Privacy Policy and Terms of Use

TERMS AND CONDITIONS OF USE AND SERVICE

Hello, welcome to  BeNow!

BeNow is an App by 50-50 SEL Solutions which aims at sharing your emotional state and the source of your emotions (personal, family background, professional,) on an “Emotions Diary” enabling to monitor your emotional profile and therefore creating  a“ General Emotions Panel” that demonstrates the collective emotional state of cities, regions and countries. It generates a connectivity network of these areas to elaborate   insights for the development of social emotional skills that will help everyone to live in a healthier world by developing a subjective well-being throughout the whole world.

 

On these TERMS AND CONDITIONS OF USE, you will find out the right way of using our App and you will also discover  what you should or should not do to make the most  of all benefits we have made available to you.

The TERMS AND  CONDITIONS OF USE  described may be changed at any time by 50-50 SEL Solutions, thus changing the management of the “Diary of emotions”  and the   “General Panel of Emotions ”.

But don’t worry:  50-50 SEL Solutions will always keep you informed of any changes and will present the new published version of TERMS AND CONDITIONS OF USE.

USE  OF THE BRAND AND OTHER DISTINCTIVE ELEMENTS

In respect of Brazilian and international laws and the intellectual property of 50-50 SEL Solutions, you, user, commit to respect the BeNow brand of  50-50 SEL Solutions, should not  attempt to appropriate it or otherwise modify it for your own use without the express consent from 50-50 SEL Solutions.

Therefore, your commit yourself to:

  1. NOT register, modify; remove any part; distort; alter; shorten; abbreviate; create acronym; use in a generic, plural or progressive way, incorporate or transmit the elements or any other distinctive sign of the brand, whether wholly or partially.
  2. NOT cause misinterpretation of the origin of the elements or any other distinctive signs of the brand, even less create or use similar brands capable of generating confusion in third parties.
  3. NOT imitate, reproduce or copy – in whole or partially – the appearance of the product and other distinctive signs of the brand and the aesthetics of the products from  50-50 SEL Solutions, including, but not limited to, the colors, the font, the style, the designs, the shapes, the graphic pattern, the way in which the content is presented, etc.
  4. NOT exceed your relationship with 50-50 SEL Solutions, or even less, to use the brand  or its distinctive signs in an illegal or reprehensible form, except for oneself.
  5. NOT make any use the brand and its distinctive signs, without express authorization in written form  – which shall point out necessarily the purpose of use  – whether this authorization is an autonomous instrument or a specific clause within a greater instrument.

GENERAL OBLIGATIONS OF GOOD USE

  1. Make your registration using your data and personal information, data with your place of residence, your age, occupation, your emotional and behavioral state, keeping them always updated l , so that may get the most out of your learning pathway.
  2. Fix any damage caused to  50-50 SEL Solutions or to third parties  when you act in an unlawful or improper way  or when you input or use incorrect, inexact or even false data.
  3. Keep your access data (ex: login and password) in absolute and  complete confidentiality. You must alter your password or – in case it is impossible-  notify   50-50 SEL Solutions by means of contacting  benow@50-50selsolutions.com whenever you   are aware of your account unauthorized use  in case you have your mobile phone robbed/ stolen.
  4. To be a physical person with over 18 years of age and fully capable.
  5. To be in full possession of your mental faculties at the moment of the registration.
  6. Be approved by 50-50 SEL Solutions account.
  7. Be responsible for the truthfulness and accuracy of the provided registration information.
  8. To have only one BeNow account.
  9. To read and respect all information made available by 50-50 SEL Solutions by means of  BeNow App,

VIOLATIONS OF THE TERMS AND CONDITIONS OF USE

  1. To use the App to disclose information that may be contrary to Brazilian and international laws and regulations.
  2. To use 50-50 SEL Solutions platform  to disseminate illegal, immoral,  inappropriate or offensive content.
  3. To copy, assign, sublicense, sell, lease or pledge, reproduce, donate, dispose in any way, transfer in whole or in part, under any modalities, for free or onerously, temporarily or permanently, the App, as well as its modules, parts, manuals, or any information regarding it.
  4. Employ software, techniques and/or artifices in order to misuse the App for harmful practices to 50-50 SEL Solutions or to third parties, such as  exploits, spamming, flooding, spoofing, crashing root kits, etc.
  5. To reproduce, adapt, modify and/or employ, in whole or in part, for whatever purpose, the App or any content from information Portal without express authorization from 50-50 SEL Solutions.
  6. To publish or transfer any file that may contain virus, worms, trojans or any other contaminating or destructive programs, or that somehow would interfere in the proper functioning of the App.
  7. To use the App for a different purpose from what it was made available by 50-50 SEL Solutions.
  8. To perform reverse engineering.
  9. To employ social engineering techniques to apply acts of fraud that constitute a criminal offense typified in the criminal and civil liability legislation.
  10. To use the App for disclosure of illegal goods or services under criminal and civil liability law and any international pacts.
  11. To create or use the BeNow App account with third-party data.

MEASURES IN CASE OF VIOLATION SUSPICION

  1. Any suspicion of disrespect regarding the rules of this TERMS AND CONDITIONS OF USE may  imply in the interruption of use and access to your BeNow App account  and in opening a contact with 50-50 SEL Solutions call center to provide information or evidence that can help resolve the situation.

 

  1. You may have the right of access and the App use temporarily removed in the following situations:
  2. a)  Use the App to acquire illegal goods or services under criminal and civil liability laws and eventual international
  3. b)  When 50-50 SEL Solutions believes the suspension is a condition to  guarantee  the security of  50-50 SEL Solutions or third parties,
  4. c)  When suspension is derived from a judicial determination or is necessary to fulfill a legal obligation.
  5. d) at exclusive 50-50 SEL Solutions criteria provided that it does not harm you.

 

  1. You may have your right of access and use of the App definitely removed in the following situations:
  2. a) In cases your account is excluded.
  3. b)  When it is a condition for security guarantee of 50-50 SEL Solutions or third parties.
  4. c)  When the revocation results from a court order, or it is necessary for the fulfillment of a legal obligation.
  5. d)  When you fail to comply with the obligation to pay the loyalty fees owed by you.

TYPES OF DATA AND ITS USES

  1. The data collected are  of personal, family and professional order, , data from emotional status, location.
  2. Personal data are personal, non-transferable and non-disseminated. These data are those that fill in the  “Emotions Diary”.
  3. Some data contained in the “Emotions Diary” feed the “ General Emotions Panel”, this, yes, is visible to all users of the base, therefore, information such as name and e-mail are preserved, nevertheless, there will always be anonymity.
  4. Data from “General Emotion Panel” that  will be disclosed are location (pin) and collective emotional references , that means, it is not possible to know who the person is who chose this or that emotion, but it is possible to know the collective emotional state  in that location.
  5. There is still the emotional profile tool. On this tool there is the test answered by the user which is available to be repeated at every  4 weeks, so that the App is able to follow the development of the user’s socioemotional skills.
  6. Filling out all these data, generates a database stored in a cloud within the Ocean (IaaS) infrastructure hosted in New York.
  7. The database is not encrypted and  all 50-50 SEL Solutions collaborators may have access to any of the harvested information.
  8. The database may be used even after user inactivity, deletion request, contract termination, among other correlates, due to metrics and correlations offered by the App, including those regarding sharing, keeping the absolute user’s anonymity.
  9. Database may be matched to be used in the App marketing and/or assign or sell the generated indexes to research institutions in health, education and culture.  This may happen the following way:From October  2021 to January  2022, it was detected that BeNow users from the Northeastern region of Brazil, or in the city of Salvador/BA or in Nijmejen/Holland registered  x% of pleasant emotions such as calm and happiness. All that happens without any user’s identification.

ITS BENEFITS

  1. Records of Emotions and Emotional Diary

The user may register his/her emotion at the moment of entering the app and visualizes a demonstration table of his emotional history. This resource allows the user to follow, within the timeline, the trajectory of the registered emotions and raise awareness of their states with the percentages of the emotions felt in different periods. It also offers a demonstration panel of the emotional status, that is, if they come from family, social, or professional origins.

 

 

  1. Global General Panel

With the registries of all users coming from different regions of the world (city, region and country), the user may know the emotional collective state pointed in the world map  that highlights the predominant emotion and the percentage of all registered emotions. This is a resource that allows comparing collective emotional states per region and to raise cultural, sociological and psychological reflections on public policy interests.

 

  1. Emotional Profile

The emotional profile expresses different variables linked to socioemotional skills .
 It is useful for a general guidance about strong and week points and especially useful for self-development .

 

In case the users would like to know their level in relation  to socioemotional competences, it is possible to make an  evaluation and to know the result promptly. For that, they’ll answer a quiz and will receive specific grades for different competences. It will be possible, by means of a table  with numbers and graphs, to follow  their emotional profile progress trajectory. The users will be able to build their own personalized  learning track. The  emotional profile may be redone periodically and the BeNow journey of reading or listening  may be reoriented.

 

  1. Theme choice option

The App  thinks the user protagonism is important when  choosing  the theme of interest. It prepares a set of contents and offers the possibility to choose and construct their own reading and listening pathway, which may be altered at any time, at each one’s  choice.

 

  1. The contents

The contents are essential for research and theories linked to anthropology, sociology, psychology,  neuroscience, pedagogy mediated by wisdom, comprehension and  philosophical questionings.

  1. The contents may be shared in whole without any kind of alterations, you may favorite them, print screenshots and improve the reality that surrounds you.

FINAL CONSIDERATIONS

  1. These TERMS AND CONDITIOINS OF USE do not generate any kind of dependence, or company partnership, mandate, franchising or work relationship between  50-50 SEL Solutions  and the ACCREDITED, its Partners and/or Advertisers. In case any provision of this term is  considered illegal, null or unenforceable for any  reason, the remaining provisions will not be affected and will  remain valid and applicable  to the maximum extent possible.
  2. You declare to be aware of the rights and obligations arising from the present term, having read, understood and accepted all the terms and conditions. Any 50-50 SEL Solutions failure in imposing or exerting any provision of this term or related rights, does not constitute a waiver of that right or provision.
  3. The tolerance among parties as to non-compliance  of  any of the obligations assumed in this agreement will not imply in novation or resignation of the right. The tolerant party may, at any time, require the other party the faithful and complete compliance to this agreement.
  4. The technologies, techniques, knowhow, the brand and all the relevant elements of its creation and all information (whether confidential or not) that integrate or orbit the activities of  50-50 SEL Solutions are entirely and exclusively owned by the company   50-50 SEL Solutions, being clear from the outset that there will be no transfer of title to the intellectual or industrial properties owned by it.
  5. The USER is aware that 50-50 SEL Solutions is an educational and human development company that uses technology to  disseminate socioemotional educational content and that owns the copyright of its brand and software (including, but not limited to BeNow App) despite the status of the trademark and patent registration process with the competent body.

All software here ACCREDITED will be considered Proprietary non-commercial software.

  1. THE USER understands that the Term and Conditions of Use must be interpreted together with the Terms of Service and Privacy Policy, the Registration form and further instruments that supplement the  Software Commercial Use Licensing Agreement.

PRIVACY POLICY

50-50 SEL Solutions, its branches and collaborators are committed to searching for protection of personal information and in keeping the privacy of all of those involved in their daily activities.

To warrant the necessary transparency that is necessary for the good interaction between 50-50 SEL Solutions  and its App users, this privacy policy was agreed, which describes the type of personal information and sensitive  data that we collect or receive, as well as the way of use, processing and even the destruction method of  harvested data, when it is necessary

When there is any doubt about the  PRIVACY P0LICY you may get in touch with us by means of our call center or the field  marked “contact” available  at benow@50-50selsolutions.com or even, subsisting any need of contact with our controller, or our attendants, you may get in touch with us via  the same e-mail.

GLOSSARY:           

Personal Data: It is understood as personal data any information  regarding an identified or  identifiable, natural or legal person, directly or indirectly.

Identifiable Person: Natural or legal person that may be identified from an intelligent aggregation of a composition of data that directly or indirectly relate within a logical pattern, although a priori this pattern is not clear.

Processing: Concerns any process or operation performed about  personal data or groups of personal data such as  (but not limited to): collection, organization, structuring, storage, data query, transmission, availability, destruction, analysis, copy, etc.,

Profiling: It is an automized act or not  of treating personal data with the goal of analyzing or predicting patterns that may be behavioral, socioeconomical, ideological, political, cultural, religious, etc.

Anonymization: Way of treating personal data whereby the person holder of that personal data can no longer be identified without the use of additional information

Controller: natural or legal, public or private person, who is responsible for decisions regarding personal data

External data: These data refer to a unique identification,  or “semi- unique” of a specific individual (numbers, name, user’s name, unique ID, photo, biometric data, etc.), their ethnic information  (nationality, spoken languages, dialects, ethnicity, etc.), sexual information  (gender identity, fetishes, trends, etc.)  behavioral information (on-line or not) their demographic information (age range, income scale, physical traits, geographical location, etc.), medical information  (mental health, physical health, deficiencies, DNA, etc.) and physical characteristics (height, weight, age, hair color, skin tone, tattoos, etc.).

Internal data:  These data refer to identification of the most intimate aspects of a specific individual or of a collective group, such as knowledge and beliefs (religious, philosophical, thoughts.), preferences (opinions, intentions, interests, likes, etc.) and the authentication data known by oneself (access password, father’s name, name of the first pet,  PIN password, etc.).

Financial data: These data concern identification of financial aspects and  capabilities of a specific individual or specific groups of individuals, such as bank account data (number of the account, number of the agency, credit card’s number, credit card flags accepted by commercial establishment, etc.), information about individual property  (movable and immovable assets and properties, etc.), information about transactions (purchases, sales, revenues, registers, etc.) and the information regarding credit (credit record, credibility, creditworthiness, etc.).

Social data: These data concern the identification of social aspects and  habitus of a specific individual or groups of individuals, such as: professional information (position titles, wages, job history, evaluations, references, professional certifications, etc.), criminal information (condemnation, , charges, indults, etc.), public life information (general reputation, marital status, religion, political affiliation, communication metadata, etc.), family information (family structure, affiliation, marital status, etc.), social media information (friends, connections, acquaintances, associations, etc.)  communication information (phone calls recordings, voice mail, etc.).

Data  tracking: These data concern devices, connections and metadata used by an individual or group, such as information of the used device  ( IP address,  MAC address, web browser digital printing, etc.), contact information (electronic address, physical address, phone number ,  Skype account etc.) and location information ( GPS coordinates, apartment number, etc.).

Historical data: These data concern an individual’s personal history, such as the events that took place  in the life of an individual, directly or around him that may  have influenced his life .

Metadata: Information that qualify data or even data that orbit or are extracted from other data (ex: the opening of the camera shutter in the moment of taking a picture, date of modification of a word file, size of the file. JPEG,etc.).

In order to warrant the proper functioning of our Apps and offer our services in an effective and efficient way, according to our public’s demands, it is necessary to  gather some personal data that will vary due to a series of factors.

Aiming at clarifying the details behind personal data harvesting, this  section of   PRIVACY POLICY AND DATA USE  brings some information about which data are collected, the moment of collecting them and for which purpose personal data are collected.

I – COLLECTED INFORMATION

50-50 SEL Solutions, by means of BeNow App, collects registration data, information referring to the momentaneous emotional state supplied by the users of our software and Apps. Besides data that are input  by the user while using them  (registration, messages, information about how they are feeling),  50-50 SEL Solutions also harvests information concerning the information themselves in the form of metadata (image resolution used as the company’s logo, time, location and access date, etc.).

The  collected information is mostly internal, personal, professional, family, social and  tracking,  allowing 50-50 SEL Solutions, to occasionally harvest historical information inserted in the database by the user, himself, and deduce information based on the intelligent data analysis and previously collected information.

DEVICE INFORMATION

50-50 SEL Solutions collects several data referring to the access device (computer, smartphone, tablet,etc.) used by the user that use our software/App, with the intention of improving and facilitating the digital business now performed.

As described below, we collect the following information:

DEVICE CONFIGURATIOIN: information concerning customization or not of the devices’ usability such as access to the frontal or back camera, access to GPS location, access to photos within the device, access to microphone, permissions of notifications in the device, language, time zone, location,  etc.

DEVICE CHARACTERISTICS: information regarding the device itself, such as its operational system, the power to connect to the  internet while using  BeNow App, the  battery level in the moment of using BeNow app, the total and available storage space, the utilized navigator, installed plugins, hardware and software versions that constitute the device, the model, the processing capacity of the app, etc.

NETWORKS AND CONECTIONS: information regarding the elements that allow the device to access public or private networks and its metadata, such as IP address, connection speed, mobile operator name or internet service provider,  Wi-Fi hotspots,  Bluetooth, beacons, cell towers, direct connectivity to other devices, etc.

IDENTIFIERS: information regarding device identification numbers  – whether hardware or software – whenever they  exist, such as game account  ID, IMEI number,  Apple ID,  Google Playstore ID and further numbers that are necessary to fulfill the purpose intended by the App.

DEVICE OPERATION: information regarding device operations and performance, such as opening a navigation tab in a  certain browser, the use of  Apps in the background, the movement of display cursor, brightness screen adjustments, etc.

 COOKIES DATA: information about cookies that are stored in your device.

 

 USER INFORMATION

50-50 SEL Solutions collects personal information regarding the user and its natural person itself. Therefore, for transparency issues, we point out the collection of the following data:

REGISTRATION DATA: are those supplied in file format or registration complement  and that will always be supplied by the user himself. Registration data harvested by  BeNow are name, login and password, etc.

BEHAVIORAL DATA : they are data collected by means of an intelligent analysis of the user behavior within  50-50 SEL Solutions App and software, besides those that are input by the user inside the App system. The storage and use of these behavioral data will always be anonymous . Example of behavioral data: pattern of emotions and their origins, time of use the App and software.

SOCIALIZATION DATA: these data are related to the way  users socialize and interact with machines and other human beings. These data are about the words used when interacting with chatbot software,  user reactions upon some specific interactions (likes, clicks, assessment, comments, answers etc.), user reactions as utilities of the services that use our platforms and further data regarding the interaction between communication users  (either automatized or not).

 

II – TIME OF DATA COLLECTION

Personal data from our users is collected whenever:

  1. The user is registered in our database though this website, App or software from 50-50.
  2. The user interacts with software supplied by 50-50 SEL Solutions.
  3. The user imputes or updates the emotional link with their location.
  4. The user activates or triggers some device containing our installed software.
  5. The user gets in touch with 50-50 SEL Solutions to make some contact or request any information or assistance digitally or electronically.
  6. The user downloads  50-50 SEL Solutions App and software in a device.
  7. The user modifies some internal BE NOW 50-50 solutions and App configuration.
  8. The user manages his account.

III – PURPOSE OF DATA HARVESTING AND PROCESSING

The collected data will be treated by 50-50 SEL Solutions  with the intent of always improving the services provided from us to our users and  for those who are interested in acquiring these data for marketing, Health Research Institutions among others, not necessarily limited to the service contracted/accessed/ benefitted by the user but also for all the other services created and managed by 50-50 SEL Solutions.

The processing of the data collected, in addition to being restricted to the purposes set out below, will be carried out whenever possible  in a way to avoid full identification of the individual holder of such data in a way that his privacy and intimacy may be kept intact.

Lastly, the data collected by 50-50 SEL Solutions will be used for the following purposes:

  1. ENABLE FEEDING AND IMPROVE THE SERVICES PROVIDED

We use the collected information to provide our services in an efficient and effective way. Effective because  the harvested  data, – especially  the internal, social and tracking ones – are used with the goal of  feeding the services  to the users involved in the business (ex: without access to network and connection data would not be possible to give access to users  within their access devices) and efficient because processing these data (including internal and historical)  allows 50-50 SEL Solutions to develop  its services according to the needs and preferences  of users that effectively use the software and Apps.

  1. PERSONALIZE AND DEVELOP NEW SERVICES AND PRODUCTS

We use the gathered information to customize the services used by the users, including here, but not limited to: User Dashboard, “Emotions Diary”, General Emotions Panel, Stories dissemination, summary of indicators, etc.).

Furthermore,  50-50 SEL Solutions uses the data collected to develop new services and products. This use is intended  to meet the identified Market needs  and provide you with products and services that you would really  be interested in if they were developed, already using your metrics as a reference, that is, tailormade for you.

  1. PROMOTE OUR SECURITY

We use the information harvested to warrant 50-50 SEL Solutions software and App security, the security of business developed by  50-50 SEL Solutions, the company 50-50 SEL Solutions, and the security of all users  involved in the operations practiced within  50-50 SEL Solutions software and Apps.

To this end, we reserve the right to analyze the collected data  – with no value judgment – in an objective way, in order to identify possible cybersecurity breaches, either socially or from tracking.

Once an imminent security  risk or threat to the users of  50-50 SEL Solutions is identified,  the provisions contained in the available TERMS AND CONDITION OF USE will be applied, such as the revocation or suspension of  the right to access the  BeNow App account.

  1. PROMOTE AND IMPROVE OUR RELATIONSHIP WITH YOU

We use the collected information to promote contact with you in case a need is identified. This information  will be used in order to identify yourself,  identify if there is any need of contact (by means of an intelligent analysis from collected data) and also include the points in which our communication can be improved so that problems are solved in a faster and  efficient way, guaranteeing your satisfaction.

Still, the information we harvest may be used to develop marketing actions and to promote the dissemination of existing or recently developed  50-50 SEL Solutions services

  1. INTERNAL DATA ANALYSIS

We use the collected data to analyze  the relationships among the users of a certain location, comparing populations and their emotional states  through the harvested data processing, especially those that  demonstrate behavioral issues with emphasis on sentimental and emotions, social and historical data concerning the relationship profile within the App.

This analysis can be passed on, in part and following the dictates of the law, to the parties in the form of reports, suggestions, guidance and other forms of instrumentalization of analysis.

IV –  DATA PROCESSING AD STORAGE METHOD

Personal data processing will follow some security and anonymization data guidelines with  the power to protect its holders in case of exposure. Without  going into the merits of containment plans in case of cyber threats or in case of data leakage, they already exist in the body of  the TERM OF  SERVICE.

Personal data will be stored in the cloud, in third-party databases with periodic  backup.

Personal data storage and  maintenance will not observe a deadline, even after the end of the service supplied by 50-50 SEL Solutions, however it will be extended for an indefinite period of time according to the criteria established by  50-50 SEL Solutions.

The data anonymization will be carried  out by an intelligent organization process of collected data, in such a way that the access to certain data will be restricted by a system of access control, in layers, that  makes it difficult to access data whose correlation gives rise to the easy identification of a person.

Besides personal data, this anonymization aims to prevent  leakage of sensitive data that can be inferred by intelligent analysis of information, that correspond, but are not limited to: management, operational, commercial, legal and financial information, such as plans, strategies, costs, know-how, uses and application of products and services, Technologies, business secrets, processes, pricing policies, business methods, procedures and/or guidelines manuals, training and recruitment processes, accounting procedures, status and contents of contracts with clients and/or suppliers, technical knowledge, records, reports, analyses, studies, maps, models, market analysis, investment contracts and project development, letters of intention, protocols of understanding, as well as any warning, explanatory notes, assessments, recommendations or material related to any of the above mentioned items.

Yet, the anonymization of personal data has the power to avoid cunning manipulations of individuals, to ensure health of the ecosystem of social networks and digital media and still warrant that, digital rights  and the respect for human and fundamental rights be fully fulfilled.

This structured data anonymization system and the respect for the privacy and intimacy of its holders will be evidenced by the issuance of semi-annual reports made by the data controller that will demonstrate, semiannually, among other things, the preventive impact  of processing and storing in case of threat or data leakage.

 

DATA SHARING

Sharing the data collected by  50-50 SEL Solutions will be done among  50-50 SEL Solutions business partners with the  express consent  of the personal data subject, and also will be shared among users in absolute anonymity whenever sharing is necessary for improving the business developed by 50-50 SEL Solutions or when useful for interaction improvement among users that  use 50-50 SEL Solutions services (according to the purposes already established by this privacy policy).

 

 DATA SHARED WITH USERS

To ensure the viability of the supply and constant improvement of four services, the following will be shared with the users:

  1. Personal registration data, keeping them anonymous, as well as emotional status and geolocation,
  2. The behavior of the user who buys from the virtual shop.
  3. User device connection and  operation data.

 

DATA SHARED BY IMPOSITION

Still, sharing data  collected by 50-50 SEL Solutions can be done by court order or by force of legal imposition, observing the legislation in force at the time of sharing.

 

DATA CONTROL AND DELITION

The collected information, although they end up becoming part of 50-50 SEL Solutions database, will only be in our custody and will be subject to the control of their holder. The data control involves easier  access, correction and maintenance of  data,  data control and deletion.

To enable the control of data harvesting, the user will have the option to set up his App in the privacy authorization na  sharing field in such a way of authorizing or not the collection of useful data by 50-50 SEL Solutions software and App.

The control of  information will be done, as a rule, by the user himself, especially with regard to data made public by virtue of its exposure within  50-50 SEL Solutions software and App.

The control regarding data collection shall be done by means of following the issued reports by data controller and by a summary  of data storing authorizations which will be generated inside a specific site on the website or  within 50-50 SEL Solutions software and App upon automated request.

The  control can still be done through direct request for information to our attendants (either automated or  natural persons) and to our data  controller, following the steps indicated on the  website and the rite of service designated in the TERM OF SERVICE.

The deletion of data from the registration database implies in data deletion request and shall respect the need of keeping them or not  in the database to enable the provision of services to users who use our software and services.

Therefore, any request of information deletion that is not made available directly for user control must be requested to data controller and must follow the guidelines drawn up by the TERM OF SERVICE,  without prejudice to differentiated compliance in cases of judicial determination or by legal imposition.

In the case of third-party deletion control, 50-50 SEL Solutions will only take actions in cases of:

  1. FRAUD: Once detected fraud attempt, 50-50 SEL Solutions will act to prevent and resolve fraud issues,  the unauthorized use of intellectual property for the purpose of undue capture of customers, sale of counterfeit products, etc.  50-50 SEL Solutions is not responsible for any damages suffered due to the consumption relationship established by virtue of fraudulent artifices but is willing to withdraw the user’s access to the fraud and give support to the defrauded user according to the provisions contained in the  TERM OF USE  and TERM OF SERVICE  respectively.
  2. ILLEGAL CONTENT: Once illegal content is detected (prejudiced, that urges hatred, etc.) 50-50 SEL Solutions will remove this information from the air and may delete the data at its sole and exclusive discretion. This illegal content may also be reported by other users.
  3. INTELLECTUAL PROPERTY DAMAGE: Once the improper use of logo, image, institutional text, registration data, or any kind of information that could cause direct damage to intellectual property of a person (physical or legal), 50-50 SEL Solutions may  remove this content from air upon denouncement by another user or by its own initiative.
  4. LEGAL REQUISITION: Any kind of information may be altered, controlled and deleted by force of court order, including those determined  out of Brazil whenever 50-50 SEL Solutions finds evidence that substantiate the good faith of compliance with that judicial decision – even if not approved by the court responsible for compliance in national territory.

 

PRIVACY POLICIES ALTERATIONS

Every and any alteration in this PRIVACY POLICY  will be notified to the Users. Alterations will only be notified to bond operators in situations in which the changes generate effects in relation to them.

Whenever a change is made, a new version of  PRIVACY POLICY will replace the previous one, however the previous versions will be available on 50-50 SEL Solutions website  in the following address: http://50-50sel.com/

Together with  the notification that the  PRIVACY POLICY has been altered, the User will receive a summary of the changes that have been made ( here will be called  changelog) as well as reading the new policies will be demanded to the user, so that, in the end, he may or not accept the new terms .

 

CONTACT IN CASE OF DOUBTS

José Marcelo Corrêa

dpo@50-50selsolutions.com
+55 16 98173 5050

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