Privacy Policy

Version: April / 2023

Elefante Letrado’s Privacy Policy (“the Policy”) was created to demonstrate ELEFANTE LETRADO SERVIÇOS EDUCACIONAIS LTDA’s, a company registered under CNPJ/ME No. 18.110.449/0001-78, (referred to herein together as “Elefante Letrado”, “we” or “our”), commitment to the security and privacy of the information collected from users, who are also personal data holders (“the Holder”, “the User” or simply “you”), as well as to help them to make informed decisions with regards to their privacy.

The Policy clarifies general conditions for the collection, use, storage, and other forms of processing and protection of personal data on our website www.elefanteletrado.com.br (“the Site”), our Elefante Letrado application (“Application”) and Elefante Letrado Platform

(“the Platform"), in accordance with current Brazilian legislation on privacy and personal data protection, including, but not limited to, Federal Law No. 12.965, of April 23, 2014 and Federal Decree No. 8.771, of May 11, 2016 ("Civil Internet Framework"), Federal Law No. 13.709, of August 14, 2018 (“the Brazilian General Data Protection Act" or "LGPD").

For us to be able to maintain direct contact with data holders, Elefante Letrado has designated a Data Protection Officer responsible for the Processing of Personal Data to administer a communication channel:

Responsible: SiqueiraCastro
Contact: privacidade@elefanteletrado.com.br

This Privacy Policy may be updated or changed at any time, and notice of any changes clearly displayed on our website.

By using our website, you willingly, unequivocally and expressly agree with this Policy in a well-informed manner. We recommend that you read our Privacy Policy carefully.

1. TARGET AUDIENCE

This Privacy Policy applies to persons that:

  • Access our website
  • Access our platform
  • Use our app
  • Request a quote
  • Get in touch with us

2. WHAT PERSONAL DATA PROCESSING IS

Personal data processing (or data processing) refers to any operation carried out with these data. For example:

  • Collecting your data
  • Use of data
  • Access
  • Data Processing
  • Storage
  • Deletion
  • Communication
  • Transfer

Personal data is information referring to an identified or identifiable individual. Data referring to Elefante Letrado’s customers is considered personal data.
 

3. WHO CONTROLS YOUR DATA

For the purposes of this Policy, the Elefante Letrado acts as a controller during processing of your personal data in accordance with applicable legislation and as described in this Policy.

4. PERSONAL DATA COLLECTED BY ELEFANTE

Important: You are not required to provide us with your information. However, without providing certain information when requested, you will not be able to access certain features. In addition to the data you provide, whenever you interact with our Site, Platform or Application, information is automatically collected. Such information is generally not identifiable. However, when combined with other data that can be associated with you, such information will be processed by Elefante Letrado as personal data.

To the extent permitted by applicable laws, Elefante Letrado may process the following personal data that you provide:

SOURCE DATA COLLECTED PURPOSE OF PROCESSING

Navigating our website

Information on navigation:

data collected through means of cookies or device IDs, including IP addresses, access dates and times, pages visited, and duration of visit.

Device information: hardware and software information, model, manufacturer, operating system, unique identifiers, and data on system failures.

Cookies: enable special website functions, generate statistical information,

improve the website, and offer personalized advertising. For more information, please refer to our Cookie Policy.

Registering access: we are legally obligated to

store your information in order to be able to offer it to the authorities when requested.

Forms completed on the website

Contact information (requests from schools or clarification for questions or concerns): name, email, phone, city, State, school name, type of institution, position, number of students between 1 and 5 years of and

Respond to any questions, requests for information on Elefante Letrado and concerns;

messages.

 

Information for newsletters:

email

Allows Elefante Letrado to send newsletters to requesting users.

Message to Elefante: name, email address and message.

Allows Elefante Letrado to

respond to messages from users.

Registration on Elefante Letrado‘s platform

Student registration information: name, enrollment, avatar or photo, class, teacher, school and password.

Register studentS on our

platform, so that they can complete activities required by the school.

Teacher registration information: login, password, school, first name, last name, email, phone, date of birth and language.

Registers teachers on our platform, so that they can generate activities and manage classes.

Legal guardian registration information: email, password, student name, CPF, date of birth, ZIP code, state, city, neighborhood, address, telephone and means of payment (if necessary).

Register those individual responsible for the student in

our platform in order to allow them to monitor student development.

Student registration information: name and photo or avatar.

Register the student in our

Application, so that they can complete activities required by the school.

Please note that the personal data listed above will be collected by Elefante Letrado and further processed only as necessary to achieve the purposes established under this Policy.

We do not knowingly collect, store or otherwise process excessive quantities of data or personal data not required for the purpose for which it was collected, as well as data deemed to be sensitive (data related to ethnicity, religious beliefs, political opinion, membership in a trade union or organization of a religious, philosophical or political nature, health or sexual orientation, as well as genetic data). We, therefore, ask that you refrain from sharing such data with us. If we become aware of such data being inadvertently collected and processed, they will be deleted from our records.

5. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The legal basis for data stored and processed by Elefante Letrado listed in Section 2 will be classified upon the specific context in which we collect such data being analyzed.

Data processed by the Elefante Letrado is only collected:

  • Art. 7, I of Federal Law No. 13.709: With your consent.
  • Art. 7, II of Federal Law No. 13.709: In order to comply with legal or regulatory obligations.
  • Art. 7, V of Federal Law No. 13.709: Whenever necessary to the performance of a contract or preliminary procedures related to the contract.

6. SHARING OF PERSONAL DATA

Whenever necessary in achieving the purposes described in Section 2, Elefante Letrado may share your personal data with the third parties listed below in order to properly provide the services offered, guarantee security in the storage of your personal data, and improve your experience with Elefante Letrado. Whenever necessary, data will only be shared within established limits and according to our specific business purpose, in accordance with the purpose for processing personal data and applicable legislation. This means that your data may be shared with:

  • Olimpus: Company responsible for managing the Application.
  • CWI: Company responsible for management of the Platform.
  • DZ Estúdio: Company responsible for managing our Site
  • RD Station: Company responsible for managing communications received through our website.
  • Security service providers: Guaranteeing the security of information processed by Elefante Letrado.
  • Cloud Servers: Storing information in the cloud.
  • Government Authorities: Responding to complaints, investigations, judicial measures and legal proceedings, if requested, as well as complying with legal, regulatory and tax-related obligations.

7. RIGHTS HELD BY PERSONAL DATA HOLDERS

In the form and within the limits established under applicable laws, you, as a personal data holder, may contact us in order to exercise your rights and request:

  • Confirmation and access: Allows you to confirm whether your personal data is being processed and, if so, request access to a copy of this data.
  • Corrections: Allows you to request that data that is incomplete, inaccurate or outdated be corrected.
  • Anonymization, blocking or deletion: Allows you to request that your data be anonymized (in manner in which such data no longer refers to you), blocked (temporary suspension of the use of your data) or deleted (deleting of data, without potential to reverse operation).
  • Portability: Allows us, upon an express request being made, to deliver your personal data to another service or product provider, in a structured and interoperable format.
  • Sharing Information: Provides users with public and private entities with which personal data is shared.
  • Information regarding the option of not providing consent: Provides users with clear and complete information on the consequences of not providing consent to processing of their personal data.  Users are free to refrain from providing consent, even though this may limit what we are able to deliver.
  • Revoking consent: Allows you to revoke the consent that you have provided at any time, without affecting the legality of data that was previously processed.
  • Objection: Allows you to object to the processing of your personal data if you have not consented to such processing.

Your request can be made free of charge at the email address privacy@elefanteletrado.com.br. We will review your request and complete the requested actions as soon as possible, taking the periods and terms provided for under applicable legislation into account. If it is not possible to immediately fulfill your request, we will describe legal motives and events preventing us from doing so.

Elefante Letrado is not responsible for the accuracy, veracity, authenticity, completeness and updating of data provided by Data Holders. Data Holders are solely responsible for exclusively providing correct, truthful, authentic, complete and up-to-date information.
 

8. HOW WE STORE AND PROCESS PERSONAL DATA

Elefante Letrado adopts security, technical, and administrative measures to ensure that all stored data remains safe through means of internal guidelines, confidentiality clauses and strict access control. Our employees only access data as strictly required in fulfilling the specific purposes described in Section 2. Data collected through our Site are stored, processed and protected through means of best practices for hosting and data processing.

Data Holders must be aware, however, that no Internet security system is guaranteed to offer protection against unwanted intrusions, and Elefante Letrado’s commitment is limited to the adoption of recommended protective measures in accordance with the latest technologies and standards.
 

9. INTERNATIONAL TRANSFER OF PERSONAL DATA

Elefante Letrado will only carry out the international transfer of your data to other countries or international bodies when strictly necessary to achieving the purpose that gave rise to the processing of your personal data, prioritizing, whenever possible, storage on servers located within the Federative Republic of Brazil. Whenever Elefante Letrado transfers your personal data outside of Brazil, we will take appropriate measures to ensure that your personal data is adequately protected in accordance with requirements established under applicable data protection laws, including by entering into the appropriate data transfer agreements with third parties wherever necessary.

10. PERIOD FOR WHICH INFORMATION IS STORED

We will store and retain your information: (i) for legally required periods of time; (ii) until the processing of personal data is complete, as mentioned below; (iii) for the time necessary in safeguarding Elefante Letrado’s regular exercise of rights as part of judicial, administrative or arbitration proceedings. We will, therefore, process your data, for example, during applicable limitation periods or as necessary in complying with legal or regulatory obligations. The processing of personal data will be considered complete in the following cases:

  1. Whenever the purpose for which personal data held by the respective Data Holder was collected is achieved and/or the personal data collected is no longer necessary or relevant in achieving such a purpose;
  2. Whenever the Data Holder withdraws their consent or exercises a right to request that processing of their data be ceased and their personal data deleted; and
  3. When a legal determination is handed down in this regard. Adhering to the principle of necessity, certain data forwarded through Elefante’s Site may be deleted from our records through the maintenance of routine records. We are not obligated to store personal data indefinitely and are exempt from any liability arising from or related to destruction of this personal data. Upon the processing of your personal data being completed, except in the cases established under applicable legislation or this Privacy Policy, they will be deleted from Elefante Letrado’s database. In cases in which it is not initially possible to delete such data, it will be stored securely and isolated from any further processing until deletion is possible.
     

11. COMMUNICATION POLICY

We seek to prevent the sending of unsolicited emails by restricting communications to subjects that are relevant to users or of specific interest. If you prefer not to receive additional information from us, you can request that your subscription be removed through the ‘unsubscribe’ link included in the email itself or in the message received (opt out), or request that your subscription be removed through our Site.
It is important to note that many common scams involve the use of recognized brands in an attempt to obtain personal information such as passwords and financial information. Elefante Letrado WILL NEVER REQUEST FINANCIAL INFORMATION VIA EMAIL OR TELEPHONE. IN THE EVENT THAT ANY OTHER SUSPICIOUS BEHAVIOR OCCURS, YOU CAN FORWARD YOUR CONCERN OR AN ALERT BY EMAIL TO THE ADDRESS privacy@elefanteletrado.com.br.
 

12. LINKS TO OTHER SITES

Our Site may contain links or frames from other websites. These links or frames are used to add additional benefits to the content and services offered to the User.

We wish to clarify that the inclusion of these links on our Site does not infer that Elefante Letrado is aware of, agrees to or is otherwise responsible for the contents of such links and frames. It is important to emphasize that our objective is to merely provide links or frames from reputable and reliable companies, and Elefante Letrado is not responsible for information, products and services obtained by the User on such websites, nor for the commercial practices and privacy policies adopted by these companies. Furthermore, Elefante Letrado will not be held responsible for any losses and damages or loss of profits suffered due to the use of these resources. Given that linked websites are not part of our Site, we do not control, recommend, nor endorse these sites and their content, products, services, policies and their privacy practices; we do not have access to your personal data collected and processed by such websites, as well as their advertising policies, cookies and terms of use. We therefore recommend that you carefully read such documents before using third party websites.

By accessing our Site and interacting with us, you agree and accept the terms established under this document.