Privacy Policy

Privacy Policy

TERM OF FULL CONSENT – ARTICLE 7 AND 9 OF THE GDPR

By clicking on the agreement button regarding the terms of use and privacy policy, the user expressly consents and confirms to all the rules contained therein, as well as agrees and accepts that Astrolink treats the data offered herein and the other collected during the use of the platform. We make it clear that this consent may also be terminated at any time (article 7, paragraph 3 of GDPR).

Astrolink warns that if the user does not agree with the data provided in the documents below, he should not access our network.

 

SECURITY

Your privacy is extremely important to Astrolink and we value measures that make your browsing even safer. Thus, our website uses the HTTPS protocol, offering an extra layer of security that allows your data, such as username, password and personal information, to be encrypted and verified by the server through digital certificates. In practice, HTTPS makes it difficult for hackers to attack, gain unauthorized access to sensitive data and protect the information on our website.

Statement of Rights and Responsibilities

This Privacy Policy governs the relationship of the full Astrolink network of websites, including, but not limited to, its website, interactive features, applications, widgets, blogs or any other services to which the Astrolink website network is inserted, with users and third parties who otherwise access or interact with Astrolink, whether through computers, mobile devices or any other capable technology (“User”). It is worth highlighting that the User category is configured even if the individual has not registered on the Astrolink network.

This Privacy Policy must always be interpreted in conjunction with the Astrolink’s Terms of Use. Having transparency as one of the values, this "Privacy Policy" is intended for publicity and clarification on the rules imposed on the data of all Users, under the terms of the applicable legislation, on all platforms related to Astrolink, highlighting the forms of data collection, use, storage, handling and protection. If the User does not agree with the content of this Privacy Policy, he/she should not access or use the Astrolink network websites.

It is also worth highlighting that all the information entrusted by the User in his or her registration will be used by Astrolink, being incorporated into its database for the operation of the Astrolink website, through the User’s identification by login and password.

It’s important for us to highlight the application of the GDPR principles, according to article 5º, regarding the processing of your personal data, such as the transparency in its use, with a determined, explicit and legitimate purpose. Also, Astrolink emphasizes the fact that all data processed is appropriate to relevance and importance in our storage, and inaccurate data, or the ones for purposes other than our treatment, will be deleted or rectified without delay. 

We ask that all users take a moment to read this document before registering with Astrolink.

Information Collected

1. Astrolink may collect information in several ways. Some personal information may be obtained upon User registration and may also be collected in the content of the User’s posts (such as comments on the website), and Astrolink may collect all information actively entered into Astrolink website by the User.
2. Astrolink may collect information automatically, when the User accesses the Astrolink website, as well as use tools for automatic collection of data transmitted by Astrolink, such as cookies, web beacons, crawlers, among others, from partners and suppliers, such as Google Analytics and eventually the characteristic data of the access instrument (browser), such as accessed websites, computer model, operating system.
3. Any data transmitted by the User through the Astrolink website may be collected, including forms, posts, messages and comments.
4. Under Brazilian law, in all access, including upon registration, the user’s IP address, time and date will be collected.

Data Handling

5. The information collected by Astrolink may be used to customize and improve the content and/or services that will be made available on the Astrolink website to the User. The knowledge about the User will enable his or her personalized service, with more efficiency and respect, including making navigation easier.
6. For any marketing campaigns specific to the target audience, the data collected may help to delimit the user’s interest in offering exclusive products.
7. The data collected may be made available for targeted marketing services and for the preparation of statistical reports for Astrolink.
8. Some data may be provided to advertisers, partners, sponsors, including for sending email marketing and for billing procedures for Subscriber services. You can object to these processing operations by forwarding a message to our DPO. We will evaluate your request and whenever possible we will comply, informing you of the consequent limitations in the use of the services.
9. The data may be forwarded at the request of the competent authorities, as well as for possible judicial or extrajudicial claims as a defense instrument, preparation of complaints or other procedures of interest to Astrolink.
10. The Astrolink database is an asset of the company eSapiens Internet SA, and may, in the event of corporate changes, be handed over to the appropriate party, as well as being negotiated separately.

Data Storage

11. All websites related to Astrolink use the HTTPS protocol, offering an extra layer of security that allows your data, such as User, password and personal information, to be encrypted and verified by the server through digital certificates.
12. As a security standard provided for by the Brazilian legislation, Astrolink: 
- Maintains strict control over access to data by defining the responsibilities of the people who will have access and exclusive access privileges for certain Users;
- Created mechanisms to authenticate access to records, aiming to ensure the individualization of the person responsible for handling the records;
 - Maintains a detailed inventory of access to application access logs, containing the date and time of use from a given IP address, including for compliance with Brazilian legislation;
13. Astrolink undertakes to retain as little personal data, private communications and connection and access logs to applications as possible, which must be deleted as soon as the purpose of their use is reached; or after the expiration of the period established by legal obligation.
14. Astrolink reserves the right to keep user data for the period provided for in the Brazilian legislation, to comply with an order issued by the competent authority.

General Provisions

15. Any tolerance by Astrolink in relation to non-compliance with the provisions of this Policy will not constitute, under any circumstances, a waiver or novation, nor will it prevent Astrolink from asserting any rights established herein;
16. If any clause of this Privacy Policy is declared void for any reason, the other clauses will remain in force and will fully produce their effects. If the nullity affects the balance of this relationship, the parties undertake to renegotiate the conditions established herein in good faith.
17. The Terms of Use are an integral part of this document, both of which will be applied and interpreted together. In case of divergence between the Terms of Use and the Privacy Policy or other documents, the provisions of the Terms of Use will prevail.
18. Astrolink reserves the right to change this Privacy Policy to adapt it to applicable law or best business practices at any time and regardless of justification.

 

Astrolink's Cookie Policy

Effective from May 7, 2021.

The purpose of this Policy is to provide clear and accessible information about the cookies that Astrolink uses and the roles they play. This policy does not exclude the provisions of the Privacy Policy and aims to detail and complement it.

What are cookies

Cookies: Cookies are simple text files, sent by the website to the browser the first time you visit it to ensure the proper functioning of websites and services on the web. They make it easy to adapt Astrolink to your personal needs, helping you to use our services and making your browsing experience more enjoyable. In addition, cookies are used to better understand how our visitors and users use our website and services.

Astrolink uses the following types of cookies on its website, application and services:

  • Session cookies: These are temporary use cookies, deleted when you close your browser. If you reopen your browser and access the website again, you will be treated as a new visitor;
  • Necessary cookies: They are strictly necessary for the correct functioning of our website, allowing them to access and use our resources;
  • Persistent cookies: Cookies that are stored in your browser until they are manually deleted or according to the established duration period. When you return to the Astrolink website, application or services you will be recognized even if you have previously closed your browser.

 

Data collected automatically

Tracking technologies: Astrolink may also use other tracking technologies that may collect information such as IP addresses, log files and web beacons, among others, that help us to provide the Astrolink website, application and services to your personal needs.

When your device is connected to the internet, it will receive a number referring to the IP (Internet Protocol) address that is used to identify it. Every time you connect to the internet your computer receives an IP assigned by your internet service provider. We may register IP Addresses for the following purposes:

  • Maintain the protection and security of our website, application and services;
  • Understand how our users and visitors use our website, application and services;
  • Through geographic location, adapt navigation and content to user needs.

 

Log files (logs)

Logs: Astrolink or a third party, working on our behalf, may collect information in the form of log files that detail website activities and collect statistics about user browsing habits, including, for example, which pages were visited. Typically these logs are generated anonymously and help us understand details such as:

  • The type of browser and system used by users of our website or online services;
  • Details about the user's session, including the originating URL, the date, time and which pages the user visited on our compatible sites and services, and how long the user spent using them;
  • Other navigation or click count details including website traffic reports, unique visitor counts and similar data.

 

Other records treated

Beacons (web beacons) or pixels: We may use web beacons (or clear GIFs) on Astrolink websites. Web beacons (also known as webbugs or web beacons) are small sequences of code that allow the delivery of a graphic image on a web page for the purpose of transferring data back to us. We use information from web beacons for a variety of purposes, including:

  • Understand how a user responds to email campaigns;
  • Traffic reports from our website and compatible services;
  • Perform unique visitor counts, audit and reporting of advertising and email, as well as personalization on our websites and other compatible services.

 

Granular consent

Whenever possible, as long as it does not interfere with the functionality and security of the platform or with our legal obligations, we will offer you the possibility to select which records you want to be recorded or read.

On the other hand, it is important to remember that it is up to you to ensure that the settings on your computer, account on the platform or handheld device reflect whether or not you consent to accept Cookies.

Most browsers allow you to set rules to warn you before accepting Cookies or simply rejecting them. You do not need to have Cookies enabled to use or browse all parts of Astrolink's website and online services, however, in this case, we cannot guarantee that you will be able to access all of its features and functionality, which could result in an unpleasant experience. .

We recommend that you see in your browser how to configure the necessary settings for your privacy. Remember that if you use different browsers, or even different computers and/or handheld devices in different locations, you will need to ensure that each device and browser is set to your personal Cookie preferences.

As our web beacons or pixels may be part of a web page (embedded in code), it is not possible to opt-out of this type of feature, but you can make it completely unavailable. -functional by enabling the “opt-out” feature for Cookies placed by this flag.

Data Protection Officer

If you have any doubts about, or want to question any provision, or even oppose any processing operation that we establish in this policy or request data deletion, please contact our Data Protection Officer, through our Privacy Center.

 

More Information

  • E-mails received are answered as soon as possible. This site respects and seeks to respond to all emails sent;
  • Astrolink states that it does not use emails for Spam or unwanted email policies;
  • Astrolink is not responsible for the information content, promises and veracity of information displayed by any advertisements placed by its sponsors. All responsibility lies with the advertisers;
  • Astrolink is not responsible for the content, promises and veracity of information displayed by any information registered by its users in the profiles, acting only as a virtual conveyor of such information. All responsibility lies with their respective users;
  • The profiles registered on the site are displayed online for as long as the user wishes, and may undergo changes by the site's administration team, arising from the clauses described in the Terms of Use;
  • The display of user profiles are displayed freely over the internet through your profile address registered on the website. Search engines such as Google will be able to independently index your website. We are not responsible for this process, as it is done by third parties and we have no power in this decision. If you do not want your information to be indexed by search engines, we advise you not to create a profile on "Astrolink";
  • For more information, carefully read the site's Terms of Use.

Personal information collected

Information is collected by Astrolink in creating your profile, such as your name, email address, date and place of birth when you register an account to become a user of the site, and also when you interact with Astrolink pages and features, including Astrolink's mobile applications, software and platform technologies.

Other information such as your IP, browser and operating system used, telephone operator, internet provider, urls from where you came from and urls of websites you later accessed may also be collected through cookies and other technologies, in order to personalize and improve your user experience. of Astrolink, as well as adapting advertisements on and off the site.

The branch of activity performed by the site is exclusively in relation to sensitive personal data of users, in relation to their life, deserving specific support in the GDPR law, due to its fragility and need for greater caution regarding treatment. Thus, based on article 9º, §2º, A, the treatment of this data must be explicitly consented by the user, so that we can use it correctly and in accordance with the law.

The data collected may be provided to marketing services, advertisers, partners and sponsors, depending on the subject matter. Astrolink warns that this type of sharing will occur for cases of specific marketing campaigns, which will direct, based on user data, reach the target audience, in the same way, to static reports and billing procedures for subscriber services.

Based on the second paragraph of article 9º of General Data Protection Regulation, your data may be sent to the competent authority, as well as to judicial or extrajudicial claims as a form of defense, complaint, or other procedures that Astrolink deems relevant.

The database constitutes an asset of eSapiens Tecnologia S/A, and may, in case of corporate changes, be delivered to those entitled, as well as may be the subject of isolated negotiation. However, the user will be informed about such modification and will be asked for this consent to the processing of the data.

In line with article 32 of GDPR, the data controller will apply the appropriate technical measures to ensure a high level of security fitting to the risk, including:

  • The pseudonymisation and encryption of personal data;
  • The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  • A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

Astrolink undertakes to retain as little personal data, private communications and connection and access logs to applications as possible, which should be deleted as soon as the purpose of their use is achieved. 

Likewise, on the basis of the article 5º, n. 1, “e” and considering article 39 of GDPR, the data will be kept for as little time as possible, for specific purposes of any legal obligations to retain the data for a certain period of time. The data, which will be accurate and updated, once they exceed the period entered six months, must be subject to new consent by the user, ensuring transparency and description of the reasons why their data will be reprocessed.

Use of personal information

Your information is used to improve your experience and navigation on the Astrolink website, as well as the communication and visualization of interested parties in your profile.

We also use your information to manage your account and customize the service provided by Astrolink, always improving and evolving based on this information and also to send you various communications or important notices by email.

Astrolink reserves the right to edit, block and even cancel a user's profile if it comes to the conclusion that the user is not acting in accordance with the site's terms of use set out in the Terms of Use and the Privacy Policy.

Your information-related choices

Astrolink allows you to improve or edit your personal information on your personal profile page, and also to request the termination of your account through "Account".

The basics rights of the user

Since you are the data subject, according to the articles 13 and 14, you have the right to:

  • Confirm the existence and the treatment of the data, such as withdraw the consent at any time; 
  • Be informed of the reason of the data treatment, preserving the transparence and the processed lawfully of the relation, as well as the legal basis for the processing;
  • Correct incomplete, outdated and inaccurate data; 
  • Anonymize, block or eliminate the existence of unnecessary, excessive data or treatment in disagreement with GDPR; 
  • Eliminate data previously consented; 
  • To be informed by the possibility of the fact that the controller intends to transfer personal data to a third country or international organization and the existence or absence of an adequacy decision by the Commission;
  • The period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
  • The right to lodge a complaint with a supervisory authority;
  • Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information;
  • The right to have a copy of the accessed data and other basic rights of the data protection.

Contacts

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Esapiens Tecnologia SA has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, Esapiens Tecnologia SA has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR: