1. Definitions

1.1. The terms and expressions initiated in capital letters used in this Policy, whether in the singular or plural, when not defined in other sections of this Policy, shall have the respective meanings assigned to them, as set forth below:

1.1. The terms and expressions initiated in capital letters used in this Policy, whether in the singular or plural, when not defined in other sections of this Policy, shall have the respective meanings assigned to them, as set forth below:

ANPD

means the National Data Protection Authority in Brazil, as defined in the LGPD

Controller Personal Data

means any Personal Data shared by Controller for Processing by Contractor or any of its Processors.

International Transfer

means the transfer of personal data to a third country or international organization to which Brazil is a party.

LGPD

means Law No. 13,709 of August 14, 2018 (Brazilian General Data Protection Law, as amended).

Data Subject

means an identified or identifiable natural person. An identifiable natural person is any person whose identity can be determined, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more elements of the physical, physiological, genetic, psychic, economic, cultural or social identity of said person.

Personal Data

means any information related to a Data Subject. Personal Data does not include information from which the User cannot be identified (referred to simply as data, non-personal data, or anonymized data).

Processing

means any operation or set of operations carried out on the Personal Data or on a set of Personal Data, whether or not by automated means, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction.

Sensitive Personal Data

means personal data revealing racial or ethnic origin, religious beliefs, political opinions, membership to a trade union or religious, philosophical or political organizations, data concerning health or sex life, genetic data or biometric data, when related to a natural person.

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