Updated: 05/02/2021

These Privacy Policies apply to services provided by the legal entity RADIO MEMORY SERVIÇOS DE INFORMATICA LTDA, duly registered under CNPJ No. 07.673.191 / 0001-00, headquartered at Av. Contorno, 2090, Sala 302 A, Floresta, Belo Horizonte / MG, hereinafter called RADIO MEMORY.

When deciding to use the services offered by RADIO MEMORY, the customer automatically AGREES AND ACCEPTS the Privacy Policies and takes note of all the clauses listed here.

You must check frequently for updates regarding this Privacy Policy. Radio Memory may update this Privacy Policy from time to time to reflect changes in personal data practices related to the service or changes in applicable laws.

We will post a notice on the Radio Memory website to alert you in advance of important changes to our privacy policy and will indicate at the top of the Privacy Policy when it was last modified.

1 GENERAL INFORMATION

1.1 This Privacy Policy (“Policy”) is intended to inform you, the user of RADIO MEMORY, about what information is collected, as well as how it is treated, in what situations are shared, and when they are deleted. As of May 25, 2018, the General Regulation on the Protection of Personal Data – Regulation no. 2016/679 of the European Parliament and the Council, of 27 April 2016, establishes the rules regarding the protection, processing, and free movement of personal data of natural persons and which applies directly to all entities that process such data, in any Member State of the European Union.

1.2 The acceptance of this Privacy Policy will occur when you provide personal information such as name, telephone, address, e-mail, among others, to contract the services or even when you explicitly accept this privacy policy, expressing your consent free, express, and informed. Do not use the RADIO MEMORY website and services if you do not agree with this Privacy Policy or any other agreement regarding the service and use of the website.

2 USER RIGHTS

2.1 The user of the website has the following rights, conferred through the General Data Protection Regulation – GDPR

  1. Right of access: it is the user’s right to obtain from the website the confirmation that the personal data concerning him are or are not subject to treatment and, if that is the case, the right to access his data;
  2. Right of rectification: it is the user’s right to obtain from the website, without undue delay, the rectification of inaccurate personal data concerning him;
  3. Right to delete data (right to be forgotten): it is the user’s right to have his / her data deleted, as requested by him/her;
  4. Right to limit the processing of data: it is the user’s right to restrict the processing of his data, obtaining it when contesting the accuracy of the information when the processing is illegal when the site no longer needs the data for the purposes proposals when opposed to the processing of data and in case of processing unnecessary data;
  5. Right of opposition: it is the user’s right to, at any time, oppose the treatment of personal data concerning him for reasons related to his particular situation, and may also oppose the use of his data to define the marketing profile (profiling);
  6. Data portability right: the user’s right to receive personal data concerning him/her and which he has provided to the company, in a structured format, in current use and automatic reading, and the right to transmit this data to other companies; 

2.3 The user will be able to implement his rights through written communication sent to the company with the subject “GDPR”, specifying: 

  1. Full name or company name, TIN (Tax Identification Number) or company identification number and email address of the user and, if applicable, of their representative,
  2. Right, you want to exercise with the company,
  3. Order date and user signature,
  4. Any document that can demonstrate or justify the exercise of your right.
  5. The user will be informed in case of rectification or deletion of his data.

3 RESPONSIBLE FOR DATA PROCESSING

3.1 RADIO MEMORY SERVIÇOS DE INFORMATICA LTDA, duly registered under CNPJ No. 07.673.191 / 0001-00, headquartered at Av. Contorno, 2090, Sala 302 A, Floresta, Belo Horizonte / MG, is responsible for the treatment of personal data, under the GDPR.

4 OF THE DATA PROTECTION CHARGE

4.1 Radio Memory has a Data Protection Officer – EPD (DPO – Data Protection Officer), who 

  1. Provides information and advises the controller, the subcontractor, as well as the workers who process the data, about their privacy and data protection obligations;
  2. Controls the compliance of data processing with applicable standards;
  3. Provides advice, when requested, concerning the impact assessment on data protection and controls its implementation;
  4. It is a contact point for the holder of personal data to clarify issues related to the processing of their data by Radio Memory;
  5. It is also the point of contact for the control authority (National Data Protection Commission – CNPD) on issues related to processing, cooperating with this entity.

4.2 The Data Protection Officer can be contacted through the contact channels on the Radio Memory website.

5 OF THE BASE OF THE PROCESSING OF PERSONAL DATA

5.1 Consent: your consent must be expressed, either in writing, orally, or through the validation of an option, prior, provided in a free, informed, specific and unequivocal manner.

5.2 As examples: your consent for Radio Memory to analyze the use of our services and make consumption profiles (display of personalized advertising);

5.3 Specifically: consent by minors (13 years old): In the case of processing personal data of minors, Radio Memory will require that consent be given by the holders of parental responsibilities, namely for services that involve the recording of their voice and image; or

5.4 Execution of contracts and pre-contractual steps: When the processing of personal data is necessary for the execution, execution, and management of contracts entered into with Radio Memory, such as, for example, the acquisition of archive content or provision of services; or

5.5 Compliance with legal obligation: When the processing of personal data is necessary to fulfill an obligation with a legal framework to which Radio Memory is subject, such as, for example, the communication of identification or traffic data to police, judicial, fiscal entities or regulatory, or location data to ensure emergency services; or

5.6 Legitimate interest: The processing of personal data by Radio Memory can be justified on grounds of legitimate interest related to the performance of tasks relating to its activity as a company, such as the processing of data to improve the quality of service; or

5.7 Vital interest of data subjects: The processing of personal data by Radio Memory can also be justified when it is necessary to protect an interest essential to the life of the data subject or any other natural person, for example, if the processing is necessary for humanitarian purposes, including the monitoring of epidemics and their spread or in humanitarian emergencies, in particular in situations of natural or man-made disasters; or

5.8 Public Interest Mission The processing of personal data by Radio Memory may be necessary for the exercise of functions and the pursuit of attributions in the public interest of Radio Memory.

6 INFORMATION COLLECTED

6.1 The collection of data from users will take place following the terms of this Privacy Policy and will depend on the user’s consent, which is dispensable only in the cases provided for in article 7 and following of the GDPR.

6.1.1 Types of data collected

6.1.1.1 User identification data

The service offered by RADIO MEMORY consists of computer systems and services for professionals, academics, and patients, improving and organizing the production and access to images and radiological diagnoses and dental treatments, promoting the continuous and sustainable development of dentistry.

In this health context, it is necessary to acquire personal information and sensitive data that are essential for:

  1. Perform quality clinical care (name, date of birth, sex, photos, x-ray, reports, and cephalometric analysis, and other types of exams);
  2. Facilitate communication between those involved (e-mail, telephone);
  3. Execute and monitor services and contracts (TIN, address);
  4. Internal research and development, creating new and improving our current software systems (statistical processing of data, images, x-rays, and anonymized exams). 

6.1.1.2. Data entered in the contact form

The data eventually informed by the user who contracts the service or uses the website, including the content of the message sent, will be collected and stored.

6.1.1.3. Data related to the execution of contracts signed with the user

For the execution of the purchase and sale contract or the provision of services eventually signed by us with the user from this site, other data related to or necessary for its execution, including the content of any communications with the user, may be collected and stored.

6.1.1.4. Sensitive data

There is the collection of sensitive data, thus understood those defined in articles 9 and 10 of the GDPR. The collection of this data is essential for the activity that the company provides. This data will not be shared with third parties, except:

  1. In specific products and partnerships, and only with the explicit consent of the holder;
  2. In academic partnerships, and only after anonymization.

6.1.1.5. Collection of data not expressly provided

Eventually, other types of data not expressly provided in this Privacy Policy may be collected, granted that they are given with the user’s consent, or that the collection is permitted or imposed by law.

6.1.2 Legal basis for the processing of personal data

By using the services of the website, the user is consenting to this Privacy Policy. The user has the right to withdraw his consent at any time, without compromising the lawfulness of the processing of his personal data before the withdrawal. The withdrawal of consent may be made by the Service Center of the Cardholder. The consent of the relatively or absolutely incapacitated, especially of children under 13 (thirteen) years old, can only be done, respectively, if properly assisted or represented.

6.1.3 Purposes of the processing of personal data

The personal data collected by the website are intended to facilitate, streamline and fulfill the commitments established with the user and enforce requests made by filling out forms. They may also be used for commercial purposes, to personalize the content offered to the user, as well as to subsidize the website in order to improve the quality and functioning of its services.

The registration data will be used to allow the user to access certain content exclusive to the site. In addition, the collection of data related to or necessary for the execution of a purchase and sale contract or the provision of services eventually signed with the user will have the purpose of providing the parties with legal certainty, in addition to facilitating and enabling the conclusion of the deal.

The processing of personal data for purposes not provided for in this Privacy Policy will only occur upon prior notification to the user, and, in any case, the rights and obligations provided for herein will remain applicable.

6.1.4 Period of retention of personal data

The user’s personal data will be kept for a period not exceeding that required to fulfill the purposes for which they are processed. The data retention period is defined according to the following criteria: 

  • The data will be stored for the time necessary to provide the services provided by the website, which can vary from 1 to 12 months, according to the person’s order status;
  • The personal data of users can only be kept after the end of their treatment in the following cases:
  • For the fulfillment of a legal or regulatory obligation by the controller,
  • For a study by a research body, guaranteed, whenever possible, the anonymization of personal data;
  • For the transfer to a third party, provided that the data processing requirements provided for in the legislation are respected;
  • For the exclusive use of the controller, access by a third party is prohibited and provided the data is anonymized.

6.1.5 Recipients and transfer of personal data

The user’s data will not be shared with third parties. Therefore, they will be treated only by this website.

7 SECURITY IN THE PROCESSING OF USER’S DATA

7.1 We undertake to apply technical and organizational measures to protect personal data from unauthorized access and situations of destruction, loss, alteration, communication, or dissemination of such data. To guarantee security, solutions will be adopted that take into account: the appropriate techniques, the application costs, the nature, the scope, the context and the purposes of the treatment, and the risks to the user’s rights and freedoms.

7.2 We use the SSL-certified website (Secure Socket Layer) which guarantees that personal data is transmitted securely and confidentially, so that the data transmission between the server and the user, and in feedback, occurs in an encrypted or encrypted way.

7.3 However, we are exempt from liability for the sole fault of third parties, such as in the event of an attack by hackers or crackers, or the exclusive fault of the user, as in the case where he transfers his data to a third party. We also undertake to notify the user promptly in the event of any breach of the security of your data that could cause you a high risk to your rights and freedoms.

7.4 A breach of the security of personal data causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure, or unauthorized access to personal data transmitted, stored, or subject to any other type of treatment. Finally, we undertake to treat the user’s data with confidentiality, within the legal limits.

8 COMPLAINT TO A CONTROL AUTHORITY

8.1 Without prejudice to any other means of administrative or judicial appeal, all data subjects are entitled to complain about a supervisory authority. The complaint may be made to the authority of the website’s headquarters, the user’s country of habitual residence, his place of work, or the place where the infraction was allegedly committed.

9 NAVIGATION DATA (COOKIES)

9.1 The User, from this agreement, expressly authorizes the website to use resources, such as, but not limited to, “cookies”, to offer a better and more personalized service.

9.2 Cookie represents a small amount of data, usually including an anonymous unique identifier, sent to you by a website and stored on your computer’s disk.

9.3 The User can configure his browser to accept all cookies, reject them, or be notified when a cookie is sent.

9.4 As each browser does this differently, check your browser’s constant help tool to find out how to modify your cookie preferences.

9.5 ATTENTION: If the User chooses to reject all cookies in his browser, he will not be able to use all the features and services offered by the website. The website uses its cookies for a variety of purposes, including:

  1. Account-related cookies: If you create an account with us, we will use cookies to manage the registration process and general administration. These cookies will generally be deleted when you log out of the system, however, in some cases, they may remain later to remember your site’s preferences when you log out.
  2. Login-related cookies: We use cookies when you are logged in so that we can remember this action. This saves you from having to sign in every time you visit a new page. These cookies are normally removed or cleared when you log out to ensure that you can only access resources and restricted areas when you log in.
  3. Email newsletter-related cookies: This website offers newsletter or email subscription services and cookies can be used to remember whether you are already registered and whether to show certain notifications valid only for registered/unsubscribed users.
  4. Orders processing-related cookies: This website offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
  5. Research-related cookies: We periodically offer surveys and questionnaires to provide interesting information, useful tools or to understand our user base more accurately. These surveys may use cookies to remember who has already participated in a survey or to provide accurate results after changing the pages.
  6. Form-related cookies: When you submit data using a form such as that found on contact pages or comment forms, cookies can be set to remember the user’s details for future correspondence.
  7. Site preference cookies: To provide a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. To remember your preferences, we need to set cookies so that this information can be called up whenever you interact with a page that is affected by your preferences..

9.6 In some special cases, we also use cookies provided by trusted third parties. These cookies can track items such as how much time you spend on the site and the pages you visit so that we can continue to produce compelling content.

10 AMENDMENTS

10.1 This version of this Privacy Policy was last updated on 02/05/2020.

10.2 The publisher reserves the right to modify, at any time and without any prior notice, these rules, especially to adapt them to the evolution of the site, whether by making new features available, either by suppressing or modifying those already existing or even to meet the evolution of current legislation.

10.3 Thus, we invite the user to periodically consult this page to check for updates.

10.4 When using the service after any modifications, the user demonstrates his agreement with the new standards. If you disagree with any of the changes, you must immediately request the cancellation of your account and submit your reservation to the customer service, if you wish.

11 OF THE EXTERNAL LINKS

11.1 The page that offers the service object of this instrument contains external links redirecting the user to other internet pages, over which the editor has no control. Despite prior and regular checks carried out by the publisher, he disclaims any responsibility for the content found on these sites and the services offered by him.

11.2 Access to the websites linked to such links is not governed by these Terms and Conditions of Use and is not protected by the Policies. RADIO MEMORY recommends that the User consult the terms and conditions of use established by each site linked to the links inserted in the Site. RADIO MEMORY will not be responsible, directly or indirectly, for any damages or losses caused or related to the use of any information, content, goods, or services made available on the Site or on any third-party site accessed through the links made available on the Site.

11.3 The inclusion of pages that disclose any type of illegal, violent, pornographic, xenophobic, discriminatory, or offensive information will not be authorized and is not responsible if such information is contained in the external links available on the Site.

12 OF THE ELECTION JURISDICTION

12.1 It is elected, to settle any doubts and resolve conflicts arising from this contract, the forum of the City of Belo Horizonte, State of Minas Gerais, with a waiver of any other, however privileged it may be, except for USERS who fall under the legal concept consumer and opt for the legal prerogative.

13 FINAL PROVISIONS

13.1 This Agreement will be governed by the laws of the European Parliament, the general principles of law, and international standards for electronic commerce.

13.2 If the User does not agree with a certain clause of this Agreement, and obtains its nullity in court, the other provisions will not be harmed and will remain in force.

BY USING OUR SERVICES YOU AGREE THAT YOU HAVE READ AND UNDERSTAND THE TERMS AND PROVISIONS OF THIS AGREEMENT AND ARE AWARE OF ITS ENTIRE CONTENT, ACCEPTING ITS CONDITIONS.