Política de Privacidade

PRIVACY POLICY OF THE PARK EDUCATION NETWORK

Updated February 1, 2021

The Privacy Policy of the Park Education network, controlled and operated by the company Park Idiomas Franchising Ltda (“Park Education”) was created to show our commitment to always treating your personal data with security, privacy and transparency.

This Privacy Policy applies to all personal information collected by us at Park Education on different access platforms, whether in the application, on the website, among others, and describes what personal data we collect, how it is used, stored and shared by us and your rights in relation to such data. Therefore, we recommend careful reading.

The practices described in this Privacy Policy only apply to the processing of your personal data in Brazil and are subject to applicable local laws, in particular Law No. 13.709/2018 (General Law for the Protection of Personal Data, or "LGPD") a from its entry into force.

1. INTRODUCTION

When purchasing a product or service from any of the companies that are part of the Park Education network, you provide us with your personal data so that we can make the hiring of our products and services possible and to deliver the best experience possible. At Park Education, privacy, security and transparency are core values ??and we will always adopt the best practices to ensure the confidentiality and integrity of your personal data.

By accepting the terms of this Privacy Policy, you are aware that the controller of your personal data, that is, the company responsible for taking decisions on the treatment of your personal data, will be Park Idiomas Franchising Ltda., registered with the CNPJ under nº 04.096.685/0001-72, headquartered in the city of Uberlândia, State of Minas Gerais, at Avenida Governador Rondon Pacheco, nº 4175, sala 01, Bairro Cazeca, CEP 38400-050.

After reading this Privacy Policy, if you have questions, complaints, want to exercise your rights related to your personal data or communicate with Park Education about this matter, you can contact us through our service channels, directly at the Unit Park Education that you have contracted or contact our supervisor (DPO) by email: support@parkidiomas.zendesk.com.

1. INFORMATION COLLECTED

Your personal information may be collected in three ways:

Directly provided by you: When you interact with our services or products by informing your personal data, on our website, in our application or when you open our email communications;

Directly provided by you or guardians: When you, your parents or legal guardians or the Park Education unit you have hired (including your teacher) disclose personal information for registration in our systems to use the services;

Automatically: When we collect application and system log data, which

may include: the Internet protocol (“IP”) address; the name of the connection provider (responsible for providing the internet); connection type (wired or Wi-Fi); the type of browser used (browsing information); language of the browser and operating system you use; usage information (exercise responses and interactions); longitude / latitude geolocation of a device (mobile); the type of device used; navigation information from other websites; dates and times; unique device identifiers as well as hardware or operating system device identifiers (eg, IDFA for iOS and AAID for Android); the region where your device is located; network your device is connected to; SDK data; engagement data; geo-IP data; the mobile operator (if available); the app you came before and visited after; We also collect personal information such as your name, address, telephone number and email address.

The personal information collected will depend on the activity you are linked to in the Park Education network. So:

1. Registration to access our products or services, we will collect: name, surname, email address and date of birth. When relevant, we may also collect: age group, gender and unit or company linked to the Park Education network – an institution that is enrolled.
2. Registration of teachers, pedagogical coordinators, commercial consultants and Franchisees in our services: name, surname, date of birth, CPF, RG, home address, cell phone and email address. When relevant, which Park Education Unit is linked;
3. For the normal use of our services: students, teachers, pedagogical coordinators, sales consultants, administrative assistants and Franchisees may also generate personal information when using the Park Education network systems and services. Thus, the systems will be able to record responses to student exercises, concepts and comments from teachers or pedagogical coordinators, details of student interaction with the books (which already accessed, how many units did it, learning time in each unit, response time of each exercise), personal information contained in the student's personal responses, as well as notes from business advisors, contact information, and interactions.

By accepting the terms of this Privacy Policy, you expressly agree to provide only true, current and accurate personal data and not to alter your identity or your personal data in any way when accessing and using our products or services. You will be solely responsible for false, outdated or inaccurate information that you provide directly to any company or member of the Park Education network.

Information relating to the audience, such as APP traffic, User navigation and the most visited pages, is intended for statistical surveys, aiming at the continuous improvement of our applications and better meeting the needs of its Users.

It is important to emphasize that the User must take certain precautions when accessing the secure area, such as:

1. the use of sequential passwords or passwords that do not contain personal data and (ii) password change periodically.

1. HOW THE PARK EDUCATION NETWORK USES ITS DATA

The Park Education network uses your personal data in order to provide a high quality service and offer you the best products. We detail below the purposes for which we use the

your personal data:

1. Provision of services, offering of contracted products and improvement of the use and experience with the application, website and its derivatives of the Park Education network;
2. Marketing, prospecting, market research, opinion and promotion of our products and services, or our partners, including enabling offers and sending information about products, services, news, features, content, news and other events relevant to the maintaining the relationship with you;
3. Prevention and resolution of technical or security problems;
4. Improvement of our products and services;
5. Operationalization of new products and services;
6. Recommendation of new services, products or application features, including services from partners that may interest you;
7. Display of advertising, whether on our website, social media or third-party websites;
8. Generation of statistics, studies, surveys and surveys relevant to activities and behavior in the use of products or services;
9. To better understand our service indicators and enable the constant improvement of our products, such as: establishing how many times our services and products were visited; record which services and products were visited so that we can improve the content and layout of our platform; understand the effectiveness of our email communications; monitor the health of our services; detect unauthorized access and fraudulent activities; prevent and respond to security incidents and appropriately escalate IT resources, conduct assessments of your learning.

1. SHARING PERSONAL DATA

Your personal information will be shared in specific situations. The sharing of your data can be done with companies that make up the Park Education network, with third-party partners and with authorities, when necessary. Whenever carried out, data sharing will be carried out within the limits and purposes of our business and in accordance with what is authorized by applicable law. Your data will not be subject to any commercialization or commercial transaction with the purpose of obtaining financial advantages.

Your data can be shared with:

1. With our service providers (for example, providers that develop or host our services), provided they are approved in an internal compliance process;
2. With third parties who are providing services on our behalf. For example, and without limitation, (i) integrated companies, necessary for the provision of services, according to the contracted offer;
3. We may also share Commercial Customers' credit card information with our third-party banking and payment portal for the purpose of collecting payments due to us or to facilitate payment to a Commercial Customer; (iii) we may share information relating to any sweepstakes, contests or other promotions that you have entered or intend to enter for the purpose of facilitating your participation in such sweepstakes, content or other promotion;

1. If it is a legal or regulatory requirement;
2. When verified a non-compliance with the Applicable Laws, with regulatory agencies or educational institution;
3. With legal guardians or business partners responsible for paying for our services;
4. With specific third parties, if you choose to use their services (you will be actively notified by Park Education prior to making this sharing);

1. With companies from the same economic group, to send marketing and analysis to improve products and services;
2. In case of corporate transactions;
3. In other situations, with the specific consent of the user.

From time to time, we may use the personal data in our custody to send you marketing communications. This hypothesis will only occur when:

1. You have provided us with a valid and informed consent for this purpose; or
2. Through our Legitimate Interest, as long as you have this expectation, and always by opt-out .

Attention: We will not send marketing communications to a user who has chosen not to receive them, and we will not forward marketing communications to any individual 12 years of age or younger registered to use our services and products.

To be clear, we may, to the extent permitted by applicable law, collect or create information that is not personal information, such as aggregated datasets and other generalized information, including information about navigation, usage and interactions, and unidentified personal information that does not disclose your information. identity. We retain the right to use and disclose information that is not personal information in any manner permitted by law.

1. RETENTION AND DELETION OF YOUR PERSONAL DATA

Your personal data will be kept in our databases while you are a Park Education customer or user and during the use of our products and services, we will keep your personal data on file only for the time reasonably necessary to meet the objectives set with you. At all times, they will be kept in a safe and controlled environment.

When applicable, and even after cancellation of your service or login, we may store your personal data for an additional period of time for auditing purposes, compliance with legal or regulatory obligations, for the regular exercise of Park Education's rights or also by period required in accordance with the legal basis that justifies the retention of data.

1. YOUR RIGHTS AS A HOLDER OF PERSONAL DATA

As of the entry into force of the LGPD, you, as the holder of personal data, can exercise your rights vis-à-vis the controllers of your personal data. Therefore, you have rights relating to your personal information, including:

1. the right to confirm the existence of treatment;
2. access, through a copy (simple or complete) of your personal data;
3. correction of incomplete, inaccurate or outdated data;
4. anonymization, blocking or deletion of unnecessary, excessive data or if you believe that Park Education is treating it in violation of the law;
5. portability of data to another service or product provider;
6. information about the public or private entities with which we share your personal data;
7. information about the possibility that you (your parent/legal guardian) may not provide consent, as well as being informed of the consequences in case of refusal;

1. obtain a review of any decisions taken automatically;
2. revocation of your consent.

If access to our services has been given through a commercial partner (such as educational institutions) the request to exercise these rights must initially be requested directly from this partner (through the appropriate channel), at the headquarters the facility or by such other means as the Park Education network facility establishes. For other situations, the request to exercise rights must be sent to support@parkidiomas.zendesk.com.

1. INTERNATIONAL TRANSFER OF PERSONAL DATA

Some or all of your personal data may be transferred abroad, for example when they are stored by Park Education on cloud computing servers located outside Brazil. For this, Park Education complies with all requirements established by current legislation and adopts the best security and privacy practices to ensure the integrity and confidentiality of your personal data.

1. ACTIVITY REGISTER

We may record the activities you carry out when using our application, website or blogs, creating, where possible and applicable, logs (records of activities carried out on the websites and applications and services) which will contain: the IP address, access and actions performed by you on the service provided, date and time of each action performed and information about the device used, such as operating system version, browser and geolocation.

We may also use certain technologies, our own or third parties, to monitor the activities carried out while you access our websites and blogs, such as:

Cookies: are internet files that temporarily store what you are visiting on the network. Park Education has cookies on its websites, applications and blogs and also receives information from partners regarding cookies placed on their respective websites. Cookies can be used for a variety of purposes, including remembering you and your preferences, persisting information related to your activities on the website you visit, or collecting information that can be used to deliver content in a personalized way. Our websites may also use locally stored objects to provide certain content.

We have third-party cookies enabled on our website. Privacy practices will be governed by the privacy policies and terms of use of these third parties, and we cannot control or be responsible for the privacy practices and content of third parties. Therefore, we emphasize that you can, at any time, block the use of cookies by activating a setting in your internet browser and your ability to limit cookies will be subject to your browser's settings and limitations. You can also delete existing cookies through the same settings as your internet browser. If you choose to disable cookies, you will be able to continue browsing the websites and blogs, but some parts of the pages may no longer function.

Web beacon: Web beacon is a technique that allows you to map who is visiting a particular web page, identifying their behavior with different websites or web servers.

Analytics tools: These tools may collect information such as how you visit a website, including which pages and when you visit those pages, and other websites that you have visited before, among others.

All technologies used by us will always comply with the terms of this Privacy Policy.

1. SECURITY MEASURES

We maintain adequate technical and organizational measures to prevent any unauthorized access, accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate treatment of personal data. This includes the physical, electronic and administrative procedures necessary to protect the integrity, access and use of data.

1. CHANGE IN COMPANY CONTROL

Without limiting our other rights to transfer data and information as set forth in this Privacy Policy, in the event that Park Education sells or transfers ownership, operation or control, is acquired or merged with a third party, or in the unlikely event of bankruptcy, insolvency, reorganization, liquidation or assignment of Park Education for the benefit of creditors, or the application of laws or equitable principles that affect the rights of creditors generally, Park Education reserves the right, in any of these circumstances, to transfer or assign the information collected (including any personal information, if any) as part of any such merger, acquisition, sale, reorganization or other change of control.Any entity that acquires assets comprising or consisting of your information must agree to handle such information in accordance with the terms of this Privacy Policy.

1. DEFINITIONS OF TERMS

Every time the terms below appear in this Privacy Policy, they are inserted in the text with the following definitions:

1. You: data subject who uses the services or otherwise accesses the Park Education network's systems and website.
2. Business Partners: Learning providers such as schools, colleges, local education authorities, private language schools, educational agencies, or any other organization that purchases access to services for users to use in your organization.
3. Applicable legislation: Law 13.709/2018 (General Data Protection Law).
4. Personal Data: information related to an identified or identifiable natural person.
5. Treatment: any operation performed 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, diffusion or extraction.
6. Opt-out: opportunity given to the holder to object to the processing of personal data.
7. Legitimate Interest: justification for support and promotion activities, as long as it does not violate the holder's fundamental rights and freedoms.
8. Anonymization: use of reasonable technical means available at the time of processing, whereby data loses the possibility of direct or indirect association with an individual.
9. Consent: free, informed and unambiguous expression by which the holder agrees with the processing of their personal data for a specific purpose.

1. CHANGES TO THIS PRIVACY POLICY

Park Education reserves the right to change or replace this Privacy Policy at any time and from time to time. Any changes or replacements related to this Policy on

Privacy will be observed through directions on our app, website or communicated by email. Whenever any relevant condition of this Privacy Policy is changed, these changes will be valid, effective and binding after the new version is posted on our website or emailed to you. We will state the date this Privacy Policy was last updated.

We always value transparency: every time a material change is made, we will send you a notice indicating the current version. By continuing to use our products and services after a Privacy Policy change, you will agree to the new conditions – but you can always express your disagreement through our service channels, if applicable.

1. CONTACT INFORMATION

Remember that the processing of your personal data is a necessary condition for us to provide our services and deliver our products to you. If you have questions about any of the terms explained here, we are available through our service channels to help you.

Nosso endereço postal é: Park Idiomas Franchising Ltda. Av. Rondon Pacheco, 4175, sala 01, Cazeca, CEP: 38450-050 – Uberlândia/MG.

Park Education's privacy team can be reached via email: support@parkidiomas.zendesk.com.