Privacy Policy

Think Marketing Gestão Esportiva LTDA is committed to complying with the laws that protect the data privacy of its clients and the general public.  This page is designed to provide information on how we follow data protection standards, what information we collect while you navigate our communication channels, and how this information is collected, used, and protected by us, in compliance with Law No. 13,709/2018 (General Data Protection Law – “LGPD”). The use of our products and services, as well as our platforms and other available means of interaction, is conditioned upon the acceptance of this Privacy Policy, including regarding our employees.

1. Source of Personal Data

Think Marketing Gestão Esportiva LTDA will have access to personal data in the following situations:

Through interaction with a client: When the Client provides and inputs personal data necessary for the provision of services and use of products provided by Think Marketing Gestão Esportiva LTDA.
Interaction with its collaborators: When employees and collaborators of any nature use its systems and platforms to fulfill duties and obligations arising from the contractual relationship they hold.

2. Types of Personal Data and Sensitive Personal Data Collected

Without prejudice to data commonly collected and processed from its collaborators for the purposes of their legal relationship, Think Marketing Gestão Esportiva LTDA may also collect the following personal data:

Names and contact details: Such as first and last name, email address, postal address, phone number, and other similar types of contact data;
Device information: Such as information about your device, including IP address, location, or provider;
Usage information and browsing history: Such as information on how the User navigates within our services, their browsing history, and which elements of Think Marketing Gestão Esportiva LTDA's services are most used.

Any sensitive personal data that may be collected by Think Marketing Gestão Esportiva LTDA will have its purpose disclosed separately to the User, who must provide consent for Think Marketing Gestão Esportiva LTDA to use it for specific purposes. In the event of disagreement, the data will be automatically deleted from Think Marketing Gestão Esportiva LTDA.

A Think Marketing Gestão Esportiva LTDA does not collect data from minors, except with the authorization of parents or guardians. If collected without authorization, Think Marketing Gestão Esportiva LTDA will immediately delete the collected data upon becoming aware of it, in accordance with the Terms of Use and this Privacy Policy.

Use of Collected Personal Data

When collected, Think Marketing Gestão Esportiva LTDA will use personal data to:

Provide and improve contracted services;
Comply with legal or regulatory obligations;
Administer the relationship with Users;
Set up and administer User accounts;
Provide technical assistance, support, and training to the User;
Contact Users;
Internal research and development purposes to improve, test, and refine features and functions of services Think Marketing Gestão Esportiva LTDA;
Provide Users with marketing, advertising, and publicity, including from Partner companies Think Marketing Gestão Esportiva LTDA, as permitted by law;
Meet internal and external audit requirements, including information security obligations; Think Marketing Gestão Esportiva LTDA;
Send electronic mail messages for: a) confirmations or cancellations of requests; b) communicating future changes to this policy; and c) disclosing updates, changes, and improvements to the platform;
Exercise the rights of the da Think Marketing Gestão Esportiva LTDA, including privacy, security, and property rights Think Marketing Gestão Esportiva LTDA;
To comply with requests from courts, law enforcement agencies, regulatory bodies, and other public institutions and governmental authorities, including, but not limited to, any applicable rules outside the user's country of residence;
To exercise the rights of Think Marketing Gestão Esportiva LTDA and to defend against potential legal actions, as well as to comply with any legislation or regulation applicable to Think Marketing Gestão Esportiva LTDA or third parties with whom we work, and to ensure the proper fulfillment of contracts entered into between Think Marketing Gestão Esportiva LTDA and its users;

Sharing Personal Data with Third Parties

The User accepts and agrees that Think Marketing Gestão Esportiva LTDA may share their personal data with:

Companies that provide access or are responsible for the registration on which the user depends; 
Partner companies, such as third-party service providers and other entities that assist us in offering our services or that may take action on our behalf to protect our rights, users, systems, and services;
Third parties to whom the Think Marketing Gestão Esportiva LTDA is accountable or is authorized by law to disclose information (e.g., governmental bodies, regulatory agencies, the judiciary, and other public authorities);
Third parties for the purpose of participating in a sale, merger, acquisition, restructuring, joint venture, assignment, or transfer of part or all of Think Marketing Gestão Esportiva LTDA’s business; in which case, User data will be considered an asset and transferred in a potential negotiation;
Third parties who require data to protect the rights of Think Marketing Gestão Esportiva LTDA;
Any person or entity for which the User requests data portability.

International Transfer of Personal Data

Think Marketing Gestão Esportiva LTDA does not intend to transfer any collected personal User data outside of Brazil. Except for the cases listed below, Users will be informed in advance via email, at which point the user may accept or decline the transfer. In the event of disagreement, Think Marketing Gestão Esportiva LTDA may restrict the user's access rights.

International data transfers as described in the General Data Protection Law (LGPD) require the designation of guidelines to be established by the National Data Protection Authority (ANPD); once defined, Think Marketing Gestão Esportiva LTDA commits to complying with them in their entirety.

Protection of Personal Data

Think Marketing Gestão Esportiva LTDA utilizes appropriate technologies and procedures to protect any collected personal data (including administrative, technical, and physical safeguards) according to the risk level and the service provided. The company maintains a team legally responsible for handling secure data management in line with legal provisions, regulatory requirements, technological changes, among other relevant factors that may influence personal data protection methods.

Think Marketing Gestão Esportiva LTDA employs all reasonable market efforts to ensure the security of its systems and collected data, utilizing highly qualified and reputable internet providers, database servers, and storage, in addition to security certificates (SSL) and software to protect against unauthorized system access, as well as standard methods for encrypting and anonymizing collected data.

This Policy represents Think Marketing Gestão Esportiva LTDA’s effort to safeguard User information. However, due to the inherent nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing stored information; therefore, should this occur, Think Marketing Gestão Esportiva LTDA shall be liable within the limits provided by Law.

Within a reasonable timeframe to be defined by the National Data Protection Authority (“ANPD”), Think Marketing Gestão Esportiva LTDA, shall communicate to the ANPD and the affected User the occurrence of any security incident that may result in relevant risk or damage to the affected User, mentioning, at a minimum:

a description of the nature of the affected personal data;
information regarding the data subjects involved;
an indication of the technical and security measures used for data protection, observing commercial and industrial secrets;
the risks related to the incident;
the reasons for the delay, in the event that communication was not immediate; and
the measures that have been or will be adopted to reverse or mitigate the effects of the damage.

Data Processing and Responsibility of Think Marketing Gestão Esportiva LTDA

Think Marketing Gestão Esportiva LTDA shall have its processing liability defined as follows:

When dealing with personal data provided directly by its Clients, Think Marketing Gestão Esportiva LTDA shall act as the Processor, acting without interference in the processing method indicated by the Controller, but under the terms of the LGPD;
Think Marketing Gestão Esportiva LTDA shall be the Controller of its employees' Personal Data, processing them based on the Execution of Contracts, Compliance with legal or regulatory obligations, and also, in specific and determined situations, on Consent.

A Think Marketing Gestão Esportiva LTDA may adopt different legal bases for distinct personal data processing activities.

Personal Data Retention Period

Think Marketing Gestão Esportiva LTDA calculates the personal data retention period according to the following criteria:

The period necessary to fulfill the purpose of collection;
The moment when there is a revocation of consent or a request for the deletion of personal data by the Data Subject;
The time necessary to comply with legal, regulatory, or contractual obligations of Think Marketing Gestão Esportiva LTDA;
The necessary period provided for by Law, regulations, judicial decisions, etc;
Determination by the National Data Protection Authority (ANPD);
Compliance with legal or regulatory obligations by the Controller;
The proper execution of the contract;
Needs regarding compliance with the legal system, as well as for potential legal disputes;
Transfer to a third party, provided that the data processing requirements set forth by law are respected; or
Exclusive use by the controller, with access by third parties prohibited, and provided that the data is anonymized.

User Rights

Under the LGPD, the User has the right to:

Right of Confirmation: the User may confirm whether Think Marketing Gestão Esportiva LTDA processes any of their personal data;
Right of Access: the User may submit a written request to obtain details on how their information is being used, as well as to obtain a copy of said information;
Right to Rectification: the User may correct or remove any of their data that is incomplete, inaccurate, or outdated;
Right to Anonymization, Blocking, or Deletion: the User may request the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the purposes for which consent was given, while observing other legal regulations;
Right of Erasure: the User may request the erasure of certain data, except for those where the law authorizes its retention;
Right to Information: the User may request information regarding the public and private entities with which Think Marketing Gestão Esportiva LTDA has shared data, as well as the consequences of choosing not to consent to the collection and processing of their personal data;
Right to Opt-out of Marketing: the User may, at any time, request to stop receiving advertisements and other materials through the link provided in the marketing emails sent; 
Right to Portability: the User may request that their personal data be transferred to themselves or third parties, except for data that has already been anonymized and deleted by Think Marketing Gestão Esportiva LTDA;
Right to Withdraw Consent: the User may withdraw any consent previously granted to Think Marketing Gestão Esportiva LTDA to use their personal data. The User is aware that withdrawal will not affect the use or sharing of data performed prior to the withdrawal request.

The rights provided in this chapter are not absolute; whenever the User wishes to exercise them, they must contact Think Marketing Gestão Esportiva LTDA through the channel: This email address is being protected from spambots. You need JavaScript enabled to view it..

Think Marketing Gestão Esportiva LTDA commits to fulfilling such requests as soon as possible and at no cost to the User, within a maximum period of 15 (fifteen) days from the receipt of the request, unless a longer period is required due to complexity or factual or legal reasons, in which case the User will be notified.

Think Marketing Gestão Esportiva LTDA will immediately notify the processing agents with whom it has shared User data regarding any rectification, erasure, anonymization, or blocking of data, so that they may perform the same procedure.

The confirmation of existence or access to User personal data provided in this chapter will be delivered electronically or in writing, in a simplified format or through a clear and complete declaration indicating the origin of the data, the absence of records (if applicable), the criteria used, and the purpose of the processing, while always observing Think Marketing Gestão Esportiva LTDA’s commercial and industrial secrets.

Cookies

Think Marketing Gestão Esportiva LTDA and its partners may use cookies and other similar technologies to store and manage User preferences, deliver targeted advertising, enable content, and collect analytical and usage data, for example. The use of cookies and other tracking technologies is a standard across websites and platforms, through which information about User activities on the platform, websites, or other services is collected.

A cookie is a small text file placed on a computer or other device, used to identify the User and the device, and to collect information. They may perform the following functions:

Strictly Necessary Cookies: These are essential to allow the User to navigate a platform and use its features. 
Performance Cookies: These collect information on how the User uses the Think Marketing Gestão Esportiva LTDA and serve to improve navigation and enhance the experience. Information collected includes, for example, internet browsers and operating systems used, the domain name of the previously visited website, the number of visits, average visit duration, and pages viewed.
Functional Cookies: These allow the platform to remember choices the User has made (such as username or ID, language preference, or the area/region where the User is located) and provide enhanced, more personal features.
Advertising Cookies: These track User browsing habits and are used to deliver targeted advertising. These cookies also limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They also remember that the User has visited a website, and this information is shared with other organizations, such as advertisers.

A Think Marketing Gestão Esportiva LTDA utilizes Strictly Necessary and Performance cookies. 

At any time, the User may disable Cookies through their browser settings, by installing commercially available plug-ins, or by using other technologies they deem necessary.

In addition to cookies, Think Marketing Gestão Esportiva LTDA uses other tracking technologies, such as:

Web Server and Platform Logs: Think Marketing Gestão Esportiva LTDA servers automatically collect certain information to assist, administer, and protect the services offered, as well as to analyze usage and improve the User experience. The information collected includes:

IP address and browser type;
Device information, including the Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA), and similar identifiers assigned by us or third parties;
The device's operating system and other technical data;
The city, state, and country from which you are accessing the BRASIL RISK [sic] platform, including for fraud prevention purposes;
Information or text typed;
Links and buttons clicked;

Social Media Connections: Some of Think Marketing Gestão Esportiva LTDA services may include social media features, such as Facebook “Like” buttons and widgets; “Share” buttons, and interactive mini-programs.

Think Marketing Gestão Esportiva LTDA may allow the User to choose to use their own social media logins to access some of the services offered, in which case Think Marketing Gestão Esportiva LTDA may receive and store authentication information from those services.

Contact Information

Questions, comments, suggestions, and/or complaints regarding this Privacy Policy, as well as any need for information, or the modification or deletion of personal data, may be directed by the User to Think Marketing Gestão Esportiva LTDA, via email at: contato@ thinksports.com.br.

Alterations

Think Marketing Gestão Esportiva LTDA seeks constant updates and improvements; therefore, this Privacy Policy may be updated at any time, always aiming for better service and protection for users.

In the event of changes affecting the purpose and duration of the processing of the User's personal data, the User will be informed via the email registered in our services or through the platform itself 30 (thirty) days in advance. In case of disagreement with the changes, the User may withdraw the consent provided, thereby becoming unable to use Think Marketing Gestão Esportiva LTDA's services.

Should Think Marketing Gestão Esportiva LTDA change its policy in the future to include data sharing with third parties, the company will send a notice 30 (thirty) days in advance to the user via the registered email; the user may disagree with the sharing, in which case they will continue to use Think Marketing Gestão Esportiva LTDA's services.

Users are advised to periodically read this policy to stay updated on its content.

Legislation and Jurisdiction

This Policy shall be governed, interpreted, and enforced in accordance with the laws of the Federative Republic of Brazil, regardless of any conflict of laws with those of other states or countries. The Courts of São Paulo are hereby designated as competent to resolve any disputes arising from this instrument, with the express waiver of any other jurisdiction, however privileged it may be.