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HEAVEN PRIVACY POLICY

 

Last Update: 06/20/2023

 

Welcome! Thank you for using HEAVEN and its applications!

 

This application and its content are controlled and operated by HEAVEN itself. All rights reserved .

 

This policy and terms of use are intended to define the rules to be followed for the use of HEAVEN and its subdomains, without prejudice to the application of current legislation.

 

These terms of use are intended to define the rules to be followed for the use of HEAVEN ("Terms of Use of HEAVEN") and its subdomains, without prejudice to the application of current legislation. Thus, the term governs your access and use anywhere in the world, of applications, Internet sites, contents, goods and also of all services made available by GREENN INTERNATIONAL LTDA, registered in the National Register of Legal Entities of the Ministry of Finance (CNPJ /MF) under n. 45.328.197/0001-20 (“HEAVEN”) or any of its affiliates.

  

Acceptance of our Policy will be made when you access or use the HEAVEN website, application or services. This will indicate that you are aware of and fully agree with how we will use your information and data.

This Policy is divided as follows to facilitate its understanding:

  1. What information HEAVEN collects and purposes;
  2. How HEAVEN uses the collected information;
  3. How, when and with whom HEAVEN shares your information;
  4. What rights you have to the information we collect;
  5. How HEAVEN protects your information;
  6. How long we retain your personal information;
  7. Updates to this privacy policy;
  8. Our Communication Channel;
  9. Applicable law.

 

This document should be read in conjunction with our Terms of Use , which contains an overview of our platform. If you have questions or need to address any matter related to this Policy, please contact us at privacy@heaven.me

 

1. DEFINITIONS

 

  • HEAVEN web platform. A digital platform of online services that connects third-party producers of free or paid digital content (video, audio, text, etc.) to end users.
  • User of the application: That owns the digital content (video, audio, text, etc.) called Product, which sells the product within the Platform. Producer is the exclusive holder of the intellectual property rights of the Products made available on the Platform.
  • Co-producer. User of the application together with the Producer, owner of the digital content (video, audio, text, etc.) called Product, which sells the product within the Platform. Producer is the exclusive holder of the intellectual property rights of the Products made available on the Platform.
  • Affiliates. Application users (web or application) are individuals interested in registering with HEAVEN to manage their activities and tasks.
  • End customer. User who purchases the products available from the Producers on the platform.
  • Digital product. The digital content (events, video, audio, text, etc.) created by the Producers are made available on the Platform.
  • Physical product. Any type of material product that may be made available for sale on the platform.
  • Heaven Club. Academy or member area, where the producer inserts his digital content to be made available on the platform.

 

2. INFORMATION WE COLLECT

 

 The personal data collected by HEAVEN varies according to the type of interaction the user has with the Platform. We collect the following types of information:

2.1. Information you provide to us.

That includes:

  • Data on Producers, Co-producers and Affiliates . When you access these conditions on the HEAVEN platform, you provide us with information on:
  • Registration: full name, e-mail, cell phone, CPF and CNPJ (optional);
  • Dashboard: photo (optional), ID and address;
  • Validation and User Authenticity: attached document (RG, CPF or CNH) and facial identification via video; It is
  • Banking information: banking institution, account number, account type and branch.
  • End Customer Data . When you log in as a producer on the HEAVEN platform, you provide us with information on:
  • Checkout page: full name, email, cell phone, CPF or CNPJ; It is
  • Banking information: credit card data, cardholder. Validity and verification code

2.2. Information generated when you use our services.

We collect the following generated information:

  • Access logs . HEAVEN automatically collects application access logs, which include the IP address, with date and time, used to access HEAVEN.
  • HEAVEN CLUB . In the same way as HEAVEN, logs of access to content in the members area are automatically collected, including IP address, date and time used in access. Valid for the same legal obligations above and availability.
  • Communications with HEAVEN via chatbot . When you communicate with HEAVEN, we collect information about your communication, including metadata such as date, IP and time of communications and all their content, as well as any information you provide within the Platform, in accordance with Law 12.965/2014.
  • Open a Claim / Request a Refund. The user can open a Complaint about the product or request a refund through the HEAVEN website, the following must be informed: Invoice number and CPF used in the purchase, for both situations the producer will be informed and will be able to interact to resolve the situation , for more details, see the specific section on the topic in the platform's Terms of Use.
  • Cookies, pixel and similar technologies . We use cookies, which are text files generated and stored in your browser or device by websites, apps and online advertisements. HEAVEN has its own Cookie Policy, accessible at HEAVEN's Cookie Policy.
  • Payment details . When you make payments on HEAVEN, payment data may be stored, such as date and time, amount and other details of the transaction, which may also be used for fraud prevention purposes. In this way, we can provide you with a safe and suitable environment for you to carry out your transactions. Payments made in HEAVEN must be made within the application, through payment links made available by producers, co-producers and affiliates and in accordance with the terms of use available in the HEAVEN purchase terms.

2.3. What is our legal basis for processing information

HEAVEN prioritizes the security of your information in accordance with Brazilian legislation through the General Data Protection Law (LGPD) - Law 13.709/2018, using the following legal bases for processing personal data that may vary depending on your relationship with the platform:

  1. Execution Contract . We rely on this legal basis to process purchases and downloads of our products and services, to perform a contract with you.
  2. Consent. We rely on this legal basis to process information for marketing activities, sales, events and to keep you updated about our products and services that may be of interest to you.
  3. Comply with applicable laws and regulations . We rely on this legal basis to comply with legal requirements (whether federal, state or local law), any requirements under international law and to comply with a subpoena or other legal process.
  4. Regular exercise of rights in judicial, administrative or arbitration proceedings . We rely on this legal basis when there is a need to comply with data processing due to judicial, administrative or arbitration proceedings.
  5. Legitimate Interest . We rely on this legal basis when processing your contacts and information in order to communicate with you in an accessible and efficient manner. We also use legitimate interest to analyze, develop, optimize and improve services, products and maintain the security of our applications.

2.4. Processing of Personal Data of Minors

HEAVEN does not collect data from minors. If such an atypical situation is verified, the account will be automatically canceled and data deleted immediately, unless there is a legal obligation to be fulfilled and platform security.

 

3. HOW WE USE YOUR INFORMATION

 

It doesn't hurt to remember, we value your privacy very much. Therefore, all data and information about you are treated as confidential, and we will only use them for the purposes described and authorized by you, mainly so that you can fully use HEAVEN, always aiming to improve your experience as a user.

3.1. Authorized uses

In this way, we may use your data to:

  • Allow you to access and use all HEAVEN functionalities;
  • Allow customizing use and access by updating registration, purchase and sales history, publishing content, disclosing content available on the platform;
  • Send you messages regarding support or service, such as alerts, notifications and updates via email, SMS, whatsapp or telephone;
  • Communicate with you about products, services, promotions, news, updates, events and other matters that you may be interested in regarding the Platform (marketing, remarketing, newsletter, advertising campaigns);
  • Perform communication and manage the payment method services on the platform;
  • Customize the service to suit your tastes and interests more and more;
  • Create new services, products and features;
  • Detection and prevention of fraud, spam and security incidents;
  • Verify or authenticate the information you provide, including against data collected from other sources;
  • Better understand user behavior and build behavioral profiles regarding the Platform;
  • Support activities with the platform;
  • Comply with legal obligations.

Eventually, we may use data for purposes not provided for in this privacy policy, but these will be within your legitimate expectations. Any use of your data for purposes that do not comply with this prerogative will be done with your prior authorization .

3.2. Monitoring

HEAVEN reserves the right to monitor the entire platform, mainly to ensure that the rules described in our Terms of Use are being observed, or that there is no violation or abuse of applicable laws.

3.3. HEAVEN as Operator

HEAVEN in certain circumstances interacts with personal data as a mere operator for processing personal data. When personal data is transferred to producers, co-producers and affiliates, they may be under their control, and they are responsible for respecting and guaranteeing the protection of personal data in accordance with applicable laws.

 

4. INFORMATION SHARING

 

HEAVEN may share Essential Information pursuant to business activity or with third parties under the following circumstances or when otherwise described in this Privacy Policy.

HEAVEN does not transfer or share your personal information with third parties outside of its primary business and legal basis in running our system.

The sharing of information will occur anonymously and/or encrypted, whenever possible, in order to preserve your privacy. You hereby expressly consent to such sharing .

International Transfer and Storage . HEAVEN and its third parties may transfer your personal data to countries other than where you are located. In this case, the international transfer will comply with adequate personal data protection and applicable laws and certifications.

Consent Producers, Co-producers and Affiliates . By accepting to use the platform, the user consents to some of his information being accessed and shared with producers, co-producers and affiliates.

Fraud prevention, harm and security . Your personal data, restricted only to the necessary, may be shared with third parties in order to prevent fraud, verify user authenticity, authenticate documents and for evaluations, monitoring and use of the platform.

Payment services. Personal data is shared with third-party banks, credit card brands, payment institutions or credit institutions partnering with the platform when users, in any way, make use of these services available on the HEAVEN platform. This sharing is intended to process payments, prevent, detect any fraud or resolution involving refunds.

Legal Compliance. HEAVEN, in response or legal requests, in certain cases may provide the data collected to bodies and entities related to the Judiciary, arbitration courts or competent administrative authorities.

Integrations. HEAVEN may, in specific cases, link third parties to the platform through an API (Application Programming Interface), which will not be interacting directly with the platform's services and obey their own and different terms and conditions. Therefore, HEAVEN IS NOT RESPONSIBLE FOR THESE SERVICES WHEN YOU INTERACT WITH THEM.

Service Providers linked to HEAVEN . Your data may be shared with third parties that are directly involved in the main activity of the platform, for example, accounting, financial, legal advice, potential investors, third parties involved in providing data backup, cloud computing providers or for internal analysis.

All data, information and content about you can be considered active in the case of negotiations in which HEAVEN takes part. Therefore, we reserve the right, for example, to include your data among the company's assets if it is sold, acquired or merged with another company. Through this Policy you agree and are aware of this possibility.

HEAVEN reserves the right to provide your data and information about you, including your interactions, if legally required to do so, necessary act for the company to comply with national laws, or if you expressly authorize it.

 

5. HOLDERS' RIGHTS

 

You can always communicate with us to exercise requests related to your rights under applicable laws through our Privacy Center.

You will always have rights relating to privacy and the protection of your personal data. However, if you choose not to disclose your data to us, please keep in mind that some of this data may be required to use the functionality of our applications.

Through our Privacy Center you will be able to access your data, rectify your information, eliminate personal data or any other demand regarding the processing of your personal data.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We may also contact you for more information regarding your request in order to expedite our response. We attempt to respond to all legitimate requests within fifteen (15) business days. Occasionally, it may take longer than fifteen (15) days if your request is particularly complex or if you have made multiple requests. In this case, we will communicate with you and keep you updated on the progress of your request.

If you have any questions about these matters and how you can exercise these rights, please feel free to contact us at privacy@heaven.me .

 

6. INFORMATION SECURITY

 

All your data is confidential and only people with the proper authorizations will have access to it. Any use of these will be in accordance with this Policy. HEAVEN will use all reasonable market efforts to ensure the security of our systems and your data. Our servers are located in different locations to ensure stability and security, and can only be accessed through previously authorized communication channels.

All your information will be, whenever possible, encrypted, if it does not prevent its use by the platform. At any time, you may request a copy of your data stored in our systems. We will keep the data and information only for as long as they are necessary or relevant for the purposes described in this Policy, or for periods predetermined by law, or as long as they are necessary for the maintenance of HEAVEN's legitimate interests.

HEAVEN considers your privacy extremely important and will do everything in its power to protect it. However, we cannot guarantee that all data and information about you on our platform will be free from unauthorized access, especially if there is improper sharing of the credentials necessary to access our application. Therefore, you are solely responsible for keeping your access password in a safe place and sharing it with third parties is prohibited. You undertake to notify HEAVEN immediately, through secure means, regarding any unauthorized use of your account, as well as unauthorized access by third parties to it.

6.1. Monitoring and security

HEAVEN spares no efforts to ensure the privacy and security of its application in the internet environment.

In this application, data mining of any kind or kind, use of message bots, mass operations, under the application of Brazilian criminal legislation and repairing damages resulting from this use are prohibited.

 

7. INFORMATION RETENTION TIME

 

HEAVEN retains collected data for different periods depending on what data it is, how we use it and how you have configured your settings and according to your interactions with the platform. However, unless determined in specific Laws or Legal Obligations, HEAVEN generally retains the information obeying the maximum time for disposal of your information:

  • when communicating the disconnection of the platform or cancellation of the contract with users;
  • in achieving the purpose of treatment;
  • when data is no longer necessary and relevant to the platform and its collection purpose;
  • upon revocation request by the user; and/or
  • by application of legislation or command of competent bodies.

In certain situations, depending on your interaction with the platform, third parties and users involved may retain your personal data after the aforementioned cases, due to legal or regulatory obligation. In these cases, the data will be stored in a safe place and automatically discarded for as long as the legal or regulatory obligation lasts.

HEAVEN has a retention and deletion policy to ensure they are safely and completely removed from our servers or retained only anonymously. We strive to protect our services and information from accidental or malicious deletion, so there may be a longer window of time for deletion due to our active and backup systems.

 

8. PRIVACY POLICY UPDATES

 

HEAVEN reserves the right to change this Policy as many times as necessary, in order to provide you with more security, convenience, and increasingly improve your experience, without prior notice. That's why it's very important to access our Policy periodically. To make it easier, we indicate at the beginning of the document the date of the last update.

If relevant changes are made that give rise to new authorizations from you, we will publish a new privacy policy and notify the user by email or via access on the platform with a summary of the main changes. However, changes will be effective the day they are posted.

This Policy prevails over the others published, as well as any previous understandings related to privacy and your personal data. If you do not agree with the new version of this Policy, we advise you to completely cease using your account and the HEAVEN platform.

 

9. COMMUNICATION CHANNEL

 

HEAVEN, in compliance with article 41 of the General Data Protection Law, lists Fabio Gomes as the person in charge of data processing, with contact being possible through the following email: privacy@heaven.me .

 

10. APPLICABLE LAW

 

This document is governed by and must be interpreted in accordance with the laws of the Federative Republic of Brazil. The Jurisdiction of the Judicial District of Cidade Gaúcha Paraná, Brazil is elected, as the competent one to resolve any issues that may arise from this document, with express waiver of any other, however privileged it may be.


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