1. Ownership and Presentation

This HACKR ADS digital platform is exclusively owned and managed by HACKR SOLUCOES DE PERFORMANCE DIGITAL LTDA, hereinafter referred to as HACKR ADS, with address at Rua Arrudas, nº 225, Santa Lúcia, Belo Horizonte, Minas Gerais, zip code 30360-400, registered in the National Registry of Legal Entities of the Ministry of Finance under number 35.813.513/0001-04 and e-mail to contact [email protected]

This is the Privacy and Security Policy for the HACKR ADS platform. The platform’s proposal is to allow the automation and optimization of Facebook advertising campaigns, including the collection of email subscribers and the creation of personalized Facebook audiences.

What HACKR seeks, in this way, is to make life easier for those who make online ads, so that they profit more and more from this type of ads, investing less time and less money.

It is important to highlight that this document is the main one regarding privacy, data treatment and security, but all other documents that govern the relationship between USERS and HACKR are an integral and inseparable part of this Privacy Policy.

This instrument describes the Privacy and Security Policy that must be observed by HACKR, detailing the ways of collecting, storing, using, sharing, and disclosing the Personal Data of people who access and use the HACKR ADS platform, hereinafter referred to as “USER”, in the singular, or, “USERS”, in the plural, further detailing the measures that are taken to ensure the protection of the Data collected by HACKR.

2. Contact

Communications to be carried out by the USER with HACKR to deal with the HACKR ADS platform may be carried out through the following channels:

HACKER Customer Service Page;

“Help” button on the login page;

“Help” button when the USER is logged into the account.

The service channels are open from Monday to Friday, from 9:00 am to 6:00 pm. The maximum response time for a ticket submitted on any day from Sunday to Thursday is 48 hours (2 days). For chats sent on Fridays, Saturdays and holidays, the waiting time is about 96 hours (4 days).

If the platform is in an exceptionally high traffic period, the USER ticket will be immediately answered with a warning about the waiting list.

In case of other questions related to HACKR communication channels and contact, we recommend that the USER access the link: [https://hackr.zendesk.com/hc/pt-br/articles/360036261231-Atendimento-e-suporte-como-funciona-]

Regarding the communications that HACKR wishes to make to the USER, all of them will be carried out securely, according to the registration and information provided by the USER before HACKR on the HACKR ADS platform. Exceptionally, HACKR will communicate with the USER by other means of communication, such as cell phone, SMS, MMS, or physical correspondence.

Importantly, HACKR respects the privacy of its USERS and does not send unwanted and unsolicited emails to them.

In addition to essential information, which include those necessary for using the HACKR ADS platform, HACKR will send advertising and promotional messages about the functionalities of the HACKR ADS platform to the e-mail provided at the time of registration. It may also include products, services, promotions, content, and news from our partners. The sending of these messages will only occur with the prior consent of the USER, provided at the time of registration by marking this option specifically, the USER may, at any time, request the cancellation of the sending of advertising or marketing emails.

If the USER decides that he no longer wants to receive emails from HACKR or its partners, he must, when receiving any of these emails, click on the unsubscribe field, which appears in the email received. Another option is to contact HACKR through any of the available channels, informing the desire to unsubscribe from receiving e-mails.

When HACKR becomes aware of the USER’s decision to no longer receive the emails, it will send the means to fulfill this request. HACKR will cancel the sending of new e-mails within five days, not being responsible only for e-mails that were already scheduled to be sent before the request and that cannot be cancelled.

The USER must also be aware that no request for cancellation to receive e-mails includes those referring to important and necessary information for the use of the platform and the relationship with HACKR.

3. Data Collection, Use and Storage

3.1. Data provided by the USER

For full use of the HACKR ADS platform, it is necessary to create an Access Account with the USER’s data record. The USER Data requested in the forms of the HACKR ADS platform serve for management, navigation, and consultation of the HACKR ADS platform itself.

HACKR will also use this data to send advertising and marketing, promotions, discounts, events, and satisfaction surveys, always prioritizing respect for the USER’s privacy and other fundamental rights, always seeking to improve their experience, and never acting in an undesirable way.

3.2. Data collected automatically

Information may also be collected on how the services, pages, features and platform are used by the USER. This collection may include data such as: characteristics of the access device, browser, IP (with date and time), IP origin, information about clicks, pages accessed, the following pages accessed after exiting the pages, or any search term typed on the websites or in reference to them, among others. For such collection, HACKR will make use of some standard technologies such as cookies, pixel tags and local shared object.

The Data collected automatically is used mainly for the purpose of improving the USER’s browsing experience on the pages, according to their habits and preferences, and the speed of future activities and experiences within the pages and on the platform.

HACKR may also use this data so that advertising and marketing, promotions, discounts, and events take place sparingly and according to the USER’s preferences and habits. This type of use of information, when performed, will prioritize the well-being inside and outside the platform and will always respect the fundamental rights and privacy of the USER.

It is important to inform that the use of this information is restricted to the purposes indicated in this document, and HACKR undertakes not to use or share it with third parties for purposes other than those mentioned in this instrument.

At any time, the USER may use their browser tools that prevent the installation of cookies and, furthermore, delete any existing cookies on their Internet connection devices. However, the automatic data produced and collected are essential for the operation of some services available on the websites and on the HACKR digital platform, and, thus, the non-authorization or blocking by the browser may cause errors to occur or that some features may not be available.

3.3. Financial data

Payment processing will be carried out by an outsourced platform, namely, Hotmart, a platform specialized in the management and automation of online payments, and the USER must pay attention to also follow the Terms of Use of this partner, to avoid any problems for payment authorization.

Thus, payment information will not be stored by HACKR, but solely by Hotmart, for payment processing purposes only.

HACKR reserves the right to make unilateral changes to the payment procedures and the respective amounts resulting from the use of the HACKR ADS platform, at its discretion, in accordance with its best fit, always with adequate prior communication to USERS, who may freely choose to cancel or continue their Access Account.

3.4. Other data

Exceptionally, HACKR may collect information entered by the USER, other than those expressly identified in this document or in the Terms and Conditions of Use, which are entered by the USER and about the USER voluntarily in the platform navigation process, or when contacting the HACKR.

HACKR guarantees that Personal Data and information entered on the platform, even if stored in a database, will not be used, or shared in violation of the applicable legislation and the provisions of this instrument.

In addition to the ways exposed so far, HACKR may use the USER Data in the following ways:

registration update;

to provide services to the USER, including managing and creating an Access Account, solving technical difficulties, and enabling or disabling features;

guarantee of USER safety;

response to the USER’s own requests;

information about changes in the terms and its accessories;

production of statistics regarding the use of the platform and contracted services, ensuring the anonymity of the USER, including for the purpose of improving and understanding the profile of the USERS to improve the platform;

improvement of interactivity tools between the platform and the USER, guaranteeing their anonymity;

compliance with court orders;

defense of the rights of HACKR against the USER and third parties in judicial or administrative proceedings;

to customize offers and experiences;

to monitor USER activities and traffic on the platform;

to contact the USER, including about service matters, HACKR contact responses or marketing communications permitted through any available means of communication;

to assist in complying with the Terms and Conditions of Use of the platform and its Policies, such as this one.

4. Sharing and Disclosure of USER Data

HACKR values the confidentiality of USER Data and makes it a priority in its business. Thus, HACKR undertakes not to disclose, share, give access, facilitate access, rent, sell, exchange or in any other way make such information available to other USERS and third parties, under any pretext, except in cases expressly authorized by the USER and by applicable legislation, as indicated below.

The delivery of USER Data will be allowed in case of compliance with court orders and/or defense of HACKR’s rights against the USER and third parties in judicial or administrative proceedings. HACKR undertakes to inform the USER, if allowed, and to disclose such Data only to the extent necessary to comply with the court order, keeping confidential the Data not required by the authority in question or not necessary for the demand.

There is a possibility that HACKR may need to disclose the data if required by law, subpoena or other legal procedure; or, if we believe in good faith, that disclosure is necessary to: (I) investigate, deter or take action related to suspected or actual illegal activities or to cooperate with public bodies; (II) perform HACKR contracts; (III) investigate and defend against any claims or allegations by third parties against HACKR; (IV) protect the security or integrity of the services (for example, sharing with companies that are experiencing similar threats); or (V) exercise or protect the rights and safety of HACKR, USERS, employees or third parties. Whenever this occurs, we will try to notify USERS about legal demands regarding their personal data, unless prohibited by law or court order or if the request is an emergency. HACKR may contest any demand for access to data, in its sole discretion, when it deems the requests to be excessive, vague, or made by incompetent authorities.

If HACKR goes through any corporate transaction or sale of intellectual property that is part of a sale, merger, change in control or any preparatory event for any of these transactions, it will be authorized to share the USERS’ data with third parties participating in the event. Any other entity that purchases HACKR, or any part thereof, shall have the right to continue using the data if subrogating to all rights included in this document.

HACKR reserves the right to share certain information, if it is not personal, being statistical and/or anonymized data – Data that does not identify the platform’s USERS individually – and that does not expose the detailed content of the services performed between the USERS, with third-party service providers, partner companies or approved researchers, in order to better understand which advertisements and services may be of interest to the USER, to improve the USER’s experience and the quality and general effectiveness of the services provided by HACKR or their service, to contribute to academic research or any other type of negotiation of interest to HACKR.

5. USER Rights

HACKR will store and process the USER’s data as long as he maintains an active account on the HACKR ADS platform. This includes all data entered on the platform, produced on the platform and those automatically generated.

5.1. Right to access and control data

The USER may request, at any time, the deletion of all their data, through the contact channels indicated in item 2.

The USER may also request the interruption of the use of all or some of their personal data, or limit their use by HACKR, being aware that this type of interruption may cause the interruption of services provided or received or the impossibility of maintaining them.

At any time, the USER may request a copy of all personal data held by HACKR. The format of the file containing the data will be defined according to the criteria of HACKR, and this request cannot be subject to excessive burden.

5.2. Deletion of Access Account and Revocation of Consent

If the USER chooses to delete his account from the HACKR ADS platform or revokes the consent given to HACKR to process his Personal Data, he must be aware that HACKR may store his data even after the deletion, which will only occur (I) when there are other legal hypotheses for the treatment, provided for in the legislation applicable to this relationship; or (II) in relation to data essential for HACKR to comply with its legal obligations, to resolve disputes, ensure security, prevent fraud and abuse or to respond to any request not to receive e-mails or messages.

Data that do not identify or are unable to identify USERS may be kept even after the exclusion of the Access Account, that is, as long as it is personal data anonymized, for purposes of becoming statistical data.

6. Applicable Laws

As provided for in the Terms and Conditions of Use of HACKR ADS, the legislation applicable to this relationship is that in force in the Federative Republic of Brazil.

Thus, HACKR, whose principle of action is respect for the USER, will always act in accordance with Brazilian law, and especially about data protection, in accordance with the General Law for the Protection of Personal Data – LGPD (Federal Law 13.709 of 2018), the Marco Civil da Internet (Federal Law 12.965 of 2014) and others.

Additionally, HACKR assures its USERS that it cares and is in line with the main international legislation that provides for data protection, such as the GDPR (General Data Protection Regulation), aiming to establish the best possible relationship with its USERS, in a comfortable and secure way.

It is also important to note that, as provided for in the Terms and Conditions of Use of HACKR ADS, if there are any doubts regarding the interpretation of this document, arising from the various versions in different languages, the provisions of the Portuguese language version should be considered, since this is official version. The translations of the document into other languages consist solely of a way of facilitating the understanding of USERS who do not understand the Brazilian language, and the official version indicated herein must always prevail.

7. Legal Assumptions for Treatment of the USER Data

HACKR collects and processes Personal Data in accordance with the hypotheses expressly provided for in the GPDR and which are in line with the main international legislation governing data protection.

Among these hypotheses, we highlight the Consent that is expressly provided by the USER before the creation of the Access Account, being essential to access the services.

The consent given by the USER is specific for the purposes described in this document, being certain that, whenever this document or any functionality of the HACKR ADS platform undergoes updates or modifications that result in a change in the treatment of personal data, the USER will be informed so that he can give his consent again.

Other legal hypotheses may authorize HACKR to process USER data through the HACKR ADS platform, even without the express consent of the USER to do so. In these cases, HACKR ensures that it will act in compliance with the applicable legislation and in compliance with the main international laws, ensuring respect for the USER.

8. Storage and Security Measures

Concerned with the security of the information that transits on the HACKR ADS platform, HACKR performs the storage of all data on a Cloud server that has the most advanced security protocols, featuring SSL protection (encryption) and barriers against unauthorized access to the database (firewalls).

Even with HACKR’s greatest efforts and dedication to its USERS, the current stage of technology does not allow an absolutely inviolable and secure Database to be created against attacks, and HACKR uses all the protection compatible with its performance and size.

Thus, HACKR recommends that the USER use a password that does not contain parts of their personal data (name, birthday, etc.) and that contains capital letters, numbers, and special characters. It is also recommended that the USER does not use the same password for other websites and/or services and that he periodically changes his password. In addition, it is important that the USER keep their Access Account data to the HACKR ADS platform (login and password) under complete confidentiality, not disclosing them to other USERS or third parties.

HACKR will never ask the USER to inform their password outside the HACKR ADS platform, by phone, email, or any other means of communication. The USER’s password must be used exclusively when entering the USER’s Access Account on the platform. If the USER suspects that their password has been exposed to other USERS or third parties, HACKR recommends the immediate replacement of the password.

9. Policy for under the age of eighteen (18) years old

The registration, on the HACKR ADS platform, of USERS under the age of 18 (eighteen) who are not duly accompanied or represented by their legal guardians at the time of registration will be prohibited.

Consequently, the forms and questionnaires on the HACKR ADS platform are also not intended for persons under 18 (eighteen) years of age, so that HACKR does not intend to obtain data from these people. However, if, for any reason, such data are entered by underage, its legal representative, who does not agree with what happened, may contact HACKR through any of the contact channels indicated in item 2, to rectify, modify or remove such data.