Welcome to the Bem na Rede Competition website, called Curious! This Competition Privacy Policy (“Privacy Policy”) is applicable exclusively to participants of the Bem na Rede Competition (“Competition”), who must be Brazilian users.
As further described in this Privacy Policy, the Curious application (the “Platform”) is a product of Child Mind Institute, Inc. (referred to in this policy as “CMI”, “we”, “our” or “us”), a non-profit dedicated to transforming the lives of children and families struggling with mental health and learning disorders by giving them the help they need to thrive.
For participating in the Competition, created and managed by Juntô!, an initiative launched by the Stavros Niarchos Foundation (SNF) Global Center for Child and Adolescent Mental Health at the CMI together with Felipe Neto Institute you as the user(s) of the Platform (hereinafter referred to as "you" or "user") must create an account on the Platform to submit your project.
1. To What Information Does this Privacy Policy Apply?
The privacy and security of your information is very important to us, and we are committed to protecting it through our compliance with this Privacy Policy. Accordingly, we have created this Privacy Policy to describe how we collect, use, protect and disclose the information you provide when you sign up to participate in the Competition. This Privacy Policy should be read in conjunction with our Competition Terms of Use, available at [·] [PNA1] (the “Terms”).
A Note to Parents or Guardians of users younger than 18 years old: In connection with the minor’s participation in the Competition, we collect Personal Information (as defined below) from the minor for the sole purpose of allowing his/her participation in the Competition. For more information, please see Section 7 below titled “Notice to Parents or Guardians of Minors Users”.
2. What Categories of Personal Information Do We Collect?
To allow your participation in the Competition we collect and process limited Personal Information (as defined below), including[PNA2] :
Identifiers, such as your name, email address, country, age, username and password;
Your explanation of the project you submit through the Platform; and
Your image and voice if you choose to upload a video of you explaining your project.
“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular person, but does not include any information that is aggregated.
Additionally, we may automatically collect certain information about you through online technologies when you visit the Platform, that may also constitute Personal Information; such information may include[PNA3] :
IP address or other device address or ID;
The type of browser, operating system or equipment used to access the Platform;
Usage details, such as the date and time you visited the Platform, the Internet address of the site from which you linked to the Site or the Curious App, the links you follow from Platform, and the reading history and other analytics related to how you use and view the content we have provided via the Platform; and
General activity information as part of our fraud-prevention programs.
Please note that for participation in the Competition our collection and process of your Personal Information is very limited and does not include, in any instance, health information or any personal data concerning racial or ethnic origin, religious belief, political opinion, affiliation to trade unions or to a religious, philosophical or political organization, data regarding sex life, genetic or biometric data.
3. From What Sources Do We Collect Personal Information?
All Personal Information we collect in connection with your participation in the Competition is provided directly through you or through your legal representative, such as when you fill out forms or fields, register for an account, engage with us as a representative or contact us or request information about us (whether by email or other means).
Additionally, when you visit the Platform, we may automatically receive and record certain information from your computer, web browser or mobile device that may constitute Personal Information (as further described above).
For example, when you use the Platform, we may send one or more cookies (which are small text files containing a string of alphanumeric characters that are placed either on your computer’s hard drive or in your computer’s random-access memory) to your computer or mobile device to make the Platform easier to navigate, recognize your browser and store visitor preferences, record past activity to provide better service, help analyze our web page flow and/or promote trust and safety.
Please note that if your browser permits, you may configure your browser to refuse or delete cookies, or to alert you when cookies are being sent. Please consult the corresponding instructions of the manufacturer for more detailed information on the actual procedure. If you choose to turn off cookies, however, some parts of the Platform may not work properly. Even if you block or delete cookies, not all of the tracking that we have described in this Privacy Policy will stop.
Do Not Track Disclosure: Third parties such as advertising networks, analytics providers and widget providers may collect information, including Personal Information, about your online activities over time and across different websites when you access or use our services. Currently, “Do Not Track” signals are a privacy preference that users can set in certain web browsers. When a user turns on the “Do Not Track” preference signal, the browser sends signals to websites requesting them not to track the user. The Site does not recognize or respond to “Do Not Track” signals.
4. How Do We Use the Personal Information We Collect?
We may use the Personal Information we collect for the following purposes:
To provide you with information you request from us or to fulfill any other purposes for which you provide such information (including to request parental consent where required under applicable law).
To provide, maintain and administer your Platform account to allow your participation in the Competition.
To analyze the project you submit to the Competition and verify if your project meet the applicable criteria.
To disclose your project if you are one of the winners of the Competition.
To provide you with your prize if you are one of the winners of the Competition.
To contact you for administrative purposes such as account recovery or to notify you of changes to the Platform, our policies or our services.
For any other purpose for which we have your express consent.
Additionally, we may use non-identifying information (including aggregated data) about your access to or use of the Platform to understand and analyze the usage metrics and trends and preferences of our users, to monitor, analyze the effectiveness of or otherwise improve the Platform, and to improve fraud detection and information security, without restriction.
5. To Whom and For What Purpose Do We Disclose Your Personal Information?
We may disclose Personal Information that we collect or you provide as described in this Privacy Policy (whether directly or automatically) to the following categories of third parties for the enumerated processing activities:
To our partners in the conduction of the Competition, which includes Felipe Neto Institute;
To our third-party service providers, including fraud screening providers, hosting providers and other third-party service providers (the foregoing “Service Providers”), to provide application and website development, hosting, data storage, maintenance, accounting, legal, advisory and other services for us.
To third parties as permitted or required to do so by applicable law or regulation or in the good-faith belief that such action is necessary to take precautions against liability; to comply with various reporting obligations; to protect ourselves and our other users from fraudulent, abusive, or unlawful uses or activity; to protect the security or integrity of the Platform; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to comply with state and federal laws; or in response to a court order, judicial or other government subpoena or warrant.
To a buyer, investor or other successor in the event of a business transaction such as a divestiture, merger, consolidation, investment or asset sale, whether as a going concern or in the unlikely event of a bankruptcy or similar proceeding.
To any other third party in any way we may describe to you when you provide such information, to fulfill any other purposes for which you provide such information or for any other purpose with your consent or at your direction.
Additionally, we may disclose aggregated information about our users, and information that cannot independently be used to identify any individual, without restriction.
6. Our Commitment to Minor’s Privacy.
Protecting the privacy of minors is especially important, and we are committed to providing a safe and secure online experience for children who visit the Platform and their families.
The Competition is directed exclusively to users from sixteen (16) years old to twenty (20) years old and therefore, we do not knowingly collect, use or disclose Personal Information from anyone under the age of thirteen (13) in connection with the Competition.
As provided in the Terms, if you are over sixteen (16) years old and under eighteen (18) years old, you need your parents or legal guardians to assist you while on our Platform.
Once you have registered for an account, you or, where applicable, your parent or legal representative, may request updates, corrections, or deletion of your profile information and preferences at any time by submitting a support ticket.
7. Notice to Parents or Guardians of Minors Users
The Competition is target to Brazilian youth from sixteen (16) years old to twenty (20) years old. Accordingly, in connection with our administration of the Competition, we collect and process certain identifiers about minors, as described in this Privacy Policy.
To participate in the Competition, participants must register for an account with the Platform and will need to provide certain identifiers, such as their name, an email address and password; this account will allow the minor to participate in the Competition.
Other than this limited information, we will not collect nor will we require the minor to disclose more information than is reasonably necessary to participate in the Competition.
You can request to review any Personal Information that we have collected on behalf of a minor to which you are the parent or legal representative by asking such information via email at [email protected][PNA4] .
In any instance that we collect Personal Information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request, to ensure the security of our users and our services, or otherwise as required by law. Additionally, other than as described in this Privacy Policy, we do not and will not disclose any such information about the minor.
8. Our Commitment to Data Security.
We follow generally accepted industry standards to protect the Personal Information submitted to us in order to protect against the loss, misuse or alteration of such information; however, no method of transmission over the Internet or of electronic storage is 100 percent secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us through the Platform, and you do so at your own risk.
We are not responsible for circumvention of any privacy settings or security measures contained on Platform. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.
9. Visitors from Outside the United States.
The Site and Curious App are controlled and operated by CMI in the United States. If you are located outside the United States, and choose to access the Platform, you should be aware that the laws of the United States may be deemed to have inadequate data protection by your country; you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to allow your participation in the Competition. Where required, we take all appropriate actions to comply with applicable legal frameworks relating to the collection, storage, use, and transfer of Personal Information.
10. Your privacy rights
You have the following rights in relation to your Personal Information processed by us:
· Obtain confirmation that we process your personal data. In response to this request, we will inform you whether we process your personal data or not.
· Access your personal data. If you are interested, you can receive a report in which we present the personal data related to you and processed by us.
· Correct personal data that is incomplete, inaccurate or out of date. If you understand that your personal data is incorrect, you can request correction, indicating what needs to be changed and why. We may ask for proof to make the required update.
· Request anonymization, blocking or deletion of unnecessary, excessive or processed personal data that does not comply with the provisions of the Brazilian law. If you understand that we are processing your personal data in an unnecessary, excessive or non-compliant manner with the Brazilian law, you can request that the personal data be anonymized, blocked or deleted.
· Request the portability of your personal data to another service or product provider, subject to our commercial and industrial secrets, after regulation by the relevant authority. You are the owner of your own personal data. Therefore, you may request that this personal data be transferred to another service or product provider, in accordance with regulations, as long as commercial and industrial secrets are respected.
· Obtain information about who we share your personal data with. You can request that we provide information on which entities we share your personal data with.
· Obtain information about the possibility of not providing your consent and the respective consequences. When consent is used as a legal basis for the processing of personal data, you have the right to be informed about the possibility of not providing consent and the consequences of refusal.
· Revoke your consent to the processing of your personal data. If your personal data is processed based on consent, you may revoke this consent. As a result, any processing of your personal data that is being carried out based on consent will be ceased.
· Oppose processing that violates the law. If you understand that we are processing your personal data in a manner contrary to the law, you can object to this processing. The request will be analyzed very carefully and, if we agree, the processing of your personal data that does not comply with the law will be ceased.
· Request the review of decisions made solely based on automated processing of your personal data. It is possible that decisions will be made based on the automated processing of your personal data. If this occurs, you can request a review of these decisions.
To exercise your rights or if you have any other questions about our use of your Personal Information, please contact us using the methods set forth in Section 13 below. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to exercise your rights.
11. Legal bases for processing your personal data
Depending on the specific Personal Information concerned and the factual context, when we process Personal Information, we rely on the following legal bases as applicable:
As necessary for our contract: When we enter into a contract (including our Terms) with you, we process your Personal Information on the basis of that contract in order to prepare and enter into the contract, as well as to perform and manage the contract. Where we are relying on this legal basis, we may not be able to provide these activities if we do not process your Personal Information;
Consistent with consent: Where required by law, we also rely on your prior consent to conduct a processing activity. You have the right to withdraw your consent at any time by contacting us using the methods set forth in Section 13 below.
As necessary to comply with our legal obligations: We process your Personal Information to comply with the legal obligations to which we are subject. This may include detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity and includes compliance with applicable laws;
As necessary for our (or others’) legitimate interests: We process your Personal Information based on such legitimate interests to (i) develop, test, and improve our Platform; and (ii) ensure authentication, integrity, security, and safety of us and other persons, including detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
12. Changes and Updates to this Privacy Policy.
We reserve the right to make changes to this Privacy Policy at any time. If we make any material change to this Privacy Policy, we will post the updated Privacy Policy and indicate at the top of the Privacy Policy when it was last updated. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. If you disagree with our Privacy Policy modifications, you may choose not to participate in the Competition.
13. Our Contact Information:
Please contact our Data Protection Officer with any questions or comments about this Privacy Policy at [email protected].
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