1. Our commitment to your Privacy

SAN Mobile is committed to protecting the privacy of its potential and existing customers. The privacy policy (“Privacy Policy”) applies to all Personal Data (described below) that we process, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages, or through other online or offline channels, better described below.

  1. Dados Pessoais

Dados Pessoais” são informação ou extratos de informação que o permitem ser identificado, como por exemplo:

  • Name and contact details (e.g. postal or e-mail address, telephone number)
  • Account information (e.g. username, profile photo or social network account ID)
  • Country of Residence
  • Date of birth
  • Technical information, e.g. pseudonym, IP address, browser and equipment data, information collected through cookies, pixel tags and other technologies, log data on server, app usage data and location data
  • Preferences (e.g. consumption habits, deprecated professional courses)
  • Company or school name and address
  • Credit and debit card number
  • Medical conditions (e.g. allergies or illness)

How do we collect Personal Data?

We collect Personal Data in several ways:

  • Directly from you: The information is collected directly from you, either through information provided directly by you, or when you act to provide us with the information, for example:
    • Offline: We collect Personal Data offline, for example when you contact customer service, sign up for a product or service, or provide us with information in writing.
    • Online: We collect your Personal Data through BugScout, for example when you register to receive the newsletter or a brochure, sign up for a product or service. We also collect Personal Data:
      • Through cookies. Cookies allow the web server to transfer data to a computer or device for maintaining history and for other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to refuse the use of cookies. For detailed information about the cookies we use and the purposes for which we use them, please see our Cookies policy.
      • Through the use of a Mobile Phones application. When allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the application accessed our servers and what information and files were downloaded for the cell phone application, based on their equipment number.
      • Through your device. As long as you have enabled this feature on your device, we collect your physical location to provide you with personalized location-based services and content. Read more about these services below “How do we use Personal Data?”
    • From our affiliated companies, business partners, assistance providers and complaints managers. We may receive Personal Data from other entities along with your program, including:

      • Our partners and affiliates, such as the company SAN Mobile, which promotes the sale of our services and offers customer service in your country of residence and provides us with your Personal Data that are necessary to reach an agreement with you on the your order, or the school in your destination country that provides some of the services you have requested, or the parent company, which is based in brazil and is responsible for fulfilling the contract with you for all SAN Mobile offers.
      • Business partners, such as local sales agents, who promote the sale of our services in your country of residence.
      • Claims managers who receive information about their insurance claims, according to the insurance situation.
    • If you browse our sites, we may also collect information about your use of our services through your browser, for monitoring activity on our sites, such as your Media Access Control (MAC) address, type of computer (Windows or Macintosh) , monitor resolution, operating system name and version, equipment manufacturer and model, language, Internet browser type and version, service provider and the name and version of the SAN Mobile Product you are using. In addition, an IP address is identified and accessed automatically by our server log files whenever you visit SAN Mobile Products, along with the visit time and the page (s) you visited. These data are only stored and used together with other Personal Data that you have submitted, if you have given your consent to do so. You can read more about the collection of the IP address and other browser data in our Cookies policy.

      How do we share Personal Data?
      • We share your Personal Data with our affiliated companies, business partners and service providers, both inside and outside Brazil:
        • For statistical purposes, calculating degrees of utilization and helping to diagnose server problems with SAN Mobile, as well as to ensure that the Products work properly.
        • Para permitir contatá-lo e ser contatado por outros utilizadores através da SAN Mobile, conforme permitido pelo produto aplicável;
      • To allow you to participate in message boards, chat, profile pages and blogs and to use other services, allowing you to publish information and materials.

      • If you have given your consent:
        • To market our products and services, including special promotions based on your interests, for example through e-mail marketing solutions such as RD Station management software, which maintains e-mail lists and calendars and modifies e-mail messages -mail based on what recipients read, click or send. This email communication will clearly include an unsubscribe link.

How do we share Personal Data?

  • We share your Personal Data with our affiliated companies, business partners and service providers, both inside and outside Brazil:

    • Our affiliated companies are, for example, a local SAN Mobile company that promotes the sale of our services and offers customer service in your country of residence, or the school in the country of destination that provides you with some services you have requested, or one of the parent companies that offers another service from the SAN Mobile Program.

    • Business partners are, for example, local sales agents who promote the sale of our services in your country of residence; transport or accommodation service providers to manage one of our programs; or course leaders, activity leaders or others hired to manage one of our programs; or a travel insurance company that arranges travel insurance for you.

    • Service providers, namely providers of IT systems, for example to manage customer relations or payments, schedule classes or store learning results; or software and service providers for digital marketing automation or analytics.
We have implemented adequate guarantees for the transfer of your Personal Data, following the concepts and regulations of LAW No. 13,709, OF AUGUST 14, 2018 -. For more information on standard contractual clauses applied for data transfer, please see the contact section below.
  • We share Personal Data to the extent that we consider necessary: ​​(a) in accordance with applicable law; (b) to comply with the legal process; (c) to respond to requests from public authority or governments, including public authorities and governments outside your country of residence; (d) to execute our terms and conditions or a contract; (e) to protect our operations and those of our affiliates; (f) to protect our rights, privacy, security or property, and / or that of our affiliates, yours and others; and (g) to allow us to take actions for damages or to limit damages that we may suffer.

On what do we base our right to collect and use Personal Data?

We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services and products you request from us, or when there is a legitimate interest from us (ie service provider) in using your Personal Data, namely for marketing products or services similar to the one (s) you have already purchased from the same legal entity.

To the extent that we use sensitive Personal Data, we rely on your explicit consent. Sensitive data can be, for example, information about your health, ethnicity or religious beliefs, read more in “Sensitive Data”.

To the extent that we use your Personal Data to send you offers other than those considered to be within our legitimate interest, such as marketing products and services provided by a SAN Mobile affiliate, we rely on your specific consent.

  1. Safety

We take appropriate organizational, technical and administrative measures to keep Personal Data in our possession correct and up-to-date, as well as to protect Personal Data from unauthorized or illegal treatment and accidental loss, destruction or damage to Personal Data.

  1. Cancellation

If at any time you wish to stop receiving our marketing communications, you can use the option to unsubscribe from the marketing communication you received, or send us that information using the contact details in the “Contact- U.S”. In your order, please indicate that you want to stop receiving our marketing communications.

Please note that changes may not be applied immediately. We will make every effort to satisfy your order (s) as soon as reasonably possible.

Third Party Sites

This Privacy Policy does not address nor are we responsible for the privacy, information or other practices of any third party, including any third party operating on any website where a SAN Mobile Product contains a link. The inclusion of a link in SAN Mobile Products does not imply acceptance of the linked site by us or our affiliates.

In addition, we may provide you with access to third party features that allow you to share your activities on SAN Mobile Products on your social network account (s), for example Facebook or LinkedIn. Please note that any information you provide through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and will not be responsible for, the use of information from any third party you provide through the use of this functionality.

  1. How Long Do We Keep Personal Data?

We will only retain your Personal Data for as long as necessary for the purposes for which it was collected, or in accordance with the time limits stipulated by law or market practices, unless future retention is necessary to fulfill a legal obligation or for the establishment, exercise or legal action or for a specific time communicated by you.

We will keep limited parts of your Personal Data that are necessary for marketing purposes until you withdraw your consent, but never for more than 10 years after your last service or product delivery.

  1. If you are under 16

If you are under the age of 16, you should review this text together with your guardian to make sure you both understand it. We are not responsible for checking your age, but sometimes we still do checks. If we find that you are under 16 and that we collect information about you without the consent of your parent, we will delete the information as soon as possible and you will not be able to use SAN Mobile Products.

  1. Sensitive Data

We do not intend, in general, to collect sensitive Personal Data. Sensitive Personal Data is data related to racial and ethnic origin, political orientations or philosophical ideologies, health or medical condition, criminal record or union membership. Under certain conditions, however, this may be necessary (for example in order to provide you with services and products you have requested for insurance). We will make sure that we receive your explicit consent for such treatment and that we handle this information securely.

  1. Changes to the Privacy Policy

Our Privacy Policy can be modified at any time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any updates to the Privacy Policy on this page and, before implementing such updates, we will communicate to you through a more prominent notice. Whenever required by law, we will obtain your prior consent to any changes.

  1. Your Rights

You have the right to contact us once a calendar year and, without any associated costs, find out what information about you is being used. You have the right to receive your Personal Data in a readable format and you have the right to transfer your Personal Data to another data controller.

You have the right, at any time, to withdraw your consent or refuse us the use of your Personal Data for direct marketing purposes and you can, at any time, request that the use of your Personal Data be restricted and we will eliminate the your Personal Data. However, please note that the restriction or deletion may mean that we will not be able to provide you with the information, services or products you have requested. Upon your request, we are also required to correct Personal Data about you, which is incorrect, incomplete or misleading.

  1. Contact us

If you want a copy of the information that SAN Mobile holds about you, a copy of the standard contractual clauses or if you would like to exercise your rights, please contact us at SAN Mobile at info@sanmobile.io. If you have complaints about our handling of your Personal Data, you have the right to contact the supervisory authority in the country where you reside.