privacy policy (lgpd)

The Rocket Science Group LLC Terms and Conditions d / b / a Mailchimp

Effective August 14, 2020

Mailchimp takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use personal information and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure that you are fully informed. However, to facilitate a review of the parts of this privacy policy that apply to you, we have divided the document into sections that are specifically applicable to Members (Section 2), Contacts (Section 3) and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.

If you have any questions or concerns about the use of your personal information, please contact us using the contact details provided at the end of Section 5.

To the extent that we advise you of different or additional privacy policies, those policies will govern such interactions.

1. The basics
A. About us
Mailchimp is an online marketing platform operated by The Rocket Science Group LLC, a company based in the state of Georgia, in the United States (“we”, “us”, “our” and “Mailchimp”).

Our service allows our members, among other things, to send and manage email campaigns through channels, run ads and create websites and landing pages. We also provide other related services, such as real-time data analysis and insights to help our members track and personalize their marketing activities. Find out more about our service here.

B. Key terms
In this privacy policy, these terms have the following meanings:

“Affiliate” means an entity that controls directly or indirectly, is controlled by or is under the common control of an entity.

“Contact” is a person that a Member can contact through our Service. In other words, a contact is anyone on a member's distribution list or about whom a member has provided us with information. For example, if you are a member, a subscriber to your email marketing campaigns would be considered a contact.

“Control” means a property, vote or similar holding representing fifty percent (50%) or more of the total outstanding shares then in circulation of the entity in question. The term “Controlled” must be interpreted accordingly.

“Distribution list” is a list of contacts that a member can upload or manage on our platform and all associated information related to those contacts (for example, email addresses).

“Mailchimp Site (s)” has the meaning ascribed to it in our Standard Terms of Use.

“Member” means any person or entity registered with us to use the Service.

“Mobile application (s)” means any or all of the Mailchimp applications available for Members to use on their mobile devices.

“Personal information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of personal information include, but are not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information.

“Service” has the meaning ascribed to it in our Standard Terms of Use.

“Visitor” means, depending on the context, anyone who visits any of our Mailchimp Sites, offices or otherwise gets involved with us at our events or in connection with our marketing or recruitment activities.

“You” and “yours” means, depending on the context, a Member, a Contact or a Visitor.

2. Privacy for members
This section applies to Personal Information that we collect and process from a Member or possible Member through the provision of the Service. If you are not a member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, "you" and "yours" refer to members and potential members.

A. Information we collect
The personal information we collect depends on the context of your interactions with Mailchimp, your Mailchimp account settings, the products and resources you use, your location and the applicable law. However, the personal information we collect generally falls into the following categories:

(i) Information you provide to us: You (or your organization) may provide us with certain Personal Information when you sign up for a Mailchimp account and use the Service, consult our customer service team, send us an email, integrate the Service with another website or service (for example, when you choose to connect your e-commerce account with Mailchimp), or communicate with us in any other way.

This information may include:

Business contact information (such as your name, title, organization, location, telephone number, email address and country);
Marketing information (such as your contact preferences);
Account login credentials (such as your email address or username and password when signing up for an account with us);
Troubleshooting and support data (which is the data you provide or collect in connection with the support questions we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help query); and
Payment information (including your credit card numbers and associated identifiers and billing address).
(ii) Information we automatically collect: When you use the Service, we may automatically collect or receive certain information about your device and the use of the Service (collectively, “Service Usage Data”). In some (but not all) countries, including countries in the European Economic Area (“EEA”), this information is considered Personal Information in accordance with applicable data protection laws. We use cookies and other tracking technologies to collect some of this information. If you are using our mobile application, we may collect this information using our software development kits (“SDKs”) or APIs the first time that the SDK or API is launched in your mobile application. For more information, see the section below and our Cookie Statement available here.

Service usage data may include:

Device information: We collect information about the device and the applications you use to access the Service, such as your IP address, operating system, browser ID and other information about your system and connection. If you are using our mobile app, we may also collect information about the cellular network associated with your mobile device, the operating system or platform of your mobile device, the type of mobile device you use, the name of your mobile device and unique ID of the device and information about the features of our mobile app that you have accessed.

Log data: Our web servers maintain log files that record data each time a device accesses those servers and the nature of each access, including source IP addresses and their activity on the Service (such as the time stamps associated with the your usage, pages and files viewed, searches and other actions you take (for example, what resources you used)), device event information (such as system activity, error reports (sometimes called 'memory dumps') )) and hardware settings. We may also access metadata and other information associated with the files you upload to our Service.

Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times when you access the Service and your browsing activities (such as the parts of the Service you used). We also collect information about the performance of the Service, including metrics related to the ability to deliver emails and other communications sent through the Service. If you are using our mobile app, we may collect information about how often you use the mobile app and other performance data. This information allows us to improve the content and operation of the Service and to facilitate research and analysis of the Service.

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners.

Examples of information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about the use of social media sites, page view information and search results and links). We use this information, alone or in combination with other personal information we collect, to improve our ability to provide you with relevant marketing and content and to develop and deliver the most relevant products, resources and services.

B. Use of personal information
We may use the Personal Information that we collect or receive through the Service (alone or in combination with other data that we provide) for the purposes and on the legal bases identified below:

To bill and collect money owed to us by you to perform our contract with you for the use of the Service or when we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Service. This includes sending emails, invoices, receipts, delinquency notifications and alerting you if we need a different credit card number. We use third parties for the secure processing of credit card transactions, and these third parties collect billing information to process your credit card orders and payments. To learn more about the steps we take to protect this data, see the “Our security” section of this privacy policy.
To send system alert messages based on our legitimate interests in administering the Service and providing certain features. For example, we may inform you of temporary or permanent changes to our Service, such as planned interruptions, or send account, security or compliance notifications, such as new features, version updates, releases, abuse notices and changes to this privacy policy. .
To communicate with you about your account and provide customer support to execute our contract with you for the use of the Service or where we have not entered into a contract with you, based on our legitimate interests in administering and supporting our Service. For example, if you use our Mobile Apps, we can ask if you want to receive push notifications about activities in your account. If you have chosen to receive these push notifications and no longer wish to receive them, you can disable them through the operating system.
To ensure compliance with our Standard Terms of Use and applicable law, and to protect the rights and safety of our Members based on our legitimate interest in protecting against the misuse or abuse of our Service and to seek remedies available. This can include developing tools and algorithms that help us prevent breaches. For example, we sometimes review the content that our Members upload or display to ensure that it complies with our Standard Terms of Use. To improve this process, we have software that helps us find content that may violate our Standard Terms of Use. We may, or our third party service provider, also review the content that our Members send or display. This benefits all Members who comply with our Standard Terms of Use, as it reduces abuse and helps us maintain a reliable platform. Do not use Mailchimp to send or display confidential information.

To meet legal requirements, including compliance with court orders, valid discovery requests, valid subpoenas and other appropriate legal mechanisms.
To provide information to representatives and consultants, including lawyers and accountants, to help us comply with legal, accounting or security requirements based on our legitimate interests.
To sue and defend a court, arbitration or similar legal procedure.
To respond to legal requests from public authorities, including to comply with national security or law enforcement requirements.
To provide, support and improve the service to perform our contract with you for the use of the service or where we do not enter into a contract with you, based on our legitimate interests in administering and improving the service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your personal information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For more information on how we share your information, see Section 5 below.
To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience based on our legitimate interests in administering the Service and providing certain features. This includes adding features that compare members' email campaigns, using data to suggest other publishers your Contacts might be interested in, or using data to recommend products or services that you may be interested in or that may be relevant to you or your Contacts. Some of these suggestions are generated by analyzing the data used in our data analysis projects, as described below.

To undertake data analysis projects based on our legitimate business interests in improving and enhancing our products and services for our members. Our data analysis projects use data from Mailchimp accounts, including personal contact information, to provide and improve the service. We use information such as your shipping habits and purchase history from your Contacts, so that we can make more informed forecasts, decisions and products for our members. For example, we use data from Mailchimp accounts to enable product recommendation, audience segmentation and forecasted demographic features for our members. If you or your contact prefers not to have your data used for this purpose, you can change your account settings (as described here) to disable data analysis projects or your contact can disable data analysis projects a any time by sending us an email to personaldatarequests@mailchimp.com. As always, we take the privacy of Personal Information seriously and will continue to implement adequate safeguards to protect that Personal Information from misuse or unauthorized disclosure.
To personalize the Service, content and advertisements we serve you based on our legitimate interests in supporting our marketing activities and providing certain features within the Service. We may use your personal information to serve you specifically, such as to provide you with marketing information, product recommendations and non-transactional communications (for example, email, telemarketing calls, SMS or push notifications) about us, according to your preferences of marketing and this Privacy Policy.

C. Third party integrations
We may use the Personal Information we collect or receive through the Service, as a processor and as otherwise stated in this privacy policy, to allow you to use the integrations and plug-ins you choose to connect to your Mailchimp account. For example, if you choose to connect a Google integration to your Mailchimp account, we will ask you to grant us permission to view and / or download, as applicable, your Google Sheets, Google Contacts, Google Analytics and Google Drive. This allows us to configure your Google integration (s) according to your preferences. For example, if you want to use the Google Contacts integration to share the templates in your Mailchimp account with the contacts in your Google address book, we will need to access your Google Contacts to share your templates.

D. Cookies and tracking technologies
We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service (as discussed above), and this may include the use of cookies and similar tracking technologies, such as pixels, web beacons and whether you use our Mobile Apps, through our SDKs deployed on your mobile device. For example, we use web beacons in the emails we send on your behalf, which allows us to track certain behaviors, such as whether the email sent by the Service was delivered and opened and whether links in the email were clicked. Both web beacons and SDKs allow us to collect information such as the recipient's IP address, browser, type of email client and other similar data, as described in the details above. We use this information to measure the performance of your email campaigns, to provide analytical information, to increase the effectiveness of our service and for other purposes described above. Reports are also available to us when we email you so that we can collect and review this information.

Our use of cookies and other tracking technologies are discussed in more detail in our Cookie Statement available here.

E. Member distribution lists
To send an email campaign or use certain features in your account, you need to upload a Distribution List that provides us with information about your Contacts, such as your names and email addresses. We use and process this information to provide the Service in accordance with our agreement with you or your organization and this privacy policy.

A Distribution List can be created in a number of ways, including by importing Contacts, such as through a CSV or directly from your email client. We do not, under any circumstances, sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we can contact that person. You can export (download) your Mailchimp distribution lists by accessing your account's “Public” tab.

If we detect abusive or illegal behavior related to your Distribution List, we may share your Distribution List or parts of it with the affected ISPs or anti-spam organizations to the extent permitted or required by applicable law.

If a contact chooses to use the Forward to a Friend (FTF) link in an email campaign sent by a member, this will allow the contact to share the member's email content with individuals who are not on the distribution list of the member. When a contact forwards an email to a friend, we do not store the contact's email address or your friend's email address and no one is added to any distribution list as a result of the FTF link. The Member who created the email campaign sees only an aggregate number of times that their email campaign has been forwarded by a Contact and does not have access to the email addresses used to share or receive this forwarded content.

F. Your data protection rights
Depending on the country in which you reside, you may have the following data protection rights:

Access; correct; update; door; delete; restrict; or object to our processing of your personal information.
You can manage your individual account and profile settings in the panel provided via the Mailchimp platform, or you can contact us directly by email at personaldatarequests@mailchimp.com. You can also manage information about your contacts in the panel provided through the Mailchimp platform to help you respond to requests for access, correction, updating, portability or deletion of information you receive from your contacts. Please note that if any of your contacts wishes to exercise any of these rights, they must contact you directly or contact us as described in the “Privacy for Contacts” section below. You can also contact us at any time to update your marketing preferences (see Section 5. General information, C. Your options and opt-out options below). Mailchimp takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date.
The right to complain to a data protection authority about the collection and use of personal information. For more information, contact your local data protection authority. Contact details for data protection authorities in the EEA and the UK are available here, and Switzerland is also available here.
Likewise, if Personal Information is collected or processed based on consent, the data subject can withdraw his consent at any time. The withdrawal of your consent will not affect the legality of any processing carried out prior to your withdrawal, nor will it affect the processing of your Personal Information conducted based on legal processing reasons other than consent. If you receive such requests from Contacts, you can segment your lists on the Mailchimp platform to ensure that you market only to Contacts who have not opted to receive such marketing.
We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity to help us respond efficiently to your request. If we receive a request from one of your contacts, we will direct the contact to contact you or, if appropriate, respond directly to the request.

3. Privacy for contacts
This section applies to information that we process about our members' contacts as a data controller. Our service is intended for the use of our members. As a result, for much of the Personal Information that we collect and process about Contacts through the Service, we act as a processor on behalf of our Members. Mailchimp is not responsible for the privacy or security practices of our members, which may differ from those set out in this privacy policy. Please check with individual Members about the policies they have in place. For the purposes of this section, "you" and "your" refer to Contacts.

A. Information we collect
The Personal Information that we may collect or receive about you broadly falls into the following categories:

(i) Information we receive about our Members' Contacts: A Member may provide us with Personal Information about you through the Service. When a member uploads his distribution list or integrates the service with another website or service (for example, when a member chooses to connect his e-commerce account with Mailchimp), or when you sign up for a member distribution list on a Mailchimp or other registration form, the member may provide us with certain contact information or other personal information about you, such as your name, email address, address or telephone number. You may have the opportunity to update some of this information by choosing to update or manage your preferences through an email you receive from a Member.

(ii) Information we collect automatically: When you interact with an email campaign that you receive from a member or browse or purchase from a member's connected store, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies are discussed further below and in more detail in our Cookie Statement available here.

Device information: We collect information about the device and the applications you use to access email sent through our Service, such as your IP address, your operating system, your browser ID and other information about your system and connection.
Usage data: It is important for us to guarantee the security and reliability of the Service we provide. Therefore, we also collect usage data about your interactions with campaigns (and / or emails) sent through the Service, which may include dates and times when you access the campaigns (and / or emails) and your email activities. browsing (such as which pages are viewed and which emails are opened). This information also allows us to ensure compliance with our Standard Terms of Use and Acceptable Use Policy, to monitor and prevent abuse of the service and to ensure that we meet certain usage standards and metrics in relation to our Service. We also collect information about the performance of the Service, including metrics related to the ability to deliver emails and other electronic communications that our Members send through the Service. This information allows us to improve the content and operation of the Service and facilitate research and conduct analysis on the use and performance of the Service.

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third party sources, such as social media platforms and third party data providers.

B. Use of personal information
We may use the personal information that we collect or receive about you based on our (and, where applicable, from our members) legitimate interests for the following purposes:

To ensure compliance with our Standard Terms of Use and applicable law. This may include using usage data and developing tools and algorithms that help us to prevent breaches.
To protect the rights and security of Members, third parties or Mailchimp. For example, we sometimes review the content of our members' email campaigns to make sure that they comply with our Standard Terms of Use. To improve this process, we have software that helps us find email campaigns that may violate our Standard Terms of Use. We, or our third-party service provider, may review these specific email campaigns, which may include your contact information. This reduces the amount of spam sent through our servers and helps us maintain high delivery capacity.
To meet legal requirements, including compliance with court orders, valid discovery requests, valid subpoenas and other appropriate legal mechanisms.
To provide information to representatives and consultants, including lawyers and accountants, to help us comply with legal, accounting or security requirements.
To sue and defend a court, arbitration or similar legal procedure.
To respond to legal requests from public authorities, including to comply with national security or law enforcement requirements.
To provide, support and improve the Service. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to our Members. When we share personal information with third parties, we take steps to protect your information in a manner that is consistent with applicable privacy laws. For more information on how we share information, see Section 5 below.

To carry out data analysis projects. Our data analysis projects use data from Mailchimp accounts, including your personal information, to provide and improve the service. We use information, such as your purchase history, provided to us by Members, so that we can make more informed forecasts, decisions and products for our Members. For example, we use data from Mailchimp accounts to enable product recommendation, audience segmentation and forecasted demographic features for our members. If you prefer that your data is not used in this way, you can cancel your data analysis projects at any time by filling out this form or sending us an email to personaldatarequests@mailchimp.com.
For other commercial purposes. For other legitimate business purposes, as well as other legal purposes about which we will notify you.
C. Cookies and tracking technologies
We and our third-party partners may use various technologies to automatically collect and store certain devices and usage information (as discussed above) when you interact with a member's email or connected store campaign, which may include the use of cookies and similar tracking technologies, such as pixels and web beacons, or if a member is using our mobile app, we may collect this information through our SDKs deployed on our member mobile devices. For example, we use web beacons in the emails we send on behalf of our members. When you receive and engage with a member's campaign, web beacons track certain behaviors, such as whether the email sent through the Mailchimp platform was delivered and opened and whether the links in the email were clicked. Both web beacons and SDKs allow us to collect information such as your IP address, browser, type of email client and other similar data, as described above. We use this information to measure the performance of our members' email campaigns and to provide analytical information and improve the effectiveness of our service, and for the other purposes described above.

Our use of cookies and other tracking technologies are discussed in more detail in our Cookie Statement available here.

D. Your data protection rights
Depending on the country in which you reside, you may have the following data protection rights:

Access; correct; update; door; delete; restrict or oppose our processing of your personal information.
For more information on how you can exercise these rights, see our Data Subject Requests form. You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, contact your local data protection authority. The contact details of the EEA data protection authorities are available here.
As described above, for much of the Personal Information that we collect and process about Contacts through the Service, we act as a processor on behalf of our Members. In such cases, if you are a contact and wish to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your personal information is treated by Mailchimp as a processor on behalf of our individual members , you should contact the relevant Member who is using the Mailchimp Service and consult their separate privacy policies.

If you no longer wish to be contacted by one of our Members through our Service, unsubscribe directly from that Member's newsletter or contact the Member directly to update or delete your data. If you contact us directly, we can forward your request to the Member in question or provide the Member's identity so that you can contact him directly.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity to help us respond efficiently to your request.

4. Privacy for visitors
This section applies to the personal information we collect and process when you visit Mailchimp websites and in the normal course of our business, such as in connection with our recruitment, events, sales and marketing activities or when you visit our offices. In this section, "you" and "yours" refer to visitors.

A. Information we collect
(i) Information you provide to us on the Mailchimp sites or otherwise: Our Mailchimp sites offer several ways to contact us, such as submitting forms, email or phone, to ask about our company and service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, participate in surveys, sign up for marketing, apply for a role at Mailchimp or contact us. We may also collect your personal information in person when you attend our events or fairs, if you visit our offices (where you will be required to register as a visitor and provide us with certain information that may also be shared with our service providers) or by telephone with one of our sales representatives. You can choose to provide additional information when you communicate with or interact with us, and we may keep copies of such communications for our records.

The personal information we collect may include:

Business contact information (such as your name, phone number, email address and country);
Professional information (such as position, institution or company);
Nature of your communication;
Marketing information (such as your contact preferences); and
Any information you decide to provide to us by filling in any “free text” boxes on our forms.
(ii) Information we collect automatically through the Mailchimp Sites: When you visit our Mailchimp Sites or interact with our emails, we use cookies and similar technologies, such as pixels or web beacons, either alone or in conjunction with cookies, to collect certain information automatically from your browser or device. In some countries, including EEA countries, this information may be considered Personal Information in accordance with applicable data protection laws. Our use of cookies and other tracking technologies are discussed further below and in more detail in our Cookie Statement available here.

The information we collect automatically includes:

Device information: such as your IP address, browser, device information, unique device identifiers, mobile network information, requested information (speed, frequency, the website from which you linked us (“reference page”), the name of the site you choose to visit immediately after ours (called an "exit page"), information about other sites you have recently visited and the web browser you used (software used to surf the Internet) including your type and language)
Usage data: such as information about how you interact with our emails, Mailchimp sites and other sites (such as the pages and files viewed, surveys, operating system and system configuration information and timestamps associated with your use) .
B. Use of personal information
We may use the information we collect through our Mailchimp sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a number of reasons, depending on our legitimate interests, including:

To provide, operate, optimize and maintain Mailchimp sites.
To send you marketing information, product recommendations and non-transactional communications (for example, email, telemarketing calls, SMS or push notifications) about us, according to your marketing preferences, including information about our products, services , promotions or events, as necessary for our legitimate interest in conducting direct marketing or to the extent that you have given your prior consent.
For recruitment purposes, if you signed up for a role at Mailchimp.
To answer your questions and requests online, and to provide you with information and access to resources or services that you have requested from us.
Manage Mailchimp sites and system administration and security.
To manage registration and participation in events, including sending communications related to you.
To register visitors to our offices for security reasons and to manage non-disclosure agreements that visitors may be required to sign.
To improve the navigation and content of the Mailchimp sites.
To identify any server problems or other IT or network problems.
To process transactions and set up online accounts.
To compile aggregate statistics on the use of the website and to better understand the preferences of our visitors.
To help us provide, improve and personalize our marketing activities.
To facilitate the security and the smooth running of the Mailchimp Sites.
Conduct research and development to improve our Mailchimp sites, products and services.

To conduct marketing research, advertise for you, provide personalized information about us on and off our Mailchimp Sites and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or cases where we ask for your consent.
To carry out other legitimate business purposes, as well as other legal purposes, such as data analysis, monitoring and fraud prevention, identifying usage trends and expanding our business activities based on our legitimate interests.
To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to the extent that this requires the processing or disclosure of personal information to protect our rights or is necessary for our legitimate interest in protecting against use misuse or abuse of our Mailchimp sites and services, protecting property or personal safety, seeking solutions available to us and limiting our damages, complying with court procedures, court orders or legal processes, or responding to legal requests.
C. Public information and third party websites
Blog. We have public blogs on the Mailchimp sites. Any information you include in a comment on our blog can be read, collected and used by anyone. If your personal information appears on our blogs and you want to remove it, contact us here. If we're unable to remove your information, we'll let you know why.
Social media platforms and widgets. Mailchimp sites include social media features, such as the Facebook Like button. These resources may collect information about your IP address and which page you are visiting on our Mailchimp website, and may set a cookie to ensure that the feature works correctly. Social media features and widgets are either hosted by third parties or directly on our Mailchimp Site. We also maintain a presence on social media platforms, including Facebook, Twitter and Instagram. Any information, communications or materials that you send to us through a social media platform are done at your own risk and without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with these features and platforms are governed by the privacy policies of the companies that provide them.

Links to third party websites. Mailchimp sites include links to other sites, whose privacy practices may differ from ours. If you submit personal information to any of these sites, your information will be governed by their privacy policies. We recommend that you carefully read the privacy policy of any website you visit.
Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes or other promotions on the Mailchimp sites or through social media (collectively, “Promotions”). Participation in our promotions is completely voluntary. The information requested for entry may include personal information, such as your name, address, date of birth, telephone number, e-mail address, username and similar details. We use the information you provide to administer our promotions. We may also, unless prohibited by the rules or laws of the Promotion, use the information provided to communicate with you, or others you select, about our Service. We may share this information with our affiliates and other organizations or service providers in accordance with this privacy policy and the published rules for our promotions.
D. Cookies and tracking technologies
We use cookies and similar tracking technologies to collect and use personal information about you, including to serve interest-based advertising. For more information about the types of cookies and tracking technologies we use, why and how you can control them, see our Cookie Statement available here.

E. Other data protection rights
Depending on the country in which you reside, you may have the following data protection rights:

Access; correct; update; door; delete; restrict or oppose our processing of your personal information. You can exercise these rights by visiting this page or by sending an email to personaldatarequests@mailchimp.com.
You may also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, contact your local data protection authority. The contact details of the EEA data protection authorities are available here.
Likewise, if we collect and process your personal information with your consent, you can withdraw it at any time. The withdrawal of your consent will not affect the legality of any processing carried out prior to your withdrawal, nor will it affect the processing of your Personal Information conducted based on legal processing reasons other than consent. You can also contact us at any time to update your marketing preferences (see Section 5. General information, C. Your options and opt-out options below).

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity to help us respond efficiently to your request.

5. General Information
A. How we share information
We may share and disclose your personal information with our affiliates and the following types of third parties for the purposes described in this privacy policy (for the purposes of this section, "you" and "yours" refer to members, contacts and visitors, the unless otherwise indicated). Our affiliates include Courier Holdings Ltd. located in the United Kingdom. You can learn more about Courier and its privacy practices here.

(i) Our service providers: we sometimes share your information with our third party service providers who work on our behalf for the purposes described in this privacy policy. For example, companies we hire to help us provide and support our Service or assist in the protection and security of our systems and services and other business-related functions.

Other examples include data analysis, data hosting, involving technical support for our Service, payment processing and content delivery.

We use YouTube's API services in connection with our Service to provide certain features. As such, you acknowledge and agree that by signing up for an account and using the Service, you are also subject to Google's Privacy Policy. In addition to the rights set out in Section 2, you can manage your YouTube API data by visiting the Google security settings page at https://security.google.com/settings/security/permissions

In connection with our Service, we also use a third party service provider, Twilio, Inc. We use the Twilio API, which allows us to build resources in our Mailchimp application to allow us to communicate with our Members via text messages and calls, and its “Authy” Product, which we use for two-factor authentication in our application. If you are a member, Twilio may need to collect and process certain personal information about you as a controller to provide such services. To learn more about Twilio's privacy practices, visit https://www.twilio.com/legal/privacy

(ii) Advertising partners: we may partner with third party advertising networks, exchanges and social media platforms (such as Facebook) to display advertising on Mailchimp sites or to manage and serve our advertising on other sites, and we may share personal information Members and Visitors with them for this purpose. We and our third-party partners may use cookies and other similar tracking technologies, such as pixels and web beacons, to collect information about your activities on the Mailchimp and other sites, in order to provide you with targeted advertising based on your browsing activities and interests. For more information, see our Cookie Statement available here.

(iii) Any competent law enforcement agency, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish or defend our rights, or (c) to protect your vital interests or those of any other person.

(iv) A potential buyer (and its agents and consultants) in the event of a sale, merger, consolidation, liquidation, reorganization or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including their rights of access and choice. We will notify you of the change by sending an email or posting a notice on our Mailchimp Site.

(v) Any other person with your consent.

B. Legal basis for processing personal information (only for EEA and UK people)
If you are located in the EEA or the United Kingdom, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information in question and the specific context in which we collect it.

However, we will normally collect and use your personal information when processing is in our legitimate interest and is not nullified by your data protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this privacy policy in the sections above entitled "Use of Personal Information", but generally include improving, maintaining, providing and improving our technology, products and services; ensuring the security of the Service and our Mailchimp Sites; and supporting our marketing activities.

If you are a member, we may need your personal information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect your personal information. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not, as well as the possible consequences if you do not. provide your personal information.

When required by law, we will collect Personal Information only when we have your consent to do so.

If you have questions or need more information about the legal basis on which we collect and use your personal information, please contact us using the contact details provided in the “Questions and concerns” section below.

C. Your choices and opt-outs
Members and visitors who have opted in to receive our marketing emails can opt out of receiving our marketing emails at any time by clicking on the “unsubscribe” link at the bottom of our marketing messages.

In addition, all cancellation requests can be made by sending us an email using the contact details provided in the “Questions and concerns” section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of receiving these messages unless you cancel your Mailchimp account.

D. Our Security
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of Personal Information. For more information about our security practices, see our Security page available here. If you have any questions about the security of your personal information, you can contact us at privacy@mailchimp.com.

Mailchimp accounts require a username and password to login. Members must keep their username and password safe and never disclose it to third parties. Since the information in a member's Mailchimp account is private, the account passwords are hashed, which means that we cannot see a member's password. We also cannot resend forgotten passwords. We will only provide Members with instructions on how to reset them.

E. International transfers
(i) We operate in the United States

Our servers and offices are located in the United States, so your information can be transferred, stored or processed in the United States. While data protection, privacy and other laws in the United States may not be as comprehensive as those in your country, we have taken many steps to protect your privacy, including offering our members a Data Processing Agreement available here.

(ii) Data transfers from Switzerland, the United Kingdom or the EEA to the United States

Mailchimp participates and certifies its compliance with the EU-USA. Structure of Privacy Shield and Swiss-US Structure of Privacy Shield. We are committed to submitting all Personal Information received from EEA member countries, the United Kingdom and Switzerland, respectively, based on each Privacy Shield Framework, to the applicable Principles of each Framework. To learn more about Privacy Shield frameworks and view our certification, visit the United States Department of Commerce's Privacy Shield website, available here.

A list of Privacy Shield participants is maintained by the Department of Commerce and is available here.

Mailchimp is responsible for the processing of the Personal Information we receive under each Privacy Shield Framework and, subsequently, we transfer to a third party acting as an agent on our behalf. We comply with the Privacy Protection Principles for all subsequent transfers of Personal Information in the EEA, United Kingdom and Switzerland, including the subsequent transfer liability provisions.

With respect to personal information received or transferred in accordance with the Privacy Shield frameworks, we are subject to the regulatory powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to legal requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data usage issue that we have not satisfactorily resolved, contact our U.S. dispute resolution provider (free of charge to you) at https://feedback-form.truste.com / watchdog / request. Under certain conditions, described in more detail on the Privacy Shield website, here, you may have the right to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Members located in Switzerland, the United Kingdom and the EEA are subject to our Data Processing Addendum available here, as described in our Standard Terms of Use.

(iii) Members, contacts and visitors located in Australia

If you are a member, contact or visitor who accesses our service in Australia, this section applies to you. We are subject to the application of the Privacy Act 1988 (“Australian Privacy Act”). Here are the specific points you should be aware of:

As stated in our Acceptable Use Policy available here, confidential personal information is not allowed on the Mailchimp platform and Members are prohibited from importing or incorporating any sensitive personal information into their Mailchimp accounts or sending any sensitive personal information to Mailchimp servers.
Please note that if you fail to provide us with your personal information or if you withdraw your consent to collect, use and disclose your personal information, we may be unable to provide the service to you.
When we collect personal information from our visitors, the personal information we ask you to provide will be information reasonably necessary for, or directly related to, one or more of our functions or activities. Please refer to Section 4 of this privacy policy for examples of the types of Personal Information that we may request from Visitors.
When we affirm that we assume an obligation on personal information, we also demand that our contractors and subcontractors assume a similar obligation.
We will not use or disclose personal information for direct marketing purposes to you, unless:
you have consented to receive direct marketing;
you reasonably expect us to use your personal data for marketing purposes; or
we believe that you may be interested in the material, but it is not practical for us to obtain your consent.

You can choose not to receive any marketing material that we send to you through a subscription unsubscribe mechanism. If you have requested that you no longer receive direct marketing messages, we may continue to send messages that are not considered “direct marketing” under the Australian Privacy Act, including changes to our terms, system alerts and other information related to your as permitted by the Australian Privacy Act and Spam Act 2003 (Cth).

Our servers are located in the United States. In addition, we or our subcontractors may use cloud technology to store or process personal information, which may result in data being stored outside Australia. It is not feasible to specify in advance which country will have jurisdiction over this type of offshore activity. All of our subcontractors, however, are required to comply with Australia's Privacy Act regarding the transfer or storage of Personal Information abroad.
We may also share your personal information outside Australia with our business operations in other countries. While it is not feasible for us to specify in advance each country where your personal information may be disclosed, we can normally disclose your personal information to the United States, Canada and the European Union.
You can access the personal information we hold about you. If you wish to access your personal information, you can do so by visiting this page or by sending an email to personaldatarequests@mailchimp.com. We will respond to all requests for access within a reasonable time.
If you believe that the information we hold about you is inaccurate, outdated, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information at your request. If you feel that the information we have is not up to date, is inaccurate or incomplete, please contact us in writing at dpo@mailchimp.com, so that we can update our records. We will respond to all requests for correction within a reasonable time.

If you are not satisfied with our response to a privacy question, you can consult an independent consultant or contact the Office of the Australian Information Commissioner for further assistance. We will provide our full cooperation if you follow this course of action.

F. Data retention
We retain personal information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but we will generally refer to these criteria to determine the retention period:

Whether we have a legal or contractual need to retain data.
Whether data is needed to provide our service.
Whether our members have the ability to access and delete data from their Mailchimp accounts.
If our members would reasonably expect that we would retain data until they removed it or until their Mailchimp accounts were closed or closed.
When there is no legitimate business need in progress to process your personal information, we will delete or make it anonymous or, if this is not possible (for example, because your personal information has been stored in backup files), we will securely store your information. Personal information and isolate it from any further processing until deletion is possible.

G. California Privacy
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights to their Personal Information. You have the right to request that companies subject to the CCPA (which may include our Members with whom you have a relationship) disclose certain information to you about the collection and use of your Personal Information in the past 12 months. In addition, you have the right to ask these companies to delete your collected personal information, subject to certain exceptions. If the company sells Personal Information, you have the right to cancel that sale. Finally, a company cannot discriminate against you for exercising a CCPA right.

In offering services to its members, Mailchimp acts as a "service provider" under the CCPA and our receipt and collection of any personal consumer information is completed on behalf of our members so that we can provide the service. Forward all requests for access or deletion of your Personal Information under the CCPA to the Member with whom you have a direct relationship.

Under California law, if you choose to exercise your applicable CCPA rights, we will not charge you different prices or provide services of different quality. If we ever offer a financial incentive or product improvement that depends on the provision of your personal information, we will not do so unless the benefits to you are reasonably related to the value of the personal information you provide to us.

H. Do not track
Certain state laws require us to indicate whether we respect the "Do not track" settings in your browser. Mailchimp adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

I. Changes to this Policy
We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the date of the version located at the top of this privacy policy. All updates and changes take effect immediately after notification, which we can provide by any means, including, but not limited to, posting a revised version of this privacy policy or other notice on the Mailchimp sites. We encourage you to review this privacy policy frequently to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are considered to be the true, complete, valid, authentic and applicable copy of the version of this privacy policy that was in effect on each respective date on which you visited the Mailchimp Site.

J. Questions and concerns
If you have any questions or comments, or if you have any questions about how we handle any privacy issue, please use our contact form to send us a message. You can also contact us by mail or email at:

For residents of the EEA, Switzerland and the United Kingdom:

For the purposes of EU data protection legislation, The Rocket Science Group LLC d / b / a Mailchimp is the controller of your personal information. Our data protection officer can be reached at dpo@mailchimp.com.

For any other residents:

The Rocket Science Group LLC d / b / a Mailchimp
Attn. Privacy Officer
privacy@mailchimp.com
675 Ponce de Leon Ave NE, Suite 5000
Atlanta, GA 30308 USA

E-commerce Terms and Conditions at Nawa Institute

Simply called Instituto Nawa, and, on the other hand, the customer Instituto Nawa, qualified at the time of purchase of Instituto Nawa products, hereinafter simply called Customer.

Whereas Instituto Nawa sells products and services over the internet; Considering the Client's interest in purchasing the products offered by Instituto Nawa (“Products”) in its sales channels; The purpose of this contract is to establish the general conditions of use and purchase of products and services from the client on the Instituto Nawa website.

I. Confidentiality: Instituto Nawa is responsible for preserving the confidentiality of all data and information provided by the Client in the purchase process. The security of the website is audited daily and is guaranteed against the action of hackers, through the seal "Site Blindado".

II. Customer Service (SAC): The customer has this service to answer their doubts, resolve any requests or complaints regarding their order or any content available on the website. The SAC may be activated by telephone or form on the website.

III. Delivery policy: the deadline for delivery of the Products is informed during the purchase procedure, counted in working days. Products are delivered from Monday to Friday, from 8 am to 10 pm. Exceptionally, some deliveries of Products may occur on Saturdays, Sundays and holidays.

III.I - The checking of the adequacy of the dimensions of the product is the responsibility of the Customer, who must ensure that they are in accordance with the spatial limits of the elevators, doors and corridors at the place of delivery. Product assembly or disassembly, transportation by stairs and / or doors and windows, or lifting of deliveries will not be carried out.

III.II - Up to three delivery attempts will be made at the informed location, on alternate days, with an interval of up to 48 hours between one delivery and another. It is essential that, at the requested address, there is a person authorized by the buyer, over 18 years old, and carrying an identification document to receive the goods and sign the delivery protocol. If there are three unsuccessful delivery attempts, the order will be returned to the Nawa Institute Distribution Center.

III.III - After completing the order, it is not possible to change the form of payment and / or delivery address, request an advance or even priority of delivery.

III.IV - The delivery period informed during the product purchase procedure takes into account the stock, the region, the invoice issuing process and the product preparation time. With each update in the order's delivery status, Instituto Nawa's system automatically sends alert emails to the Customer.

III.V - The value of the delivery freight is calculated based on the delivery location, weight and dimensions of the Product.

III.VI - Instituto Nawa does not authorize the carrier to: enter the home; deliver by alternative means (example: hoisting product by window); perform installation or maintenance of products; open the product packaging; deliver to an address other than that stated in DANFE; delivery to minors or without identification document.

III.VII - Instituto Nawa is not responsible for the retention of goods at SEFAZ when this is due exclusively to the customer's pending items, therefore, it is necessary to appear at the tax post for the goods to be released, considering that in these cases the information regarding releases and payments is only passed on to interested parties.

IV. Right of regret: the Customer will be entitled to exercise the right to regret the purchase, with the purpose of returning the Product, in which case the following conditions must be observed: the deadline for withdrawing the purchase of the product is up to 7 (seven) calendar days from the date of receipt; in case of return, the product must be returned to Instituto Nawa in the original packaging, accompanied by the DANFE (Auxiliary Document of the Electronic Invoice), the manual and all its accessories.

IV.I - The Customer must request the return through the Customer Service (SAC) or directly on the Control Panel, in the topic “cancel order”. Expenses arising from the collection or postage of the Product will be borne by Instituto Nawa.

IV.II - After the product arrives at the Distribution Center, Instituto Nawa will check if the above conditions have been met. If so, it will provide a refund for the total purchase price.

IV.III - In purchases with a credit card, the card administrator will be notified and the chargeback will occur on the next or subsequent invoice, at once, regardless of the number of installments used in the purchase. The reimbursement period and, still, the collection of the remaining installments after the full refund of the Product value on the Client's credit card carried out by Instituto Nawa, is the responsibility of the card administrator. In the event of collection of future installments by the card administrator, the Customer will not be encumbered, since Instituto Nawa, as mentioned above, reverses the full value of the Product in one single payment, with the credit referring to the reversal being granted in full by card administrator on the billing invoice subsequent to the month of cancellation.

IV.IV - In purchases paid by bank slip or debit, the refund will be made through bank deposit, within 10 (ten) business days, only in the current account of the buyer, which must be individual. It is necessary that the CPF of the current account holder.