At Smart Travel, privacy and security are priorities and we are committed to the transparency of the processing of personal data of our users/customers. Therefore, this Privacy Policy sets out how the collection, use and transfer of information from customers or other people who access or use our website is carried out.
By using our services, you understand that we will collect and use your personal information in the ways described in this Policy, under the Data Protection rules (LGPD, Federal Law 13.709/2018), the consumer provisions of Federal Law 8078/1990 and other rules of the applicable Brazilian legal system.
Thus, (business name), hereinafter referred to simply as "Smart Travel", in the role of Data Controller, is bound by the provisions of this Privacy Policy.
Our website collects and uses some of your personal data, in order to enable the provision of services and improve the user experience.
1.1. Personal data provided by the holder
Name
Telephone
1.2. Personal data collected automatically
browser
location
system language
In this sense, the collection of your personal data takes place as follows:
Through voluntary filling out of contact forms.
Automatically via navigation analytics data.
2.1. Consent
It is with your consent that we process your personal data. Consent is the free, informed and unambiguous expression by which you authorize Smart Travel to process your data.
Thus, in accordance with the General Data Protection Law, your data will only be collected, processed and stored with prior and express consent.
Your consent will be specifically obtained for each purpose described above, evidencing Smart Travel's commitment to transparency and good faith towards its users/clients, following the relevant legislative regulations.
By using Smart Travel's services and providing your personal data, you are aware of and consent to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.
At any time and at no cost, you may revoke your consent.
It is important to highlight that the revocation of consent for data processing may imply the impossibility of the proper performance of some functionality of the website that depends on the operation. Such consequences will be informed in advance.
Smart Travel assures its users/customers their rights as holders provided for in article 18 of the General Data Protection Law. This way, you can, for free and at any time:
Confirm the existence of data processing, in a simplified way or in a clear and complete format.
Access your data, being able to request them in a legible copy in printed form or electronically, secure and reputable.
Correct your data, when requesting the editing, correction or update of these.
Limit your data when unnecessary, excessive or treated in violation of the law through anonymization, blocking or deletion.
Request the portability of your data, through a registration data report that Smart Travel handles about you.
Delete your processed data with your consent, except as provided by law.
Revoke your consent, disallowing the processing of your data.
Inform yourself about the possibility of not giving your consent and about the consequences of denial.
To exercise your rights as a holder, you must contact Smart Travel through the following means available:
sales@smarttravelit.com
In order to ensure your correct identification as the holder of the personal data object of the request, we may request documents or other proof that may prove your identity. In this case, you will be informed in advance.
Your personal data collected by Smart Travel will be used and stored for the time necessary to provide the service or for the purposes listed in this Privacy Policy to be achieved, considering the rights of data subjects and controllers.
In general, your data will be kept for as long as the contractual relationship between you and Smart Travel continues. After the period of storage of personal data, they will be deleted from our databases or anonymized, except in the cases legally provided for in article 16 general law on data protection, namely:
I – compliance with a legal or regulatory obligation by the controller;
II – study by a research body, ensuring, whenever possible, the anonymization of personal data;
III – transfer to a third party, provided that the data processing requirements set out in this Law are respected; or
IV – exclusive use of the controller, its access by a third party being prohibited, and provided that the data is anonymized.
That is, personal information about you that is essential for the fulfillment of legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be kept, despite the exclusion of other data.
The storage of data collected by Smart Travel reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions capable of guaranteeing the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and access control to stored information.
To keep your personal information secure, we use physical, electronic and management tools aimed at protecting your privacy.
We apply these tools taking into account the nature of the personal data collected, the context and purpose of the processing and the risks that any violations would generate for the rights and freedoms of the holder of the data collected and processed.
Among the measures we have adopted, we highlight the following:
Only authorized people have access to your personal data.
Access to your personal data is only made after the commitment to confidentiality
Your personal data is stored in a safe and sound environment.
Smart Travel is committed to adopting the best postures to avoid security incidents. However, it is necessary to emphasize that no virtual page is entirely safe and risk-free. It is possible that, despite all our security protocols, problems that are exclusively of third parties may occur, such as cyber attacks by hackers, or also due to the negligence or recklessness of the user/customer.
In the event of security incidents that may generate relevant risk or damage for you or any of our users/customers, we will communicate to those affected and the National Data Protection Authority about what happened, in accordance with the provisions of the General Law for the Protection of Data.
In order to preserve your privacy, Smart Travel will not share your personal data with any unauthorized third party.
In addition, there are also other hypotheses in which your data can be shared, which are:
I – Legal determination, application, requisition or court order, with competent judicial, administrative or governmental authorities.
II - Case of corporate changes, such as mergers, acquisitions and incorporations, automatically
III – Protection of Smart Travel's rights in any type of conflict, including those of a judicial nature.
7.1. international data transfer
Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. Under these conditions, in any case, your personal data will be subject to the General Data Protection Law and other Brazilian data protection legislation
In this regard, Smart Travel is committed to always adopting efficient cybersecurity and data protection standards, in its best efforts to guarantee and comply with legislative requirements.
By agreeing to this Privacy Policy, you agree to this sharing, which will take place in accordance with the purposes described in this instrument.
Smart Travel makes use of Cookies, which are text files sent by the platform to your computer and stored on it, which contain information related to browsing the site. In short, Cookies are used to enhance the user experience.
By accessing our website and consenting to the use of Cookies, you acknowledge and accept the use of a navigation data collection system with the use of Cookies on your device.
Smart Travel uses the following Cookies: (description of the types of Cookies used by the website).
You may, at any time and at no cost, change permissions, block or refuse Cookies. However, the revocation of consent to certain Cookies may make it impossible for some platform features to function correctly.
To manage your browser's cookies, just do it directly in your browser settings, in the Cookies management area. You can access tutorials on the topic directly from the links below:
If you use Internet Explorer.
If you use Firefox.
If you use Safari.
If you use Google Chrome.
If you use Microsoft Edge.
If you use Opera.
You can find out more about the Cookies we use and how they work in our Cookie Policy, available at this link (link to the Cookie Policy).
The current version of the Privacy Policy was formulated and last updated on: (date of the last update of the Privacy Policy).
We reserve the right to modify this Privacy Policy at any time, mainly depending on the adequacy of any changes made to our website or in the legislative framework. We recommend that you review it frequently.
Any changes will take effect as of their publication on our website and we will always notify you of any changes that have occurred.
By using our services and providing your personal data after such modifications, you consent to them.
Smart Travel provides for the responsibility of agents who work in data processing processes, in accordance with Articles 42 to 45 of the General Data Protection Law.
We are committed to keeping this Privacy Policy updated, observing its provisions and ensuring compliance with it.
In addition, we are also committed to seeking technical and organizational conditions that are surely able to protect the entire data processing process.
If the National Data Protection Authority requires the adoption of measures in relation to the data processing carried out by Smart Travel, we undertake to follow them.
10.1 Disclaimer
As mentioned in Topic 6, although we adopt high security standards in order to avoid incidents, there is no virtual page that is entirely risk-free. In this sense, Smart Travel is not responsible for:
I - Any consequences arising from the negligence, recklessness or malpractice of users in relation to their individual data. We guarantee and are solely responsible for the security of the data processing processes and the fulfillment of the purposes described in this instrument.
We emphasize that the user is responsible for the confidentiality of access data.
II – Malicious actions by third parties, such as hacker attacks, unless proven guilty or deliberate conduct by Smart Travel.
We emphasize that in case of security incidents that may generate relevant risk or damage to you or any of our users/customers, we will communicate to those affected and the National Data Protection Authority about what happened and we will take the necessary steps.
III – Inaccuracy of the information entered by the user/client in the records necessary for the use of Smart Travel services; any consequences arising from false information or entered in bad faith are entirely the responsibility of the user/customer.
Smart Travel provides the following means for you to contact us to exercise your rights as a holder: (means of contact).
If you have any questions about this Privacy Policy or about the personal data we handle, you can contact our Personal Data Protection Officer, through the following channels:
sales@smarttravelit.com
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Email: sales@smarttravelit.com.br
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