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Dado Global network privacy policy

Last review date: January 2019

1. Summary

The Dado Global network and its subsidiaries, such as Dado Tecnologia da Informação LTDA ('Dado Global', 'we' or 'we') recognize and value the importance of protecting the privacy of our customers and end users . Our Privacy Policy is based on the General Data Protection Law, where the collection, storage, use and disclosure of 'personal information' is regulated by the Privacy Law of 13,709 of 14 August 2018.

This privacy policy is a simple summary of a statement about:

• how and why we collect, retain, use and disclose your personal information;
• the nature of our business, customers and services;
• our approach to advertising, marketing and security; and
• how you can contact us to access or correct your personal information, make a complaint or ask a question.

2. Introduction

Dado Global provides a range of products and services to our business customers (our 'Providers'), to assist them as the ultimate Wi-Fi service providers for you (the 'Service') at their respective facilities. Our providers also use the products and services we provide to help them analyze the behavior of visitors to their facilities. In most cases, our Providers choose to operate the platform necessary to provide the Service entirely on their own, however, in certain limited circumstances, we may operate it on your behalf.

When we provide products and services to our Providers (including our facilitation of receiving the Service), we collect personal information on your behalf and on our own behalf. The provision of the Service to you by the Provider is governed by that Provider's terms of use and privacy policy. Our involvement (including facilitating the provision of the Service and the collection of personal information) is governed by our "Terms of Use". More information is available about our products and services and with us through our website at https://dado.global (“website”)

By registering and using the Service, you agree to our Terms of Use and this Privacy Policy and our Provider's terms of use and privacy policy. Please read these documents carefully. If you do not agree with all of these documents, you should not use the Service.

This Privacy Policy is divided into several sections and includes information about how we manage your personal information, as well as answers to frequently asked questions.

3. What is personal information?

When used in this Privacy Policy, the term “personal information” has the meaning given to it in the Law. In general terms, it is any information that can be used to identify you personally. This may include, but is not limited to, your name, phone number and email address. The information that we and our Providers normally collect is defined in paragraph 5. If the information we collect personally identifies you or if you are reasonably identifiable, the information will be considered personal information.

4. Why do we need to collect your personal information?

Dado Global collects personal information and other information to facilitate the provider that provides Internet connectivity on its premises. Dado Global is able to facilitate our Providers by providing the Service to you because both Dado Global and our Providers collect certain information about your use of the Service and behavior on your premises, for example on how, where and for how long you use it o Service as facilities. You can think of this as a "fair exchange", in which the Provider provides (and we facilitate the provision) of the Service to you in exchange for collecting information about your activities and your receipt of content. Our data analysis allows our providers to better understand how you and other customers get involved in your business and facilities. Ultimately, this allows our providers to make their service offering more attractive and interesting. The products and services provided by Dado Global support the collection and analysis of several different data sources and each of our providers can use different products and services. Our providers may also have their own terms and conditions and privacy policies that will be made available to you when you register for the service. It is important that you carefully consider how our Providers will use and treat your personal information, as set out in their respective terms of use and privacy policy.

Although it is possible for you to interact with us under a pseudonym in some cases, it is still necessary to collect some personal information from you. We will not collect more than we reasonably need to facilitate the provision of the Service to you and to provide our products and services to our Providers.

5. How do we collect your personal information?

We collect your personal information in three main ways:

1. you may be asked to provide certain personal information when you register as a user of the Service. At that time, you will be asked to acknowledge that you have read and accepted our Terms of Use and this Privacy Policy and / or our Terms of Use and Privacy Policy.
2. we (or our Provider) will also collect personal information about you while you receive and use the Service, for example, your browsing history while on the premises of the relevant Provider. In most cases, you will not know that we (or our Provider) are collecting this second layer of personal information as it does automatically in the background. Other trusted partners may also collect non-personally identifiable data about you through cookies when you visit specific websites.
3. through our website or directly when companies, advertisers and potential partners contact us about our products and services

When you register to use the Service, the types of personal information we collect or infer depend on the service and products we provide to the relevant Provider. Different Providers may request information different from you at registration and at other times when you use the Service. In most cases, we collect some or all of the following information in the registry (or if you contact us directly):

• your full name and prefix (for example, Mr. or Mrs.)
• your cell phone number
• your email address, so that we can authenticate you electronically and manage your account
• your date of birth
• your gender
• your social media contact and publicly available details
• your postal code
• your country or state of residence

In most cases, we will also collect (directly or through our Supplier) or infer the following information regarding your use of the Service

• the time, date and location of the record
• the duration and frequency of use of the Service and visits to the facilities of our providers
• the approximate location of your device, while on the premises of the Providers
• your browsing history while using the Service
• demographic information, such as age and gender
• general information from (and a unique identifier for) the navigation device, such as Media Access Control (MAC)

You may not be able to register to use the Service if you do not provide us with a minimum of personal information, which is usually your email address. Since the information you provide to us is linked to the device you use to access the Service, you must not allow anyone to use your device while connected to the Service.

We will never collect “confidential” information about you. Confidential information includes certain types of information about you, such as your political views or your racial or ethnic origin.

6. How do we use your personal information?

Registration allows a single wireless device to log into the service conveniently, wherever it is provided. This may include registering for the Service at one of our Provider's facilities before using the Service at a different Provider's facility. Our providers may share your personal information with each other for this and for their own purposes, as set out in this Privacy Policy and / or their respective privacy policies, and we can facilitate this process.

We use your personal information to facilitate the provision of the Service to you from our Providers and to provide products and services to our Providers, as well as for our general operational, technical and administrative purposes. We generally do not have any direct relationships with users of the Service whose personal information we process. The products and services we provide to our providers may include the marketing services discussed below, as well as analysis of data about your activities at your facility (for example, your device's location and browsing history).

We may, from time to time, process your personal information to place it in a form from which your identity is not reasonably verifiable ("Unidentified Information"). We use this unidentified information for analytical purposes and we may disclose that information to others for commercial purposes, including improving our products and services. Unidentified information is outside the scope of the law.

7. Use of cookies and tags

"Cookies", also known as HTTP cookies, web cookies or browser cookies, are simply small pieces of data, which are stored as text files in your mobile device's browsers, whenever you visit certain websites. Your typical goal is to help websites remember specific actions you may have taken there in the past. For example, cookies can track when you have connected to a website, visited certain pages or clicked on certain buttons or links. We, the providers and our trusted third-party partners, may use cookies to:

• remember when you opened a mobile app or visited a website
• remember that your preferences, searches and favorites
• target more relevant advertising to you.

Although we, our suppliers or third-party partners, may use cookies to collect information to improve your user experience, this information is not personally identifiable. We do not use cookies to store any personal information, such as name, address or contact details.

However, if you wish to disable or remove cookies, please refer to the "Help" section of your browser or mobile device. Each browser or device handles cookie management differently, so you will need to consult the appropriate "Help" documentation.

Tags are small pieces of code that are executed every time a web page is loaded. In our service, these tags are executed every time that our captive portal is loaded both for the registration of a new user and on the welcome back page. The tags are not stored on your device and also do not collect any personal information. We generally use tags to generate statistical and demographic data on the use of the service. As well as cookies, our providers and partners may use this statistical data to improve their services and try, through their means, to offer something personalized for you, always respecting your privacy in accordance with current legislation.

8. Advertising and marketing

As mentioned above, you can think of the provision of the Service by our Suppliers as a fair exchange for certain things that you provide or agree to receive. One of these "exchanges" is the provision of advertising and marketing content, similar to what you may have seen elsewhere (for example, ad-supported video content). By registering and using the Service, you agree with Dado Global or any Supplier that sends advertising and marketing material direct to you, and providing associated interactive functionality, which we or any Provider considers to be of interest to you.

You can cancel the supply of some or all of the direct marketing materials using the unsubscribe option or by contacting us. Some advertising (which may not be direct) is an inherent part of the Service you are receiving, and it is not operationally possible to refuse any advertising displayed as part of your access to the Service (for example, advertising displayed on WiFi login).

9. How do we disclose your personal information?

We will generally disclose your personal information to our Providers in connection with our provision of products and services to them, as well as to facilitate the provision of the Service to you. We may also facilitate the sharing of your personal information between our Providers, regardless of which specific Provider you received the Service from.

Dado Global is part of a group of companies and we may (in rare circumstances) also transfer your personal information between different Dado Global entities, however, we will do this in accordance with all applicable laws. Information about the different Dado Global entities that make up the group can be found on our website.

Dado Global or our Providers may also disclose your personal information when it is reasonable to do so or if we are authorized or required to do so under applicable law. For example, we may disclose your personal information confidentially to a third party contractor who has been contracted to provide services to us. In very rare circumstances, we may also transfer your personal information abroad (for example, as part of disaster recovery processes in relation to our data center), however, we will not do this as usual.

10. Which Dado Global company is responsible for your personal information?

Dado Global is committed to complying with all privacy laws in each jurisdiction in which it operates.

In almost all cases, your personal information will be collected, maintained, used and disclosed by Dado Tecnologia da Informação. If you register for or receive the Service abroad, your personal information is likely to be provided and maintained by Dado Tecnologia da Informação LTDA. If that changes, we will take reasonable steps to draw attention to that.

11. Security

We are committed to protecting your personal information by taking all reasonable measures to prevent the personal information we hold about you, through misuse, interference or loss, and from unauthorized access, modification or disclosure. Our security measures meet the highest industry standards and you can feel confident in our processes. These include access control procedures, network firewalls, encryption and physical security.

Your personal information will be encrypted and, whenever possible, will also be anonymized and aggregated.

12. Quality of your personal information

We will take reasonable steps to ensure that the personal information we own, use and disclose is accurate, up-to-date and complete. However, we will not take any administrative action to verify the accuracy or completeness of the information you provide us (or a third party as our providers provide us) at the time of collection (for example, if you make a mistake when entering your data or choosing for using a pseudonym).

If you suspect or believe that the personal information we have is not correct, complete or up-to-date, please contact us in the details below and we will respond to your request within a reasonable time. In responding, we will take reasonable steps to correct this information and ensure that it remains accurate, complete and up-to-date in the future. If, for any reason, we are unable to correct your personal information, we will provide our reasons in writing and your other complaint options. We will not charge you for requesting the correction of your personal information.

13. Access to your personal information

You have the right to access the personal information we hold about you upon request, subject to a limited number of exceptions. If the information is incorrect, it will be updated or deleted, unless we have to maintain that information for legitimate business or legal purposes. We may reject requests that are unusual and repetitive, require disproportionate technical effort, risk the privacy of others, or that are extremely impractical (for example, requests residing in backup systems).

If, for any reason, we are unable to provide you with access to your personal information, we will provide our reasons in writing, as well as your other complaint options. If your order relates to your personal information that we do not collect directly from you, it will usually be more practical for us to pass your request for access to the relevant third party (for example, our Provider).

You can make a request for access using the contact details below and we will respond to your request within a reasonable time. We will ask you to verify your identity so that we can fulfill your request. Ordinarily, we will require you to come to our office to do so and have access to your personal information in secure circumstances, but we will give reasonable consideration to any other access procedure you may suggest in writing, where practicable (in whole or in part) ). We will not charge you for access to your personal information unless it requires a disproportionate effort.

14. How long will we keep your personal information?

We retain personal information for the purposes for which we collect or receive it. The length of time that we keep your personal information will be influenced by the nature of that information and our contractual agreements with our Providers. Unless otherwise required by our Providers or you, we will begin to delete most of your personal information about three years after collection, as this is the average life of most devices using the Service. When it is no longer needed, Dado Global will use its best efforts to ensure that all such information is destroyed in a secure or unidentified manner within a reasonable time.

15. How to contact us

If you want to contact us, including to ask a question or make a complaint, we can be found in the details below:

Dado Tecnologia da Informação

SIA TRECHO 1 number 230, room 120 Part 2N

Brasília DF - 71.200-010

email: contato@dado.global

We may modify or alter the provisions of this Privacy Policy from time to time. We will take reasonable steps to bring any modifications or changes to your attention.