PRIVACY POLICY

This Privacy Policy was created on November 6, 2020.

This Privacy Policy was last updated on August 01, 2022.

Introduction

Darkside Europe GmbH (further stated as “Darkside Europe”) is strongly committed to protecting personal data. This privacy policy describes why and how we collect and use personal data and provides information about individuals’ rights in relation to personal data. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection.

As used in this privacy policy, “Darkside”, “us”, and “we” refer to the Darkside network and/or one or more of its Member Firms that may process your personal information. Each Member Firm in the Darkside network is a separate legal entity. The data controller of your personal information is Darkside Europe.
Darkside Europe processes personal data for numerous purposes. Our policy is to be transparent about why and how we process personal data.

Our legal grounds for processing your personal data
Your local law may require us to set out in this privacy policy the legal grounds on which we rely in order to process your personal information. In such cases, we rely on one or more of the following processing conditions:

· our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses and the legitimate interests of our clients in receiving products, services, etc. from us as part of running their organization (provided these do not interfere with your rights);
· our legitimate interests in developing and improving our businesses, services and offerings and in developing new Darkside technologies and offerings (provided these do not interfere with your rights);
· to satisfy any requirement of law, regulation or professional body of which we are a member (for example, for some of our services, we have a legal obligation to provide the service in a certain way);
· to perform our obligations under a contractual arrangement with you; or
· where no other processing condition is available, if you have agreed to us processing your personal information for the relevant purpose.
Transfers of personal data
Cross-border transfers
If we process your personal information, your personal information may be transferred to and stored outside the country where you are located. This includes countries outside Brazil, outside the European Economic Area (EEA).
Where we collect your personal information within Brazil, transfer outside Brazil will be only:
· to a recipient located in a country which provides an adequate level of protection for your personal information; and/or
· under an agreement which satisfies Brazilian requirements for the transfer of personal data to data processors or data controllers outside Brazil in the form of specific contractual clauses for a given transfer, standard contractual clauses, etc.
Other Darkside Member Firms
We may share personal data with other Darkside Member Firms where necessary in connection with the purposes described in this privacy policy. For example, when providing services to a client we may share personal information with Darkside Member Firms in different territories that are involved in providing services to that client.
Third Party Providers
We may transfer or disclose the personal data we collect to third party contractors, subcontractors, and/or their subsidiaries and affiliates (i.e., to LLC “Company SendPulse” (Service SendPulse), LLC “Facecast” (Service for online Facecast), Tilda Publishing, CRM, etc.). Third parties support the Darkside Network in providing its services and help provide, run and manage IT systems. Examples of third party contractors we use are providers of identity management, website hosting and management, data analysis, data backup, security and cloud storage services. The servers powering and facilitating our IT infrastructure are located in secure data centers around the world, and personal data may be stored in any one of them. The third party providers may use their own third party subcontractors that have access to personal data (sub-processors). It is our policy to use only third party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by Darkside Europe, and to flow those same obligations down to their sub-processors.
Other disclosures
We may also disclose personal information under the following circumstances:
· with professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the services they have been engaged to provide;
· when explicitly requested by you;
· when required to deliver publications or reference materials requested by you;
· to law enforcement, regulatory and other government agencies and to professional bodies, as required by and/or in accordance with applicable law or regulation. Darkside Europe may also review and use your personal information to determine whether disclosure is required or permitted.

Our processing activities
To find out more please go to the sections of this policy that are relevant to you.
Business contacts

Collection​ ​of​ ​personal​ data
Darkside Europe processes personal data about contacts (existing and potential Darkside Europe clients and/or individuals associated with them).
This includes name, employer name, contact title, phone, e-mail and other business contact details. In addition, we may record information about our interactions with contacts.
Use​ ​of​ ​personal​ data
Personal data relating to business contacts may be used for the following purposes:

• Administering, managing and developing our businesses and services
• This includes:
• managing our relationship with clients;
• developing our businesses and services (such as identifying client needs and improvements in service delivery and learning more about a client relationship opportunity);
• analyzing and evaluating the strength of interactions between Darkside Europe and a contact;
• performing analytics, including producing metrics for Darkside leadership, such as on trends, relationship maps, sales intelligence and progress against account business goals;
• administering and managing IT systems, websites and applications; and
• hosting or facilitating the hosting of events
• Providing information about Darkside Europe and its services
• We use client business contact details to provide information that we think will be of interest about Darkside Europe and its services, in accordance with any permissions required by law which may include industry updates and insights, other services that may be relevant and invites to events.
• Darkside Europe does not sell or release personal data to third parties for purposes of allowing them to market their products and services without consent from individuals to do so and in accordance with any applicable law.

Data retention
Personal data will be retained for as long as we have, or need to keep a record of, a relationship with a business contact, which is for the duration of our relationship with a contact or their organization. Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Corporate clients (and individuals associated with our corporate clients), personal clients

Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients to only share personal data with us where it is strictly needed for those purposes.
Where we need to process personal data to provide products, professional services, we ask our clients to provide the necessary information to the data subjects regarding its use. Our clients may use relevant sections of this privacy policy or refer data subjects to this privacy policy if they consider it appropriate to do so.
The categories of personal data processed by us in relation to the products, services we provide are generally:
· Personal details (e.g., username, name, age/date of birth, country of residence);
· Contact details (e.g., e-mail address, contact number, postal address);
· Financial details (e.g., tax status, bank accounts); and
· Job details (e.g., role, place of work, job title).
Generally, we collect personal data from our clients or from third parties when providing services to the relevant client.
Use of personal data
We use personal data for the following purposes:
· Providing professional products, services

We provide a diverse range of professional products, services. Processing of personal data is necessary to follow the steps prior to entering into a contract with you. For example, we will not be able to provide you with our professional products, services if you do not provide us with appropriate categories of personal data.

· Administering, managing and developing our businesses and services

This includes:
o managing our relationship with clients and prospective clients;
o developing our businesses and services (such as identifying client needs and improvements in service delivery);
o administering and managing IT systems, websites and applications; and
o hosting or facilitating the hosting of events.
· Security, quality and risk management activities

We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful e-mails. We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements. We collect and hold personal data as part of our client engagement and acceptance procedures.
· Providing clients and prospective clients with information about us and our range of services

We use client and prospective client business contact details, contact details to provide information that we think will be of interest about us and our services in accordance with any permissions required by law. This includes industry updates and insights, other services that may be relevant and invites to events.
· Complying with any requirement of law, regulation or a professional body of which we are a member

As with any provider of professional products, services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our products and services are provided in compliance with those obligations and those records may contain personal data.
· Improving and developing our products, services

We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients particularly, we may use information that we receive in the course of providing professional products, services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, to improve our business, service delivery and offerings and to develop new Darkside Europe technologies and offerings.
Data retention
We retain the personal data processed by us for as long as necessary for the purpose for which it was collected. Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Individuals who use our applications

We provide external users access to various applications managed by us. Such applications will contain their own privacy policy explaining why and how personal data is collected and processed by those applications. We encourage individuals using our applications to refer to the privacy policy available on those applications.

Individuals whose personal data we obtain in connection with providing professional products, services to our clients

Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data with us where it is strictly needed for those purposes.
Where we need to process personal data to provide our products, services, we ask our clients to provide the necessary information to the individuals who are the subject of the data.
Given the diversity of the products, services we provide, we process many categories of personal data, including:
· Personal details (e.g., username, name, age/date of birth, country of residence);
· Contact details (e.g., e-mail address, contact number, postal address);
· Financial details (e.g., tax status, bank accounts); and
· Job details (e.g., role, place of work, job title).
Generally, we collect personal data from our clients or from a third party acting on the instructions of the client.
Use of personal data
We use personal data for the following purposes:

• Providing professional products, services
• We provide a diverse range of professional products, services. Some of our products, services require us to process personal data in order to provide professional products, services.
• Administering, managing and developing our businesses and services
• This includes:
• managing our relationship with clients;
• developing our businesses and services (such as identifying client needs and improvements in service delivery);
• administering and managing IT systems, websites and applications; and
• hosting or facilitating the hosting of events.
• Security, quality and risk management activities
• We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful e-mails. We monitor the products, services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our products, services and manage risks in relation to client engagements. We collect and hold personal data as part of our client engagement and acceptance procedures.
• Complying with any requirement of law, regulation or a professional body of which we are a member
• As with any provider of professional products, services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our products, services are provided in compliance with those obligations and those records may contain personal data.
• Improving and developing our products, services
• We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients particularly, we may use information that we receive in the course of providing professional products, services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, improve our business, service delivery and offerings and to develop new Darkside Europe technologies and offerings.

Data retention
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected. Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

This section describes how Darkside Europe handles personal information collected via this site and any other Darkside Europe sites that link to this privacy policy (collectively, “the Websites”).

By using the Websites and providing personal information to us, you acknowledge you have read this privacy policy, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use and disclosure of such personal information by the Darkside network and any third party recipients in accordance with this privacy policy.
By accessing any sites available within the Websites or content within them, you (a) acknowledge you will review the privacy policy and (b) to the extent required under applicable law, consent to the collection, processing and use of your personal data as described in this privacy policy.
Third Party Links
The Websites may link to third-party sites not controlled by Darkside Europe and which do not operate under Darkside Europe’s privacy practices. When you link to third-party sites, Darkside Europe’s privacy practices no longer apply. We encourage you to review each third-party site’s privacy policy before disclosing any personally identifiable information.
Under the Brazilian General Data Protection Law (further stated as «LGPD»), Federal Law No. 13,709/2018 (entered into force on September 18, 2020) personal data is any information related to an identified or identifiable natural person.
Collection of personal information through the Websites
When you use our Websites, we may collect information about you and your use of the relevant site. We may collect personal information about you, such as your name, username, job title, company name, address, e-mail address and telephone number, either directly from you or by combining information we collect via the Websites with personal information we collect and maintain through other channels (such as client relationship management systems or identification and access management systems, including IP addresses) or as we may lawfully collect from other third-party sites.
Below are examples of how you may provide personal information to us via Websites:

• subscribing to or ordering newsletters and/or publications;
• registering for premium online services;
• participating in “join our mailing list” initiatives;
• participating in Q&A sessions, bulletin boards, discussion, push-notices, invitations or message forums;
• entering Quick Surveys;
• registering for events and conferences;
• contacting us for further information; and/or
• providing us with business cards or other contact information.

We do not intend to collect sensitive information through the Websites unless we are legally required to do so. We ask that you do not provide sensitive information of this nature when using the Websites. If you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local applicable law, for us to collect and use that information in the ways described in this section of this privacy policy or as described at the point where you choose to disclose this information.
It is our policy to collect only minimum personal information required. If the Websites seek non-mandatory personal information about you, you will be notified of this at the point of collection. If you believe the Website has collected excessive information about you, please contact us immediately to raise any concerns.
Some pages on the Websites may permit you to send e-mails to us. Messages sent via the Websites will contain your screen name and e-mail address, as well as any additional information you wish to include in the message.
Registered Users
If you choose to become a Registered User, as part of the registration process you will be asked to provide us with personal information through a registration form. Information we collect may include: your name, e-mail address, password, country, organization, and job title. Some of the information is required and, if you do not provide it, you will not be able to register and receive the benefits of being a Registered User (for example, obtaining access to premium content). We have marked with an * /in red those registration fields seeking information that you must provide in order to become a Registered User.
For as long as you are a Registered User, you are responsible for providing us with accurate information about you and for keeping that information up to date. You may update your information by editing your user profile in your account.
Once you are a Registered User, we may combine the information you give us as part of the registration process with information we collect and/or have previously collected. As a Registered User, all of the data you provide as part of registration may be tied back to the information we collect or have previously collected about you.
We may also match the information you provide us against third-party data to supplement your user profile. For example, if a third party has additional information related to your e-mail address (such as a social media profile URL or a photo), we may match your e-mail address and activity on the Websites (including activity information collected prior to your becoming a Registered User) against that data and then use the third party data for additional permissible in accordance with local applicable law activities.
Use of personal information
When you provide personal information to us through the Websites, we may use it for any of the purposes described in this section of the privacy policy or as stated at the point of collection (or as obvious from the context of collection), including:

• to administer and manage the Websites, including to confirm and authenticate your identity and prevent unauthorized access to restricted areas of the site, premium content, or other services limited to Registered Users;
• to sort and analyze user data (such as determining how many users from the same organization have subscribed to or are using the Websites);
• to determine the company, organization, institution, or agency that you work for or with which you are otherwise associated;
• to develop our businesses and services;
• to conduct data analysis including, for example, regarding usage of the Websites and analyses of their users;
• to conduct quality and risk management reviews;
• to monitor and enforce compliance with applicable terms of use, including acceptable use policies; and/or
• any other purposes for which you provided the information to Darkside Europe, including any of the purposes given in the “Collection of personal information” section above.

Our Websites do not collect or compile personal information for sale to non-Darkside Europe parties for consumer permissible commercial purposes.
Registered Users: additional uses of personal information
If you choose to become a Registered User, we may also use your information for the following purposes:

• to tailor the content within our Websites and across Darkside Europe digital properties;
• to manage our relationship with you or the organization for which you work (for example, by including personal data we collect about you in our customer relationship management systems);
• to provide you with information about us and our products, services including via personalized permissible in accordance with local applicable law messages and/or communications unique to your organization about our products and services;
• to invite you to attend events, participate in sessions, forums, etc.;
• to conduct quality and risk management reviews;
• any other purposes for which you provided the information to Darkside Europe.

Automated Solutions
We do not make decisions about you based on automated processing of your data. We also do not use your personal data to automatically assess aspects of your personality (profiling).
Cookies
Cookies are small text files that can be used by the Websites to make the user’s experience more efficient. The law states that we can store cookies on your device, if they are strictly necessary for the operation of the Website. For all other types of cookies we need your permission/consent.
The Website uses different types of cookies. Some cookies are placed by third party services that appear on our pages.
You can at any time change or withdraw your consent from the Cookie Declaration on the Website.
You need to state your consent ID and date when you contact us regarding your consent.
Use of cookies
We use cookies to personalize content, to provide features and to analyze our traffic. We also share information about your use of the Websites with our partners and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services.
Use of Cookiebot Consent Management Platform (CMP)
Cookiebot CMP enables us to monitor and document tracking on the Websites, display the relevant information to the Website visitors as well as obtain and log user consents.
Cookiebot CMP brings three core functions that are easy to implement: cookie consent, cookie monitoring and cookie control. Cookiebot CMP enables us to be compliant with privacy legislations through respectful and transparent data exchange, based on consent between you as end-users and the Websites you visit.
Cookiebot CMP provides Darkside Europe Websites’ with the following: cookie consent compliance (customized user consent for the Websites), cookie monitoring (monitoring and reporting of types of cookies and similar tracking on the Websites), cookie control (blocking of all first – and third party cookies on the Websites until consent is given). Before navigating the Website, you are entitled to choose from “Deny”, “Allow selection”, “Allow all” cookies.
Registered Users
We use these technologies to make navigation of the Websites easier for you and to better deliver tailored content to you. If you choose to become a Registered User, we will use cookies to facilitate your registration and remember your preferences. If you choose to become a Registered User, you will receive the benefits of registration only if you accept the strictly necessary cookies, which include those cookies used as part of registration.
Analytics and site statistics
We also use these technologies to gather usage information and statistics regarding use of the Websites. For example, we collect information about page visits and navigation to determine what information and topics are of greatest interest and if users are able to find content easily. Likewise, we collect information about which information and content are viewed and whether it is viewed in its entirety to determine what content is of most interest to users. We also use usage information to generate various reports regarding use of the Websites. These reports contain aggregated information about users and do not single out users individually. If you are a Registered User, we may also collect information on what specific interests you have, including what information you have viewed on the site in order to understand what content interests you most.
Managing cookies on your device
You can control and manage cookies using your browser. Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.
Using your browser to control cookies
Most browsers allow you to view, manage, delete and block cookies for the Website. Be aware that if you delete all cookies, then any preferences you have set will be lost, including the ability to opt-out from cookies as this function itself requires placement of an opt-out cookie on your device. Guidance on how to control cookies for common browsers is on its pertinent websites.
Managing Analytics Cookies
You can opt-out of having your anonymized browsing history within our Websites or applications recorded by analytics cookies. We use the following service provider and you can learn more about its privacy policies and how to opt-out of its analytics cookies by clicking on the following link:
Google Analytics: https://www.google.com/analytics/learn/privacy.html
Cookie disclosure
The following section explains the types, categories, and purpose of cookies on the Websites.
Types of cookies:
Session cookies: these cookies remain in your browser during your browser session only, i.e. until you leave the Website.
Persistent cookies: these cookies remain in your browser for a set period of time after the browser session (unless deleted by you).
Categories of cookies:
Necessary Cookies: Necessary cookies help make the Website usable by enabling basic functions like page navigation and access to secure areas of the Website. The Website cannot function properly without these cookies.
Preferences Cookies: Preferences cookies enable the Website to remember information that changes the way the Website behaves or looks, like your preferred language or the region that you are in.
Statistics Cookies: Statistics cookies help the Website owners to understand how visitors interact with the Website by collecting and reporting information anonymously.
Unclassified Cookies: Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
Darkside Europe does not sell your data to any third parties.
Information about the cookies commonly used on the Websites can be found below. Darkside Europe sites may use additional cookies or third-party analytics tools. For more information about those additional cookies and third-party analytics tools used, please review the pertinent sites you visit.

Commonly used cookies on the Websites
The following cookies may be present on certain of the Websites.

Provider

Name

Purpose

Type

Duration

Google Analytics
__utma
This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behavior and measure site performance. It is used to calculate new and returning visitor statistics. The cookie is updated every time data is sent to Google Analytics.
First and third party
2 years
Google Analytics
_utmz
Stores the traffic source or campaign that explains how you reached the Websites. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.
Third party, persistent

Google
Ide
This is a Google UserID cookie used to help track users across various portions of the Websites to assist Darkside Europe in understanding how individuals use our Websites, what content they view, and to help Darkside Europe improve Website performance.
Third party
Two years
Google
Nid
This is a Google UserID cookie used to help track users across various portions of the Websites to assist Darkside Europe in understanding how individuals use our Websites, what content they view, and to help Darkside Europe improve Website performance.
Third party
6 months
Google Analytics
_gat
This cookie name is associated with Google Universal Analytics, according to Google documentation it is used to throttle the request rate – limiting the collection of data on high traffic sites. It expires after 10 minutes.
First party, session
1 minute
Google Analytics
_gid
This cookie stores a unique user session identifier.
First and third party
24 hours
Google Analytics
_ga
This cookie is typically written to the browser upon the first visit to the Websites. In most cases, this cookie is used to understand whether a visitor is a single time visitor or a returning visitor to the Websites and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure.
First and third party, persistent
2 years
Google Analytics
__utmb
This cookie is used to determine new sessions/visits.
First party
30 minutes from set/update
Data retention
We will retain your personal information on our systems only for as long as we need it, given the purposes for which it was collected, or as required to do so by law. We keep mailing list information until a user unsubscribes from our mailing lists and in accordance with local applicable law.
Subscriptions
If you opt into any subscriptions, you will receive automated e-mails when content is updated. If you opt into any newsletters, you will receive curated e-mails known as newsletters. If you select any preferences such as issues, topics, subjects or industries, you may receive e-mail communications related to those self-selected topics.
Unsubscribe
If you want to unsubscribe from mailing lists or any registrations, you should look for and follow the instructions we have provided within the appropriate area(s) of the Websites or in the relevant communications to you.
If you do not wish to receive e-mails or any communications from us, you can at any time contact us to request that such communications cease. If you wish to unsubscribe or no longer receive only certain communications, please identify such communications in your request.
Account Deactivation
If you are a Registered User, you may deactivate your account at any time via the Registered User section of the Websites. If you deactivate your account on the Websites, you will no longer receive the benefits of being a Registered User.
If you have other registrations with Darkside Europe, or have provided your information to Darkside Europe through other means (such as subscribing to newsletter), those registrations will be maintained unless you take specific action to inform us to cease contacting you.
Access to data
We are committed to providing reasonable and practical access that allows visitors to the Websites to identify and correct any inaccuracies in the information we collect about them.
When we keep personal information about you, we are responsible for keeping an accurate record of the information that you have submitted to us. If you are a Registered User, you may update your personal information; to do so, log in using your account credentials and update your information.
If you have questions about the accuracy of identifying information you previously submitted to Darkside Europe, or want to have outdated information removed, please contact us. When requested, and in accordance with the LGPD (as amended), we will delete identifying information from current operational systems.

Access to personal information is going to be provided, upon request of the data subject, within a period of up to 15 days of the data subject’s request, if the data requested is more than the simplified request version.

Under the LGPD (as amended), there is no a list of reasons to refuse an access request as well as it does not include a list of rights and freedoms that needs to be balanced against the right to access.
Children
We understand the importance of protecting children’s privacy, especially in an online environment. The Websites covered by this privacy policy are not intentionally designed for or directed at children or adolescents, and our terms and conditions of the Websites’ use require all users to be above the age of majority in their local country. We adhere to laws regarding children. We never knowingly collect or maintain personal information about individuals under the age of majority, and children or adolescents are banned from using the Websites due to the proper age gate installation.

Communication activities

Communications
Communication activities include any communications about Darkside Europe products and services. Where we are legally required to obtain your explicit consent to send you permissible in accordance with local applicable law materials, we will only provide you with such materials if you have provided consent for us to do so.
We retain contact information (including name, username and e-mail address) on our mailing lists until an individual unsubscribes from our mailing lists.
Darkside Europe does not sell personal information to non-Darkside Europe parties for consumer communication purposes.
How to unsubscribe from communication activities
You can at any time contact us to request that we stop sending you e-mail communications. If you want to unsubscribe from mailing lists, you should look for and follow the instructions we have provided in the relevant communications to you.
If you wish to no longer receive only certain communications, please identify such communications in your request.

Others who get in touch with us

We collect personal data when an individual gets in touch with us with a question, complaint or feedback (such as name, username, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with us. We only use the data as necessary to respond to the communication or resolve the complaint.

Security
We have implemented standards of technology and operational security, technical and administrative security measures in order to protect personal information from unauthorized accesses, and accidential or unlawful situations of destruction, loss, alteration, communication, or any improper or unlawful processing. Only authorized persons are provided access to personal information; such individuals have agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal data and taking into account the provisions of the Brazilian Internet Act (as amended), the transmission of data over the Internet (including by e-mail) is never completely and fully secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to or by us.

Your legal rights in relation to personal data
Every natural person is assured ownership of her/his personal information, with the fundamental rights of freedom, intimacy and privacy being guaranteed, under the terms of the LGPD (as amended).
You may have certain rights under your local law in relation to the personal information we hold about you. In particular, you may have a legal right to: at any time and by means of request,
1.obtain the following from us: confirmation of the existence of the processing;
2.free access to the data;
3.correction of incomplete, inaccurate or out-of-date data;
4.anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD (as amended);
5.portability of the data to another service provider or product provider, by the means of an express request, pursuant with the regulations of the national authority, and subject to commercial and industrial secrets;
6.deletion of personal data processed with your consent, except for the situations provided in compliance with a legal or regulatory obligation by Darkside Europe, the transfer to third parties, provided that the requirements for data processing as provided in the LGPD (as amended) are obeyed, or exclusive use of Darkside Europe, with access by third parties being prohibited, and provided the data has been anonymized;
7.information about public and private entities with which we have shared data;
8.information about the possibility of denying consent and the consequences of such denial;
9.revocation of given consent.
Your personal information is carried out in good faith and based on the following principles: purpose, suitability, necessity, free access, quality of the data transparency, security, prevention of nondiscrimination, and accountability.
Under the LGPD (as amended), collection and processing is referred to as «data treatment», and is defined as all operations carried out with personal data.
If you consider that the processing of your personal data infringes the law, you may have the right to lodge a complaint with the data protection regulatory authority responsible for enforcement of data protection law in the country where you normally reside or work (i.e., with the supervisory authority in Brazil, i.e. with the National Data Protection Authority (ANPD)), or in the place where the alleged infringement occurred.
Changes to this privacy policy
This privacy policy was last updated on August 01, 2022.
We may update this privacy policy at any time by publishing an updated version here. So, you know when we make changes to this privacy policy, we will amend the revision date at the top of this page. The new modified or amended privacy policy will apply from that revision date. Therefore, we encourage you to review this privacy policy periodically to be informed about how we are protecting your information.
Contact us
· Please submit a request to our e-mail to exercise a legal right in relation to your personal data, or an enquiry if you have a question or complaint about the handling of your personal data, or a request to delete your personal data and/or account. This process may take up to 15 (Fifteen) days or be organized immediately in accordance with applicable local law requirements.
· You may also contact us at the following postal address:

Darkside Europe GmbH
Darkside Europe Gesellschaft mit beschränkter Haftung
Berlin
Olivaer Platz 10, 10707
Germany
E-mail: officede@d-tabak.com
Tel.: + 49 (30) 403 68 45 70