INSTITUTO FRONTEIRAS defends civil rights and freedoms and, therefore, is committed to promoting adequate levels of online security to ensure your privacy and protect your personal data.

This Privacy Policy establishes how the collection, use and transparency of information from anyone who has any kind of relationship with our organization and other people who access or use our website is done .

The objective is to provide transparency to the practices related to our website so that you have confidence in our commitment and compliance with the General Law for the Protection of Personal Data – LGPD (Law No.

In this way, INSTITUTO FRONTEIRAS, registered with the CNPJ/MF under nº 32.908.502/0001-01, in the role of Data Controller, is bound by the provisions of this Privacy Policy.

Eventually, this Policy may undergo adjustments and revisions in order to better match the commitment to protect your data. Therefore, we will keep the last updated date at the end of the document and recommend that you check back periodically.

1. What data do we collect automatically?

It is important for you to know that the website automatically collects data associated with your electronic devices, such as:

1. a) access provider;
2. b) operating system;
3. c) default browser or the one used for access;
4. d) video settings (size/resolution and amount of colors);
5. e) date and time of access;
6. f) city and country of access.

This is a standard collection normally performed by websites to generate access statistics.

2. What data do we collect only with your consent?

Our website does not collect or store your personal data without you having voluntarily made it available , that is, there is no automatic collection of information such as:

1. a) full name;
2. b) date of birth;
3. c) marital status;
4. d) profession;
5. e) race or gender;
6. f) RG or CPF;
7. g) bank or payment details;
8. h) e-mail address, residential or business, work or any other that identifies you personally.

3. How can you give us your consent?

If any of the personal data informed above is necessary for us to provide services, news or products, we will ask you to fill out a form or register in a free and clear way.

4. How will we store your data?

The request, collection and storage of personal data by INSTITUTO FRONTEIRAS must be restricted to the minimum sufficient to meet your demand or to correspond to the level of relationship you have with our organization, whether you are:

1. a) interested;
2. b) partner or volunteer;
3. c) project participant or course participant;
4. d) employee;
5. e) supporter, donor or funder.

This means that there is no single rule for which data are collected, with a degree of variation due to the different possible relationship levels. However, on the other hand, it means that we do not collect unnecessary data and that sensitive data will be requested with due justification.

5. By what means do we collect your personal data?

The information we collect about you may have been provided directly by you, by third parties, collected automatically or from public databases available online.

5.1 Personal data provided by you:

In many of our activities, we may ask you to fill out an electronic form or registration, using applications or online platforms.

5.2 Personal data obtained through other platforms:
               In some circumstances, our website may redirect you to a registration and payment management platform:

1. a) Even3;
2. b) PagSeguro ;
3. c) PayPal;
4. d) Picpay ;
5. e) Google Pay;
6. f) another banking tool or payment slip generator;

These tools will operationalize the collection of personal data and will transfer them to INSTITUTO FRONTEIRAS automatically.

5.3 Personal data collected automatically:

In some situations, we may also automatically collect data from the devices you use to access our website or mobile application. This information helps us generate access statistics and thus better understand the public that uses them. This is important so that we can improve them more and more and adapt them to the widest possible audience. Some of this data may be collected through Cookies or similar technologies.

5.4 Publicly available personal data:

We may also process information that is in the public domain and that is found in official databases, including, but not limited to:

1. a) Facebook;
2. b) Instagram;
3. c) LinkedIn ;
4. d) Twitter;
5. e) other social media.

In this case, the information is only collected if you have previously allowed it, ensuring the right to revoke the permission.”

6. Consent

It is with your consent that we process your personal data. Consent is the free, informed and unequivocal statement by which you authorize INSTITUTO FRONTEIRAS to process your data.

Thus, in line with the General Data Protection Law, your data will only be collected, processed and stored with prior and express consent.

Your consent will be obtained specifically for each purpose described above, evidencing INSTITUTO FRONTEIRAS’s commitment to transparency and good faith towards the holders, following the relevant legislative regulations.

By providing your personal data, you are aware of and consenting to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

At any time and at no cost, you may withdraw your consent.

7. For what purposes do we store and use your personal data?

The personal information collected by INSTITUTO FRONTEIRAS serves different purposes depending on your level of relationship with the organization.

The rule is that the data only serve the purpose for which they were provided to us by you, or for other compatible purposes and provided that they were informed to you at the time of data collection.

• Enabling everyday activities

Based on our legitimate interest, we may also process your personal data to enable the daily activities of INSTITUTO FRONTEIRAS.

• Contents of interest

We may also collect your data to send you notifications of publications that are in line with your interests identified by the algorithm used on our website.

Our aim is to guarantee you a better browsing experience and send you quality content according to your preferences.

8. What are your rights?

INSTITUTO FRONTEIRAS ensures the rights of holders of personal data provided for in article 18 of the General Data Protection Law. Article 18: Personal Data Subject’s Rights in Relation to the Controller – Chapter 3 – Data Subject’s Rights – LGPD Brazil (lgpd-brazil.info)).

This way, you can, free of charge and at any time:

1. a) confirm the existence of data processing, in a simplified way or in a clear and complete format;
2. b) access your data, being able to request them in a readable copy in printed form or electronically, safe and reputable;
3. c) correct your data, when requesting their edition, correction or update;
4. d) limit your data when unnecessary, excessive or treated in violation of the legislation through anonymization, blocking or deletion;
5. e) request the portability of your data through a registration data report that [Name of civil society organization] deals with;
6. f) delete your processed data based on your consent, except in cases provided for by law;
7. g) revoke your consent, disallowing the processing of your data;
8. h) find out about the possibility of not providing consent and the negative consequences.

9. How can you exercise your titleholder rights?

To exercise your rights as a holder, you must contact Instituto Fronteiras through the following available means:

E-mail: frontiers@ifronteiras.org

Phone: +55 68 99258-5325

10. How and for how long will your data be stored?

Your personal data collected by INSTITUTO FRONTEIRAS will be used and stored for as long as necessary so that the purposes listed at the time of consent are achieved, considering the rights of data subjects and controllers.

10.1 End of storage period for collected data

After the period of storage of personal data, these will be deleted from our databases or anonymized, except for the hypotheses legally provided for in article 16 of the General Data Protection Law. Read article 16 Article 16: Deletion of Personal Data – Chapter 2 – Processing of Personal Data – LGPD Brazil (lgpd-brazil.info)

Thus, personal information about you that is essential for the fulfillment of legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be maintained, despite the exclusion of other data.

11. Our commitment to data protection

The storage of data collected by INSTITUTO FRONTEIRAS reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions able to guarantee the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and control access to stored information.

12. What do we do to keep your data safe?

In order to keep your personal information safe, we use physical, electronic and managerial tools aimed at protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and the purpose of the treatment. Among the measures we adopt, we highlight the following:

1. a) Data encryption: We use encryption to protect the stored personal data. Encryption converts the data into an unreadable format unless the person has the correct decryption key. This helps protect information from unauthorized access to systems or the data itself;
2. b) Appropriate access controls: We implement strict access controls to ensure that only authorized persons can access personal data. This includes adopting strong authentication policies such as strong passwords, two-factor authentication, and proper user credential management;
3. c) Updates and security patches: We keep all systems and software up to date with the latest versions and apply security patches provided by vendors. Updates and patches often include fixes for known vulnerabilities that could be exploited by hackers;
4. d) Security Awareness Training: We educate employees and users on good data security practices and raise awareness of the most common threats such as phishing and social engineering. By making people aware of the risks, it is possible to reduce the likelihood of human errors that could result in data leakage.

We seek to apply internal protocols that determine how personal data should be handled by the organization, defining roles and responsibilities. These norms are intended to ensure the proper and lawful treatment of the personal data we hold, including yours. We are committed to adopting the best postures to avoid security incidents. However, it is necessary to point out that no virtual page is entirely safe and risk-free. It is possible that despite all of our security protocols, security incidents may occur.

In the event of security incidents that may generate significant risk or damage to you or any other data subject, we will notify those affected and the National Data Protection Authority of the incident, in line with the provisions of the General Data Protection Law. Data.

13. With whom may your data be shared?

The nature of the activities carried out by INSTITUTO FRONTEIRAS, as a rule, involve cooperation with other civil society organizations, public bodies or management platforms , which may lead to the sharing of information.

However, if there is a need to share personal data, this will only occur if you are informed/and consent. Sharing will be limited to the minimum appropriate and necessary for the fulfillment of any of the specific purposes previously informed to you. And, when this occurs, we incorporate liability clauses into the contractual instruments to ensure that any third party that receives the data guarantees adequate protection and preserves privacy. We do not share personal data with any unauthorized third parties.

1. Cookies or browsing data

INSTITUTO FRONTEIRAS uses cookies, which are text files that can be stored on your electronic devices when you visit a website. By accessing our website and consenting to the use of cookies, you acknowledge and accept the use of a navigation data collection system with the use of cookies on your device.

INSTITUTO FRONTEIRAS uses the following cookies:

1. a) Strictly necessary cookies: These cookies are essential to allow users to navigate the website and use its features, such as accessing secure areas.
2. b) Performance cookies: These cookies collect information about how users interact with the website, including which pages are most visited, the time spent on them and possible errors encountered. This data is used to improve the functionality of the website.
3. c) Functionality cookies: These cookies allow the website to remember choices made by users (such as username, language or region) and provide personalized features. They can be used to provide a more personalized experience.
4. d) Advertising Cookies: These cookies track users’ activity across the site to deliver targeted and relevant advertisements. They may be used by third-party ad networks to display ads based on users’ interests.
5. e) Social media cookies: These cookies allow users to share website content on social media platforms such as Facebook, Twitter etc. They may also track users’ activity on these platforms for ad targeting purposes.
6. f) Analysis cookies: These cookies collect information about how users arrive at the website and how they interact with it. They are used for analysis and reporting, helping site owners understand the performance and effectiveness of their marketing strategies.
7. g) Preferences Cookies: These cookies allow a website to remember a user’s preferences, such as preferred language or personalized display settings. This improves the user experience when returning to the site.
8. h) Targeting cookies: These cookies are used to create user profiles based on their interests and browsing behavior. The information is used to personalize the display of targeted content and advertisements.
9. i) Remarketing cookies : These cookies allow advertisers to show personalized advertisements to users who have visited the website previously. They are used to remind users about previously viewed products or services, encouraging them to return and complete a purchase.
10. j) Third-party cookies: These cookies are set by third parties, such as advertisers or ad networks, to collect data about user behavior on different websites. They are commonly used for targeted advertising purposes.

14.1 Revocation of permission or blocking of cookies

You can, at any time and at no cost, change permissions, block or refuse cookies. However, revoking the consent of certain cookies may prevent the correct functioning of some platform features. To manage your browser’s cookies, simply do it directly in your browser settings, in the Cookie Management Area.

15. Amendment of this Privacy Policy

The current version of the Privacy Policy was formulated and last updated on: July 20, 2023.

We reserve the right to modify this Privacy Policy at any time, mainly in terms of adaptation to any changes made to our website or in the legislative field. We recommend that you review it frequently.

Any changes will come into force from their publication on our website and we will always notify you about the changes that have occurred. By providing your personal data after such modifications, you consent to them.

16. Responsibility

INSTITUTO FRONTEIRAS provides for the responsibility of agents who work in data processing processes, in accordance with articles 42 to 45 of the General Data Protection Law. We undertake to keep this Privacy Policy up to date, observing its provisions and ensuring compliance.

In addition, we are also committed to seeking safe technical and organizational conditions to protect the entire data processing process.

If the National Data Protection Authority requires the adoption of measures in relation to the data processing carried out by INSTITUTO FRONTEIRAS, we undertake to follow them. We emphasize that, in the event of security incidents that may generate risk or significant damage to you or any of our users, we will inform the affected parties and the National Data Protection Authority about what happened and we will comply with the necessary measures.

1. Data Protection Officer

INSTITUTO FRONTEIRAS provides the following means for you to contact us to exercise your titleholder rights:

E-mail: frontiers@ifronteiras.org

Phone: +55 68 99258-5325

If you have questions about this Privacy Policy or about the personal data we process, you can contact our Personal Data Protection Officer through the following contact:

Name of Person in Charge: Hilaritsa Moura

E-mail of the person in charge: borders@ifronteiras.org

18. Definitions

In order to provide you with greater clarity regarding the content of this Policy, the words and expressions, in the singular or plural, have been used with the following meanings:

Holder: natural person to whom the personal data refer;

Controller: term that designates who is responsible for decisions regarding the processing of personal data, in our case it is INSTITUTO FRONTEIRAS – Board of Directors .

Person in charge: term that designates the person appointed by INSTITUTO FRONTEIRAS to act as a communication channel between our organization, you and the National Data Protection Authority (ANPD).

Personal data: any information that identifies or may identify a natural person, such as – for example – a name, an identification number, location data, electronic identifiers or one or more specific elements of physical, physiological, genetic identity , mental, economic, cultural or social status of that natural person;

Sensitive personal data: any personal data concerning racial or ethnic origin, religious conviction, political opinion, union membership or organization of a religious, philosophical or political nature, as well as data referring to health or sexual life, genetic data or biometric;

Treatment: collection, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, updating, communication, transfer, sharing and extraction of personal data;

Anonymization: procedure that breaks the connection between the data subject and the information about him/her, in a way that prevents the identification of the person from the personal data.

Cruzeiro do Sul, July 20, 2023.

BORDERS INSTITUTE