3PICOS privacy policy

Last updated: January 15, 2020

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Privacy policy

Last updated: January 5, 2020

 

3PICOS is a Brazilian technology, communication and advertising startup. We have a new and modern location technology, our systems allow the sending of information and data, creating flow barriers, directing or redirecting flow based on mappings made by highly complex algorithms generating databases that are applied in advertising and targeted advertising in addition to products available based on proximity and places visited. 3PICOS is hired by any company and / or advertiser in order to improve its services, allowing communication at the right time and time.

So that we can work, making it possible to send advertising intelligently, some data from your mobile device is collected when you use applications. The applications inform you through their policies the collection of this data. And when installing applications, you accept and agree or disagree with these terms. Each application tells you what kind of data 3PICOS or other companies can collect from your device.

It is worth remembering that this privacy policy deals with 3PICOS privacy issues related to device data collected and handled by applications that 3PICOS uses for data collection.

 

1. The Data

When you use an application that uses our system, we may be collecting data about the device, including Advertising Identifier from Android, iOS or other similar operating systems, as well as location data received from the device's sensors. In addition to this data, 3PICOS also collects data about advertising on the device, including clicks made from it, impressions and length of time spent in advertising. It is important to note that not all applications collect all of this data.

In compliance with the transparency requirements, we detail below your device data that 3PICOS can collect if you use an application with our system:

A. Information about your device: Electronic advertising identifier (“Advertising ID”) of the operating system (Android Advertising ID - AAID, Apple ID for Advertising - IDFA, or other), model, manufacturer, operating system, telecommunications operator , mobile browser, type and speed of the internet connection being used, IP address of the internet connection, GMT time zone, Hot Site User Agent and applications installed on the device, including the identification of applications that have 3PICOS software;
B. Data from WiFi, GPS, Bluetooth, accelerometer, magnetometer, gyroscope and proximity sensors when these accesses are available in the partner application;
C. Information about the advertising received, viewed and clicked on the device, including the type of advertising, as well as information about the user’s interaction with the advertising: how / where they clicked, how much time they spent viewing, how much time spent within the content after running the click, and access the pages viewed within the Hot Site that the user may have been directed to after clicking on advertising;
D. Data on the user's age and gender.

At this point, it is also important to indicate that 3PICOS may receive data from your device that our partners have collected, such as information about your device's activity on their services.

This data, collected and received, is stored by 3PICOS based on the advertising ID of its operating system (AAID, IDFA or other), which allows us to recognize your mobile device over time.

It is important to note that not all partner applications collect all of this data. This is the maximum amount of data we can collect from a given advertising ID under current technical conditions. The minimum amount of data that partner applications allow us to collect is related to items A and C described above.

In addition to this data from your device, 3PICOS can also process the data collected, in order to make inferences about the location profile and interests associated with the device. We detail the inference data about the device's advertising ID below:

A. Country, City, State and neighborhood;
B. Estimated latitude and longitude coordinates of workplace and home, as well as neighboring devices associated with these coordinates;
C. Geographic data, such as climate and vegetation;
D. Profession, Education and Economic Class;
E. Store segments physically visited;
F. Cultural profile;
G. Age and sex;
H. Means of transport;
I. Internet provider;

Bearing in mind that, in the case of partner applications that have only the minimum data collection permissions, 3PICOS only makes partial data inferences about items D and F indicated above.

This data from your mobile device, collected and processed by 3PICOS, does not include personal data such as your name, civil identification numbers (such as CPF and RG) or email, which is a differential of 3PICOS. Our company works with the concept of "privacy by design" and treats the theme of privacy as fundamental, following all legal requirements not only in Brazil but in other countries where it operates.

Specifically in relation to your email, if you have specifically and unequivocally consented to the collection and processing of it for purposes of correlation and aggregation with the database of any of our partners, we will only store it in the form of a hash (which cannot be understood in natural language), in order to make this data anonymous in our database.

In order to further guarantee your privacy, 3PICOS does not collect or make any kind of treatment of data considered as sensitive, such as, for example, religious options, policies, credit card details and bank details in general.

In addition to these measures, 3PICOS also does not collect information about fixed hardware identifiers (such as MAC - Media Access Control, or IMEI - International Mobile Equipment Identity) from your mobile device.

Thus, the data collected does not allow us to know your identity in real life, but only to understand preferences and context as a consumer, allowing us to recognize your device over time.

Finally, it is important to clarify that 3PICOS does not collect any of the device data listed above, when the partner application is targeted at children. Thus, in partner applications aimed at children, 3PICOS does not collect or perform any type of treatment with data from the device, with the exception of collecting contextual information from the application, such as type of content or application, in order to be able to send themed advertisements. In addition, 3PICOS follows the privacy standards of Brazilian law and also of the American Children's Online Privacy Protection Act (COPPA), which is why it also does not process any data, as indicated above, related to applications directed to adolescents under 13 years.

 

2. How we at 3PICOS use the data collected

The data on your device that 3PICOS collects when you use any of our partner applications is used to generate consumer profiles based on Advertising IDs, allowing us to send ads and promotions to your device in a more intelligent and relevant way, avoiding randomness.

3PICOS 'differential is precisely our location technology, which allows, with greater precision, to determine the place where the mobile device is or has been, by sending more relevant advertisements.

In addition to the specific uses of the collected device data described in this Privacy Policy, 3PICOS may also use it to:

 

A. Assess which ads have already been sent and viewed on certain devices, preventing them from recurring at an uncomfortable frequency;
B. Analyze consumption trends;
C. Produce and send reports to partners who use the 3PICOS service to reach consumers interested in their products and / or services, who may have aggregated information, such as: which ads a particular group of consumers clicked on, which time consumer group is more likely to check an ad, which product or service brought a particular consumer group to the advertiser's store, etc.
D. Improve the security of the data collected and improve the services provided by 3PICOS;
E. Identify fraud in ad views in order to protect the interests of our partner advertisers.

It is also important to make it clear that 3PICOS may recognize a mobile device in our database when an Advertiser shares device advertising IDs (AAID or IDFA) with us. The purpose of this sharing is to maximize the effectiveness of the partners' advertisement network, thus ensuring more intelligent and relevant advertising.

Specifically in relation to the advertising that you may receive through the 3PICOS partner apps on your mobile device, we would like to clarify that the third party ads and content displayed on the partner apps are not under the control or responsibility of 3PICOS, being the responsibility exclusive to advertisers.

 

3. How we store and protect the data collected

The security of the data collected by 3PICOS is very important and that is why we use security mechanisms, such as encryption, both in the transport and storage of data, in addition to always updating our protection system.

The collection of data made by 3PICOS occurs through a secure transport protocol that uses encryption to protect the data in its transport to our servers.

The data collected is then stored in a secure database, in an encrypted form and with restricted access, only being used for the purposes expressly provided for in this Privacy Policy.

 

4. Sharing of collected data with third parties

3PICOS also enters into contracts for the sharing of device data collected with some of our business partners, in order to enable the improvement of the experience of the users of these partners. The shared device data has the device advertising IDs (AAID or IDFA), or your email, with the protections described above as the identification key.

In these contracts, 3PICOS establishes clauses with obligations for partners to maintain the same data security and privacy standards as in this privacy policy.

In addition to the data sharing relationships with partners, 3PICOS will only provide collected data related to a given advertising ID or email (with the protections described above and when collected) in the event of a specific court order in this regard, in accordance with the establishing the applicable legislation.

 

5. International data transfer

3PICOS may store and process device data collected on servers of contracted companies located in other countries, including member countries of the European Union or in the United States of America. In contracting these services, 3PICOS will always look for companies with a high level of information security, establishing contracts that do not violate the privacy definitions provided for in this policy. Here it is worth noting here that all data stored by 3PICOS is encrypted, which guarantees another level of security for the data.

3PICOS may also share the data collected from your device with partners located in countries other than your country of origin. We emphasize that in the case of international data transfer, 3PICOS establishes obligations in the transfer contracts with partners, in order to maintain the same data security and privacy standards present in this privacy policy.

In addition, 3PICOS may share the data collected with other companies in the 3PICOS group to perform the activities specified in this Privacy Policy.

 

6. Opting out

3PICOS is always concerned with the experience of consumers and, therefore, we offer you the option of “opt-out”. To start the opt-out process click here.

Opt-out is a consumer right that does not want to share data from his device with companies that enable the sending of intelligent advertising. We clarify that when performing the opt-out you will not be excluding the partner application that makes 3PICOS work on your device viable, nor will you have any other type of damage in the use of this application.

By doing this opt-out procedure, you will be disabling the collection and processing of data from your device for the purpose of selecting ads using 3PICOS technology. But if you regret it, it will always be possible to reactivate our services by sending an email to atendimento@3picois.com.br

We emphasize, however, that the 3PICOS opt-out procedure does not disable the receipt of advertising on your device. You will still continue to receive advertising, but without ads selected based on 3PICOS technology.

Finally, we clarify that the opt-out here exposed only disables the action of 3PICOS, which means that the data on your device may still be collected by companies other than 3PICOS. If you want to completely disable data collection from your device associated with your advertising ID, you can change your device's settings if your device is running the Android or iOS operating system, as instructed below:

iOS 6:
• Select "Settings"> "General"> "About"> "Advertising"
• Select “Limit crawled advertising”

iOS 7 or higher:
• Select "Settings"> "Privacy"> "Advertising"
• Select “Limit crawled advertising”

Android:
• Select “google parameters”> “ads”
• Select “Disable interest advertising”

There is also the possibility for you to reset your advertising ID, generating a new advertising ID, and therefore avoiding the recognition of your mobile device based on the historical data associated with your old advertising ID. To do this, if you have the Android or iOS operating system, you can follow the steps below:

iOS 6:
• Select "Settings"> "General"> "About"> "Advertising"
• Select “Reset advertising identifier”

iOS 7 or higher: • Select "Settings"> "Privacy"> "Advertising"
• Select “Reset advertising identifier”

Android:
• Select “Google parameters”> “Ads”
• Select “Reset advertising code”

If you still have any doubts about the opt-out, contact 3PICOS through our service channel: atendimento@3picos.com.br

 

7. Changes to the Privacy Policy

3PICOS is always working to improve the services provided and bring innovations to consumers. This means that we may update and change the terms of this Privacy Policy from time to time. On our website, you will always find the latest version of the terms.

If you prefer, we can still notify you by email whenever the Privacy Policy is changed, you just have to sign up by sending an email to atendimento@3picos.com.br

Finally, we would like to remind you that if, as of any future modification, you fail to agree with our Privacy Policy, it is possible to use the opt-out, as explained in point 7, disabling the data processing of your device by 3PICOS.

 

8. Contact us

If even with the information in this Privacy Policy you still have questions, please contact us through our service channel, 3PICOS encourages you to send comments, questions, suggestions. To contact us you can send an email to atendimento@3picos.com.br

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