Privacy Policy

We at FutManager are constantly committed to respecting the privacy of our users and to demonstrating how their Personal Data is Processed within our Platform.


We have prepared this document to explain how we Process your Personal Data. If you still have any questions, you may contact us at [email protected], and we will be pleased to answer them. It is very important that you read this document carefully and, to facilitate your reading, we have prepared this table of contents that will take you directly to the topics of greatest interest to you.


Let's get started!


Table of Contents
  • 1. DEFINITIONS
  • 2. INFORMATION WE COLLECT
  • 3. DATA SHARING
  • 4. PROCESSING OF PERSONAL DATA
  • 5. PROTECTION AND SECURITY
  • 6. RIGHTS OF DATA SUBJECTS
  • 7. RETENTION AND DELETION OF PERSONAL DATA
  • 8. UPDATES TO THE PRIVACY POLICY
  • 9. ANTIBOT PROTECTION

1. DEFINITIONS

First, we will present the definitions of certain terms that will appear throughout this document.

1.1 - PERSONAL DATA: information relating to an identified or identifiable natural person;

1.2 – SENSITIVE PERSONAL DATA: Personal Data concerning racial or ethnic origin, religious belief, political opinion, membership in a trade union or in a religious, philosophical, or political organization, data concerning health or sex life, genetic data, or biometric data, when linked to a natural person;

1.3 – DATA SUBJECT: the natural person to whom the Personal Data that is the subject of Processing relates;

1.4 – PROCESSING: any operation performed on Personal Data, such as those relating to collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction;

1.5 – ANONYMIZATION: the use of reasonable technical means available at the time of Processing through which data loses the possibility of association, directly or indirectly, with an individual;

1.6 – CONSENT: a free, informed, and unambiguous manifestation by which the Data Subject agrees to the Processing of their Personal Data for a specified purpose;

2. INFORMATION WE COLLECT

Now that you know what we are referring to, we will explain which of your Personal Data we collect, noting that we only work with information that is essential for the purposes of our Platform, it being understood that other information may be collected and Processed pursuant to legal requirements applicable to our services.

2.1 - Data Provided by the User:

a) Platform Registration Data: name, email address, and telephone number.
To verify such information provided directly by you, we may request that you submit photographs of the document(s) containing the information mentioned above.

2.2 - Data Collected by the Platform:

a) Location Data: We do not collect information of this nature.

b) User Profile: When you use the Platform, we will collect information about how you use our Platform, such as most frequently accessed pages, dates and times of access, application failures, and other information related to your use. Such information will be collected for the purpose of ensuring the ongoing quality of the features available on the Platform.

c) Transaction Data: Payment transactions for use of the Platform will be processed through PagSeguro or PayPal, and FutManager assumes no responsibility whatsoever for such transactions, nor does it collect data of this nature.

d) Electronic Device Data: When using the FutManager Platform, minimum data will be collected in accordance with Brazilian law, such as actions taken within the Platform, IP address, date, and time. Such information will be collected for the purpose of complying with Law No. 12.965/2014, known as the Brazilian Internet Civil Framework (Marco Civil da Internet).

e) Our Platform uses Google Analytics for the collection and Processing of Data, in accordance with Google's policies. The uses of data carried out by Google or its partners are the sole and exclusive responsibility of Google, and FutManager assumes no liability arising from such use.

3. DATA SHARING

Now that you know what types of information we collect, you may have a question: “Will FutManager share my data with any other person and/or company?” In this section, we will answer that question.

As we stated at the outset, our users' privacy is a constant concern. Accordingly, we will not share your data with third parties, except in the circumstances set forth below. It is important to note that, in such cases, whenever the security of the information depends on FutManager, we undertake to use our best efforts to keep your data fully secure.

a) Sharing pursuant to the Data Subject's Consent: your data will be shared whenever you expressly request and/or authorize us to carry out such operation;

b) Sharing with public authorities and public entities: we may share your data with public authorities and public entities to comply with any legal and/or regulatory obligations imposed on the services we provide, as well as to comply with any judicial orders that may be imposed;

c) Sharing with law enforcement authorities: we may share your Personal Data and other information we deem necessary if, at FutManager's discretion, there is suspicion of the commission of any act considered a crime or misdemeanor under applicable law. In such case, the existence of a legal and/or regulatory obligation, as well as of a judicial order, is expressly dispensed with;

d) Sharing with service providers and business partners: we may share your Personal Data with service providers and business partners, such as companies that operate as payment processors.

4. PROCESSING OF PERSONAL DATA

We Process the data you provide to us for the purpose of offering you a personalized and efficient experience in our services. This includes, but is not limited to, improving our products and services, providing customer support, performing data analysis to enhance our processes, and customizing the content you see on our platforms.

In addition, we Process your data to fulfill contractual obligations, such as providing access to our services as agreed in our Terms of Service, as well as to comply with legal obligations, such as fraud prevention and compliance with applicable regulations.

We understand the importance of your privacy and data security and undertake to use your data only for the purposes set forth in this policy, strictly adhering to the data protection principles established by applicable privacy laws.

5. PROTECTION AND SECURITY

Now that you understand what data we collect and under what circumstances we will share such information, it is time to explain how we will keep your data protected and secure.

We use state-of-the-art information security systems across all of our systems and devices, which include the use of technological tools such as encryption, access controls, firewalls, account creation and access logs, among others.

It is important to note that we apply these security layers only from the moment your information is received by FutManager and for as long as it is retained by us. Accordingly, we cannot guarantee the security of the electronic device or of the networks you are using to access our Platform.

Although we use our best efforts to protect our users' data, we acknowledge that incidents may occur. Accordingly, if any of your Personal Data is exposed in any manner, we will send you a notice within a reasonable period containing the following information: (i) a description of the nature of the Personal Data affected; (ii) an indication of the technical and security measures used to protect the data; (iii) the risks related to the incident; (iv) the reasons for any delay, in the event the notice was not immediate; and (v) the measures that have been or will be adopted to reverse or mitigate the adverse effects.

6. RIGHTS OF DATA SUBJECTS

As the owner of your own Personal Data, you have several rights that may be exercised at any time by submitting a direct request to FutManager. Below, we explain each of these rights, demonstrating our commitment to transparency:

a) Confirmation of the existence of Processing: you may submit a request to us to confirm whether we are carrying out any type of Processing related to your Personal Data, as well as which data we hold about you;

b) Access to data: in addition to confirming whether we are Processing your Personal Data, you may also request access to all data we hold about you;

c) Correction of incomplete, inaccurate, or outdated data: if you verify that your data is incomplete, incorrect, or outdated on our Platform, you may request that we correct the information;

d) Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully Processed data: if you believe that we are Processing data about you in an excessive manner, you may request that we anonymize, block, or delete such information. With respect to this right, it is important to note that we will first conduct a review to verify whether we truly no longer need the data that was collected;

e) Portability of data to another service or product provider: if you choose to use a Platform that competes with FutManager, you may request that we send all of your information that we hold directly to that new Platform. However, we will preserve any trade secrets and industrial secrets that may be involved in the operations;

f) Deletion of Personal Data Processed with the Data Subject's Consent: if you have provided us with your Consent for the Processing of your Personal Data, you may request the deletion of such data, except where we are required to retain such information under applicable law, in which case we will inform you thereof;

g) Information regarding the public and private entities with which we share your data: you may request from us details regarding which public authorities and/or companies we share your Personal Data with;

h) Information regarding the possibility of withholding Consent and the consequences of refusal: whenever we require your Consent for the Processing of your Personal Data, we will inform you of the possibility of not providing such authorization, as well as of the consequences that may result therefrom;

i) Withdrawal of Consent: you may withdraw the Consent you provide to us to Process your Personal Data. However, we may retain information as necessary to comply with laws and/or regulations, as well as in other circumstances expressly provided for by law.

7. RETENTION AND DELETION OF PERSONAL DATA

We will retain your information for as long as you maintain your account on our Platform (which we hope will be for a long time!). If you choose to close your account, you may request the deletion of your Personal Data directly through our communication channels, noting that merely logging off / signing out of the Platform is not sufficient for your information to be deleted.

We also note that, even upon your request for deletion of data, we may retain certain information, in accordance with applicable law. In such case, we will inform you thereof. Furthermore, we may retain your data in anonymized form for FutManager's exclusive use.

8. UPDATES TO THE PRIVACY POLICY

We will send you a notice whenever we make any update and/or amendment to this Privacy Policy and, if your Consent is required, we will request it promptly.

9. ANTIBOT PROTECTION

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