WHAT WE DO WITH YOUR INFORMATION

We have done our best to explain clearly and simply what personal data we will need from you and what we will do with each of them. Therefore, we have separated the most important points below as a summary, and if you want to know more, you can find very complete and detailed information in our Privacy Notice.

In addition, we are always available to answer any questions you may have via email contato@intermidiasp.com.br , or by phone and WhatsApp (11) 5581-3002. To speak specifically about your personal data, we have a specific channel: lgpd@intermidiasp.com.br.

• Who is responsible for processing your personal data?

We are controllers of the processing of personal data relating to Visitors, that is, once the Visitor accesses our website or contacts us using the “Contact Us” button, which directs them to our WhatsApp, we will collect some information and make decisions in order to provide our service in the best and safest way possible.

Some operators are necessary for the website to be available, such as: server platforms, hosting, chatbots , among others. As a result, these companies have access to your data. However, our contracts always prioritize the secure treatment of your information.

• How will we secure your data?

INTERMÍDIA is very concerned about the security of your personal data. Therefore, it implements all the measures suggested by the National Data Protection Authority (ANPD) in its Guidance Guide for Small-Scale Data Processing Agents, which includes a variety of technologies and security procedures to help protect your information.

• For what purposes do we use your personal data?

All your data is processed for specific purposes and in accordance with the General Personal Data Protection Law. By clicking on the WhatsApp “Contact Us” button, you can provide us with the following information: Name, Email and Telephone.

We may process this information to:

• Respond to your questions or requests;
• Provide technical support;
• Send quotes, proposals and other financial information to clients;
• Send sales and marketing related contacts;
• Offer our services or products.

We may also collect some information indirectly, as per our  .

To better understand what we do with information, we have provided a table in our Privacy Notice.

• Who do we share your personal data with?

We will not share your data with third parties, except in the cases mentioned in this Notice, in the case of legal consent from the holder of the personal data and by force of court order or legal determination.

• Will your access logs be collected?

When you access our website, we collect your access logs, that is, the set of information relating to the date and time of use of a given internet application from a given IP address. This information will be kept by INTERMÍDIA , confidentially, in a controlled and secure environment, for a minimum period of 06 (six) months, in accordance with Law No. 12,965/2014, and article 7, II, of Law No. 13,709/18.

• Will communications records be stored?

We will also store the conversations you have with us on our communication channels, as this will improve your service and make it more efficient. Without this history, every time you contacted us you would probably have to repeat what you had already told us previously.

• What are your rights?

Even if you have already provided your personal data, you have the full right to, at any time, request from the controller: confirmation of the existence of processing of your data; access to your data; correction of your data; anonymization of data; blocking or deletion of unnecessary, excessive data or data processed in non-compliance with the Law; portability of data to another supplier; deletion of data, except those required by law; obtaining information about who INTERMÍDIA NETWORKS shared data with; obtaining information about the possibility of not providing consent and about the consequences of refusal; and going back and revoking your consent.

• What is the content of the Privacy Notice?

The Privacy Notice is divided as follows to facilitate your access to the information:

1. Date of Text Availability;
2. Explanation of Technical Terms or in a Foreign Language;
3. Treatment Agents;
4. Information Security;
5. Data Collection;
6. Processing of Personal Data;
7. Data Deletion;
8. Rights of the Personal Data Holder;
9. Changes to the Privacy Notice;
10. Privacy Communication Channel;
11. Contact About General Matters.

INTERMÍDIA NETWORKS

PRIVACY NOTICE – INSTITUTIONAL SITE

Before accessing the INTERMÍDIA website or contacting us via Whatsapp , it is important that you read, understand and freely, unequivocally and informedly accept this Privacy Notice.

This website, whose electronic address is https://www.intermidiasp.com.br/ , is owned and maintained by INTERMIDIA COMERCIO E SERVICOS LTDA , a business corporation constituted as a Limited Liability Company, registered with the CNPJ under no. 03.215.230/0001-66, with address at Rua Acarapé, no. 52, Chácara Inglesa, city of São Paulo, state of São Paulo, CEP 04.139-090, (” INTERMIDIA NETWORKS “).

This document aims to provide information on the collection, use and storage (“processing”) of data provided by Visitors and complies with Law No. 12,965/2014 (Marco Civil da Internet) and Law No. 13,709/18 (General Data Protection Law).

1. DATE OF AVAILABILITY OF THE TEXT

1.1. This version of this document was made available on 09/03/2024 .

2. EXPLANATION OF TECHNICAL TERMS OR TERMS IN A FOREIGN LANGUAGE

2.1. Below are the meanings of technical nomenclatures and terms in the English language:

• Controller: a natural or legal person, under public or private law, responsible for decisions regarding the processing of personal data.
• Cookies : small text files that are saved on the user’s computer and can be retrieved by the website that sent them during browsing. They are mainly used to identify and store information about visitors.
• Cryptography: set of principles and techniques for encrypting writing, making it unintelligible to those who do not have access to the agreed conventions.
• Personal data: information related to an identified or identifiable natural person.
• Responsible: person appointed by the controller and operator to act as a communication channel between the controller, data subjects and the National Data Protection Authority (ANPD).
• IP (or Internet Protocol ): unique identification for each computer connected to a network.
• Operator: a natural or legal person, under public or private law, who processes personal data on behalf of the controller;
• Data processing: any operation carried out with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
• Visitor(s): those who use our website.

3. TREATMENT AGENTS

3.1. We are controllers of the processing of personal data relating to Visitors, that is, once the Visitor accesses our website or contacts us via the “Contact Us” button, which directs them to our WhatsApp, we will collect some information and make decisions in order to provide our service in the best and safest way possible.

3.2. Some operators are necessary for the website to be available. Therefore, they will have access to Visitor data for the following purposes:

3.2.1. Microsoft: since personal data is stored on its servers;

3.2.2. WhatsApp : as it is the main communication tool between INTERMÍDIA and Visitors, it may be used to store records of conversations and/or customer service.

3.2.1.1. These companies are independent and have no connection with this text. Therefore, we recommend that the Visitor also read the terms of use and privacy notice of these tools and see if he/she agrees with all the provisions before continuing to use the website.

3.3 Our contractors always value the secure handling of your information. Therefore, from the moment these companies have access to this data, they will become responsible for the security, handling and appropriate sharing of this information, and may not disclose it for other purposes, in violation of current legislation or this Privacy Notice, under penalty of being liable for all penalties, especially those of a civil and criminal nature and those applied by the National Data Protection Authority.

3.4. International Transfer: The servers used by INTERMÍDIA , which are equipped with mechanisms capable of ensuring the security of your data, are located outside Brazil, more precisely, in the United States and are used so that INTERMÍDIA can perform its service appropriately, as determined by article 33, IX, of Law No. 13,709/18.

4. INFORMATION SECURITY

4.1. INTERMÍDIA is very concerned about the security of your personal data. Therefore, it implements all the measures suggested by the National Data Protection Authority (ANPD) in its Guidance Guide for Small-Scale Data Processing Agents, which includes a variety of security technologies and procedures to help protect your information.

4.1.1. In addition, we have effective measures and controls to avoid or reduce Information Security risks, with an approach focused on the Principles of the matter, in order to prevent, detect, respond and recover quickly from a threat to protect the confidentiality, integrity and availability of technological assets and information.

4.2. All access records, a set of information relating to the date and time of use of a given internet application from a given IP address, will be kept by INTERMÍDIA , confidentially, in a controlled and secure environment, for a minimum period of 06 (six) months, in accordance with Law No. 12,965/2014, and article 7, II, of Law 13709/18.

4.3. INTERMÍDIA is committed to preserving the stability, security and functionality of the website, through technical measures compatible with international standards and by encouraging the use of good practices. However, no service available on the internet has a complete guarantee against illegal invasions. In cases where unauthorized third parties invade the system illegally, INTERMÍDIA will do its best to find the person responsible for the illegal activity, but is not responsible for any damages caused by them.

5. DATA COLLECTION

5.1. Contact history: INTERMÍDIA stores information about all interactions that have already taken place between Visitors through the website, such as WhatsApp, telephone and/or email contacts, as this will improve its service and make it more efficient. Without this history, every time you contacted us you would probably have to repeat what you had already told us previously.

5.2. Information we collect indirectly : We may collect some information indirectly, as set out in our Cookie Policy.

6. PROCESSING OF PERSONAL DATA

6.1. By accepting this privacy notice, the Visitor understands that INTERMÍDIA processes their personal data, in accordance with the information presented in the table below.

Type of Personal Data	Legal Basis	Purpose
Name	Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Art. 7, V, Law No. 13,709/2018).	Used to identify the Visitor, provide support, respond to your requests in a targeted manner, and send you quotes, proposals and/or contracts.
Email / Phone	Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Art. 7, V, Law No. 13,709/2018).	Used as a means of communication with the Visitor to provide support, respond to your requests in a targeted manner, and send you quotes, proposals and other financial information.
Chat history	Necessary to meet the legitimate interests of the controller or third party (Art. 7, IX, Law No. 13,709/2018).	Creation of a history about the Visitor, ease of communication, greater effectiveness in resolving queries and improvement in the Visitor’s experience with the services provided by INTERMÍDIA.
Access log (IP – Internet Protocol – date and time of access)	Compliance with a legal or regulatory obligation by the controller (Art. 7, II, Law No. 13,709/2018).	Compliance with article 15 of Law No. 12,965/2014, which imposes the duty of INTERMÍDIA to maintain the respective records of access to internet applications, confidentially, in a controlled and secure environment, for a period of 6 (six) months.

7. DATA DELETION

7.1. When the purpose of data processing ends or upon request by email to lgpd@intermidiasp.com.br , the Visitor will have all of his/her data deleted immediately and permanently, except for data whose maintenance is mandatory by law or regulation, data necessary for the regular exercise of rights in judicial, administrative or arbitration proceedings, such as access records (set of information regarding the date and time of use of a given internet application from a given IP address), which will be kept confidential, in a controlled and secure environment, for a period of 6 (six) months, under the terms of Law No. 12,965/2014 and with the legal basis of art. 7, II, of the General Law for the Protection of Personal Data.

8. 
   RIGHTS OF THE HOLDER OF PERSONAL DATA

8.1. The holder of personal data has the right to obtain from the controller, in relation to the data processed by him/her, at any time and upon request:

8.1.1. Confirmation of the existence of data processing;

8.1.2. Access to data;

8.1.3. Correction of incomplete, inaccurate or outdated data;

8.1.4. Anonymization, blocking or deletion of unnecessary, excessive data or data processed in non-compliance with the provisions of Law 13,709/2018;

8.1.5. Portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;

8.1.6. Deletion of data processed with the consent of the holder, except in the cases provided for in Law 13,709/2018;

8.1.7. Information on public and private entities with which the controller shared data;

8.1.8. Information about the possibility of not providing consent and the consequences of refusal;

8.1.9. Revocation of consent.

9. CHANGES TO THE PRIVACY NOTICE

9.1. INTERMÍDIA may unilaterally add and/or modify any clause contained in this Privacy Notice. The updated version will be valid for the use of the website after its publication. Continued access or use of the website after its publication will confirm the validity of the new Privacy Notice by Visitors.

9.2. If the change made requires the Visitor’s consent , the option to freely, unequivocally and informedly accept the new text or to reject it will be presented.

9.3. If the Visitor does not agree with the change, he/she may not provide consent for specific acts or may completely terminate his/her relationship with INTERMÍDIA . Such termination will not, however, exempt the Visitor from complying with all obligations assumed under the previous versions of the Privacy Notice.

10. PRIVACY COMMUNICATION CHANNEL

10.1. INTERMÍDIA informs that, as it is owned by a startup/small business, it is exempt from appointing a data controller, under the terms of CD/ANPD Resolution No. 2 of January 27, 2022.

10.2. However, we emphasize that your privacy continues to be our priority, which is why we provide the following channel for communication on any matter involving personal data: lgpd@intermidiasp.com.br.

10.3. INTERMÍDIA has a specific text to regulate the license of use, rights, duties, guarantees and general provisions: the  . All these documents form an inseparable part of this Privacy Notice.

11. CONTACT ON GENERAL MATTERS

11.1. INTERMIDIA NETWORKS provides the following channels to receive all communications that Visitors wish to make: via email contato@intermidiasp.com.br , or by telephone and WhatsApp (11) 5581-3002.