Gramado Parks Privacy and Data Protection Policy
Last updated on October 1, 2021 GRAMADO PARKS INVESTIMENTOS E INTERMEDIAÇÕES SA, a legal entity registered with the CNPJ under no. 00.369.161/0001-57, with headquarters at Rua Santa Maria, no. 193, Room 01, Bairro Carniel, in the City of Gramado/RS, CEP 95.670-000, a private law legal entity, with headquarters at R. Rua Santa Maria, no. 193, Bairro Carniel, Gramado/RS, CEP 95.670-000, and other affiliated and controlled companies (“Gramado Parks” or “We”), respects the privacy of all individuals who interact with Gramado Parks products, services and attractions (You) and is committed to maintaining the integrity and security of your personal information. Gramado Parks values transparent and accessible communication, presenting its Privacy Policy (“Policy”), in accordance with these values and with Brazilian Law. This Policy applies to all individuals who maintain a relationship with Gramado Parks and describes how your Personal Data is treated. Please read this Policy carefully and if you do not agree with this Policy, please do not use our website or our physical facilities. 1 – What are the main terms used in this Policy?
1.1. This Policy shall be governed by the definitions of the capitalized terms listed below. If there is any term not covered in this Policy, the interpretation shall be in accordance with Brazilian Law: (i) Brazilian Law: all legal standards in force, or in vacatio legis (total or partial), related to the protection of Personal Data, including, but not limited to the Brazilian Federal Constitution; General Data Protection Law (Law No. 13,709/2018); Internet Civil Rights Framework (Law No. 12,965/2014); Regulatory Decree of the Internet Civil Rights Framework (Decree No. 8,771/2016); Civil Code (Law No. 10,406/2002), Consumer Defense Code (Law No. 8,078/90); Access to Information Law (Law No. 12,527/2011);(ii) General Law on the Protection of Personal Data - “LGPD”: provides for the Processing of Personal Data, in physical and digital media, by a natural person or by a legal entity under public or private law;(iii) Personal Data: information related to a natural person, identified or identifiable;(iv) Sensitive Personal Data: data on racial or ethnic origin, religious belief, political opinion, membership in a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data which, together with Personal Data, will be called Personal Data; (v) Processing: any operation performed with Personal Data, such as those related to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction; (vi) Controller: within the scope of this Policy, and within the scope of the relationship with You, Gramado Parks, which is responsible for decisions regarding the Processing of Personal Data; (vii) Operator: a natural or legal person, under public or private law, that carries out the Processing of Personal Data on behalf of the Controller; (viii) Data Subject: within the scope of this Policy, You, the natural person to whom the Personal Data that will be subject to Processing refer. 2 – Which Personal Data will be subject to processing and how do we collect them?
2.1. In order to understand your needs and provide our services in the best possible way, we may collect the following Personal Data: 1. Identification Data, which includes your name, postal address, email, telephone number, nationality, profession, date of birth and social media profiles, in addition to your CPF and RG; 2. Photographs and videos; 3. Health data when you are a person with a disability or reduced mobility and who depends on priority care or special care, as defined by Brazilian Law; 4. Technical information about the computer/mobile device you use, such as the IP address used to connect your computer or device to the internet; the type of operating system and the type and version of the web browser; advertising ID; geographic location; 5. Financial and payment information that we need 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 forms of payment (if available); 6. Data on children and adolescents in accordance with Brazilian legislation.
2.2. We will have access to your Personal Data when: 1. You provide it to us directly through the use of our website, when making a reservation or purchasing a ticket/voucher, as well as when visiting our physical facilities; 2. You share information publicly on a social network that shares such information with us, or when You interact with Gramado Parks on a third-party social network, such as Facebook or Instagram; 3. Through consumer-facing booking websites operated by or for Gramado Parks, including websites we operate under our own domains/URLs and pages we maintain on third-party social networks, such as Facebook; 4. Through email, text messages, electronic messages or Customer Service; 5. Offline registration forms. Printed or digital records and similar forms by which we collect Personal Data, for example, Service Acceptance Forms, and communications about leisure practices within our facilities, conventional mail, in-store demonstrations, contests and other promotions or events; 6. Interactions with advertisements. Interactions with our advertisements (for example, if you interact with one or more of our advertisements on a third-party website, we may receive information about that interaction); 7. Through security cameras that capture images for security purposes of Gramado Parks spaces, as well as interactive totems; 8. Data from other sources. Third-party social networks (such as Facebook, Google), market research (if the feedback is not given anonymously), third-party data aggregators, promotional partners or travel/tourism agencies; 9. When you participate in one of our Campaigns, in accordance with their own regulations, or when you join our Benefits Club; 10. When you apply, through our website or partner websites, for vacancies at Gramado Parks.
2.3. We use Cookies on our website. Cookies are small text files that can be saved on electronic devices and allow us to store and recognize your browsing preferences and other information about you. The following types of cookies may be used when browsing the Gramado Parks website: 1. Functionality Cookies: are essential for the website's performance and include user preferences in order to personalize navigation; 2. Security Cookies: are used to authenticate users and prevent illegal activities such as fraud, increasing the website's security level and making it safer for you; 3. Analysis Cookies: are collected to check user interaction with the website, frequently improving our features and delivering a better experience to you on each visit.
2.4. Through the use of cookies, Gramado Parks memorizes your information while you browse our website, to provide you with a personalized and appropriate experience; to allow you to access the website again without starting a new session; and to automatically fill in forms such as “Contact us”.3 – For what purposes do we process your Personal Data?
3.1. Personal Data will be used by Gramado Parks to provide its services, including: 1. Execution of Contract and Work, Internship or Provision of Services; 2. Sending newsletters to registered users; 3. Delivering, selling or exchanging promotional tickets and/or vouchers; 4. Granting discounts to children and adolescents and/or people with disabilities, as and if provided for in Brazilian Law; 5. Sending marketing emails and SMS about news, services and facilities that may interest you; 6. Responding to contact that You have initiated through one of our service channels. 7. Recording calls, when required by Brazilian Law, at which time you will be informed of the recording in advance; 8. Capturing images or videos in certain services or attractions. In these cases, You are aware that attractions that have this functionality will have a visible notice indicating the possibility of collecting images and videos; For hiring purposes, when you apply for one of our opportunities; 10. Contact the parents or guardians of children or adolescents if necessary, in accordance with Brazilian Law; 11. Regular exercise of rights in judicial, administrative or arbitration proceedings, in addition to compliance with legal and/or regulatory provisions, in addition to meeting demands from public bodies; 12. To ensure the physical and property safety of all those involved, in addition to meeting the legitimate interests of Gramado Parks or group companies, always limited to that provided for in Brazilian Law; 13. Make reservations, participate in rewards clubs or for specific promotional campaigns, in accordance with their own regulations; 14. For analyses related to website security and information security, preventing errors/technical failures.
3.2. When the Processing of Personal Data involves information from children and adolescents, Gramado Parks will collect the consent of parents or guardians, in accordance with Brazilian Law, when this is the necessary formality for this purpose.4 – With whom do we share your Personal Data?
4.1. Personal Data may be shared to achieve the purposes described in this Policy. Gramado Parks undertakes to do so only with partners that employ a high level of information security, establishing contractual clauses that do not violate the provisions of this Policy. In addition, we list below the hypotheses in which your information may be shared: 1. With payment methods and other companies that are part of the financial system to complete your reservation or purchase of products, tickets and/or vouchers; 2. With Service Providers for the regular operation of Gramado Parks' activities, such as marketing companies, information technology companies, technology developers, security companies; 3. With consulting companies and law firms, to protect our interests, including cases of legal, arbitration and administrative claims; 4. By court order or at the request of Public or Regulatory Authorities that have the authority to make the request; 5. With public bodies and authorities, for the purpose of complying with legal and/or regulatory obligations; 6. With companies that are part of the same corporate group to improve the Gramado Parks experience and offer specialized services and plans, as well as in merger, acquisition or incorporation activities.
4.2. Considering the nature of a website, Personal Data, including data from children and adolescents, may be transferred to other countries for cloud storage purposes. In such cases, Gramado Parks undertakes to do so only with partners that employ a high level of information security. 5 – How long do we store your Personal Data?
5.1 Gramado Parks will keep your Personal Data until the purposes described in this Policy are achieved and/or, even if the purpose ends, to comply with legal and regulatory obligations arising from the activities provided, or when storage is not prohibited by Brazilian Law.
5.2 You, your parents or legal representatives may revoke the consent given for the Processing of your Personal Data, or the Personal Data of children and adolescents in some situations. Gramado Parks undertakes to make all necessary efforts to fulfill such requests, if applicable, in the shortest possible time and in compliance with Brazilian Law.6 – How do we protect your Personal Data?
6.1 Gramado Parks undertakes to adopt all reasonable efforts, considering the available and applicable technological solutions, to preserve the integrity and security of your Personal Data;
6.2 Gramado Parks uses the principle of privacy by design, which means that we think about privacy before carrying out our activities, respecting and protecting Personal Data in our internal procedures;
6.3 Gramado Parks adopts high information security standards to maintain the confidentiality and security of your Personal Data. Despite this, it is not possible to absolutely guarantee that there will be no errors on the website, security incidents, breaches or unauthorized access, considering that internet security practices are constantly evolving. It should be noted, however, that Gramado Parks is committed to monitoring developments and implementing security improvements on an ongoing basis, if possible and reasonable. 7 – User Rights
7.1. You, and/or the child or adolescent represented by You, may exercise your rights as holders of Personal Data, as provided for in the LGPD, such as but not limited to: Request confirmation of the existence of processing, access to Personal Data; Request the correction of incomplete, inaccurate or outdated data; Request the deletion of Personal Data processed after obtaining your consent, as well as the revocation of consent; Clarify doubts about this Policy and/or the processing of your Personal Data.
7.2. Requests for these rights and the resolution of queries may be exercised through the Gramado Parks Data Subject Portal available at https://portaldotitular.gramadoparks.com. Gramado Parks will make every effort to respond to and fulfill requests promptly and completely, if applicable, in the shortest possible time and in compliance with Brazilian Law.
7.3. In certain circumstances, it may be necessary to retain some of your Personal Data after you have requested its deletion, in order to satisfy legal or contractual obligations.8 – Third Party Links
8.1. On the Gramado Parks website, some products, content and services available may include third-party materials. You are aware and agree that the existence of these links does not represent sponsorship of third-party websites and acknowledge that you are subject to the terms of use and privacy policies of third-party companies, which must be verified by you.9 – How do we communicate with you?
9.1. As a way of providing our services and ensuring transparency with You, we may contact You through the following communication channels: (i) WhatsApp; (ii) Telephone; (iii) SMS; (iv) Email.
9.2. By accepting this Policy, you agree and authorize us to use your telephone number to communicate with you via WhatsApp.10 – Changes to this Policy
10.1. Considering that Gramado Parks is always seeking to improve its services, this Policy may be updated. Therefore, we recommend that you visit this page periodically.
10.2. If we make material changes that require new consent, we may place a notice on our website or send you an email/SMS/WhatsApp, together with the updated Privacy Policy, to obtain your consent, where necessary.Last updated on October 1, 2021
