PRIVACY POLICY – OHMRESEARCH
PLEASE CAREFULLY READ THIS DOCUMENT, AS THE USE OF THE OHMRESEARCH PLATFORM BY YOU DEMONSTRATES THAT YOU AGREE WITH THIS POLICY.
The OHMRESEARCH website and application (jointly, the “OHMRESEARCH Platform”) are a service offered by OHMRESEARCH CONSULTORIA E ANÁLISES DE TÍTULOS E VALORES MOBILIÁRIOS LTDA., a limited liability company [sociedade limitada], enrolled in the National Register of Legal Entities (CNPJ) under No. 35.573.785/0001-76, with its principal place of business at Av. Santo Amaro, n. 1.159, 8º andar, cj. 84, City of São Paulo, State of São Paulo (“OHMRESEARCH,” “we” or “our”). This Privacy Policy, together with the Terms of Use of the OHMRESEARCH Digital Platform, describe the terms and conditions applicable to access and use the OHMRESEARCH Platform by user.
1. Scope and accept
1.1. This Privacy Policy (“Policy”) deals with processing of personal data, or other information such as: the cookies used, how we can disclose your information, your right to access, correct, update and delete your personal information, among others (“Information”) provided by Users (“Users,” “user,” “you,” “your”) on browsing, accessing and/or using the OHMRESEARCH Platform.
1.2. UPON CLICKING THE BOX “I HAVE READ AND ACCEPT” OR “I ACCEPT”, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY, OR UPON BROWSING THROUGH THE OHMRESEARCH PLATFORM, YOU WILL BE EXPRESSLY STATING THAT YOU AGREE WITH THE TERMS OF THIS POLICY. BE AWARE THAT THE PROVISIONS HEREIN SHALL REGULATE THE RELATIONSHIP BETWEEN OHMRESEARCH AND YOU. IF YOU DO NOT AGREE WITH ALL TERMS BELOW, YOU CANNOT USE OR ACCESS THE OHMRESEARCH PLATFORM IN ANY WAY. Therefore, we suggest that you carefully read this document, as well as any updates hereto, before deciding to use or continue using the OHMRESEARCH Platform and to engage the Services.
2. OHMRESEARCH commitment to user’s privacy
2.1. OHMRESEARCH is committed with the safety and privacy of OHMRESEARCH Platform Users in all its applications, products and services. Thus, all User information are treated with full confidentiality and are not sold, exchanged or disclosed to third parties, except when expressly provided for in this policy, or when required by court order or regulatory agencies.
2.2. We do not collect or knowingly request Information from minors under the age 18.
2.3. OHMRESEARCH may modify this Privacy Policy at any time. In case of changes to the Privacy Policy, OHMRESEARCH will request a new acceptance of the updated version of the Policy, in your next access to the Platform. If Users do not agree with the new Privacy Policy, it may be rejected, free of charge. The rejection of the new version of the Privacy Policy, however, means that the user will no longer be able to use the OHMRESEARCH Platform. The fact that you accept the terms or continue to access OHMRESEARCH after the update means that you have agreed to the changes to this Privacy Policy. All transactions that occur in the Applications will be subject to the latest version of the Policy
3. Information collected by the OHMRESEARCH Platform
3.1. Personal data is information that identifies the User, a natural person. The data can be collected directly from You, through internet interaction and during your use of the platform, we may collect the following Information:
- Personal Information: such as, full name, individual taxpayer number (CPF), postal address, e-mail address, telephone number, user’s face images or selfie videos for authentication purposes, or other physical characteristics for any biometric recognition and authentication.
- Personal Financial Data and Bank Data: the registration on the OHMRESEARCH Platform also entails to provide User’s bank account data (data on bank, branch, account number, and type of account) for payment of User’s compensation in consideration for the services provided to Subscribers.
- Copies of Documents: we may collect, through our own or a service provider functionality, as a part of the procedure for registration and analysis of application for registration on the Omninvet Platform by OHMRESEARCH Platform Users, a copy of the identity card (RG), proof of residence, and other certificates necessary for acting as Analysts or Experts, when applicable.
- Browsing information: information on user’s mobile phone/smartphone, IP address, type of browser used, operating system version, reference source, duration of the visit on the OHMRESEARCH Platform, pageviews, page browsing tracks, internet band, operator, pageview behavior, geolocation, visited pages.
- Geolocation information: OHMRESEARCH may collect information about your location. Your fixed or mobile device or the browser used to access the Platform may offer the option of not sharing this data, you may not allow such data to be collected without prejudice to your use of the Platform.
- Information collected by Cookies: A cookie is a small file added to user’s device or computer to provide a personalized experience of accessing the OHMRESEARCH Platform. The cookies help analyzing the internet traffic or allow us to know when the user at issue has visited a specific website. A cookie does not give access to a computer or reveal information in addition to the data that the user chooses to share with us. On accepting this Privacy Policy, the user is aware and agrees that OHMRESEARCH may install. The Cookies used by Omnininvest are the following:
- Log in cookies
- Comments cookies
3.2. Advertisers – Platform partners, as the case may be – do not transmit cookies to the Users’ browser or device when the OHMRESEARCH Platform is used. However, when the user clicks on advertisements or links that lead to a third-party website or service, such third-party may transmit cookies to such user. Please note that this Policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy practices and policies
4. Use of collected information
4.1. OHMRESEARCH Platform Users’ information will be used for the purposes established in this Policy, whether to enable the use of the OHMRESEARCH Platform, detect possible fraud, produce statistics, and implement marketing and relationship campaigns:
(a) In the registration and identification of Users on the OHMRESEARCH Platform;
(b) In the analysis of the application to act as User on the OHMRESEARCH Platform;
(c) In the measures deemed necessary or recommended by OHMRESEARCH for constant improvement of OHMRESEARCH Platform’s functionalities and actions performed to offer services through the OHMRESEARCH Platform, as well as to better understand the Users’ needs;
(d) In a notice to Users about changes in the OHMRESEARCH Platform and/or in services, as well as to meet obligations arising from law and assumed on accessing and using the OHMRESEARCH Platform; and
(e) To report transactions, storage of information, data, communications and others related to the access and use of the OHMRESEARCH Platform and use of services, as well as to meet other legal and regulatory obligations imposed on the OHMRESEARCH Platform.
5. Data sharing
5.1. UPON AGREEMENT WITH THE TERMS OF THIS PRIVACY POLICY, THE USER AGREES AND CONSENTS ALSO IN AN EXPRESS AND CLEAR MANNER TO THE GRANTING OF ACCESS AND SHARING OF USER’S INFORMATION WITH OHMRESEARCH, AS WELL AS WITH SELECTED THIRD PARTIES, AS LISTED BELOW, FOR ACHIEVEMENT OF THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY:
- Employees and companies of the group, investors, business partners, partner banks, agents and/or service providers, in Brazil or abroad, of OHMRESEARCH, for the purposes of maintenance of the OHMRESEARCH Platform, service provision to OHMRESEARCH and/or in case of other necessary procedures.
- Governmental authorities and/or judicial courts that may require, by operation of law or of a court order, full or partial disclosure of the information.
- Any other third parties with whom we are obliged to share the information by virtue of legal and regulatory obligations and/or the disclosure of information of which is necessary or recommended for proper, effective and efficient operation of the OHMRESEARCH Platform and its functionalities, as well as for the offer of services.
- Agents: We may employ other companies and individuals (“Agents”) to carry out tasks in our name and, therefore, we may need to share OHMRESEARCH Platform Users’ Information with such Agents to provide Users with access and use the OHMRESEARCH Platform and/or engagement of Services. The Agents are not entitled to use the Information we shared with them beyond what is necessary to assist us in their tasks and/or for proper, effective and efficient operation of the platform and its functionalities.
6. What are you data rights?
6.1. The User can make changes in data files in User’s account. However, certain specific data (such as name and CPF, for example), are considered key and may be only changed by OHMRESEARCH upon specific request to the email compliance@ohmresearch.com.br. For the remaining data, in case you wish to make any change, please access your account, and adjust the corresponding data.
6.2. You agree that OHMRESEARCH may keep a copy of your data in absolute security and in a private manner, in order to comply with legal or regulatory obligations.
7. Place of storage of Users’ Information and Use of collected Information
7.1. On accepting this Privacy Policy, You are aware and agree that the information collected upon access or use of the OHMRESEARCH Platform may be transferred and stored at a destination outside Brazil, to the extent permitted by law. In addition, You are aware and agree that, on accessing, using the OHMRESEARCH Platform, and sending us your personal data, your Information will be transferred, stored, processed and used in the format exposed in this Privacy Policy. We take all reasonably necessary care to ensure that your data be processed in a safe manner and pursuant to this Privacy Policy.
8. Security
8.1. The information collected from Users travels and is stored securely through encrypted processes.
8.2. An user’s account on the OHMRESEARCH Platform is protected by a personal and non-transferrable password, which exists for Users’ privacy and security. The User shall prevent the unauthorized access to User’s account and to User’s Information by properly selecting and protecting User’s password, and limiting the access to User’s computer or device and browser, and the User at issue shall sign off from the OHMRESEARCH Platform after ending accessing User’s account and using the OHMRESEARCH Platform.
8.3. The password to access User’s account on the OHMRESEARCH Platform is stored on our databases using the most modern forms of encryption and, to ensure User’s security, nobody has access to such databases. THIS MEANS THAT OHMRESEARCH WILL NEVER REQUEST THE PASSWORD TO ACCESS USERS’ ACCOUNT MAINTAINED ON THE OHMRESEARCH PLATFORM BY E-MAIL OR TELEPHONE.
8.4. If a User has any reason to believe or suspect that any third party had access to user’s password to access the User’s account, we kindly request that the User contact compliance@ohmresearch.com.br.
8.5. We will endeavor to protect the privacy of our Users’ account and other Information that we keep in our records. The unauthorized access or use, hardware or software failure, and other facts may compromise the security of user’s information at any time. ACCORDINGLY, THE TRANSMISSION OF INFORMATION THROUGH THE INTERNET IS NOT COMPLETELY SECURE FOR SEVERAL FACTORS, INCLUDING NETWORK AND OPERATION FACTORS.
8.6. According to our obligations to maintain records and in keeping with the purposes described in this Privacy Policy, we will retain your personal information for at least five (5) years after closing of your account, mainly, by virtue of any legal and regulatory obligations and protection in judicial defenses.
9. OHMRESEARCH’s Protection
9.1. We reserve the right to store, access, read, preserve, and disclose any information we deem necessary to comply with the law or a court order to the extent required by applicable laws and regulations, this Privacy Policy and any other agreements, or terms with which Users agreed, as well as to protect the rights, ownership or security of OHMRESEARCH, of the OHMRESEARCH Platform and of its employees, service providers, Users, clients, and others.
10. Confirmation of understanding and consent
By checking the box provided, you confirm that you have read and accept the terms of this Privacy Policy, and expressly agree with the collection, storage, sharing, and use of my personal information.