Privacy Policy

Informations you will find in this privacy policy:

  1. Definitions;
  2. Introduction;
  3. The data we collect about you;
  4. How is your personal data collected;
  5. How we use your personal data;
  6. Data subject rights;
  7. Data retention;
  8. Security;
  9. International data transfers;
  10. General

(The present Privacy Policy has been last updated in 24/01/2022)

  1. DEFINITIONS
  • SSD is the acronym used to refer to the company Sexo sem Dúvida (SSD Sexologia Online Ltda ME)
  • User: refers to all the visitants of our platform which might have bought some of our products, ebooks or online courses, or subscribe to receive our content.
  • Online Platform/Platform: are all websites of Sexo Sem Dúvida (SSD Sexologia Online Ltda ME) which users can access, order content, and buy our products and services.
  • Partner Sites/Partners: are the third party sites or services which we may share your data with. Please note that we will only share your data with your consent, except for cases listed in this privacy policy.
  • Anonymised Data: refers to the data which is manipulated to turn personal data in not identifiable data.
  • Personal data, or personal information: means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymised data).
  • Special Personal Data: refers to data which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
  • Cookie: is a small piece of data that is stored on your computer or mobile device. When you use the platform, we send one or more cookies to your computer that uniquely identifies your browser. Cookies help you log in faster and enhance your navigation through the site.
  • Log File Information: Log file information is automatically reported by your browser each time you access a web page. When you use our platform, our servers automatically record certain log file information. These server logs may collect Technical Data such as your IP address, browser type, and information about the number of clicks and how you interact with links on the platform, partner sites, domain names, landing pages, pages viewed, and other such information.
  1. INTRODUCTION

Thank you for choosing us!

Sexo Sem Dúvida website offers an online sexual health platform where users can find/have access to content about sexuality, ebooks, online courses and newsletters.

By using our platform, ordering content by our website or buying our services or products you understand and agree to the terms of this Privacy Policy.

Since our content is focused for adults and it is related to sexuality and sexual health, this website is not intended for visiting by any person under the age of 18.

We do not knowingly collect personal information from people under 18 or knowingly allow such persons to get access to our content. In the event that we learn that we have collected personal information from a person under the age of 18, we will delete it. If you believe that we might have collected personal information from a person under 18, please contact using the information below. In this case, if you are under age you must not subscribe or access this website.

This Privacy Policy only applies to the information we collect when you get access to our content or view the comments and does not apply to any other website linked to from ours. We are not responsible for the practices employed by websites linked to or from our platform or the information or content contained thereon.

Please remember that when you use a link to go from our platform to another website, our Privacy Policy is no longer applicable. Your browsing activity and interaction with any other website, including those that you link to from our website, is subject to that website’s privacy policy.

  1. THE DATA WE COLLECT ABOUT YOU

In order to prosecute our services and our platform, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes first name, last name, username or similar identifier, and date of birth.
  • Contact Data: includes email address and mailing address.
  • Technical Data: includes internet protocol (IP) address, unique Cookie ID, Device ID, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, accessed pages, clicks, operating system and platform, and other technology on the devices you use to access the platform.

We also might collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

Because we understand the importance of our users’ privacy, we give our best to not collect any special categories of Personal Data about you that is not necessary for prosecute our services. However, we might collect Personal Data about your sex life or sexual orientation if you subscribe for receiving our content or buy our products, ebooks or online courses, since we can have access to the content you have received or bought.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the services but we will notify you if this is the case at the time.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions: This includes personal data you provide when you:

  • Subscribe to receive content;
  • Buy products, ebooks or online courses.
  • Leave a comment;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.

Automated technologies or interactions: As you interact with our platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, log file information and other similar technologies.

We also use cookies to collect Technical Data and information about how you use the platform and Partner Sites (e.g., the pages you view, the links you click and other actions you take). We may use both persistent cookies, which remain on your hard drive after you close your browser, and session cookies which terminate when you close your browser. Many browser settings can be set to decline cookies or alert you when a website is attempting to place a cookie.

If you have questions about such functionalities, you should consult with your browser’s manufacturer. However, some features of the platform may not function properly if the ability to accept cookies is disabled.

  1. HOW WE USE YOUR PERSONAL DATA

Sexo Sem Dúvida platform uses the data collected for the following purposes:

  • Service Improvement: The information we collect may be used to customize and improve the content and / or service offered to the user. The greater knowledge about the user will enable a personalized and efficient service, including making navigation easier.
  • Transparency reports: we may use your data for the preparation of an impact report on the protection of personal data, which may be requested by the national authority, for transparency vis-à-vis the competent government bodies.
  • Security and Service: We use the information obtained to promote greater security and integrity for our platform. For example, we may use your personal data to assess harmful conduct and / or violations of the Terms of Use and Privacy Policy, as well as to detect user needs and provide technical support whenever necessary.
  • Online shopping: Some data may be provided to partner sites that provide the online transaction service and purchase with your credit card. In this case, you may need to share your data with the selected partner site. We require such websites to use the data strictly provided to provide the specific service. The data is sent in an encrypted form and used only at the time of the transaction.

We may have to share your personal data with our partner sites set out below for the only purpose of prosecute our activity:

  • Google Analytics: Google Analytics is an analytic service prosecuted by Google, Inc. Google Analytics uses “cookies”, which are text archives located in this website in order to help Sexo sem Dúvida platform to analyse the users utilization of this platform. This information will be directly transmitted and filed by Google on their servers in the United States.
  • Email marketing: The Active Campaign and Mailchimp are the marketing platforms we might use in order to realize their email marketing services to SSD. For more information: https://www.activecampaign.com/ and https://mailchimp.com/.
  • Hosting: DigitalOcean, LLC, located in the United States. For more information: https://www.digitalocean.com/. Digital Ocean has access to your data in order to realize their hosting services to SSD.
  • Payment: Hotmart is the platform which can use your data in order to realize its payment services to SSD. For more information: https://www.hotmart.com/.
  • Analysis: Hotjar is the platform which can use your data in order to realize their service of user navegability analysis. For more information, see: https://www.hotjar.com.
  • Social Media: Facebook uses pixel in order to analyze metrics and optimize advertising. For more information, see: https://facebook.com.

Sexo sem Dúvida (SSD Sexologia Online Ltda ME) may choose, if we understand that it is the best choice, to sell, transfer, or merge parts of our business or our assets for third parties. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all partner sites to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

However, we might have to use or share your personal data for purposes not included above in the following circumstances:

  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please email us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data.

In addition to the above, we may access, preserve, and disclose your personal data, including your Identity, Contact, or Technical data, if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order, government request, or subpoena, or to meet national security or law enforcement requirements. We may also access, preserve, and disclose such personal data if we believe in good faith that disclosure is necessary to protect yours’, ours’ or others’ rights, property, or safety, or to investigate fraud.

  1. DATA SUBJECT RIGHTS

Since we understand the importance of respecting personal data, we ensure some rights for all our users, which are listed below:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of the personal data that we hold about you. Request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  1. if you want us to establish the data’s accuracy;
  2. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
  3. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time.

Besides that, there are some others possibilities you can use related to your data protection:

  • Opting Out of Our Newsletters and Promotional Emails: You may opt-out of Newsletters and promotional emails from us at any time by using the opt-out mechanism contained in such emails (also referred to as “unsubscribe”). You may also unsubscribe or manage your email subscription by emailing us at [email protected]. Besides, you can unsubscribe by clicking in the option “unsubscribe” which will appear in every email we send. Please note, unsubscribing from SSD emails will unsubscribe you from SSD notification emails and SSD newsletter.
  • Declining Cookies: If you do not want to accept our cookies, you can adjust your browser settings to decline cookies. You should note, however, that certain areas of the Site may not operate properly if you decide not to accept cookies.

If you wish to exercise any of the above rights please send us an email to [email protected]. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. DATA RETENTION.

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  1. SECURITY.

SSD uses commercially reasonable safeguards to preserve the integrity and security of all information collected through content selling.

To protect your privacy and security, we take reasonable steps to verify your identity before granting you access to your product.

You are responsible for maintaining the secrecy of your account for controlling access to your email communications from SSD. Notwithstanding the foregoing measures, SSD cannot ensure or warrant the security of any information you transmit to SSD or guarantee that information in our platform may not be accessed, disclosed, altered, or destroyed. SSD is not responsible for the functionality or security measures of any third party.

  1. INTERNATIONAL DATA TRANSFERS.

For users based in the European Economic Area (EEA) we may share your personal data within the SSD or with external third parties. This may involve transferring your data outside the EEA.

Whenever we transfer your personal data out of the EEA, a similar degree of protection is afforded to it by ensuring at least one of the following safeguards:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. GENERAL

Change of Purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Changes to Privacy Policy: SSD may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the bottom of this page. If you have bought our products or subscribed to receive our content we will notify you of the change by email. Your continued use of the platform following the posting of any changes to this policy means you accept such changes.

If you have any questions about this Privacy Policy, please email us at [email protected]. 

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. ADVERTISING POLICY .

In order to give you an even better experience, we can provide you some personalized advertisings. Advertising allows SSD to support and improve our services. SSD uses, and also engages third party partners and affiliates who use, cookie IDs, device IDs (including mobile), hashed email addresses, IP address, ISP and browser information, demographic or interest data, content viewed and actions taken on the website or Partner Sites,  including information about the websites you’ve viewed and advertisements you’ve interacted in order to provide you with more relevant advertising targeted to your preferences and interests derived from your interaction with the platform, partner sites or other third party websites.

To learn more about this type of targeted advertising (also called interest-based advertising), analytics services and your choices, please visit the DAA Consumer Opt-Out Page, NAI Consumer Opt-Out Page, and Google’s information page. 

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