LEGAL BASIS FOR PROCESSING PERSONAL DATA WITHIN THE TERRITORY OF BRAZIL
4Sync is committed to compliance and adherence to Personal Data privacy and protection laws, rules and regulations, including:
(i) Law 13,709/2018 of the Brazilian Congress (Lei Geral de Proteção de Dados Pessoais (LGPD), General Data Protection Law, "GDPL"); (ii) regulatory and applicable self-regulatory guidelines.
If there is any conflict between the Terms of Use or other policies described in this Privacy Policy, the Policies covered in this Section shall govern.
Data Retention
Retention of Personal Data of 4Sync Users within the territory of Brazil will be handled in accordance with 4Sync Data Retention policy (see Chapter IV, Section 5 of the Privacy Policy).
Access to and Deletion of Personal Data
Pursuant to Law 13,709/2018 of the Brazilian Congress 4Sync Users within the territory of Brazil have the right to access their Personal Data that 4Sync maintains, as well as:
- request access to and rectification or erasure of their Personal Data;
- request anonymization, restriction or deletion of unnecessary and/or excessive Personal Data or Data processed not in accordance with the provisions of the GDPL;
- exercise the right of Data portability; and
- withdraw consent without affecting the lawfulness of processing and lodge a complaint with a supervisory authority.
To exercise this right, please send us a corresponding request to the 4Sync Data Protection Officer Constantine Boitsov, at privacy@4sync.com.
For more information regarding 4Sync Users' Rights set out above, please contact us at privacy@4sync.com.
4Sync is committed to resolving complaints about our collection or use of Personal Data. Brazilian individuals who have complaints regarding this Privacy Policy should first contact the 4Sync Data Protection Officer Constantine Boitsov, at privacy@4sync.com.
Disclosure of Personal Data to Third Parties, Onward Transfer
4Sync may disclose and transfer Personal Data processed within the territory of Brazil to third parties, as described in this Privacy Policy. The Personal Data disclosed will be used for the purposes set forth in this Privacy Policy.
You may request disclosure, notification of the intended purpose, correction, addition, deletion, and cessation of use or cessation of disclosure of your Personal Data to third parties by contacting our Data Protection Officer Constantine Boitsov, at privacy@4sync.com.
Notifying Third Parties about Personal Data Restriction, Rectification, Erasure
Where 4Sync has disclosed Personal Data of its User to any third parties, and the User has subsequently exercised any of the rights of rectification, erasure or blocking, 4Sync will promptly notify those third parties of the User's exercising of those rights. In no case 4Sync shall be liable for the failure of any third party to comply with such a User's request.
4Sync is exempt from this obligation if it is impossible or would require disproportionate effort.
Collection and Use of Sensitive or Special Categories of Personal Data
4Sync does not knowingly collect, store or in any other way process Sensitive Personal Data, such as:
- Personal Data, revealing racial or ethnic origin, religious or philosophical beliefs, political opinions, trade-union membership;
- Personal Data concerning health or sex life and sexual orientation;
- biometric data or genetic data;
- Personal Data of Children under the age of 18.
If 4Sync is made aware that it has received such Sensitive Personal Data, we will take reasonable steps to remove this Personal Data from our records.
