.2019
Page 9 of 7
6. CHANGE IN CONTROL
Without limiting our other rights to transfer data and information as set forth in this Privacy Policy, in
the event that OBVIA PUBLISHERS sells or transfers ownership, operation or control, is acquired or
merged with a third party, or in the unlikely event of Bankruptcy, OBVIA PUBLISHERS' insolvency,
reorganization, judicial liquidation or assignment for the benefit of creditors, or the application of fair
laws or principles that affect the rights of creditors in general, OBVIA PUBLISHERS reserves the right,
in any of these circumstances, to transfer or assign the information. We collect (including any
personal information, if any) as part of such merger, acquisition, sale, reorganization or other change
of control. Any entity that purchases assets comprising or consisting of your information must agree
to deal with such information in accordance with the terms of this Privacy Policy.
7. COMMENTS AND QUESTIONS
We use reasonable processes to ensure compliance with this Privacy Policy and periodically check
that the policy is accurate. We encourage you to raise any concerns using the contact information
provided below, and we will investigate and attempt to resolve any complaints and disputes
regarding the use and disclosure of information. For any questions regarding our privacy practices,
you can contact us at privacy@obviapublishers.com.
8. APPS AND THIRD PARTY PARTNERS
Our APP may contain links to other APPs, including APPs from our trading partners. Other APPs may
also reference or link to our APP. Some of our partners or third party APPs may place their own
cookies and /or other data collection tools on your Internet browser; however, we do not have access
to or control over these cookies and/or other data collection tools. These other domains and/or APPs
are not controlled by us. We encourage our users to read the privacy policies of each of the APPs they
interact with. We do not endorse, select or approve and are not responsible for the privacy practices
or the content of these other APPs. Visiting these other APPs is at your own risk.
9. CHANGES TO THIS PRIVACY POLICY
OBVIA PUBLISHERS reserves the right to change or replace this Privacy Policy at any time and from
time to time. Any changes or substitutions will be noted through indications in our APP related to this
Privacy Policy. You will be deemed aware and subject to change in the Privacy Policy after the notice
v.18.10.2019
Page 10 of 7
has been posted. We will state the date this Privacy Policy was last updated. We encourage you to
review our Privacy Policy regularly.
10. CONTACT INFORMATION
Our postal address is: Obvia Editora Ltda. Rondon Pacheco Avenue, 4175, room 07, Cazeca, Zip Code:
38450-050 - Uberlândia/MG.
OBVIA PUBLISHERS privacy team can be reached at privacy@obviapublishers.com
Personal Information: The personal data entered in the Application will be stored in our databases, in
a secure environment, ensuring their confidentiality and confidentiality.
10.1. Audience Statistics: Audience information, such as APP traffic, User browsing, and most visited
pages, is intended for statistical surveys to continuously improve our applications and better meet
the needs of your Users.
10.2. It is important to note that the User must take certain precautions when accessing the secure
area, such as: (i) the use of sequential passwords or not containing personal data and (ii) periodic
password change.
11. SHARING INFORMATION
11.1. You hereby agree and agree that OBVIA PUBLISHERS may share this information with third
parties if required by law or court order. To help provide our services we occasionally provide
information to other companies that work with us, such as:
Protection or defense of our legal or property rights, or our Users.
Customization of content and ads according to users profile and preferences.
v.18.10.2019
Page 11 of 7
Supply of loyalty programs, User base, profiles and usage patterns.
11.2. Your choices and personal information can be updated at any time in your account. To make
any updates or changes, see our App.
11.3. OBVIA PUBLISHERS will, from time to time, as users change their information, or at the
initiative of OBVIA PUBLISHERS, collect information that may be used to improve the application
itself. This information will be stored anonymously and will not be associated with your name or
Account.
11.4. OBVIA PUBLISHERS does not sell or rent users' personal information to third parties.
