Privacy Policy

Please read this Personal Data Protection and Privacy Policy carefully to understand our policies and practices regarding your Personal Data and how this data is processed.

This Policy applies to individuals (natural persons) who interact with DR SERVIÇOS DE INFORMAÇÃO DA INTERNET LTDA.-ME services as consumers (“You”). This Policy explains how your Personal Data is collected, used, and disclosed by DR SERVIÇOS DE INFORMAÇÃO DA INTERNET LTDA.-ME (referred to in this policy as “dr”, “We”, “Us”). It also tells you how You can access and update your Personal Data and make certain decisions about how your Personal Data is used.

This Policy covers our data collection activities both online and offline, covering the Personal Data that We collect through our various channels, including – but not limited to – Websites, Apps, Third Party Social Media, Customer Service Consumers, Points of Sale, Surveys, and Events. Please note that We may aggregate Personal Data combined from different sources (eg our website and offline events). You can refer to the section “About your rights regarding Personal Data” for more information on how to object to this.

In some specific cases, if You decide not to provide us with Your Personal Data which you indicate is necessary (We will indicate when this is the case, for example by explicitly entering this information on our registration forms), We may not be able to provide You with our products and/or services.

Personal Data Sources

We collect your Personal Data from the following sources:

dr websites: All of our websites can be used to collect personal data. This includes both sites that we operate directly through our domains and IP addresses, as well as sites or pages that we establish on third-party services, such as Facebook, Linkedin, and other third parties that offer this type of service.

Electronic mail and instant messaging systems: Services used to maintain electronic communications between You and dr, including those made available directly by Us, or third-party services such as WhatsApp, Telegram, SMS (short message service) and the like.

dr mobile apps: Mobile applications provided directly by dr or through third-party services such as Google or Apple.

Customer service and sales center: Communications made with You through our call centers and sales.

Advertisements, advertisements, and online forms: Interactions with any type of advertisements, advertisements, and online forms by dr.

Offline records: Records completed offline, distributed during events and other interactions with dr.

Data received from third parties: Including, but not limited to, social networks and third-party websites such as Facebook, Instagram, Linkedin, and the like, data aggregator services, dr partners, public sources, and data received during acquisitions from other companies.

What Personal Data we collect about you and how it is collected

During your interaction with dr, using one of the aforementioned collection sources, we may collect various types of personal data about you, as set out below:

Contact information: It includes any type of information that may facilitate our contact with You, including your physical mailing address, telephone numbers, e-mail addresses, websites, and social media profiles.

Login information: Includes information to identify and authenticate to services provided to dr, including your registration name (login), password in irretrievable (encrypted) format, and security questions.

Demographic information and your interests: Any information that may describe your demographics, habits, or behavioral characteristics, including such things as your birthday, date of birth, age or age group, gender, geographic location, favorite products, hobbies and pastimes, other interests and information about family or your lifestyle.

Technical information about your computing equipment or mobile devices: Details about your computer or another portable device that was used to access one of our websites, services or applications, including a log of the IP address used to connect your computer or device to the internet, including your geographic location, the type, and version of operating system and web browser type and version. If You access a dr website or application using a mobile device, such as a smartphone or tablet, the information collected will also include, where permitted, Your phone's unique device ID, geographic location, and other similar mobile device data.

Information about how You use our sites and services: During your interaction with our sites and services, We use automatic data collection technologies to capture information about the actions You take. This may include details such as which links You click, which pages or content You view and for how long, and other similar information and statistics about your interactions, such as response times to content, download errors, and duration of visits to certain pages. This information is captured through automated technologies such as Cookies (Browser Cookies, Flash Cookies, and the like) and web beacons, and also via third-party tracking. You have complete freedom to oppose the use of such technologies, for this see the details in the Section “About your rights regarding Personal Data”.

Market research and consumer feedback: This is information that You voluntarily share with dr about your experience using our products and services.

Consumer Generated Content: Including any content that You create and share with dr on third-party social networks or by uploading to one of our websites, apps, and other online and offline services, including using third-party social networking applications such as Facebook, Instagram, Linkedin, and the like. This data includes text, comments, articles, photos, videos, personal stories, or other similar content and media. Where permitted, We collect and publish consumer-generated content in connection with a variety of activities, including advertising our products and services, contests, awards, and other promotions, website community features, consumer engagement, and third-party social networking.

Third-party social media information: This is any data that You publicly share on a third-party social network or information that forms part of Your profile on a third-party social network (such as Facebook, Instagram, Linkedin, and the like) and that You allow the social network to third parties share with Us. This data may include details such as your basic account information (name, email address, gender, date of birth, current city, profile picture, user ID, friends list, and similar information.) and any other information or additional activities that You allow the third-party social network to share with us. We receive your third-party social networking profile information (or portions thereof) whenever You download an item or interact with a dr application or web service on a third-party social networking site, whenever You use a social networking feature that is integrated into a dr website or whenever You interact with Us through a third-party social network.

Financial and payment information: Any data that dr needs to fulfill an order, or that You use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other payment methods used. dr or our payment processing service providers handle your financial and payment information in compliance with applicable laws, regulations, and security standards, such as PCI DSS (“Payment Card Industry Security Standards Council”).

Contacts with our Customer Service and Sales Center: Your interactions with our Customer Service and Sales Center may be recorded or overheard, in accordance with applicable laws, for dr. Financial information and payment details are not recorded. When required by law, You will be informed of such recording at the beginning of your call.

Sensitive Personal Data:dr does not normally deal with Personal Data considered sensitive according to current legislation, collected directly from natural persons. Accordingly, we do not intend to collect or process sensitive personal data in the normal course of your interactions with our products or services. When there is a legitimate interest or it is necessary to process your sensitive personal data, for whatever reason, we will obtain your prior, express, and formal consent for any processing that is voluntary (eg for marketing purposes). If we process your sensitive personal data for other purposes, We rely on the following legal bases: (i) crime detection and prevention; and (ii) compliance with applicable law.

About Personal Data of Children and Adolescents

dr does not knowingly solicit, collect, process, store, or share personal data from underage children and adolescents. If we discover the occurrence of any type of manipulation of said data, unintentionally, we will remove the personal data of that child or adolescent from our records quickly.

However, dr may collect personal data from children and adolescents directly from their parents or legal guardians, with explicit consent, and in accordance with the rules of current legislation.

About the use of Cookies, log files, and the like

Cookies are small text files that may be placed on your computer or handheld device by websites or web services that you use. They are used to ensure the proper functioning of websites and other online services, as well as to provide information to the owners of the website or online service.

Cookies are used to improve the usability and functionality of Dr's websites and other compatible web services and to better understand how our visitors use our websites and online services, as well as the tools and services they offer. Cookies facilitate the process of adapting the dr websites to your personal needs, facilitating their use whenever possible, and receiving feedback on the satisfaction of our consumers.

dr uses the following types of Cookies on its supported websites and services:

Session cookies: These are cookies for temporary use, which are deleted when you close your browser. When You Restart Your browser and return to the website that created the cookie, that website treats You as a new visitor.

Persistent cookies: They are those Cookies that remain in your browser until you delete them manually or until your browser deletes them according to the duration period established by the cookie. These Cookies will recognize your return as a visitor to a dr.

Necessary cookies: These are cookies that are strictly necessary for the operation of a dr. They allow You to browse the Site and use our features.

Cookies that send us information about you: We place this type of Cookies on a dr compatible website or service and this type of Cookie can only be read by our compatible websites and services.

Cookies in advertisements by dr: We place Cookies on advertisements and advertisements that are displayed on compatible third-party websites and services. We obtain information through these Cookies when You click on or interact with the advertisement or advertisement. In this case, dr is placing a “third party” cookie. We may use this data obtained by third-party Cookies to send you other advertisements that we believe are relevant or of interest to you based on your past behavior.

Cookies that share your information with third parties: These are Cookies placed on a dr website by our partner companies, such as online advertising services. They may use the data collected by these Cookies to anonymously send you targeted advertisements from other websites based on your visit to dr.

dr Compatible websites and services may also use other tracking technologies similar to Cookies, which may collect information such as IP addresses, log files, web beacons, and more. This data is also used to help us adapt the sites and other services supported by dr to your personal needs.

See more details below:

IP addresses: An IP address is a number used on the internet or a network to identify your computer. Every time you connect to the internet, your computer receives an IP assigned by your internet service provider. We may log IP Addresses for the following purposes:
- Dealing with technical problems;
- Maintaining the protection and security of our websites and other online services;
- Gain a better understanding of how our websites and other online services are used;
- Adapt our content to your needs depending on your geographic location.

Registry Files:dr or a third party working on our behalf may collect information in the form of log files that detail website activities and collect statistics about user browsing habits. These records are usually generated anonymously and help us understand details such as:

The type of browser and system used by users of our websites or online services;
Details about the user's session, including the URL of origin, the date, time, and which pages the user visited on our supported sites and services, and how long the user spent using them;
Other navigation or click count details include website traffic reports, unique visitor counts, and similar data.

Web beacons: We may use web beacons (or clear GIFs) on dr. Web beacons (also known as web bugs or web beacons) are small strings of code that allow the delivery of a graphic image on a web page for the purpose of transferring data back to us. We use information from web beacons for a variety of purposes, including:
- Understand how a user responds to email campaigns;
- Traffic reports from our compatible sites and services;
- Perform unique visitor counting, advertising and email auditing and reporting, and personalization on our websites and other compatible services.

It is important to remember that it is up to You to ensure that the settings on Your computer or portable device reflect whether You consent to accept Cookies or not.

Most browsers allow You to set rules to warn You before accepting Cookies or simply refuse them. You do not need to have Cookies enabled to use or browse most dr websites and online services, however in this case we cannot guarantee that You will be able to access all of their features. We recommend that you see the “help” button in your browser on how to carry out this type of configuration. Remember that if You use different browsers, or even different computers and/or handheld devices in different locations, You will need to ensure that each device and browser is set to your personal Cookie preferences.

As our web beacons may be part of a web page, it is not possible to opt-out of this type of feature, but You can make it completely non-functional by enabling the “opt-out” feature. -out” for Cookies placed by this flag.

About the use of your Personal Data

The following describes the purposes for which dr collects your Personal Data, and the different types of Personal Data we collect for each purpose. Please note that not all uses below will be relevant to all individuals and may only apply to specific situations.

Consumer services: Your Personal Data is used for the purpose of providing services to the consumer, including responding to your doubts, questions, and suggestions. This usually requires certain personal contact information and information about the reason for your inquiry, question, or suggestion, for example, what was your order, whether there is a technical problem, product question or complaint, or inquiry in general.
- Reason for using your personal data in this situation:
  - Fulfill contractual obligations;
  - Comply with legal obligations;
  - Our legitimate interests.
- Our legitimate interests in this situation:
  - Continually improve dr;
  - Continually improve the effectiveness of our customer service.

Conducting contests, promotions, and other marketing actions: With your consent (when required under current legislation), dr uses your Personal Data to provide information about products or services, for example, marketing communications, advertising campaigns, or promotions. This can be done through various means of communication, including e-mail, advertisements, sending SMS messages, telephone calls, and postal correspondence (as permitted by current legislation), in addition to our own websites and/or websites and social networks of the 3rd. In this situation, the use of your Personal Data is completely voluntary, which means that You can object, or even withdraw your consent at any time, to the processing of your Personal Data for these purposes. For more details on how to change your preferences about marketing communications, see the “About Your Rights Regarding Personal Data” section of this policy. For more information about our contests and other Promotions, please see the regulations or details posted about each contest/promotion.

Reason for using your personal data in this situation:
- Fulfill contractual obligations;
- Our legitimate interests;
- We have obtained your consent (where necessary).
Our legitimate interests in this situation:
- Understand which of our products and services may be of interest to You and provide you with information about them;
- Define consumers for new products or services.

Social networks and third-party websites: We use your Personal Data when You interact with social media functions and third-party websites, such as “likes”, to provide advertisements and interact with You on third-party social media. How these interactions work, the profiling data dr obtains about You, and how to opt-out (“opt-out”) can be understood by reviewing the privacy policies directly on the respective social networks and third-party websites.
- Reason for using your personal data in this situation:
  - Our legitimate interests;
  - We have obtained your consent (where necessary).
- Our legitimate interests in this situation:
  - Understand which of our products and services may be of interest to You and provide you with information about them;
  - Define consumers for new products or services.

Personalization (offline and online): Based on your consent (when required under current legislation), dr uses your Personal Data (i) to understand your preferences and habits, (ii) to anticipate your needs, based on our understanding of your profile, (iii) to improve and personalize your experience on our websites and apps; (iv) to ensure that the content on our websites and apps is optimized for you and your computer or device; (v) to send You targeted advertising and content, and (vi) to allow You to participate in interactive functions, whenever You choose to do so. In this situation, the use of your Personal Data is completely voluntary, which means that You can object, or even withdraw your consent at any time, to the processing of your Personal Data for these purposes. For more details, see the section “About Your Rights Regarding Personal Data” in this policy.
- Reason for using your personal data in this situation:
  - Our legitimate interests;
  - We have obtained your consent (where necessary).
- Our legitimate interests in this situation:
  - Understand which of our products and services may be of interest to You and provide you with information about them;
  - Define consumers for new products or services.

Handling your orders: We use your Personal Data to process and ship your orders, inform you of the status of your orders, and correct addresses, and conduct identity verification and other anti-fraud activities. This involves the use of certain Personal Data and, in certain situations, payment information.
- Reason for using your personal data in this situation:
  - Fulfill contractual obligations;
  - Legal obligations;
  - Our legitimate interests;
  - We have obtained your consent (where necessary).
- Our legitimate interests in this situation:
  - Improve and develop new products and services;
  - Be more efficient in meeting your requests;
  - Protect our systems, networks, and employees;
  - Fully comply with legal obligations.

Legal reasons or merger/acquisition: If dr or its assets are acquired by, or merged with, another company, including due to bankruptcy, we will share your Personal Data with our legal successors, respecting the requirements of current legislation. We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from the competent legal authority; (iv) to protect our rights, privacy, safety or property; or (v) to enforce the terms of any agreement or the terms of our website, products, and services, in accordance with applicable law.
- Reason for using your personal data in this situation:
  - Legal obligations;
  - Our legitimate interests;
- Our legitimate interests in this situation:
  - Fully meet legal obligations;
  - Protect our systems, assets, and employees.

Other purposes and situations in general:In accordance with current legislation, dr uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research and measuring the effectiveness of our advertising campaigns. We also use your Personal Data for the management and operation of our communications, IT and security and data protection systems.
- Reason for using your personal data in this situation:
  - Fulfill contractual obligations;
  - Legal obligations;
  - Our legitimate interests;
  - We have obtained your consent (where necessary).
- Our legitimate interests in this situation:
  - Improve and develop new products and services;
  - Be more efficient in meeting your requests;
  - Protect our systems, networks and employees;
  - Fully comply with legal obligations.

About the disclosure of your Personal Data

In addition to entities that are part of dr, we may share your Personal Data with the following types of third-party organizations:

Service Providers:These include outside companies that are used by dr to help operate our business. Service providers and their selected collaborators are only authorized to access your Personal Data on behalf of dr for the specific tasks that are requested of them based on our direct instructions. Our service providers are contractually obliged to keep your Personal Data confidential and secure, and in cases of violation they are jointly and severally liable in accordance with current legislation.

Third-party companies that use Personal Data for their own marketing purposes:Except for situations where You have given your specific consent, dr does not license or sell your Personal Data to third party companies for their own marketing purposes. In cases where this type of sharing occurs, the identity of these third parties will be revealed before obtaining your consent.

Third parties who use your Personal Data for legal reasons or due to merger/acquisition:We will disclose your Personal Data to third parties for legal reasons or in the context of a merger or acquisition of dr.

About retention and termination of processing of your Personal Data

In accordance with current legislation, dr uses your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected, as described in this policy, or to comply with applicable legal requirements.

Personal Data used to provide You with a personalized experience will only be kept for as long as permitted, in accordance with current legislation.

You can obtain more details about the retention of your Personal Data through the communication channels detailed in this policy.

At the end of processing your Personal Data, these will be eliminated within the scope and within the technical limits of the activities, their conservation being authorized in the situations provided for in current legislation.

About the disclosure, storage or transfer of your Personal Data

dr takes appropriate measures to ensure that your Personal Data is kept confidential and secure. However, these protections do not apply to information that You choose to share in public areas, such as third-party social networks.

Persons who may access your Personal Data:Your Personal Data will be processed by our employees or authorized agents, as long as they need to have access to such information, depending on the specific purposes for which your Personal Data has been collected.

Measures taken in operational environments:We store your Personal Data in operating environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data.

Steps Dr expects You to take:It is important that You also play a role in keeping your Personal Data secure. When creating an online account, please ensure you choose a password that is strong to prevent unauthorized parties from guessing it. We recommend that You never reveal or share Your password with others. You are solely responsible for keeping this password confidential and for any actions taken through your account on dr.

If you use a shared or public computer, never choose to remember your login name, email address or password, and make sure you log out of your account (log out) whenever you leave the computer. You must also use any privacy settings or controls that dr provides on our website, services or applications, including those deemed optional.

Transfer of your Personal Data:Given the nature of our business, it is possible that we may have to transfer your Personal Data stored within dr to third parties or receive your data from third parties, in accordance with the purposes set out in this Privacy Policy. For this reason, we may transfer or receive your Personal Data to/from other countries, provided that they have laws and regulations compatible with those in force in Brazil.

About your rights regarding Personal Data

You have the right to confirm the existence, access, review, modify and/or request an electronic copy of your Personal Data information that is processed by dr.

You also have the right to request details about the origin of your Personal Data or the sharing of this data with third parties.

At any time, You may also limit the use and disclosure, or revoke consent to any of our processing activities of your Personal Data, except in situations provided for in current legislation.

These rights can be exercised through the communication channels detailed in this policy, being necessary to validate your identity by providing a copy of your RG or equivalent means of identification, in accordance with current legislation.

Whenever a request is submitted without providing the necessary evidence to prove the legitimacy of the data subject, the request will be automatically rejected. Please note that any identifying information provided to dr will only be processed in accordance with, and to the extent permitted by, applicable laws.

Please note that in certain cases, we may not be able to delete your Personal Data without also deleting your user account. Additionally, some situations require the retention of your Personal Data after You request its deletion, in order to satisfy legal or contractual obligations.

Where available, our websites, apps, and online services may have a dedicated function where You can review and edit Your Personal Data. We emphasize that dr requests the validation of your identity using, for example, a login system with access password or similar resource, before allowing access or modification of your Personal Data, thus guaranteeing that there is no unauthorized access to your account and associated personal data.

dr does its best to be able to answer any questions you may have about the way in which we process your Personal Data. However, if You have unresolved concerns, You have the right to complain to the relevant data protection authorities.

What are your choices about how we use and disclose your Personal Data

dr makes every effort to give You freedom of choice about the Personal Data You provide to Us. The following mechanisms give You control over the processing of your Personal Data:

Cookies/Similar Technologies: You can manage your consent using:
- Our consent management solutions;
- Your browser settings to refuse some or all Cookies and similar technologies, or to alert you when they are being used.

Advertising, marketing, and promotions: You can consent to your Personal Data being used by dr to promote our products or services by checking boxes located on registration forms or by answering questions submitted by our representatives.

If You decide that You no longer wish to receive such communications, You may unsubscribe from receiving marketing-related communications at any time by following the instructions provided in such communications.

To unsubscribe from marketing communications sent by any means, including third-party social networks, You may opt-out at any time by unsubscribing, via the links available in our communications, by logging into our websites, applications, compatible online services or third-party social networks, and by adjusting your user preferences or calling our customer service directly.

It is important to remember that even if you unsubscribe from our marketing communications, you will continue to receive communications administrative services from dr, such as orders, transaction confirmations, notifications about your account activities on our supported sites and services, and other important non-marketing announcements.

Personalization (offline and online): Where permitted by law, if You would like Your Personal Data to be used by dr to provide You with a personalized experience or targeted advertising and content, You may indicate this via the relevant checkboxes located on the registration form or by answering questions presented by our representatives.

If you decide that you no longer want to benefit from this customization, you can opt-out at any time by logging in on our supported websites, applications, and services, and selecting user preferences in your account profile or by calling our customer service directly.

Targeted advertising:dr may partner with ad networks and other service or advertising providers who serve advertisements and other advertisements on our behalf or on behalf of other companies not affiliated with dr. Some of these advertisements may be tailored to your interests based on information collected on dr.

You may contact us using the communication channels detailed in this policy for more information.

Changes to our Privacy Policy

Whenever dr decides to change the way we treat your Personal Data, this Policy will be updated. We reserve the right to make changes to our practices and this Policy at any time, provided compliance with current legislation is maintained.

We recommend that You visit it frequently, or whenever You have questions, to view any updates or changes to our Privacy Policy.

How to contact

You can get in touch with:

Make questions or comments about this Policy and our privacy and Personal Data protection practices;
Complain;
Confirmation of the existence of processing of your Personal Data;
Obtain information on how to access your Personal Data;
Correct incomplete, inaccurate, or outdated personal data;
Obtain information on the anonymization, blocking, or elimination of unnecessary, excessive, or treated data in violation of the provisions of current legislation;
Obtain information about the portability of your personal data to another service or product provider, upon express request, in accordance with current legislation;
Request the deletion of personal data processed with your consent, except for the cases provided for in current legislation;
Request details of public and private entities with which we share your Personal Data;
Obtain information about the possibility of not providing consent and the consequences of this refusal;
Revoke consent for the processing of your Personal Data, except for the cases provided for in current legislation;
Other rights of the holder of personal data, according to current legislation.

For this, we request that you contact us using the following channels:

Person in charge of Personal Data Processing:
- Estevão Schults Campos
- estevao@drtransformacaodigital.com.br

Privacy Portal:

https://www.drtransformacao.digital/en/política-de-privacidade

In-person or by regular mail:

dr will receive, investigate and respond, within a reasonable period of time, to any request or complaint about the way in which We treat your Personal Data, including complaints about a breach of your rights under applicable privacy and Personal Data protection laws.