This privacy statement was last updated on July 6, 2022 and applies to citizens and legal permanent residents of Brazil.
In this privacy statement, we explain what we do with the data we obtain about you via https://frowner.blog. We recommend you carefully read this statement. In our processing we comply with the requirements of privacy legislation. That means, among other things, that:
- we clearly state the purposes for which we process personal data. We do this by means of this privacy statement;
- we aim to limit our collection of personal data to only the personal data required for legitimate purposes;
- we first request your explicit consent to process your personal data in cases requiring your consent;
- we take appropriate security measures to protect your personal data and also require this from parties that process personal data on our behalf;
- we respect your right to access your personal data or have it corrected or deleted, at your request.
If you have any questions, or want to know exactly what data we keep of you, please contact us.
1. Purpose, data and retention periodWe may collect or receive personal information for a number of purposes connected with our business operations which may include the following: (click to expand)
1.1 To be able to comply with legal obligations
1.1 To be able to comply with legal obligations
For this purpose we use the following data:
- IP address
- Geolocation data
The basis on which we may process these data is:
Upon the provision of consent.
We retain this data until the service is terminated.
2. What if you don't provide us with your personal information?
If you don't provide us with your personal information, we may not be able to provide you with the information, products or assistance that you are seeking.
4. Disclosure practices
We disclose personal information if we are required by law or by a court order, in response to a law enforcement agency, to the extent permitted under other provisions of law, to provide information, or for an investigation on a matter related to public safety.
If our website or organisation is taken over, sold, or involved in a merger or acquisition, your details may be disclosed to our advisers and any prospective purchasers and will be passed on to the new owners.
We are committed to the security of personal data. We take appropriate security measures to limit abuse of and unauthorised access to personal data. This ensures that only the necessary persons have access to your data, that access to the data is protected, and that our security measures are regularly reviewed.
The security measures we use consist of:
- Username and Password
- DKIM, SPF en DMARC
- Physical security measures of systems which contain personal data.
- Security software
- ISO27001/27002 certified
- HTTP Strict Transport Security
- Content Security Policy
- STARTTLS and DANE
- WPA2 Enterprise
- Permissions Policy
6. Third-party websites
This privacy statement does not apply to third-party websites connected by links on our website. We cannot guarantee that these third parties handle your personal data in a reliable or secure manner. We recommend you read the privacy statements of these websites prior to making use of these websites.
7. Amendments to this privacy statement
We reserve the right to make amendments to this privacy statement. It is recommended that you consult this privacy statement regularly in order to be aware of any changes. In addition, we will actively inform you wherever possible.
8. Accessing and modifying your data
If you have any questions or want to know which personal data we have about you, please contact us. You can contact us by using the information below. Your rights with respect to personal data:
- confirmation of the existence of processing;
- access to data;
- correction of incomplete, inaccurate, or outdated data;
- anonymization, blocking, or deletion of unnecessary, excessive, or processed data in disagreement with the provisions of the General Law for the Protection of Personal Data (LGPD);
- portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;
- deletion of personal data processed with the consent of the holder, except in the cases provided for in art. 16 of the General Law for the Protection of Personal Data (LGPD);
- information on public and private entities with which the controller shared data;
- information on the possibility of not providing consent and on the consequences of denial.
To exercise these rights, please contact us. Please refer to the contact details at the bottom of this Privacy Statement.
Please make sure to always clearly state who you are, so that we can be certain that we do not modify or delete any data of the wrong person.
9. Submitting a complaint
If you are not satisfied with the way in which we handle (a complaint about) the processing of your personal data, you have the right to submit a complaint to the National Data Protection Authority (ANPD):
Autoridade Nacional de Proteção de Dados
Esplanada dos Ministérios,
CEP 70297-400 - Brasília – DF.
Our website is not designed to attract children and it is not our intent to collect personal data from children under the age of consent in their country of residence. We therefore request that children under the age of consent do not submit any personal data to us.
11. Contact details
Schatzmann Coaching & Beratungen
Phone number: +41 (0)81 710 00 18