1. Welcome to our Privacy Policy

We would like to thank you for dedicating your time to reading our Privacy Policy!

In order to be able to guarantee the functionalities of GoBuddies platforms, as well as enabling the registration of users, we request information and data with the permanent objective of collecting the minimum necessary, and in respect for your privacy.

Through this Privacy Policy, we inform you the reason for which we collect your information and data, as well as the treatment these receive. Our objective is to describe our privacy practices in a simple language, so it can be easily understood. To this end, we have drafted this Privacy Policy using the following topics:

1. Welcome to our Privacy Policy
2. 2. Introduction
3. 3. Information and data collected
4. 4. ID of your device
5. 5. How the information collected is used
6. 6. Relationship with partners and advertisers
7. 7. Responsibility, protection and security for your information and data
8. 8. How the personal data of children and teenagers are treated
9. Treatment time for your data
10. 10. Transfer of data among group companies and to other countries
11. 11. Rights of the owners of data
12. 12. Interpretation, changes and updates to the Privacy Policy
13. 13. Cancellation of subscription
14. 14. How to contact us

2. Introduction

This Privacy Policy comes in force on 21/Jan/2020 and applies to all GoBuddies platforms users (app and website), such as individuals, business entities and advertisers.

We encourage our users to read this Privacy Policy carefully and with attention, as well as suggest saving a copy for eventual future consultations.

GoBuddies platforms are offered by Knox Advisors Brasil – EIRELI (“Knox”), business entity in private law registered at CNPJ of MF under no. 30.480.398/0001-71, established at Rua Chile 1.385, CJ. 02, Prado Velho, Curitiba (PR), 80215-184.

In Brazil, Knox is the controller of your information and personal data. To deal with issues in connection with this Privacy Policy, please contact our data protection department through privacy@gobuddies.com.

Said department is responsible for accepting complaints and communications from the owners of personal data and provide clarification as well as adopting necessary measures, receiving communications from the National Data Protection Authority (Autoridade Nacional de Proteção de Dados – ANPD) and adopting any pertinent measures, instructing Knox employees and outsourced service providers in terms of the practices to be deployed with relation to the protection of personal data and delivery of other attributions as determined by the controller, or established in supplementary regulations.

On reading and accepting this Privacy Policy, you hereby acknowledge its terms and conditions and agree to be fully bound by its dispositions of your own free will, as well as expressly consenting to our treatment of your data for the purposes of the GoBuddies platforms.

Whenever using GoBuddies platforms on behalf of a company, entity or organization, you declare being its legal representative, power of attorney or duly authorized representative to represent and act on its behalf, as well as, on reading and accepting this Privacy Policy, you acknowledge its terms and conditions and agree that the company, entity or organization which you represent is fully bound to its dispositions of their own free will.

This Privacy Policy applies exclusively to our privacy practices and not those of third parties, which must or should have their own privacy policies.

This Privacy Policy applies and must be addressed by users regardless of the form of access to GoBuddies platforms, whether through the website or app on a mobile device.

This Privacy Policy applies exclusively to individuals and business entities located on the Brazilian territory, country in which the GoBuddies platforms were developed and are in operation.

In the event that you do not agree with the dispositions of this Privacy Policy or in the Use Terms and Conditions, do not access GoBuddies platforms and do not register as a user, because the treatment of personal data is mandatory condition for the deployment of our platform and for the practice of our entitlement. Using GoBuddies platforms implies in the express, unequivocal and total acceptance of the dispositions contained in this Privacy Policy.

Given that GoBuddies platforms may offer additional functionalities, applications and services, we kindly request you to analyze and accept any supplementary privacy policies. Should it conflict with those in this Privacy Policy, it shall prevail over these with relation exclusively to the additional functionality, application and/or services, limited to the issues of the conflict.

Your privacy is our priority. We understand that you trust our integrity when providing your information and data, which will be cared for and treated transparently and in line with all current good security practices.

3. Information and data collected

To register a user, the following information and data are requested:

1. Name and last name;
2. Identification document number, such as ID or driving licence;
3. Picture of ID document or driving licence;
4. Date of birth;
5. Gender;
6. Nationality;
7. Complete address;
8. Mobile telephone number;
9. Email;
10. Picture of the user;
11. Language(s);
12. Name of login (access);
13.  

The following information is requested from the user in order to register a child or teenager:

1. A chosen image representing the child or teenager;
2. Name of child or teenager;
3. Date of birth of child or teenager;
4. Level of relationship between user and child or teenager;
5. Gender of child or teenager;
6. Hobbies of child or teenager;
7. Language(s) spoken by child or teenager.

The following information and data are requested to register corporate users or advertisers in Brazil or equivalent documents from companies abroad:

1. Company name;
2. CNPJ (Brazilian taxpayer ID);
3. Logotype or trademark;
4. Name, RG and CPF of legal representative;
5. Picture of RG or CNH of legal representative;
6. Complete address;
7. Telephone number;
8. Email;
9. Picture(s) of the facility;
10. Login name (access);
11.  

For your protection and for that of all our users, we may request evidence of your identity before your registration is approved or even in order to keep it active.

In addition to the information provided, other information and data about you may have to be collected for the purpose of performing financial collection for paid services. On subscribing to any of the paid services in GoBuddies platforms, we clearly state that you must provide us, or our payment services supplier, with information in connection with your debit or credit card or other financial information, as well as authorizing us to share your data with a partner financial institution and/or a means of payment partner.

We do not store financial data or data in connection with financial transactions performed by users.

GoBuddies platforms might enable your pre-user registration through the data from your login information on social media. In this case, you must allow sharing this information from your account and profile on social media with the GoBuddies platforms, as well as stating that any and all information contained therein is true and correct. Further, you acknowledge and state that you agree with all the conditions and rules contained in the Privacy Policy, Data Policy and Use Terms and Conditions of the social media used, thereby implying in the assumption of full and unrestricted acknowledgment and acceptance of said policies.

In order for the full operation of GoBuddies platforms, you hereby express and specifically authorize us to collect your exact geolocation, with latitude and longitude, through your mobile device or platforms which you use, such as GPS, Bluetooth and Wi-Fi connections, as well as granting us access to the camera on your device. If you authorize us, we will also be able to collect your geolocation when you’re not using our platforms.

For the full operation of GoBuddies platforms, you hereby express and specifically authorize us to collect files, such as pictures and videos, only when used in our platforms. To this end, you grant us a global nonexclusive, transferable, sub-licensable, royalty-free access to any content of your intellectual property you may come to publish (“Intellectual Property License”). This Intellectual Property License ends when you exclude or request the exclusion of any context of your intellectual property or of your account, except when your content has been shared with third parties of other users and they may not have excluded it. In addition, you must be attentive to item 9 of this Privacy Policy that rules on the time of treatment of your data.

GoBuddies platforms are entitled to deploying outsourced services for identity checks, for the purpose of checking and validating the user’s identity, as well as of their pictures and/or of their ID documents provided.

In the event that you choose to participate in our promotions or events, you hereby state being aware that the information required for your registration or subscription will be used.

On contacting our users care team, the information provided during the contact will be collected, monitored and/or stored, both for the purpose of guaranteeing your security and privacy as well as for guaranteeing the quality of our service delivery.

Conversations among users may also be collected, monitored and/or stored for the purpose of guaranteeing your security and privacy.

Under no circumstances, will we request sensitive personal data, as defined in Law no. 13,709/2018 (“LGPD”) as “personal data about racial or ethnic origin, religious conviction, political opinion, and affiliation to trade union or organization of religious, philosophical or political nature, data with respect to health and or sex life, genetic or biometric data, whenever linked to an individual person”.

4. ID of your device

When you access our platforms, we will receive and collect or store the exclusive identification number linked to your device (“Device ID”), cell phone service operator, brand and type of device, telephone number and, depending on the configurations of your mobile device, data of your geographic location, including GPS (i.e., latitude and/or longitude) coordinates or any other similar information related to the location of your mobile device.

We do not collect your precise geographic location without your consent, but we may be aware of the city or country in which you are located. As happens with IP addresses, the Device ID for the device on which you are accessing the platform, may be crosslinked to any of the contact information or other personal information you have provided during your use of our platforms.

We do not deploy cookies to maintain, store and/or retrieve user browsing or usage information. On the other hand, we use encoded tokens to store, for instance, information on who the user is. This resource enables us to store data to further enhance your experience with the GoBuddies platforms. You will not be able to prevent us from saving your data, but you will be able to erase or request their exclusion. However, this may interfere in the quality of your experience in our platforms.

 On clicking on accept this Privacy Policy, you are agreeing with our usage of encoded tokens.

5. How the information collected is used

For the purpose of control and security, we shall deploy the information and data collected exclusively for the purposes of the GoBuddies platforms, in order to: (i) help users to schedule playdates for the children or teenagers under their responsibility; (ii) maintain the adequate operation of the platforms offered; (iii) analyze usage profiles for the deployment of statistics, enhancements, definition of new resources and data analysis; (iv) send information in connection with updates, advertisement and announcements; (v) activate users.

For our exclusive analysis, we shall collect information about your activity when using GoBuddies platforms, as well as being able to check the way in which you relate to other users when using our platforms.

We will also use the information obtained by way of treatment of your data to send notices, information, updates, announcements and advertising, among others, both through the GoBuddies platforms (app and website) and to the email informed when registering. Depending on the plan contracted, users will have the option of enabling or disabling this function at any moment.

Since GoBuddies platforms are entitled to use identity check services, to verify and validate user identity, through their picture or of the ID document provided, personal data and pictures contained on the documents sent will be shared with our service provider, that will treat them in accordance with their Privacy Policy, with which users fully agree when submitting their personal documents.

We emphasize that we are aware to the terms of the LGPD, in the sense that the protection of personal data is based on the respect for privacy; self-determination of information; freedom of expression, of information, of communication and of opinion; inviolability of intimacy, of honor and of image; economic and technological development and innovation; free initiative, free competition and consumer rights defense; and human rights, the free development of personality, dignity and the practice of citizenship by individuals.

We further highlight that, with your user registration, part of the information provided may be available to other users, for instance, such as acceptance of playdates or not.

During the execution of our activities, eventual partnership operation processes may occur, opportunity in which information collected from users may, without the need for any prior notice or authorization, be transferred to third parties. In this case, until an eventual update or modification, this Privacy Policy and form of treatment of user data will be maintained and performed based on the terms set out herein.

Other than in the situations expressly foreseen in this Privacy Policy, we do not disclose identifiable personal information provided by users to any third-parties. Nonetheless, should we receive an instruction issued by a competent authority in delivering their legal attributions (both in Brazil and abroad), or in the case of violation or suspected violation of this Privacy Policy or of the legislation applicable, your personal information may be made available, limited to the minimum necessary to address the required purpose.

In the event of there being changes in purpose or form in which your data and information will be used, and should these not be compatible with your original consent, you shall be previously notified of these changes, enabling the revoking of your consent and cancellation of your registry, should you disagree with said changes.

6. Relationship with partners and advertisers

We may provide our partners and advertisers that make use of our platform, reports about the type of people that have viewed their advertising and announcements, as well as the performance of said marketing tools. Nonetheless, no information that may identify or make the user identifiable shall be shared, such as name or email, unless a specific permission is granted to this end.

You expressly authorize us to treat your personal data for the purpose of sending customized advertisements and announcements, both through GoBuddies platforms (app and website), and to the email provided during registration.

If you choose not to grant us authorization to treat your personal data to customize announcements and advertisement, your information will not be shared with partners and advertisers. However, depending on the plan contracted for GoBuddies platforms, you will still receive announcements and advertising of a general nature, just not personalized for you.

GoBuddies platforms may also be integrated or interact with third-party apps and websites, which have their own Use Terms and Conditions and Privacy Policy. The use of third-party platforms will be ruled exclusively by such Use Terms and Conditions and Privacy Policies.

You understand and agree that we not endorse and are not responsible for the behavior, content or resources of any third-party platform, even if initially accessed via the GoBuddies platforms, or for any operation that you might come to undertake with a third-party provider on any of these platforms.

We do not guarantee the compatibility or continuity of compatibility existing among the GoBuddies platforms and those provided by third parties.

In order to stream announcements, notices and advertising, we demand that our partners and advertisers make it clear that they are in full and total agreement with the content of this Privacy Policy, as well as their commitment to respect for all intents and purposes in the law.

7. Responsibility, protection and security of your information and data

We understand the importance of security for your information and data. Therefore, we deploy the best practices to keep them under protection. However, no matter how much we deploy the appropriate technical measures to protect your information and data, we cannot guarantee total security for your data and information, as well as not taking on liability or any responsibility for interceptions or unauthorized accesses.

Your data is treated in line with the current data protection legislation. We deploy technical and administrative measures to protect your information and data from unauthorized accesses, accidental or illicit destruction, loss, change, communication or diffusion, as well as preventing the occurrence of damage to the data due to the treatment applied.

Should we suspect or detect any violation of security or privacy, we may adopt the suspension of your registration and account as protection measure for your data, as well as suspend the partial or total functioning of our platforms without prior notice.

As a user, you must also be attentive and take the necessary measures to protect unauthorized, illicit or accidental accesses to your registry, such as the use of a strong and exclusive password to access GoBuddies platforms, access them exclusively through your personal PC or other devices, as well as finalizing the session after using our platforms.

Your password is an extremely important element in our security system. That being so and because it is extremely personal, you are responsible for maintaining the confidentiality of your password and are fully accountable and liable for any activity occurring through the use of your login and password.

Should you suspect that your account or information are not protected or have been violated, please notify us immediately through privacy@gobuddies.com or the GoBuddies platforms, by clicking on “Support”.

In the terms demanded by legislation, we shall notify the competent authority and the account holder in the event of a security incident that may result in risk or relevant damage.

As holder of personal data, you are entitled to complain to the National Data Protection Authority (Autoridade Nacional de Proteção de Dados – ANPD) in the event of concern or of identifying incident in connection with the way in which your personal data is treated.

On the GoBuddies platforms there may be links to websites and apps under the exclusive responsibility of third parties. This Privacy Policy applies exclusively to the information and data that we collect and treat. We are not liable for information and data collected and treated by third parties, that must make it available in their own Privacy Policies. That being the case, you acknowledge and agree that we are not accountable or liable, directly or indirectly, for any losses or damages eventually caused by, or in connection with, third-party platforms.

As a user, you are equally responsible for guaranteeing security and protection for your information and data and must adopt, as a minimum, the following precautionary measures:

1. maintain your login (access) data secure;
2. logout from your account (disconnect) when finishing using GoBuddies platforms;
3. apply good security practices, such as reinforce your attention on using public Wi-Fi or shared Internet access connections;
4. advise us immediately should you suspect innovation, violation or unauthorized access to your account.

8. HOW THE PERSONAL DATA OF CHILDREN AND TEENAGERS ARE TREATED

Personal data of children and teenagers are treated in attention to their best interest, in the terms of current legislation, as well as only requesting the necessary personal information for the execution of our activity and the operation of GoBuddies platforms.

On agreeing with the terms and conditions of this Privacy Policy, given the activity and purpose of GoBuddies platforms, users, in the role of one of the parents or legal responsible for the children and teenagers, grant us specific consent with respect to the treatment of the children’s and teenagers’ personal data, set out in item 3 herein.

For security reasons, we may request evidence of your identity and that you are effectively responsible legally for the child or teenager in order to consent the treatment of the children’s and teenagers’ personal data.

Registration and use of the GoBuddies platforms are limited to users of age equal to or higher than eighteen (18) years old. We do not allow the use of our platform by users under the age of eighteen (18) years old. We only collect personal data from people under the age of eighteen (18) years old for the delivery of our activity and purpose, which is to help users to schedule playdates for children or teenagers under their responsibility.

Should you suspect that an user is under the age of eighteen (18) years old, please notify us immediately through privacy@gobuddies.com or on the GoBuddies platforms, like clicking on “Support”.

9. TREATMENT TIME FOR YOUR DATA

The treatment operations for your personal data will be maintained only for the time necessary to deliver the purpose for which they were collected, including for the purpose of addressing any legal, contract, service provision or competent authority requirements.

On performing your registration, any personal data we collect will be stored as long as your account is maintained active. Should you request the exclusion of your personal data and/or your account, your personal data will be excluded or made anonymous in the terms of the current legislation. We advise, with emphasis, that data or accounts excluded cannot be recovered.

However, as a result of your registration as a user, we stress that part of the information provided may remain available to other users, such as for example when accepting or not accepting playdates for which, despite being made anonymous in the playdate history to other users, during the legal terms and timeframes here set out, may be object of request by competent authorities or through our denouncement channel.

In order to use our denouncement channel to obtain data from users excluded or made anonymous, the denouncing user must respect our procedures and legal requirements for obtaining the content requested, being subject to the existence, or not, in our records of the data requested.

The end of treatment of your personal data may also occur as a result of instruction from competent authorities.

Your personal data will not be excluded if:

1. the applicable legislation or competent legal instruction applies;
2. an instruction from a competent authority must be addressed;
3. they must be retained in order to evidence our compliance with the applicable legislation, as well as your consent to our Use Terms and Conditions, Privacy Policy and other similar authorizations;
4. there is a pending legal or administrative demand/dispute that may depend on the preservation of the data collected until settled;
5. there is a need for preservation for legitimate commercial interests, such as fraud prevention and enhancement of protection and security for users, similar to preventing the return or a new registration of a user previously banished for inappropriate or illicit behavior, or involved in any security incident.

Information in connection with access to GoBuddies platforms will be kept secure (IP address, date and time, name and ID and email of user), for a minimum of six (6) months, as established in arts. 5.º, insets III and VIII, and 15 of Law no. 12,965/2014.

10. TRANSFER OF DATA AMONG GROUP COMPANIES AND TO OTHER COUNTRIES

In order to deliver the activities specified in this Privacy Policy, your personal data may be shared with other companies in the Knox Group, including those located in other countries.

We may also subcontract the treatment, or share the user personal data, with third parties located in countries other than the user’s country of residence. Consequently, the user’s personal data may be subject to privacy laws other than the ones in force in the user’s country of residence. In these situations, we shall assure that the sharing of the user’s personal data is performed in compliance with the applicable privacy laws.

11. RIGHTS OF OWNERS OF DATA

We believe that users, as owners of their data, must be provided with a quick and easy access to information on their data we collect. Additionally, this is a legal requirement in force.

Therefore, for our new users, at any moment and by way of a request sent to privacy@gobuddies.com, we guarantee:

1. confirmation of the existence of treatment;
2. access to the data;
3. correction of incomplete, inaccurate or out of date data;
4. anonymity, blocking or elimination of unnecessary or excessive data or those treated not in compliance with the required in legislation;
5. portability of data to other service or product suppliers;
6. elimination of personal data treated with consent of the holder, except in the hypotheses established in Law and in this Privacy Policy;
7. information of public and private entities with which the controller has undertaken sharing of data;
8. information about the possibility of not providing consent and on the consequences thereof;
9. possibility of revoking the consent issued;
10. any and all other rights established in Law.

Users are also assured, as owners of their personal data, the right to petition related to their data against the controller before a competent authority and the Judiciary System.

As a user, you will always be able to choose not to disclose your data for collection and treatment. However, you must be aware that, given the usefulness of part of this data, there may be rejection or suspension of your registration, as well as rendering it impossible to use our platform.

12. INTERPRETATION, CHANGES AND UPDATES TO THE Privacy Policy

We shall interpret compliance with this Privacy Policy by users as being in agreement with our internal criteria and understanding.

We are entitled to change and update this Privacy Policy whenever deemed necessary, the applicable legislation so requires or when established by competent authorities. If this should happen, you will be advised by email or through the GoBuddies platforms (app and website).

We recommend and encourage that you frequently access, read and review this Privacy Policy, as well as suggest saving a copy of each update for potential future queries.

Changes and updates, when these occur, become applicable from the moment in which they are made available to all users.

13. Cancellation of subscription

At any moment, you are entitled to require cancellation of your subscription for reception of any announcement or advertising information or communication sent by us to the email of your registry.

To this end, contact us through privacy@gobuddies.com or click on the Cancellation of Subscription in any of the emails received.

14. How to contact us

Whenever deemed necessary, including to clarify doubts with respect to this Privacy Policy or for complaints or denouncements, please contact us through privacy@gobuddies.com or by regular mail, to the address at Rua Chile n.º 1.385, CJ. 02, Prado Velho, Curitiba (PR), 80215-184.