Heartman House is a consultancy firm specialized in Strategic Planning, Succession and Professionalization, Restructuring and Management Change. The company is fully committed to guaranteeing, protecting, safeguarding, and ensuring the privacy of the User’s personal data by putting in place the market’s best practices, always in compliance with the current legislation.

 

This Policy applies to the Company’s websites, official social media pages, applications, Wi-Fi networks, and to all means in which the company finds itself holder of any User’s personal data, including data collected offline.

 

Heartman House encourages the User to carefully read this Privacy Policy and make sure that they are fully aware that the security and privacy of their personal data will be safeguarded, thus preventing any fraud, and ensuring the compliance to all legal obligations. The Company emphasizes its commitment to security and privacy in all data processing operations.

 

Should the User still have any questions after reading this Policy, please feel free to contact Heartman House using the contact information provided at the end of this document.

1) Which types of personal data does Heartman House manage?

The User’s personal data that Heartman House may manage includes: the User’s full name, marital status, gender, civil identification number, taxpayer number, IP address, work information such as the User’s position and sector within their organization. Personal data forwarded by clients may also include their salary, macro-geographical location, address, age/date of birth and purchase preferences. The data will only be managed for professional use.

 

Heartman House cares about protecting the personal data and privacy of children and adolescents; therefore, data on children and adolescents will only be collected and processed to comply with an employment contract and to grant benefits to the employees’ dependents.

2) Cases in which Heartman House manages the User’s personal data

Whether the User is a consumer, employee or representative of a client company, Heartman House may manage their personal data to ensure the execution of the services, either due to the relationship and operation with its clients, or to the object of the services provided to its clients. In all cases, Heartman House will manage personal data in the following cases:

  • Due to the nature of the services: the Company may manage the User’s personal data during the execution of the contracted services;
  • Provided by the User: the company might process personal data upon the User’s access to its website and interaction through its contact channels;
  • Upon the User’s interaction with Heartman House’s website, thus providing information that the company believes may be of the User’s interest;
  • Personal data forwarded by its clients for the execution of the services: Heartman House might manage the User’s personal data in conjunction with other clients. Heartman House emphasizes that, in this case, the company guarantees and safeguards that the shared personal data is legitimately treated in full compliance with Data Protection laws, in particular Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados – LGPD).
By all means, Heartman House will only process User’s personal data upon express consent. When data is collected by Heartman House, the company will directly ask for the User’s consent; when personal data is forwarded by a client, the company will ensure that the clients have obtained express consent to do so.

3) How does Heartman House manage the User’s personal data

Heartman House manages the User’s data only for legitimate, specific, and limited professional purposes. The company does not use any personal data without a legitimate, specific, and limited purpose.

  • Use of personal data to provide services to clients
    Heartman House manages the User’s personal data to provide and perform services to its clients. The company might manage the User’s data within a relationship it carries out with its clients or in case the User is a representative and/or employee of one of the company’s clients;
  • Receiving contacts, and commercial or operational negotiations
    Heartman House manages the User’s data to deal with issues, possible contacts for problem solving and possible commercial or operational contacts;
  • Management of personal data to monitor the website
    Heartman House makes use of tools to monitor the traffic to its website and usage patterns. The Company might use the User’s personal data to verify their interaction with its website, as many times and as long as they navigate it, among other information;
  • Maintenance and prevention of the website’s security technical issues and operation
    Heartman House may occasionally manage the User’s personal data to carry out maintenance and preventive measures to its websites, systems, databases, and other environments.

4) Who does Heartman Heart share the User’s personal data with?

Heartman House works in partnership with other companies/suppliers and clients to offer the best range of services. The Company may share the User’s personal data with such partners, always preserving their privacy and its anonymity. The User’s data may be shared:

  • With cloud hosting service providers;
  • With partners and service providers that help the company monitor the visitation and usage profile of its website;
  • With authorities, upon legal command.

In all cases, Heartman House requires the same level of security and data protection from its partners and suppliers as it carries out internally, as described below.

5) How does Heartman Heart protect the User’s personal data

Heartman House is concerned with the security and protection of its User’s personal data; therefore, it adopts all adequate, proportionate, and reasonable information security measures, in addition to physical and electronic processes to keep all data safe, accurate and up to date. The Company also ensures that all suppliers, partners or third parties, who deal with the User’s personal data due to their services or activities, employ, at least, the same security standards as the ones adopted by Heartman House.

6) How long does Heartman Heart keep the User’s personal data for?

Heartman House holds a Personal Data retention policy in line with the applicable law. Personal data is only stored for as long as necessary to fulfill the purposes for which it was collected, unless there is any other reason to keep it, such as, but not restricted to, compliance with any legal, regulatory, contractual obligations, as long as backed by law.

 

Under no circumstances the User’s personal data will be kept once the purpose for which it was collected has been terminated. In addition, the User can contact Heartman House’s official channels, as presented in this policy, at any time, to request the total or partial deletion of their personal data.

7) What are your rights?

The User’s Personal Data belongs to the User, and the Brazilian law protects their rights. Heartman House is committed to complying with it and, this section explains how the User can make use of these rights.

Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados – LGPD) guarantees several rights to data holders, therefore should the User want to bring forth any of them, they must simply submit a request to the company’s Supervisor, at any time without any cost.

 

Whenever the data holder brings their rights forth, Heartman House may request some additional information to ensure the proper identification of the subject and avoid potential fraud. This is carried out ensure the security and privacy of the data and this process will be deployed within a reasonable time frame, always in compliance with the applicable law.

The User may contact Heartman House:

  • Should they understand that their personal data has been used in a way that is incompatible with this Privacy Policy or contrary to data protection regulations;
  • Should they want to bring forth any of the rights stated in the LGPD, especially the one on art. 18, without affecting the others, such as: (i) confirmation of the existence of the data; (ii) access to the data; (iii) correction of incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion of data that is unnecessary, excessive or dealt with in a way that does not comply with the LGPD; (v) data portability to another service or product provider, upon request in writing; (vi) deletion of data upon consent; (vii) revocation of consent previously granted; and (viii) information from public and private companies with which the controller has shared data with.
  • Should they have any questions or suggestions regarding the Notice before mentioned, as well as any other topic involving privacy and protection of their personal data.
To contact Heartman House regarding this topic, use this exclusive and official channel: lgpd@heartman-house.com.br

Updates to Heartman House’s Privacy Policy

Heartman House may update this policy at any time and will post the most current version on this website.