1. GENERAL PROVISIONS 

The general purpose of this Personal Data Privacy Policy is to ensure that the controlling company complies with the requirements of the General Data Protection Law (LGPD) and the Electronic Services Act, with the following specific purposes:

• define the actions that will be carried out by the controlling company within the scope of the protection of personal data provided by data subjects;
• justify the processing or transfer of data on the basis of the LGPD;
• guarantee data subjects clear, adequate and ostensible access to the processing of their personal data. 

NEW WAY CONSULTORIA INTERNACIONAL LTDA, as a service provider, takes special care to protect all the interests of data subjects. No more personal data will be collected than is strictly necessary to achieve the purpose of the processing. This Personal Data Privacy Policy only covers processing carried out on the http://www.newestlog.com/ platform, and documents originating from the platform are linked to the information entered by the controlling company. These provisions do not apply to the physical processing activities of the company. To ensure greater protection for the data subject, the parent company provides technical measures to prevent the acquisition and modification of personal data sent electronically by unauthorized persons, protecting the data set from unauthorized access and access to the account only after providing an individual login and password. 

2. ABOUT DATA PROCESSING ON THE PLATFORM 

The controlling company processes personal data for the following purposes:

• legitimate interest linked to the parent company’s core business;
• compliance with legal obligations, including tax and accounting regulations;
• conducting judicial, arbitration, enforcement and mediation proceedings;
• document the contractual relationships for the purposes of proof for the limitation period of the claims related them;
• carry out direct marketing of services or goods offered, including through e-mail correspondence, such as newsletters, with the consent of the owners;
• the processing of claims arising from the rights under the guarantee the personal data of Clients may be transferred to third parties involved in the processing of the data and public administration authorities, it being the responsibility of the controlling company to indicate this to the data subjects;
• Examples of third parties involved in the processing of personal data are companies that provide accounting, controllership, legal services, human resources, etc;
• The controlling company declares that, in order to guarantee the security the processing of personal data, it has introduced a Personal Data Protection Policy, as provided for in art. 50, § 2, paragraph I of the LGPD, and should aim to adapt its procedures for the processing of personal data.
• The personal data processed by the company providing the electronic services is covered by the hypothesis that it is necessary for the execution and fulfillment of the contract for the use of the Account, since it is merely the provider of the electronic services of the Website.
• As such, it may process the following personal data of the parent company’s customers:
• Name and surname;
• E-mail;
• Data and information will be obtained when the User:
• Access the platform at http://newestlog.com/ and the social networks Facebook and Instagram;
• Interact with the various functionalities on the platform, providing information voluntarily; or Contact us through the available communication channels.
• The company providing the electronic services also processes anonymous data relating to the use of the Site (for example, the number of Customers) in order to generate statistics on the use of the platform. This data is aggregated and anonymous, i.e. it does not contain features that identify any data subject. 

4. STORAGE AND PROTECTION OF DATA AND INFORMATION

NEW WAY CONSULTORIA INTERNACIONAL LTDA, exercising the role of controlling company, takes special care to protect all the interests of the data subjects, thus guaranteeing that:

• all personal data collected is processed in accordance with the law;
• the collection of personal data will always be for specific and lawful purposes, and will not allow any further processing that is not appropriate for the stated purpose;
• all personal data is stored in such a way that data subjects can be identified;
• identifiable data is collected directly for specific purposes, for as short a time as possible, after which measures will be taken definitive deletion. We will actively review the personal data stored and delete it securely or anonymize it when the legal, commercial or user obligation to store it ceases.
• The parent company ensures that all third-party companies involved in the data processing process have assignment agreements, outlining responsibilities regarding the privacy and protection of personal data.
• The controller company declares that it has implemented the appropriate technical and organizational measures that guarantee an adequate level
• of security corresponding to the risk related to the processing of the personal data entrusted to it.
• The processing of personal data as part of the purposes indicated above includes, in particular, its collection, modification, storage, visualization, updating, analysis and archiving and deletion.
• Personal data will be stored by the controlling company for the following periods:
• in situations where the legal basis for the processing of personal data is the fulfillment of a contractual obligation, the period stated in the contract shall prevail or in situations where there are still obligations to be fulfilled arising from the contract, in which case the data may be stored until the period of limitation of the contract.
• in situations where the legal basis for processing personal data is the legitimate interest of the controlling company, personal data will be stored for the period stipulated in the Personal Data Protection Policy.
• The parent company guarantees that it will periodically check, at least annually, whether the data in storage should be kept in its legitimate interest or deleted/deleted.
• in situations where the legal basis for the processing of personal data is compliance with a legal obligation, personal data must be kept for the minimum period indicated by law, rule or regulation.
• The company’s DPO undertakes to regularly check and update the technical and organizational measures used to provide an adequate level of protection for the personal data entrusted.
• The controlling company declares that it adopts security in the processing of personal data, introducing a Personal Data Protection Policy, in accordance with art. 50, § 2, paragraph I of the LGPD, and must aim to adapt its procedures for the processing of personal data.

5. ABOUT COOKIES AND PERFORMANCE DATA

 The Service Provider does not process data contained in Cookies when using the Site. 

6. ABOUT YOUR RIGHTS AS A DATA SUBJECT

The controlling company will provide the data subjects with the following information via the communication channel, whenever requested:

• data protection impact report, when requested by the National Data Protection Agency or in situations where information security breaches occur;
• the purposes for which personal data are processed and their legal basis;
• the personal data collected or categories of personal data;
• about the transfer of data to third parties, especially in situations involving international organizations;
• the maximum storage period for personal data or the criteria that will determine this period;
• the consequences in situations where consent is denied by the data subject.
• The controlling company will always inform the data subject of situations in which personal data is used for a purpose other than that stated, in compliance with the requirements of the LGPD.
• In situations of revocation of consent, this can be done at any time, as long as it does not affect the processing already carried out by the controlling company.
• When requested to provide information regarding the personal data collected by the data subject, the controlling company will provide all the information required by the data subject, as well as the appropriate supporting documents.
• In addition to providing the above-mentioned information, the controlling company will maintain a communication channel for data subjects to submit suggestions, complaints and denunciations regarding data processing activities, via e-mail to contact@newestlog.com ;
• If the data subject or the controlling company identifies that the personal data collected is incomplete, they can immediately rectify or supplement it on the platform, social networks or via the aforementioned e-mail.
• Furthermore, in situations where the data subject identifies that the processing is unnecessary, they can ask the company that controls the personal data to limit the processing activities, ensuring that only processing that has the purpose of protecting and maintaining the data subject’s rights is carried out.
• The controlling company will delete or erase personal data without the request of the data subject in situations where:
• are no longer necessary for the purposes for which they were collected;
• no longer have consent, if it is based on the relevant legal basis;
• arise from improper collection or violations of the protection and privacy of personal data; and, the law, rules or regulations require deletion. 

It should be noted that the obligation to delete, eliminate, restrict and correct personal data immediately by the controlling company will not apply in situations where the procedure is impossible or requires a disproportionate and significant effort. 

Personal data processed by the controlling company for direct marketing purposes, the data subject may object at any time to the processing of their personal data for marketing purposes.

The controlling company guarantees that in direct marketing activities or any other activity in which automatic processing of personal data is carried out, no algorithmic decisions will be made in relation to personal data and their respective holders. All of this is to guarantee the protection of the rights, freedoms and legitimate interests of the data subjects. 

7. ACCEPT

 I agree to the use of the data in accordance with the above rules. I am aware that the organization has rules in place to guarantee privacy, the protection of personal data and information security, and that the collection, classification, use, processing, storage and deletion of personal data is handled with the utmost care.

I am aware that NEW WAY CONSULTORIA INTERNACIONAL LTDA, adopts technical and administrative information security measures that enable it to protect personal data from unauthorized access and that standards of security and integrity of stored data are maintained, with backups of information, in a physical and electronic environment outside its internal premises. 

I declare that all the information contained in this application is true and I take full responsibility for its content.

8. FINAL PROVISIONS

In situations where the parent company inserts links to third-party domains and websites, the responsibility for data processing, including the Cookie Policy, will lie with the third-party owner of the domain or website.

Any queries regarding this Policy or not listed here should be resolved by the parent company via the following contact: 

address Rio Branco Avenue, number 63, room 403, downtown Garibaldi/RS, contact@newestlog.com 

NEW WAY CONSULTORIA INTERNACIONAL LTDA