How do we ensure the security of your data?
To ensure your security, your personal data is transferred in encrypted form and stored on Amazon servers, with encryption at rest for data storage and backup. Additionally, we use firewalls and security certificates, which employ a variety of security technologies and procedures to help protect User information. As a result, this company has access to your data solely for storage purposes, as soon as you provide them on Sorteio.com. If you have any concerns about this, we ask that you discontinue using the platform.

What data do you need to provide when registering on the platform?
When Users register on the platform, we will ask for the following information: Instagram account name and email. To facilitate registration, the User may also log in by granting the Platform access to their Instagram account. Sorteio.com will only access the User's public profile data.

With whom do we share your personal data?
We will share your personal data with the companies referenced in these policies, with the goal of improving and executing the platform's services. Except in the cases mentioned, in the event of legal consent from the data subject and by court order or legal determination, we will not share your data with third parties.

Will your access records be collected?
When you access our Platform, we collect your access records, that is, a set of information regarding the date and time of use of a given internet application from a given IP address. This information will be kept by Sorteio.com, confidentially, in a controlled and secure environment, for a minimum period of 6 (six) months, under the terms of Law No. 12,965/2014, and Article 7, II, of Law 13,709/18.

Is there indirect data collection?
In addition to access records, we may collect information indirectly through cookies, as described in the Privacy Policies. Some of these cookies are essential for the platform to function. Will communication records be stored? We will also store all conversations you have with us through our communication channels, as this will improve your service and make it more efficient. Without this history, you would probably have to repeat previously provided information every time you used the platform.

How will your data be processed?
All your data is processed for specific purposes and in accordance with the Personal Data Protection Law. All this information is described in a table, to facilitate your viewing, in our Privacy Policies.

What are your rights?
Even if you have already provided us with your personal data, you have the full right to, at any time: confirm the existence of data processing; access your data; correct your data; anonymize data; block or delete unnecessary, excessive, or non-compliant data; request data portability to another provider; delete data, except those required by law; obtain information about with whom Sorteio.com has shared data; obtain information about the possibility of not providing consent and its consequences; and revoke your consent.

Can these conditions change?
Our Privacy Policy may change, but you will always be able to access the most up-to-date version on our platform. Additionally, if we need to take any action that requires your authorization by law, you will receive a notice beforehand so you can accept or refuse.

What is the content of the Privacy Policies?
The following Privacy Policy is divided as follows to facilitate your access to information: Text Availability Date; Explanation of Technical Terms or Terms in Foreign Languages; User Privacy and Third-Party Data Operators; Data Collection and Processing Agents; Purposes and Legal Bases for Personal Data Processing; Sharing of Users' Personal Data; Platform Cancellation, Access Account Cancellation and Data Deletion; Rights of the Personal Data Subject; Security; Changes to the Privacy Policy; Data Protection Officer and General Provisions; Contact.

Sorteio.com PRIVACY POLICIES Before accessing the Sorteio.com platform, it is important that you read, understand, and freely, unequivocally, and informedly accept these Privacy Policies. This Platform, named Sorteio.com, is owned, maintained, and operated by SORTEIO.COM GESTAO DE MIDIAS SOCIAIS LTDA, a private legal entity, registered under CNPJ No. 42.420.084/0001-62, headquartered at Rua Professor Luiz Alexandre de Oliveira, No. 715, Royal Park, ZIP: 79.021-430, Campo Grande, State of Mato Grosso do Sul, Brazil. This document aims to provide information about the collection, use, processing, and storage of personal data provided by Users and complies with Law 12,965/2014 (Brazilian Internet Civil Framework) and Law No. 13,709/18 (General Data Protection Law).

1. TEXT AVAILABILITY DATE
This document was written and made available on 10/27/2021.

2. EXPLANATION OF TECHNICAL TERMS OR TERMS IN FOREIGN LANGUAGES
Below are the meanings of technical nomenclatures and terms: Cookies: Small text files stored on the user's computer that can be retrieved by the website that sent them during browsing. They are mainly used to identify and store information about visitors. Encryption: A set of principles and techniques for encoding writing, making it unintelligible to those who do not have access to the agreed conventions. Data Protection Officer: Person appointed by the controller and operator to act as a communication channel between the controller, data subjects, and the National Data Protection Authority (ANPD). IP (or Internet Protocol): Unique identification for each computer connected to a network.

3. USER PRIVACY AND THIRD-PARTY DATA OPERATORS
3.1. Protecting your privacy is very important to us. Your data is transferred in encrypted form and stored on Amazon servers, with restricted access. Additionally, we use firewalls and SSL certificates, employing a variety of security technologies and procedures to help protect User information.
3.2. The servers mentioned in the previous clause, used by Sorteio.com, are located in the United States of America, equipped with mechanisms capable of ensuring the security of your data. By accepting these policies, the User declares awareness and agreement with international data transfer, pursuant to Article 33, VIII of Law No. 13,709/18.
3.3. All access records, a set of information regarding the date and time of use of a given internet application from a given IP address, will be kept by Sorteio.com, confidentially, in a controlled and secure environment, for a minimum period of 6 (six) months, under the terms of Law No. 12,965/2014, and Article 7, II, of Law 13,709/18.
3.4. The User must be responsible and declare themselves solely responsible for all actions, as well as for all information and the truthfulness of the content they enter on the platform.
3.5. The servers used by Sorteio.com that are capable of ensuring the security of your data are located outside Brazil, pursuant to Article 33, IX of Law No. 13,709/18.

4. DATA COLLECTION
4.1. Data provided by the User: Sorteio.com requests from the User the following identification information relevant to the platform's operation: Instagram account name and email.
4.2. Information we collect indirectly: We collect information indirectly through cookies, such as IP address used, location, visit times, and other aggregated information.
4.3. Contact history: Sorteio.com stores information about all interactions already made between Users through the platform, such as email messages, phone contacts, and file uploads, as this will improve your service and make it more efficient. Without this history, you would probably have to repeat previously provided information every time you used the platform.

5. PURPOSES AND LEGAL BASES FOR PERSONAL DATA PROCESSING
5.1. By accepting this privacy policy, the User understands that the collection and processing of the personal data below are necessary for the execution of the contract with Sorteio.com, as per the information presented below: Type of Personal Data Legal Basis Purpose Full Name Instagram Username Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Art. 7, V, Law No. 13,709/2018). User identification. This is essential personal data to enable contacting the User to meet their requests and provide targeted responses. Also, to inform the Follower User about the account related to the subscription proposal. Email Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Art. 7, V, Law No. 13,709/2018); Used for login and registration validation on the platform, as well as a means of communication with the User, for notices about giveaways they participate in or organize, in addition to contacts and interactions throughout the platform usage journey. IP (Internet Protocol), Location, Referral Source, Browser Type, Visit Duration, Pages Visited Compliance with legal or regulatory obligation by the controller (Art. 7, II, Law No. 13,709/2018). Compliance with Article 15 of Law No. 12,965/2014, which imposes the duty on Sorteio.com to maintain respective access records to internet applications, confidentially, in a controlled and secure environment, for a period of 6 (six) months.

6. SHARING OF USERS' PERSONAL DATA
6.1. Only persons linked to Sorteio.com who are strictly necessary for service provision may have internal access to User information.
6.2. Sorteio.com will share the collected data only with the "GrowSocial" platform, owned by DL WEB EIRELI, which will use the email address provided for sending email marketing to Users, based on Art. 7, IX, Law No. 13,709/2018. Thus, by registering on Sorteio.com, the User declares full awareness that the email address may be shared for email marketing purposes.
6.2.1. The User declares awareness that their Instagram profile name may be shared with the User responsible for the giveaway for the continuation of the giveaway procedures, based on Art. 7, V, Law No. 13,709/2018.

7. PLATFORM CANCELLATION, ACCESS ACCOUNT CANCELLATION AND DATA DELETION
7.1. Access account cancellation by Sorteio.com: Sorteio.com may, at its sole discretion, block, restrict, disable, or prevent any User's access to the platform whenever inappropriate conduct is detected.
7.2. Access account cancellation by the User: Users who wish to may request account (login) cancellation through the respective tab within the platform or by email contact.
7.3. Data deletion: At the time of account cancellation, when the purpose of data processing ends, or upon request, the User will have all their data deleted immediately and permanently from the platform, except for access records (a set of information regarding the date and time of use of a given internet application from a given IP address), which will be kept, confidentially, in a controlled and secure environment, for a period of 6 (six) months, under the terms of Law No. 12,965/2014 and with the legal basis of Art. 7, II, of the General Data Protection Law.

8. RIGHTS OF THE PERSONAL DATA SUBJECT
8.1. The data subject has the right to obtain from Sorteio.com, in relation to the data processed by it as controller, at any time and upon request:
8.1.1. Confirmation of the existence of data processing;
8.1.2. Access to data;
8.1.3. Correction of incomplete, inaccurate, or outdated data;
8.1.4. Anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data under Law 13,709/2018;
8.1.5. Data portability to another service or product provider, upon express request and subject to commercial and industrial secrets;
8.1.6. Deletion of data processed with the consent of the data subject, except in cases provided for in Law 13,709/2018;
8.1.7. Information about public and private entities with which Sorteio.com has shared data;
8.1.8. Information about the possibility of not providing consent and about the consequences of refusal;
8.1.9. Revocation of consent.

9. SECURITY
9.1. Sorteio.com is committed to preserving the stability, security, and functionality of the platform through technical measures compatible with international standards and by encouraging the use of best practices. However, no service available on the internet has a total guarantee against illegal intrusions. In cases where unauthorized third parties illegally invade the system, Sorteio.com will make its best effort to find the party responsible for the illegal activity but is not liable for the damages caused by them.

10. CHANGES TO THE PRIVACY POLICY
10.1. Sorteio.com may unilaterally add and/or modify any clause contained in these Privacy Policies. The updated version will apply to the use of the platform from its publication. Continued access or use of the site after disclosure will confirm the validity of the new Privacy Policies by Users.
10.2. If the change made requires User consent, the option to freely, unequivocally, and informedly accept the new text or refuse it will be presented.
10.3. If the User does not agree with the change, they may not provide consent for specific acts or may fully terminate their relationship with Sorteio.com. This termination will not, however, exempt the User from fulfilling all obligations assumed under previous versions of the Privacy Policies.

11. DATA PROTECTION OFFICER AND GENERAL PROVISIONS
11.1. Sorteio.com designates as Data Protection Officer Mr./Ms. Douglas Pesente de Lacerda, registered under CPF number 011.692.821-21, with email address douglas@dlweb.co, under the terms of Art. 41 of the General Data Protection Law, to accept complaints and communications from data subjects and the National Data Protection Authority, provide clarifications, and take appropriate measures.
11.2. Sorteio.com has a specific text to regulate the license of use, rights, duties, warranties, and general provisions: the Terms of Use. All these documents are inseparably part of these Privacy Policies.

12. CONTACT
12.1. Sorteio.com provides the following channels to receive all communications that Users wish to make: via email at contato@sorteio.com and through the form available on the website sorteio.com