We at UBOOK S.A (“UBOOK”, or “we”), registered with the CNPJ/MF under No. 19.141.082/0001-12, headquartered in the city of Rio de Janeiro, State of Rio de Janeiro, at Av. das Américas, nº 500, Bl.12 gr.303, Barra da Tijuca, under CEP 22640-100, we are a subscription service for audiobooks and digital books by streaming and we are committed to safeguarding your privacy and protecting your personal data.
We make every effort to ensure compliance with the laws that protect your privacy, in particular the General Data Protection Act (law 13.709/18), of Brazil, and the GDPR. Therefore, through this Privacy Notice (“Notice”) you will be informed in a clear and transparent way about how your personal information and data is collected, used, shared and stored.
If, after reading this Notice, you still have questions, please feel free to contact us through our service channels provided here.
We hope you have a great experience at ubook.com.
1. BASIC CONCEPTS: WHAT DO I NEED TO KNOW TO UNDERSTAND THIS NOTICE?
In order to simplify its reading, we present some useful definitions for its interpretation:
(i) “Legal Basis” are the legal hypotheses that authorize UBOOK to process your Personal Data.
(ii) “Personal Data” is any data relating to an identified or identifiable individual, including identification numbers, location data, electronic identifiers, or any data that, when combined with other information, is capable of identifying someone or making them identifiable.
(iii) “Digital Platforms” or “Platforms” are the websites and applications owned by UBOOK.
(iv) “Processing” or “Processing data” are the uses that UBOOK makes of Personal Data, including the following activities: collection, recording, storage, organization, consultation, use, disclosure, sharing, transmission, classification, reproduction, processing and evaluation.
(v) “You” or “Data Subject” is the person to whom the Personal Data relates.
(vi) “LGPD” is the acronym of the General Data Protection Law (13,709/2018) whose main objective is to protect the fundamental rights of freedom and privacy and the free development of the personality of the natural person.
(vii) “GDPR” stands for General Data Protection Regulation, and refers to the data protection regulation approved by the European Union in 2016 and in force since 2018.
2.BUT WHY DOES UBOOK TREAT MY PERSONAL DATA?
UBOOK is committed to always offering the best products and services, believing in your power of choice and in your informative self-determination. When we talk about personal data, we understand that this involves respect and commitment to your security and privacy, as well as our commitment that this same power of choice extends to your personal data.
Our activities include the processing of your data, and therefore we collect personal data at different times, such as when you subscribe to our services.
3. What is personal information?
Personal information is information that enables an individual to be identified, as defined by the applicable legislation. It does not include aggregated information that is not sufficient to identify an individual personally.
|Origin of Collection||Data category||Data Description||Purpose of Ubook||Legal base|
|Navigation on Digital Platforms||Personal browsing data.||Data collected through cookies or device IDs, including IP, date and time of access, geographic location, browser type, duration of visit and pages visited.||Make the website work: activate essential features, such as responsiveness of the website/application to desktop/mobile, among other functions.||Legitimate interest|
|Personal data about the access device||Data such as model, manufacturer, operating system, telephone operator, browser type, access device connection type and speed||Analytics: understand your browsing behavior and how the website/application is being used, to improve your experience as a User. The data collected is aggregated and, whenever possible, anonymized.||Legitimate interest||For targeting content and advertising and marketing, ours and our partners, according to your profile and preferences.||Legitimate interest|
|Registration Forms||Personal registration data||E-mail, name, telephone, address and other information (depending on the contracted service)||To provide the customized UBOOK service, or to provide the use of the trial version. Execution of a Contract||Execution of a Contract||Personal Payment Data||Payment card information||For targeting content and advertising and marketing, ours and our partners, according to your profile and preferences||Legitimate interest|
|Data collected by a Third Party||Personal Registration Data||E-mail, name, telephone, address and other information (depending on the contracted service)||To register or login to our services using another service||Legitimate interest|
|Personal data collected by authentication partners||To process the payment||Execution of a Contract||To deliver more relevant advertising and marketing||Legitimate interest|
|Ombudsman and Consumer and Data Subject Services.||Personal Registration Data||E-mail, name, telephone, address and other information (depending on the contracted service)||To fulfill the data subject's requests, such as making requests for data deletion, correction, direct complaints and customer requests, among others||Fulfillment of a legal obligation|
4. WHO DOES UBOOK SHARE YOUR PERSONAL DATA WITH?
Except for the mandatory information used for registration on the site, you can decide which personal information you provide to us. We shall only collect the personal information that you choose to provide. Whenever possible, we shall let you decide how we will use this information (for example, through opt-ins or opt-outs to receive special promotional offers).
(i) Our suppliers: UBOOK has a number of suppliers that it needs to contract to operate our services, and some of them may process Personal Data that we collect, such as advertising companies, means of payment, among others. We emphasize that, as far as possible, we always seek to carefully evaluate our suppliers and sign contractual obligations for information security and protection of Personal Data with them, with the objective of minimizing risks for the Holders.
(ii) Our commercial partners: UBOOK has Commercial partners who will eventually receive personal data in order to make a particular product or service or special condition feasible for our customers. We make our best efforts to carefully evaluate our business partners and enter into contractual obligations for information security and protection of Personal Data with them, with the aim of minimizing risks for Holders.
(iii) Public Authorities: UBOOK, like any company, must comply with the law. Therefore, if a competent authority requires UBOOK to share certain personal data, these will be shared.
(iv) Public Authorities: UBOOK, like any company, must comply with the law. Therefore, if a competent authority requires UBOOK to share certain personal data, these will be shared.
5. DOES UBOOK TRANSFER PERSONAL DATA TO OTHER COUNTRIES?
Yup. Although UBOOK is headquartered in Brazil, therefore applying Brazilian laws related to the protection of Personal Data, the Personal Data we collect may be transferred to other countries. This transfer takes place on behalf of certain suppliers and business partners that may be located outside Brazil, as well as for the performance of part of the data processing.
Whenever we transfer personal data internationally, we use tools to certify that the data transfer complies with applicable law and that the processing of your data has the same level of protection given by the GDPR.
6. WHAT ARE YOUR RIGHTS AS A HOLDER OF PERSONAL DATA?
Personal data belongs to the holder, and LGPD guarantees a series of rights related to them. We are committed to fulfilling these rights and in this section we will explain how you can exercise these rights with UBOOK.
In respect of the principle of free access, UBOOK allows you to confirm whether we are processing Personal Data about you, as well as allowing you to access this Personal Data by requesting our service channels to the Owner.
UBOOK also allows you to request corrections and rectifications of your Personal Data through our service channels.
7. HOW LONG WILL PERSONAL DATA BE STORED?
UBOOK has a Personal Data retention policy in line with the LGPD and sectoral legislation regarding its business model. In this way, we understand that Personal data is stored for as long as is necessary to fulfill the purposes for which it was collected, unless there is any other reason for its maintenance, such as compliance with any legal, regulatory, contractual obligations, among others. others, as long as they are based on a Legal Basis.
8. IS PERSONAL DATA DELETED?
We will delete your personal data so that you are no longer identified whenever the treatment has achieved its purpose, unless we are obliged to keep some information in our database, or we still have to use it for a legally justifiable reason, such as if there is an unresolved issue related to your account, such as an outstanding credit or an unresolved claim or dispute, or to comply with our legal, tax, auditing and accounting obligations.
9. WHAT ARE OUR RESPONSIBILITIES AND HOW DOES UBOOK PROTECT YOUR PERSONAL DATA?
Our responsibility is to take care of your Personal Data, and use it only for the purposes described in this Policy. And to ensure your privacy and the protection of your Personal Data, we have adopted the appropriate security practices for our market, using encryption techniques and other information security systems.
We strive to protect the privacy of your Personal Data, but unfortunately we cannot guarantee complete security. Unauthorized entry or use of your account by a third party, failure of hardware or software not under the control of UBOOK and other factors may compromise the security of your Personal Data. Therefore, its performance is essential for maintaining a safe environment for everyone. You can help us by adopting good security practices in relation to your account and your data (such as not sharing your password with third parties), and if you identify or become aware of something that compromises the security of your data, for please contact us through our service channels.
10. HOW DO I TALK ABOUT PERSONAL DATA WITH UBOOK?
If you believe that your Personal Data has been used in a way that is inconsistent with this Privacy Notice or your choices as a Subject of this Personal Data, or if you have any questions, comments or suggestions regarding this Notice, please contact us.
We have a Data Protection Officer (DPO) who is available at the following email address: firstname.lastname@example.org
11. CHANGES TO THIS PRIVACY NOTICE