We divided the policy into the following topics: (A) introduction; (B) glossary; (C) collection of personal data; (D) use of personal data; (E) sharing of personal data; (F) storage of personal data; (G) rights of personal data subjects; (H) log of activities; (I) international transfer of data; (J) security measures; and (K) general provisions.
This Policy was issued in compliance with the applicable legislation, namely, the Civil Rights Framework for the Internet (Law No. 12.965/2014) and the General Data Protection Law (Law No. 13.709/2018, or “LGPD”), and is based on our required commitment to transparency with our sponsors, suppliers, customers, and followers.
The guidelines contained in this Policy encompass the activities developed and related to our website. We draw your attention to the fact that other websites that may be accessed through links made available on this website may have privacy policies that differ from this policy, and therefore, by browsing those other websites, you will also be subject to the rules and conditions established therein.
Sign-up: the registration made by the user, through which Senna Brands is authorized to send notices to the user;
Cookies: small data files that websites request browsers to store, allowing them to identify your access device. Such files are used, for example, for security protocols, activation of features, and browsing customization;
Data: a set of anonymized data, personal data, and sensitive data;
Anonymized Data: data that have undergone a series of processing activities, so that they can no longer be directly or indirectly associated with a person, considering the available and reasonable technical methods;
Personal Data: any information related to the identified or identifiable individual, including, without limitation, name, email, IP address, and geolocation data;
Sensitive Data: any information related to racial or ethnic origin, religious belief, political opinion, membership to any union or organization of a religious, philosophical, or political nature, data related to health or sexual life, genetic or biometric data associated with an individual.
Data Protection Officer (DPO): an individual or legal entity, indicated by Senna Brands as responsible for the communication channel between Senna Brands, you, and government authorities in relation to this Policy, and the use, collection, and processing of personal data by Senna Brands;
Senna Brands: means the form how L&V Licensing Ltda – National Corporate Taxpayers Register (CNPJ) No. 52.242.286/0001-15, with headquarters at Rua Dr. Fernandes Coelho, No. 85, 13th Floor, Room 03 – Pinheiros District, São Paulo, SP, Postal Code (CEP) 05423-040, is responsible for managing the following websites, which main internet address is currently localhost, www.senna.com and www.senninha.com.br;
Logs: records of activity of users or visitors made upon accessing the website;
Communities: initiative offered by Senna Brands on the website, comprising the sending of newsletter to signed-up users with information related, directly or not, to Senna Brands‘ activities;
Data Subject: every person who visits, accesses, or interacts with the features offered by the website, provided that the user or visitor must have the legal capacity to accept and agree with the terms of this Policy, and, in the absence thereof, the necessary authorizations must be given by their legal representative.
- Collection of personal data
By visiting and using the website and the features and actions offered through it, Senna Brands automatically collects, or you directly provide us, some of your personal data and, in some cases, sensitive data. Such collection is carried out from the moment you access our website environment.
Senna Brands may also receive your personal data from contracted partners, sponsors, supporters, and service providers that support Senna Brands in the maintenance and operation of the website, as well as in activating the brands under the control and exploitation of Senna Brands, such as the community as well as in the ongoing improvement of the activities presented to you.
You undertake full and sole liability for the personal and sensitive data provided, which will be taken by Senna Brands as true, updated, and accurate. You, therefore, are solely liable for any false, outdated, or inaccurate information that you may provide to Senna Brands.
The data collected by Senna Brands are:
- Personal and/or sensitive data informed by the subject/user – registration and contact data, such as name and e-mail;
- Sensitive data – data provided by subjects/users upon using tools, games, or experiences made available through the platforms managed by L&V, such as data regarding gender, ethnic origin, and health, among others;
- Browsing data – cookies, IP address, interactions carried out, and profile of use of the website and its features, and technical data, such as information on URL, network connection, provider information; and
- Device data – device attributes, such as ID, operating system, browser and model, and device geolocation data, if authorized to be collected by the user.
- Use of personal and/or sensitive data
Personal and/or sensitive data collected as provided above are used by Senna Brands with the main purpose of offering you a quality experience when accessing the website and using its features/actions, as well as to improve and enhance the content and materials made available on the website and/or sent in notices by Senna Brands.
How Senna Brands uses data:
- Personal and/or sensitive data informed by the subject/user – performance of actions and activities offered on the website and platforms; contact for sending Senna Brands’ newsletter and other notices, including sending notices, identification, authentication, and verification of signing-up and/or account, improvement of Senna Brands‘ contents and activities, fulfilling requests and solving questions, regular exercise of Senna Brands‘ rights, collaboration or compliance with a court order, or orders issued by any proper authority or supervisory body, and compliance with any legal or regulatory obligation; and
- Browsing and device data – performance of actions and activities offered on the website and platforms; improvement of Senna Brands‘ contents and activities, generation of statistics, studies, research, and surveys related to activities and behavior regarding the use of the website, its features, and actions offered by Senna Brands; prevention and resolution of technical or security problems; regular exercise of Senna Brands‘ rights, collaboration or compliance with a court order, or orders issued by any proper authority or supervisory body, and compliance with legal or regulatory obligations.
- Sharing of personal and/or sensitive data
Data collected by Senna Brands may be shared with companies and third-party partners and/or supporters, as well as with authorities and regulatory bodies, whenever necessary and also in the events listed below.
Senna Brands shares data with:
- Partner companies – companies and organizations with which Senna Brands has a relationship due to its corporate purposes and activities (including, but not limited to, Ayrton Senna Empreendimentos Ltda. and Instituto Ayrton Senna), for the purposes of collaboration in sending the community’s newsletters and other notices, and improving Senna Brands‘ content and activities ;
- Third-party service providers – companies that provide hosting, information technology, communication, statistical services, and specialized data consulting services, for the purpose of technical support to make the website and the features/actions offered by Senna Brands, send Senna Brands’ notices, identify, authenticate and verify the sign-up, improve Senna Brands‘ contents and activities, fulfill requests and solve questions, generate statistics, studies, research and surveys related to the activities and behavior when using the website, its features, and actions offered by Senna Brands, regular exercise of Senna Brands‘ rights, compliance with the court or administrative orders, or orders issued by any proper authorities and regulators, and compliance with legal or regulatory obligations; and
- Authorities – bodies supervising Senna Brands‘ activities and compliance with applicable laws (especially, without limitation, the LGPD), for purposes of the regular exercise of Senna Brands‘ rights, compliance with a court or administrative order, or orders issued by any proper authority or supervisory body, and compliance with a legal or regulatory obligation.
- Storage of personal and/or sensitive data
Personal and/or sensitive data collected on the website by Senna Brands, or provided directly by you to Senna Brands, will be transferred and stored in secure and controlled environments as long as required to fulfill the purposes for which they were collected. For storage purposes, Senna Brands will use internal servers and/or of third-parties providing service to Senna Brands, and it may also store them through cloud computing technology and/or others that may arise in the future, always in compliance with the terms of this Policy and with Senna Brands‘ corporate purposes and activities.
Senna Brands has the right to delete such data at its convenience or if required by law. However, as an exception, Senna Brands may keep such data and your registration history even after that period for audit purposes, for compliance with legal or regulatory obligations, for the regular exercise of Senna Brands‘ rights, or for the legal term that justifies such retention.
Additionally, in relation to anonymized data or data for the purposes of statistics, studies, research, and surveys, Senna Brands may keep such data even after a request for deletion by the user or expiration of the legal retention period.
As indicated in item G, below, you may also request Senna Brands to delete your personal data, provided that, even in this case, Senna Brands may continue to keep your data stored for the purposes of complying with legal or regulatory obligations, the regular exercise of Senna Brands‘ rights or for the legal term that justifies such retention. The deletion of such data will not cover past activities in which Senna Brands has used such data.
- Rights of personal and/or sensitive data subjects
Through the channels indicated in item L, below, you may exercise the rights guaranteed by the LGPD to personal data subjects, namely:
- Access to data – request Senna Brands to access the data it holds about you;
- Data correction – in case of incomplete, inaccurate, or outdated data, request from Senna Brands the respective correction or supplementation;
- Anonymization, blocking or deletion of data – allows you to request (a) the anonymization of data, so that they may no longer be associated with you; (b) the blocking of your data, temporarily suspending their processing; or (c) the elimination and deletion of all personal data without the possibility of reversal, except in the cases provided for by law, respecting the terms established in item F, above;
- Confirmation of processing – request Senna Brands to confirm whether it processes your personal and/or sensitive data;
- Sharing information – request Senna Brands to confirm the third parties with which your personal and/or sensitive data has been shared (public or private entities);
- Consent and revocation information – allows you to have clear information about the possibility and consequence of not giving your consent, or requesting Senna Brands the revocation of your consent for future collection, handling, use, and processing of personal and/or sensitive data. However, this will not affect the legality of any previous processing. You acknowledge that your non-consent or revocation may prevent you from fully using the website and the features/actions offered by Senna Brands, or even make such use completely unfeasible, and that revocation will not cancel any previous processing; and
- Data portability – if possible, and based on the respective regulation by the National Data Protection Authority (ANPD), request from Senna Brands the portability of your data.
- Opposition – allows you to request the interruption of certain processing of personal data by Senna Brands without your consent.
For the exercise of the rights listed above, Senna Brands may request you to prove your identity as a security measure.
Senna Brands will have 15 days to answer your requests. Requests will be analyzed as provided for in current legislation and, for legal reasons, some requests may not be fulfilled and will be informed to the user.
- Log of Activities
Senna Brands may record the activities you carry out when using the website or when accessing the notices, by creating, when possible and applicable, logs (records of activities performed) that will contain: the IP address, access and actions performed, date and time of each action performed, and information about the device used, such as operating system version, browser, and geolocation.
In addition, always in compliance with the terms of this Policy, Senna Brands uses or may use other technologies, whether owned or third parties, to record your activities, as indicated below:
- Cookies – Senna Brands uses its own and third-party cookies for several functions, such as to enable and facilitate the use of the website and its features/actions, track your preferences to send content of interest to you, reduce the occurrence of failures during access, mitigate the risk of fraudulent activities, guarantee more customizable browsing, offer security features during browsing, and statistically analyze the general preferences of the set of users; and
- Analytics tool – Senna Brands uses these tools to identify your browsing patterns on the website, including pages you visit and when you visit such pages, and generate reports on such activities, so that we may improve the development of activities by Senna Brands.
Click on “Help” on your browser’s settings to find out how to prevent it from accepting cookies, to be notified when you receive new ones, to see when they expire, and to disable them. In the links below you will find more details on how to disable cookies on the most popular browsers:
- International transfer of data
As indicated in this Policy, Senna Brands uses contracted third-party servers and may even store your data on cloud computing servers located outside Brazil. In addition, in some cases, Senna Brands may share your data with a partner and/or institutional supporters located abroad, for the purpose of supporting and/or collaborating in the performance of the actions and/or features offered on the website and platforms managed by Senna Brands.
In such cases, in compliance with current legislation, Senna Brands will respect the rules established for such sending and will request such third parties to comply with the terms of this Policy and other rules and legislation that may be applicable, and adopt the best security and privacy practices available to guarantee the integrity and confidentiality of your personal data.
- Security Measures
Senna Brands takes appropriate technical and organizational measures to ensure the integrity of your personal and sensitive data. For this purpose, we use commercially reasonable industry-standard practices to maintain the security of the collection, processing, and storage activities, such as encryption, firewalls, and Secure Sockets Layer (SSL).
Nonetheless, no matter how effective the security technology is, no system is unbreakable, and unfortunately, we may not completely guarantee the security of the databases. Also, we may not guarantee that your personal data will not be intercepted. In this sense, Senna Brands disclaims any liability for any damages and/or losses resulting from failures, viruses, or database invasions, except in cases where they are proven to be caused exclusively by Senna Brands’ fault or willful misconduct.
In order to maintain the security and protection of your personal and sensitive data provided in the sign-up, under no circumstances may your login and password be shared with third parties. In addition, by signing up, especially on public computers, make sure that you have logged out of your account to prevent unauthorized persons from accessing and using information without your knowledge.
Senna Brands does not request personal data by phone, Whatsapp, SMS, or email.
IMPORTANT: If Senna Brands identifies that any of such events has occurred, it will notify users that may be affected thereby, informing them of the breach of their data and instructing them to adopt the appropriate procedures.
- General Provisions
- Amendments to this Policy
We may amend this Policy from time to time. Whenever any relevant provision of this Policy is amended, such amendments will be valid, effective, and binding as from the publication and disclosure of the new version on our institutional website.
By continuing to use our institutional website, as from the effectiveness of the new policy, you will be aware of and make no opposition to the new provisions. In case of disagreement, you may send us a message through our communication channels informed in item 3, below.
Also, if the amendment in question materially modifies our personal data processing practices, and such a new scenario depends on new consent, Senna Brands will again request your consent to the terms of the current Policy.
IMPORTANT: This Policy was last changed and published on the website in October 2020.
- Governing law and jurisdiction
This Policy is governed by the legislation of the Federative Republic of Brazil, and its wording will be interpreted in the Portuguese language.
If the mediation is unsuccessful, the parties elect the jurisdiction of the Central Courts of the Judicial District of São Paulo, State of São Paulo, to the exclusion of any other, however privileged it may be.
- Contact us
If you have any questions, suggestions, or comments about our privacy practices and use of personal data, or even about the terms of this document, please contact us:
(i) through the “Contact Us” channel on our website; or,
(ii) by email to firstname.lastname@example.org
Senna Brands remains at the disposal of visitors and users of our institutional website, in an ongoing commitment to their privacy, informative self-determination, and freedom of expression and information.