PRIVACY NOTICE
A) INTRODUCTION
Clube de Regatas do Flamengo recognizes that the security of your data and your privacy are very important to us, and we aim to demonstrate transparency to everyone who maintains a relationship with the Club, such as our members, fans, employees, sponsors, suppliers, and partners.
In respect of your rights and complying with the guidelines of Law No. 13.709/2018, the General Data Protection Law (LGPD), we publish our Privacy Notice, a document that reflects what our privacy and personal data protection policy guides employees and third parties on the processing of your data.
B) CONCEPTS AND DATA SUBJECT PORTAL
LGPD | PERSONAL DATA | SENSITIVE DATA | DATA SUBJECTS | PORTAL | RIGHTS | REQUESTS | PORTAL EXCLUSIONS | DEADLINE | SECURITY
What is the LGPD?
It is the General Personal Data Protection Law (Law No. 13.709/2018) which aims to protect the fundamental rights of freedom and privacy as well as the free development of the personality of citizens.
+ What is personal data?
According to the law, these are information related to any person that makes it possible to identify the person or make them identifiable, such as, for example, name, ID, CPF, CNH, address, email, telephone, registration number, e-social records, class councils, etc.
+ What is sensitive personal data?
These are data or information related to a natural person that identifies their racial or ethnic origin, religious conviction, political opinion, union membership or affiliation to religious, philosophical, or political organizations, and data referring to health, sexual life, genetic, or biometric data.
+ Who are the personal data subjects?
It is you, the natural person, to whom the personal data being processed refers. Under the LGPD, you are recognized as the owner of your data and, with this, you gain rights guaranteed by law.
+ What is the Data Subject Portal and what services do we provide there, where we handle data subject requests?
The Data Subject Portal is the service channel for personal data subjects, where we will enable you to exercise your rights as a subject, as provided for in the General Data Protection Law.
+ What are your rights as a data subject?
Confirm whether processing of your data exists and what it entails, have access to the data available to the organization, request correction, deletion, anonymization, portability, information about the sharing of your data, and revoke previously granted consents.
+ How can I exercise my rights and make requests to Flamengo?
Through our data subject service channel, or simply, the Data Subject Portal, which is exclusive for requests related to the exercise of your rights as a data subject.
+ What services are not handled by the Data Subject Portal?
Any others that are not related to the exercise of your rights as a data subject. If you wish to resolve any issue, such as one related to the Nação Fan Member program, billing, information about games, opening hours of the Club's Social Headquarters, or suggestions and complaints, please contact the appropriate channels, according to the intended service or our Ombudsman, if your request is not met: [email protected].
+ What is the deadline to receive a response to the request?
Our maximum estimated response time is up to 15 (fifteen) days, according to the Law. The request, its progress, and the response can be consulted through the Data Subject Portal.
+ How to take care of your security?
It is important to note that your login and password – or those of your dependents – are personal and non-transferable. Therefore, we recommend not providing this data to other people, even close ones, if they are not authorized to make requests on your behalf, as Flamengo will not be responsible for actions carried out by third parties who gain access to the data subject's data. Seek to change your password periodically and, if you suspect that someone unauthorized has gained access to your login and password, change the password immediately and notify us through the Data Subject Portal.
c) PRIVACY NOTICE
INTRODUCTION | SUMMARY BOX | FLAMENGO AS PROCESSING AGENT | DATA SUBJECT RIGHTS | ORIGIN OF DATA | DATA PROCESSED | PURPOSES AND LEGAL BASES | SHARING | COOKIES | SECURITY MEASURES | INTERNATIONAL TRANSFER | PRIVACY AREA | UPDATES | CONTACTS | LEGISLATION AND JURISDICTION
1. Introduction
CLUBE DE REGATAS DO FLAMENGO, a professional sports practice entity registered with the CNPJ under No. 33.648.575/0001-99, headquartered in Rio de Janeiro/RJ (“FLAMENGO”), understands the electronic records and personal data left by you (“User
| SUMMARY BOX | |
| FLAMENGO'S ROLE AS PROCESSING AGENT | CONTROLLER: |
| DATA SUBJECT RIGHTS |
By law, you have the right, at any time, to:
Meeting all your rights is FLAMENGO's commitment, under the terms of the LGPD and through our actions. Therefore, we provide a communication channel, the Data Subject Portal, so that you can open your requests and ask for any of your rights listed previously. Through it, you contact our DPO, and he will be responsible for returning responses to your requests. We provide the following ways to contact us:
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| ORIGIN OF PERSONAL DATA | Personal data is generally provided by the user and/or collected automatically upon the subject’s association, registration, and/or enrollment for access and/or use of services inside and outside the facilities of Clube de Regatas do Flamengo, whether as a local fan member, through embassies and consulates, admission as a permanent employee or third party allocated to the facilities, as an hourly teacher or athlete, self-employed person, bidder in tenders, suppliers or service providers, business partners, sponsors, licensees, auditors, celebrities, press, competent authorities, and interested or regulatory governmental entities. |
| PERSONAL DATA COMMONLY PROCESSED BY FLAMENGO | Basically, we collect name, affiliation (minors must have the consent of legal guardians), date of birth, place of birth, sex, telephone, email, address, identity card, CPF registration, official identification record (when foreign), and your facial biometrics, in case you are a fan member and wish to buy a ticket for a Flamengo match at Maracanã. |
| PURPOSES AND LEGAL BASES FOR PERSONAL DATA PROCESSING |
Due to the nature of Flamengo's operations, there is a very broad diversification of personal data processing purposes, according to the subject's objective. For example, for Club members: identification data (registration), contact, financial history, medical certificates for school students, digital biometrics, images from CCTV cameras (for the physical security of our member and their children) and legal responsibility – if minor; for fan members: identification data (registration), contact, billing data, purchase history, and facial biometrics; for fans who are not fan members: registration data, purchase data, bank data and or credit card (which are stored in banking institutions), facial biometrics (for access to Maracanã); for employees: registration data, employee data for proof of employment bond, security (PIS, PASEP, NIS, E-social, among others) and benefit maintenance; for athletes, in addition to the previously mentioned data, health and physical performance data is needed, to enable health care inherent to the exercise of the function; for third parties: registration data, document images, contractual data (for hiring), digital biometrics for access to facilities and physical security, and payment history. for access to facilities.
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| SHARING DATA WITH THIRD PARTIES |
We do not rent, sell, or share your information with third parties, except as described in this Privacy Notice. Eventually, we may share information in the following ways:
NOTE: FLAMENGO's partner organizations are aware of and commit to the Club to respect, under the terms of this document and our internal guidelines, the protection and privacy of your data, under the terms of the LGPD or other related national or foreign laws, depending on the application. |
| COOKIES |
Cookies are files or information that can be stored on devices when a user visits FLAMENGO's website pages and accepts the use of Cookies. Generally, a cookie contains the name of the website that originated it, its lifespan, and a value, randomly generated. FLAMENGO uses cookies to facilitate navigation and adapt the pages to your interests and needs. Cookies are also used to compile information about the use of our websites and services, which contributes to the improvement of our structures and content. Another way we use cookies is to accelerate users' future activities and experiences on our pages. They can also be used to indicate FLAMENGO pages on the websites the user visited. FLAMENGO may share this information with third parties and business partners. But it is important to warn that you can (and should) choose your cookie usage options on the website(s). We provide this functionality, and you can change your preferences at any time. See the types we use below: a) Necessary: are those that help understand how visitors interact with FLAMENGO pages, providing information about visited areas, time spent on the website, and any problems encountered, such as error messages. b) Functional: are those that allow FLAMENGO pages to remember your choices to provide a more personalized experience. Furthermore, they allow users to watch videos and use social tools, comment fields, forums, among others. c) Analytics and/or Performance: are cookies used to provide statistical information about our website - they are used to measure and improve performance. This category is also known as Analytics. Activities such as counting page visits, page loading speed, bounce rate, and technologies used to access our website are included in this category. d) Advertising: are cookies used to provide content of interest to the User and display more targeted advertising or limit the number of times it is displayed on FLAMENGO Pages. It is also possible to allow the measurement of the effectiveness of an advertising campaign. After the user consents to the use of cookies, FLAMENGO stores a cookie on their device to remember this in the next session, and the user may revoke their consent regarding cookies when they deem it appropriate. Warning: if the user does not accept some cookies from FLAMENGO pages, certain services may not function optimally. Third-party analytics are used to track and measure website usage, to enable the continuous production of attractive content. These cookies can track items such as the time you spend on the website or the pages visited, which helps us understand how we can improve the websites for you. New features are periodically tested, and subtle changes are made to how the website is presented. And these cookies can be used to ensure you receive a consistent experience while browsing, while FLAMENGO understands which optimizations our users appreciate most. |
| ADOPTED SECURITY MEASURES | To seek compliance with privacy and data protection guidelines, FLAMENGO has continuously and progressively adopted technical and administrative measures to prevent data breaches, and we demand the same practice from our third parties. Basically, we invest in physical security and information technology resources; in maintaining an area dedicated to the topic of personal data privacy and protection, the Privacy Management; in training and awareness of our employees; in partnership with the Legal Department for the joint preparation of contractual clauses in agreements and contracts with our partners regarding good practices; in the use of techniques and tools commonly used in the market to provide security, within the acquisition possibilities that FLAMENGO and the third party have; and the continuous construction of a personal data governance system and audits aimed at continuous improvement. Among other measures, FLAMENGO: |
| INTERNATIONAL TRANSFER |
The transfer can only be made to another country if it meets the requirements of article 33 of the General Personal Data Protection Law, especially its first clause, which states that the country or territory in question or the international organization concerned ensures an adequate level of protection for the user's data. If there is no adequate level of protection, FLAMENGO will make greater efforts to protect your data in accordance with the most rigorous rules, through specific contractual clauses for a given transfer, standard contractual clauses, global corporate rules, or regularly issued seals, certificates, and codes of conduct. We have some service providers such as AWS, Google, and Microsoft that maintain their Data Centers outside the country, but we prioritize using them in countries that have privacy agreements with Brazil or have specific legislation on data privacy and protection. |
| PRIVACY AREA AND DPO |
FLAMENGO's Privacy Management is composed of a team of people dedicated to the governance and management of personal data privacy and protection. In it, we also have the figure of the “DPO” (Data Protection Officer), who is the professional designated, under the terms of the law, to mediate the relationship between FLAMENGO, its data subjects, and competent authorities on the matter. In Brazil, under the LGPD, he is called “ The DPO of Clube de Regatas do Flamengo is Mr. Leandro Rocha, and you can contact him through the Data Subject Portal. |
| LEGISLATION AND JURISDICTION |
This Privacy Notice is governed, interpreted, and executed in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13.709/2018 - General Data Protection Law, regardless of the Laws of other States or countries, with the jurisdiction of the Capital District of Rio de Janeiro being competent to resolve any doubt arising from this document. Rio de Janeiro, 07/23/2024. |
