CLM Controller respects the privacy of website visitors and fully complies with the General Data Protection Law. Below, we detail which data may be stored, how they are used, and how to request their removal. If any deviation from this purpose is noticed, we ask that it be reported to us as soon as possible at the email address [email protected], and we will take the necessary actions promptly.
Cookies are small text files that a website, when visited, places on the user’s computer or mobile device through the internet browser. Storing cookies will help the website recognize your device on a subsequent visit. We use the term cookies in this policy to refer to all files that collect information in this manner. The cookies used do not collect information that identifies the user. However, if you are already our customer, we may monitor your visits to the site as long as you have initiated your navigation at least once from any communication sent by us, for example, through a portal. Cookies also collect generic information, such as how users arrive at and use the websites or the region/country from which they access the website, etc. Cookies only retain information related to your preferences. At any time, the user can, through their internet browser, decide to be notified about the receipt of cookies, as well as block their entry into their system. Refusing to use cookies on the website may result in the inability to access some of its areas or receive personalized information.
Cookies are used to help determine the usefulness, interest, and number of uses of websites, allowing for faster and more efficient navigation and eliminating the need to enter the same information repeatedly.
3.1 Persistent Cookies – They are stored at the level of the internet browser on your access devices (computer, notebook, mobile, and tablet) and are used whenever the user pays a new visit to one of our websites. They are typically used to direct navigation according to the user’s interests, allowing us to provide a more personalized service.
3.2 Session Cookies – These are temporary cookies that remain in the cookie file of your internet browser until you leave the website. The information obtained allows us to analyze web traffic patterns, identify problems, and provide a better browsing experience.
Functionality Cookies – We use functionality cookies to allow us to remember the user’s preferences. For instance, cookies prevent entering the user’s name each time they access the site. We also use functionality cookies to provide advanced services to the user, such as commenting on an article. In short, functionality cookies store the user’s preferences regarding the use of the site, so there’s no need to reconfigure the site each time you visit.
Essential Cookies – Some cookies are essential to access specific areas of our website. They allow navigation on the site and the use of its applications, such as accessing secure areas of the site through login. Without these cookies, services that require them cannot be provided.
4.2 Analytical Cookies – We use these cookies to analyze how users use the site and monitor its performance. This allows us to provide a high-quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For instance, we use performance cookies to find out which pages are the most popular, which method of linking between pages is most effective, or to determine why some pages are receiving error messages. Based on the site usage, we might also use these cookies to highlight articles or services on the site that we think will be of interest to users. These cookies are only used for statistical creation and analysis, without ever collecting personal information.
4.3 Functionality Cookies – We use functionality cookies to allow us to remember the user’s preferences. For example, cookies prevent typing the user’s name every time they access the site. We also use functionality cookies to provide advanced services to the user, like leaving comments on an article. In summary, functionality cookies save the user’s preferences regarding the use of the site, so there’s no need to reconfigure the site each time you visit.
4.4 Third-party Cookies – They are used to measure the success of applications and the effectiveness of third-party advertising on our site, where applicable.
4.5 Advertising Cookies – They are used to target advertising based on each user’s interests and the number of visits they’ve made, allowing the limitation of the ad’s display frequency. These cookies help measure the effectiveness of advertising.
After authorizing the use of cookies, the user can always deactivate part or all of our cookies. All browsers allow the user to accept, decline, or delete cookies, namely by selecting the appropriate settings in their respective browser. You can configure cookies in the “options” or “preferences” menu of your browser. Note that by disabling cookies, you may prevent some web services from working correctly, affecting the navigation on the website either partially or entirely. We remind you that when disabling cookies, parts of our site may not function properly.
Besides cookies, we and our partners may also use other technologies, including data stored in your browser or device, identifiers associated with your device, and other software that serve purposes similar to cookies. These technologies include:
6.1 IP Addresses – This is a unique address that identifies a device on the Internet or a local network. IP stands for “Internet Protocol,” which consists of a set of rules that dictate the format of data sent over the Internet or a local network. Essentially, the IP address is the identifier that allows information to be sent between devices on a network: it contains location information and makes the device accessible for communication. The Internet requires a means of distinguishing different computers, routers, and websites. The IP address provides this and is a fundamental part of how the Internet operates.
6.2 Pixel Tags – Also known as Clear Gifs, web beacons, or pixels, these are small blocks of code on a web page that allow them to perform actions like reading and storing cookies and transmitting information to our partners. The resulting connection can include information such as the IP address of a device, the time someone viewed the pixel, an identifier associated with the browser or device, and the type of browser in use.
6.3 Software Development Kits – Software development kits (also called SDKs) function like pixels and cookies but operate in the context of a mobile app where pixels and cookies may not always work. Bits of code (the SDK) are installed in the app, enabling us and our partners to gather specific information about your interaction with the app and information about your device and its network.
We and our partners use cookies to gather information on how you interact with and navigate our sites, as well as data about the device and software you use to do so. This information is detailed in our privacy policy and may include statistical data of:
• Interactions between websites and apps, including language preferences, timestamps, clicks, scrolls, browsing times, searches, referrals, and exit pages;
• Information about your device, such as IP addresses, unique device IDs, user ID, processing capabilities, make and model, language and other regional settings, geographic location, screen resolution, and similar settings;
• Your connection to online services, including details about the network and software you are using, including browser type and version, OS name and version, ISP, and your preferred settings; and
• How sites and apps perform for you, including encountered issues, such as loading errors and response times.
This data can be combined with other information we or our partners store about you, for instance, to support our marketing efforts by displaying Google ads or marketing messages based on how you’ve browsed with us or your previous visits and interactions on our site.
Cookies placed on your device by us while you are on our site are called “first-party cookies”. If our partners place cookies on your device while you are on our site, they are called “third-party cookies”. These cookies are controlled by third parties and not by us. For example, when you visit our site, Google Analytics sets its own cookies on your internet browser. They record your visit and this information is shared with other organizations.
We do not control third-party cookies and cannot remove them. Only the third party can set third-party cookies, but you can take control of removing cookies using your browser settings or our cookie preference tool. You can also read the privacy policies of our partners to ensure you are familiar with the way they use cookies. To learn more about companies that provide third-party cookies on our online services and how they use the information collected, continue reading this document.
All browsers allow the user to accept, refuse, or delete cookies, namely through selecting the appropriate settings in their respective browser. You can configure cookies in the “options” or “preferences” menu of your browser. Note that by disabling cookies, you may prevent some web services from working correctly, affecting, partially or entirely, the browsing on the website. We remind you that by disabling cookies, parts of our site may not function properly.
10.1 Cookie Warning Banner: You can use our notice to enable or disable cookies. If you choose to disable cookies, be aware that features of our site may not work as intended.
10.2 Browser Settings: You can change your cookie preferences by altering your browser settings. Most web browsers typically accept cookies, but you can adjust your browser settings to refuse new cookies, disable existing cookies, or simply be informed when new cookies are sent to your device. Users can disable the use of cookies on this webpage at any time by modifying their browser settings, for example:
• Google Chrome;
• Internet Explorer;
• Mozilla Firefox;
• Apple Safari;
• Opera.
10.3 Email Opt-out: Our website may use technologies similar to cookies, such as web beacons, pixel or gif tags, and action tags to confirm that our email messages have been delivered and opened. You can choose to opt out of receiving our emails at any time.
We may update this Cookie Notice from time to time to reflect, for example, changes in the cookies we use or for other operational, legal, or regulatory reasons. As such, users should regularly consult this cookie notice to stay informed about our use of cookies and related technologies. The date at the beginning of this cookie notice indicates the date of the last update.
The Data Protection Officer, also known as Data Protection Officer (DPO), will act as a communication channel between CLM, the data subject, and the National Data Protection Authority – ANPD (Article 41 of Law No. 13.709/2018). Contact with CLM’s Data Protection Officer should be made via the email [email protected].
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