Statement of Adherence to Brazilian Law No. 13,709/2018
General Personal Data Protection Law - LGPD
UP Lab (hereinafter the “Contractor”), through its legal representative(s) as set forth in its corporate documents, confirms that it and/or any other natural or legal person that is a partner of, or is administered, managed or contracted by it, is aware of, understands and fully adheres to the requirements and obligations of the Brazilian General Personal Data Protection Law (Law No. 13,709 of August 14, 2018, the “LGPD”), which governs the processing of personal data, including in digital media, by natural persons or legal entities under public or private law, in order to protect the fundamental rights of freedom and privacy and the free development of the personality of natural persons. Where the contractual relationship between the Consumer and
MANART COMUNICAÇÃO LTDA. involves the access, receipt, processing, transmission, handling and/or international transfer of personal data, it undertakes, through this Statement, to:
a) comply with data privacy laws regarding the processing of personal data covered by its contractual relationship with the client, as applicable;
b) process the personal data it accesses in the course of providing its services solely for the purpose of providing the services for which it was engaged, always in accordance with the criteria, requirements and specifications set out in the signed Contract;
c) not disclose to third parties the personal data it has accessed, except with the prior and express authorization of the Consumer;
d) keep strictly confidential all personal data and information entrusted to it;
e) not process personal data in any location other than that agreed by the Parties;
f) not retain any Personal Data of the Consumer for longer than necessary to perform the services and/or sell the products, in compliance with its obligations under the Contract, or as necessary or permitted by applicable law;
g) cooperate with the Consumer so that it can ensure full compliance with the provisions of personal data protection laws;
h) promptly notify the Consumer in writing whenever it knows or suspects that a security incident or a breach of personal data protection law has occurred.
Sole paragraph: For the purposes of this Statement of Adherence, “personal data” means all information accessed or received by the Partner in any tangible or intangible form relating to, or that personally identifies or makes identifiable, any employee, client, agent, end user, supplier, contact or representative of the Client. Finally,
MANART COMUNICAÇÃO LTDA. hereby declares that it has received the requirements and obligations to be observed by it, in accordance with the legislation that is the subject of this Statement.
Privacy Policy
We at
MANART COMUNICAÇÃO LTDA. (“UP LAB”) are committed to safeguarding your privacy and protecting your data. This document explains what information is collected from users of our website – https://www.uplab.cc/ – and related services (“You”) and how that data is used. To offer our services and products, UP LAB, through its websites, collects data and information, above all to provide you with an ever better experience. UP LAB recognizes that your privacy is very important, so we take every possible measure to protect it. Accordingly, this Privacy Policy (the “Policy”) informs you how your information and personal data will be collected, used, shared and stored through our websites and related services. This Privacy Policy applies when you register on our website and/or subscribe to our free newsletter, which involve online data collection, including Personal Data through our channels. In certain cases, our users may choose the types of data we collect, use and share, as described in this Privacy Policy. You accept our Policy when you register on our platform https://www.uplab.cc/ and/or subscribe to our free newsletter in order to use one of the services mentioned above. Acceptance occurs when you affirmatively agree to the use of your data for each of the purposes described here. This indicates that you are aware of and fully agree with how we will use your information and data. If you choose not to provide the Personal Data needed to use our products or to provide our services (we will indicate when this is the case), or if you do not agree with this Policy, we will not be able to provide our products and/or services to you. If you do not agree with this Policy, please do not continue the registration process and do not use our services. However, please let us know your concerns so that we can clarify or improve them. This document has been written in simple, accessible language, with several examples of data collection and use, so that you can read and understand how we use your data to offer you a safe and comfortable experience when using the services we provide. To make it easier to understand, this Policy is divided as follows:
1. What are the sources of personal data?
2. What types of data does UP LAB collect?
3. With whom does UP LAB share your data?
4. What are the rights of data subjects?
5. How long will the data be stored?
6. Changes to the Policy
1. What are the sources of personal data?
The amount and type of information collected by UP LAB varies according to how you use our services. We will collect different data if you are visiting our website. To make these definitions and differences easier to follow, we have divided user data collection into 2 parts, so that you can understand what applies specifically to you. This Policy applies to the Personal Data we collect from or about you through the following sources: Websites. Consumer-facing websites operated by or for UP LAB, including websites we operate under our own domains/URLs and mini-sites we maintain on third-party social networks such as Facebook (websites). Ad interactions. Interactions with our ads (for example, if you interact with one or more of our ads on a third-party website, we may receive information about that interaction). We also store information about all contacts already made with our users, regardless of the type of user who made the contact. By clicking the content-sharing buttons for social networks available on our pages, users publish the content through their own profile on the selected network. UP LAB has no access to users’ logins and passwords on these networks and will not publish content on a user’s behalf without the user taking this action. All the data we collect is used to provide our services. For this reason, all data and information about you is treated as confidential, and we will only use it for the purposes described here and authorized by you, mainly so that you can make full use of our services, always aiming to improve your user experience. See section 2 for what applies to you.
1.2. What are the Legal Bases for data collection?
We collect data only on legal bases authorized by law, including but not limited to consent, such as legitimate interest and the regular performance of contracts entered into. When the legal basis for collection is not consent, we will always observe the legislation in force and respect the individual rights and freedoms of data subjects.
2. What types of data does UP LAB collect?
2.1. UP LAB leads
If you interact with our materials and content, we will collect your data through your interactions with our forms and emails, for example. You may at any time request the correction or removal of your data by contacting us at olar@uplab.cc. With all this in mind, your data may be used in a number of ways. We recommend that you read the examples below: Your email is used to send the material or information you requested when filling out the form. It may also be used to send our newsletters; however, users may unsubscribe at any time; UP LAB employees may occasionally contact you by email or phone to conduct surveys or present products and services; Communicating with you about products, services, promotions, news, updates, events and other topics that may interest you; and Running targeted advertising based on your tastes, interests and other information collected.
2.3. Users of UP LAB Websites and Services If you use any of our services and/or products, we may request the following categories and types of personal data: contact data (name, email and phone number), location data (country, state and city), professional profile data (job title, name and sector of the company where you work, number of employees at that company, education and years of experience) and billing data (name, CPF taxpayer number, address, credit card).
3. With whom does UP LAB share your data?
UP LAB may operate together with sponsoring companies and online and offline communication business partners. We therefore reserve the right to share your information, including location, registration and interest data, anonymously whenever possible, in order to preserve your privacy as much as possible. We do not rent, sell or transfer your personal data to anyone. We may share your personal data in the cases listed below: Our Partners: We engage other companies to carry out work on our behalf and need to share your personal data with them to provide products and services to you. Our Partners are only authorized to use personal data for the specific purposes for which they were engaged; therefore, they will not use your personal data for any purposes other than the provision of services set out in this Statement. Statistics: Data stored by UP LAB may be used for statistical (analytics) purposes. This data is aggregated to provide a macro view of the landscape and therefore does not seek to identify or make identifiable the data subjects, but only to better understand how they access UP LAB’s platforms, in order to improve our services and tailor products more closely to users’ interests.
4. What are the rights of data subjects?
You may always choose not to disclose your data to us, but bear in mind that some of this data may be required to register on our platforms or to use some of the products we offer you. Regardless, you will always have rights relating to privacy and the protection of your personal data, and in addition to caring about the security of this data, we also want you to have access to and knowledge of all your rights regarding personal data. Below we summarize the rights you have under the General Personal Data Protection Law (LGPD), other Brazilian sector-specific data protection laws and the General Data Protection Regulation (GDPR), which are:
1. Right of access;
2. Right to rectification;
3. Right to erasure;
4. Right to confirmation of the existence of processing;
5. Right to request blocking or deletion;
6. Right to information about public or private entities;
7. Right to restrict processing;
8. Right to review of automated decisions;
9. Right to object to processing;
10. Right to an explanation of the logic behind the collection of your data;
11. Right to information about the possibility of not giving consent and the consequences of refusal;
12. Right to withdraw your consent. Below is a brief explanation and examples of some of these rights:
Request for access to your personal data. This right allows you to request and receive a copy of the personal data we hold about you. Request for rectification of your personal data at UP LAB. This right allows you, at any time, to request the correction and/or rectification of your personal data if you find that some of it is incorrect. However, to make this correction, we will need to check the validity of the data you provide. Request for erasure of your personal data. This right allows you to ask us to delete your personal data from our platform. All data collected will be deleted from our servers when you request it or when it is no longer necessary or relevant to provide our services, unless there is another reason to keep it, such as a legal obligation to retain data or the need to preserve it to protect UP LAB’s rights. To change your personal information or delete it from our database, simply send an email to olar@uplab.cc. Right to withdraw consent at any time. You have the right to withdraw your consent; however, this will not affect the lawfulness of any processing carried out before you withdrew it. If you withdraw your consent, we may not be able to provide certain products, and if so, we will let you know at that time. Right to review of automated decisions. You also have the right to request a review of decisions made solely on the basis of automated processing of your personal data that affect your interests. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or exercise your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We may also contact you for further information about your request in order to speed up our response. Your legitimate requests will be handled within 5 (five) business days. If your request is particularly complex or you have made several requests, we will notify you and keep you updated on its progress, should it take longer than provided for in this item. If you have any questions about these matters or how to exercise these rights, please feel free to contact us at
olar@uplab.cc.
5. How long will UP LAB store the data?
We will keep your personal data only for as long as necessary to fulfill the purposes for which we collected it, including to comply with any legal or contractual obligations or requests from competent authorities. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purpose of processing your personal data and whether we can achieve those purposes by other means, as well as the applicable legal requirements. If you use our products and services, your account information will be kept for as long as your account remains active. If you request cancellation, your information will be deleted within 60 days of the account being cancelled. If you are an UP LAB lead, information about your interactions with us will be stored for 5 (five) years. If you request the deletion of your data and/or account, UP LAB will keep the data for a further 72 (seventy-two) hours after your deletion request.
6. Changes to the Privacy Policy
As we are always seeking to improve our services, this Privacy Policy may be updated. We therefore recommend that you visit this page periodically to stay informed of any changes. If relevant changes are made that require your new consent, we will publish the update and ask for your consent again. Updated on 2021-09-09. This English version is a translation provided for convenience; in case of any discrepancy, the Portuguese version prevails.