Data Privacy Protection is an essential value for us, and through this Privacy Policy, we explain how GRUPO ALLOHA FIBRA, or simply ALLOHA, as the Controller of Personal Data, collects, uses, shares, or otherwise processes information and Personal Data of individuals, including customers and third parties, for the performance of our activities, including through our Websites, Platforms, and Applications.
All your personal information collected will be used to help make your visit to our websites, platforms, and applications as productive and enjoyable as possible. Ensuring the confidentiality of users’ personal data is important to us and is treated in accordance with Law No. 13,709/2018 (General Data Protection Law – LGPD). Here you can also find information about your rights regarding your Personal Data, according to the LGPD and other applicable laws.
The use of ALLOHA websites, platforms, and applications implies acceptance of this privacy agreement.
The ALLOHA team reserves the right to change this agreement without prior notice. Therefore, we recommend that you regularly check our privacy policy to stay updated.
WHAT INFORMATION DO WE USE AND HOW DO WE COLLECT IT?
We process Personal Data from our current or former customers, those who have or had any relationship with us, representatives, attorneys, employees, partners of any customer, company, or entity we are associated with, as well as individuals we intend to interact with or other data subjects.
The Personal Data we process varies according to the purposes of use, as indicated in this Policy, and the activities we perform. This includes:
Registration data: name, date of birth, gender, RG (identity card), CPF (tax identification number), and/or other identification documents, such as driver’s license, photo, residential and commercial address, residential, commercial, and mobile phone numbers, email address, profession, occupation, marital status, nationality, place of birth, among others.
Data about third parties: family members, representatives, guarantors, counterparts, attorneys, collaborators, and partners.
Information about your devices: information about your device (such as Advertising ID and technical information such as the operating system and screen size), connection (such as date, time, and IP address, network used), device identification, device usage. We may also collect, with your authorization through our applications, your geolocation for use in fraud prevention and security, comprehensive protection, and to offer products and services to you.
Browsing habits: pages and functionalities, number of clicks, pages and applications that originated access to our websites, platforms, and applications (for example, if you access a website that has a link to them, or if you access third-party pages through links on our websites, platforms, and applications).
Data from media and social platforms: interactions you may have with our social networks, such as Facebook, Twitter, Instagram, LinkedIn, YouTube, etc.
The data can be provided directly by you, collected as a result of the provision of services or the supply of services by ALLOHA to you, or provided by legitimate external sources, such as strategic partners, suppliers, service providers, public bodies, correspondents, and companies or organizations with whom ALLOHA or you have a direct or indirect relationship.
We may also obtain Personal Data and other information from public and/or publicly accessible sources, such as the Internet, media, social media, and public records, and from other sources, as permitted by applicable law. Below are some examples of these situations.
Data can be provided by you, for example, when filling out registrations, forms, proposals, simulations, adhesions, contracts, access, search, or expression of interest in products and services.
Data we generate about you resulting from your relationship with ALLOHA, such as information about hiring and use of products and services or when you interact with us through our websites, platforms, and applications, channels, establishments, and service centers.
Data received from third parties are those provided by third parties about you, even if you are not an ALLOHA customer, including companies or organizations with which ALLOHA or you have some kind of relationship. Examples of cases where this occurs are:
A customer, counterpart, partner, or service provider indicates you as their partner, representative, employee, attorney, or contact.
A partner or service provider provides us with information about you for the offer or hiring of products and services.
We seek information about you or confirm information you provide to us for our activities, such as updating your registration and experience, fraud prevention, and compliance with other legal obligations.
HOW DO WE USE YOUR DATA?
We may process Personal Data and other information for various purposes related to ALLOHA’s activities, as described below:
Perform our activities, provide our services, and supply our products in our relationship with you:
Keep your registration updated, verify your identity, and any other information.
Fulfill and perform actions related to the contract, including steps prior to hiring, during, and after hiring. Activities such as evaluation of hiring proposals, customer service through our service channels, and operational processes to ensure the best experience and service for our customers.
Attend to our customers, potential customers, and third parties, including addressing inquiries, complaints, claims, requests, and support through our service channels, enabling your contact with us whenever necessary, and vice-versa.
Sending communications about products and services contracted by you, necessary for the fulfillment of the contract.
Selection and hiring of ALLOHA employees.
Understand our customers and offer products that better suit their needs and profile:
Evaluate the profile, identify opportunities, and offer and hire products, services, initiatives, and benefits from ALLOHA and/or strategic partners that are more appropriate to the profile, interests, and needs of current, potential, and third-party customers, including through email marketing or other communications.
Evaluate user and customer navigation behaviors and profiles, including understanding if the user accessed our websites, platforms, and applications through direct access, links, or their own or third-party cookies, for example.
Carry out marketing campaigns and use information technology and online advertising solutions.
Conduct surveys with the public to improve our products, services, customer service, and initiatives.
Security and risk:
Identify, prevent, and manage potential security risks, both physical and cyber, for you, ALLOHA, or third parties.
Prevent fraud and ensure security, including using your geolocation in any ALLOHA products, services, websites, platforms, and applications for identification and/or authentication processes in our own or third-party electronic systems, which may also be Personal Data Controllers, including by developing and/or using anti-fraud tools.
Analyze profile, identify, manage, and address potential risks in the offer and hiring of products and/or services and in other ALLOHA activities, such as credit risks, operational risks, reputational risks, market risks, among others. By monitoring these risks, we are also taking care of our customers’ safety.
Compliance with legal and regulatory obligations:
Comply with legal, regulatory, and self-regulatory obligations, such as internal audit and compliance activities, prevention of money laundering and financing of terrorism and other crimes, risk management activities, reporting to the Federal Revenue Service, fraud prevention measures, provision of information to the Central Bank and other competent authorities, in Brazil and abroad, for compliance with norms, reporting of suspicious transactions to the Coaf, INSS beneficiary proof of life, assessment of legal representatives and partners of companies, among other activities.
Comply with judicial, administrative, and arbitral orders and decisions.
Protect your rights, ALLOHA’s rights, and third parties’ rights:
For the regular exercise of rights, including in contracts and judicial, extrajudicial, administrative, or arbitral proceedings.
Maintain, create, and improve our activities:
Analyze, create, and improve our products, services, and activities, both internal and external, initiatives, projects, resources, and functionalities of our platforms, websites, and applications, including to improve and provide the best experience for you.
Measure and understand user and customer interaction with us, including on social networks and our channels, as well as the use of our products, services, activities, initiatives, websites, platforms, and applications, and user and customer satisfaction. This way, we can create, maintain, and improve our products, services, and service channels.
Perform business processes, internal and managerial management to help us make better decisions about our operations, business, services, products, activities, and initiatives.
Activities related to the hiring and relationship with suppliers, service providers, and other third parties.
Other treatment situations based on legitimate purposes, such as supporting and promoting ALLOHA activities or providing services that benefit our customers.
Promote events, sponsorships, and other activities and initiatives.
CAN THE INFORMATION BE SHARED?
ALLOHA and other companies that make up the ALLOHA Group are considered controllers of personal data. The group consists of three business poles and nine commercial brands:
Mobwire Cluster: Brands Mob and Wirelink
Sumicity Cluster: Brands Sumicity, Click Telecom, Univox, and Giga+ Vip Cluster: Brands Vip, Niu Fibra, and Ligue ALLOHA only shares your information when necessary or relevant for the purposes set forth in the contracts with our customers and in this Privacy Policy, within strict security standards, always aiming to maintain the confidentiality of your information and complying with the rules of secrecy and data protection and privacy. Examples of sharing situations are:
Among ALLOHA group companies and with a foundation or entity that has any of these companies as a maintainer or that is in any way managed or linked to the group, including for the development of our activities, offering and providing services, and supplying products, risk management, compliance with legal obligations, and other purposes set forth in this Policy.
With strategic partners, including for the offer, hiring, and use of their products and services, or developed together, or that may benefit you.
With service providers, suppliers, brokers, including financial and insurance brokers, and correspondents hired by ALLOHA for the development of our activities.
With regulatory authorities, other public entities, financial institutions, and third parties, including for compliance with legal, regulatory, and contractual obligations and for the protection and regular exercise of rights.
For compliance with requests, solicitations, and decisions of judicial, administrative, or arbitral authorities.
For the identification, prevention, and investigation of possible infractions or illicit acts (including fraud, money laundering, and financing of terrorism).
To prevent risks, fraud, and ensure security, including using your biometrics (facial, fingerprint, or other) in identification and/or authentication processes in our own or third-party electronic systems, which are also Personal Data Controllers.
Situations in which sharing is relevant or necessary for the creation, offer, maintenance, operation, and improvement of our websites, platforms, and applications, as well as the activities, initiatives, products, and services of ALLOHA and strategic partners.
With credit bureaus, including in accordance with applicable law, such as compliance with positive registration legislation, in cases of non-compliance, among others.
With other financial institutions, including when necessary for the processing of any transaction or other activities for contract execution.
Sharing of anonymized, aggregated, cookie, or other information or forms that do not allow the personal identification of Data Subjects.
In the case of acquisitions, mergers, or other corporate reorganizations.
Situations in which your consent may be necessary, and if so, we will request your consent when appropriate.
ABOUT COOKIES:
Cookies allow the collection of data related to navigation, depending on the type of device used, the authorizations granted by you through the settings of your device, and the functionalities used in each application. We may use our own or third-party cookies on our websites, platforms, and applications.
What are cookies?
Cookies are small text files that can or cannot be added to the browser of the device. These files store and recognize data that ensures the correct functioning of the applications and helps us identify your preferences and improve your experiences.
Types of cookies and their purposes:
Cookies can collect data for different purposes related to the functionalities of our websites, platforms, and applications. Below are the types we use:
Operation: to guarantee the correct access and functioning of the applications.
Authentication: to recognize the user, allowing access, including to restricted access areas, and also used to offer content, offers, and/or services from strategic partners.
Security: to assist in monitoring and detecting unauthorized activities, preventing fraud and protecting users’, ALLOHA’s, and third parties’ information.
Research, analysis, and performance: to verify, measure, and analyze the audience, performance, and use of applications by users.
Advertising: to present relevant advertising from ALLOHA and partners based on the user’s profile and to know what they viewed, both on our environments and on partners’ websites, platforms, and applications. They can also be used to remember any surveys conducted by Users and, based on the results of these surveys, show advertisements or offers for products, services, and initiatives of their interest.
CAN I DISABLE COOKIES AND OTHER FORMS OF DATA COLLECTION?
You can disable or delete cookies, as well as data collection technologies, in the settings of your browser and the operating system of your device, except for operation cookies, which, if disabled, will not allow the use of our websites, platforms, and applications.
We only remind you that if certain cookies are disabled, the websites, platforms, applications, some of their features or functionalities may not work correctly.
ADS:
Like other websites, we collect and use information contained in advertisements. The information contained in advertisements includes your IP address (Internet Protocol), your ISP (Internet Service Provider), the browser you used to visit our website (such as Internet Explorer, Google Chrome, or Firefox), the time of your visit, and the pages you visited within our website.
INTERNATIONAL DATA TRANSFER:
Your personal data may be transferred and processed in other countries, according to the assumptions provided for in the LGPD and applicable legislation, for the purposes set forth in this Privacy Policy. For example, data may be transferred abroad if necessary for the execution of a contract; for compliance with legal and regulatory obligations of ALLOHA; for the regular exercise of rights in administrative, judicial, or arbitral proceedings, or for the investigation of crimes and other offenses. Furthermore, international data transfer may occur for the development of ALLOHA activities, adopting data protection measures.
HOW LONG DO WE KEEP YOUR DATA?
The period for which ALLOHA keeps the personal data collected depends on the purpose and nature of the data processing. We will treat your data for the period necessary to comply with legal, regulatory, and contractual obligations, to continue providing and improving our products and services, for risk management, for the regular exercise of rights in administrative, judicial, and arbitral proceedings, and for other purposes set forth in this Privacy Policy.
DATA SECURITY:
The security and privacy protection of personal data and ALLOHA’s information are a priority. ALLOHA establishes processes and controls for prevention, detection, and response to incidents and protection of your data against unauthorized access and use, ensuring security risk management, including cybernetics, throughout its life cycle, from the moment it is collected, through processing, transmission, storage, analysis, and disposal.
We use tools and technologies to maintain the integrity and confidentiality of information and protect it from unauthorized access. Additionally, we restrict access to data to the necessary extent, with strict confidentiality and secrecy obligations, by adopting security criteria.
YOUR RIGHTS:
The LGPD guarantees rights to the data subjects, who may make the following requests to us:
Access and confirmation of the existence of data processing.
Update, correction of incomplete, inaccurate, or outdated data.
Anonymization, blocking, or deletion of unnecessary, excessive, or data processed in violation of the LGPD provisions.
Data portability, subject to applicable rules and business secrets.
Information about public and private entities with which the Controller has shared data.
Information about the possibility of not providing consent and the consequences of refusal.
Revocation of consent, which can be done at any time and without cost, through an express manifestation.
Request the elimination of Personal Data Processed with consent, except in cases where maintaining the data is necessary or permitted by law.
Opposition to treatment carried out based on other legal bases, in case of non-compliance with the LGPD, emphasizing that there may be situations in which we may continue to perform the Treatment and refuse your opposition request.
Request the review of decisions made solely based on automated processing of Personal Data that affects you, such as credit decisions.
Request the cancellation of sending targeted offers of ALLOHA’s products and services through our channels.
To exercise your rights regarding your Personal Data, you can contact our customer service channels, choosing the most appropriate one according to your relationship.
We emphasize that we may keep some data and/or continue processing it, even in the case of a request for deletion, opposition, blocking, or anonymization, in some circumstances, such as complying with legal, contractual, and regulatory obligations, safeguarding and exercising ALLOHA’s, users’, and customers’ rights, preventing illicit acts, and in administrative, judicial, and arbitral proceedings, including by third parties’ questioning of your activities and other situations provided for by law.
DATA PROTECTION OFFICER:
To obtain more information about the Privacy Policy or how we process your personal data, you can contact us through the ethics and privacy channel.