• On the Services.
• In email, text, and other electronic messages between You and 2BeLive.
It does not apply to information collected by:
• Us offline or through any other means, including on any other Service offered or Application operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Application.
In order to receive information about Your Personal Data, the purposes and the parties the Data is shared with, contact the 2Be Live.
2BE LIVE AND DATA CONTROLLER
2Be Live Corporation, 28 Old Rudnick Lane, County of Kent, Dover, Delaware 19901, USA
2Be Live contact email: firstname.lastname@example.org
TYPES OF DATA COLLECTED
2Be Live does not provide a list of Personal Data types collected.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the Services.
Unless specified otherwise, all Data requested by the Services is mandatory and failure to provide this Data may make it impossible for the Services to provide its services. In cases where this Services specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact 2Be Live.
Users are responsible for any third-party Personal Data obtained, published or shared through the Services and confirm that they have the third party’s consent to provide the Data to 2Be Live.
CHILDREN UNDER THE AGE OF 18
The Services are not intended for users who are under the age of 18 years (“Minors”). Minors will only be permitted to access educational content on the Services through an Authorized User Account created by the Minor’s parent or legal guardian, or educational institution following written consent from the minor’s parent or legal guardian (each, a “Minor Representative User Account”) and in accordance with applicable laws and regulations. No photographs, physical addresses, names, contact information and/or any other form of Personal Data of Minors will be submitted, uploaded and/or otherwise input to the Services. By using the Services, You represent and warrant that You are of legal age to form a binding contract with 2Be Live and meet all of the foregoing eligibility requirements. If You do not meet all of these requirements, You must not access or use the Services.
MODE AND PLACE OF PROCESSING THE DATA
Methods of Processing. 2Be Live takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to 2Be Live, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by 2Be Live. The updated list of these parties may be requested from 2Be Live at any time.
Legal Basis of Processing. 2Be Live may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes. Note: Under some legislations 2Be Live may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which 2Be Live is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in 2Be Live;
• processing is necessary for the purposes of the legitimate interests pursued by 2Be Live or by a third party.
In any case, 2Be Live will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place. The Data is processed at 2Be Live’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by 2Be Live to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with 2Be Live using the information provided in the contact section.
Retention time. Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
• Personal Data collected for purposes related to the performance of a contract between 2Be Live and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of 2Be Live’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by 2Be Live within the relevant sections of this document or by contacting 2Be Live.
2Be Live may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, 2Be Live may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by 2Be Live.
In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by 2Be Live, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, 2Be Live will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from 2Be Live.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Your Right to Object to Processing. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in 2Be Live or for the purposes of the legitimate interests pursued by 2Be Live, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether 2Be Live is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Exercising Your Rights. Any requests to exercise User rights can be directed to 2Be Live through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by 2be Live as early as possible and always within one month.
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
Legal Action. The User’s Personal Data may be used for legal purposes by 2Be Live in Court or in the stages leading to possible legal action arising from improper use of the Services or the related Services.
The User declares to be aware that 2be Live may be required to reveal personal data upon request of public authorities.
System Logs and Maintenance. For operation and maintenance purposes, the Services and any third-party services may collect files that record interaction with the Services (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not Contained in this Policy. More details concerning the collection or processing of Personal Data may be requested from 2be Live at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” Requests are Handled. The Services does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
INFORMATION FOR CALIFORNIAN CONSUMERS
This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).
Categories Of Personal Information Collected, Disclosed Or Sold. In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about You:
Full name and surname
We will not collect additional categories of personal information without notifying You.
How we collect information: what are the sources of the personal information we collect? We collect the above mentioned categories of personal information, either directly or indirectly, from You when You use the Services. For example, You directly provide Your personal information when You submit requests via any forms on the Services. You also provide personal information indirectly when You navigate the Services, as personal information about You is automatically observed and collected. Finally, we may collect Your personal information from third parties that work with us in connection with the Service or with the functioning of the Services and features thereof.
How we use the information we collect: sharing and disclosing of Your personal information with third parties for a business purpose. We may disclose the personal information we collect about You to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose Your personal information to third parties when You explicitly ask or authorize us to do so, in order to provide You with our Service. To find out more about the purposes of processing, please refer to the relevant section of this document.
No sale of Your personal information. In the past 12 months we have not sold any of Your personal information.
What are the purposes for which we use Your personal information? We may use Your personal information to allow the operational functioning of the Services and features thereof (“business purposes”). In such cases, Your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use Your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use Your personal information for different, unrelated, or incompatible purposes without notifying You.
Your California Privacy Rights And How To Exercise Them
The right to know and to portability. You have the right to request that we disclose to You:
• the categories and sources of the personal information that we collect about You, the purposes for which we use Your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
◦ for sales, the personal information categories purchased by each category of recipient; and
◦ for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable You to transmit the information to another entity without hindrance – provided that this is technically feasible.
The right to request the deletion of Your personal information. You have the right to request that we delete any of Your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on the Services, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising Your right, we will delete Your personal information and direct any of our service providers to do so.
How to exercise Your rights. To exercise the rights described above, You need to submit Your verifiable request to us by contacting us via the details provided in this document.
For us to respond to Your request, it’s necessary that we know who You are. Therefore, You can only exercise the above rights by making a verifiable request which must:
• provide sufficient information that allows us to reasonably verify You are the person about whom we collected personal information or an authorized representative;
• describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify Your identity and therefore confirm the personal information in our possession actually relates to You.
If You cannot personally submit a verifiable request, You can authorize a person registered with the California Secretary of State to act on Your behalf.
If You are an adult, You can make a verifiable request on behalf of a minor under Your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle Your request. We will confirm receipt of Your verifiable request within 10 days and provide information about how we will process Your request.
We will respond to Your request within 45 days of its receipt. Should we need more time, we will explain to You the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill Your request.
Our disclosure(s) will cover the preceding 12 month period.
Should we deny Your request, we will explain You the reasons behind our denial.
We do not charge a fee to process or respond to Your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
INFORMATION FOR USERS RESIDING IN BRAZIL
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).
The grounds on which we process Your personal information. We can process Your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
• Your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the carrying out of a contract and its preliminary procedures, in cases where You are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of Yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that Your fundamental rights and liberties do not prevail over such interests; and
• credit protection.
To find out more about the legal bases, You can contact us at any time using the contact details provided in this document.
Categories of personal information processed. To find out what categories of Your personal information are processed, You can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process Your personal information. To find out why we process Your personal information, You can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to Your requests.
Your Brazilian privacy rights
You have the right to:
• obtain confirmation of the existence of processing activities on Your personal information;
• access to Your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of Your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny Your consent and the consequences thereof;
• obtain information about the third parties with whom we share Your personal information;
• obtain, upon Your express request, the portability of Your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of Your personal information being processed if the processing was based upon Your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke Your consent at any time;
• lodge a complaint related to Your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of Your personal information, which affect Your interests. These include decisions to define Your personal, professional, consumer and credit profile, or aspects of Your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if You exercise Your rights.
How to file Your request. You can file Your express request to exercise Your rights free from any charge, at any time, by using the contact details provided in this document, or via Your legal representative.
How and when we will respond to Your request. We will strive to promptly respond to Your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to You the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with Your requests. In cases where we are not processing Your personal information, we will indicate to You the physical or legal person to whom You should address Your requests, if we are in the position to do so.
In the event that You file an access or personal information processing confirmation request, please make sure that You specify whether You’d like Your personal information to be delivered in electronic or printed form.
You will also need to let us know whether You want us to answer Your request immediately, in which case we will answer in a simplified fashion, or if You need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of Your request, providing You with all the information on the origin of Your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that You file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate Your request to other parties with whom we have shared Your personal information in order to enable such third parties to also comply with Your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law. We are allowed to transfer Your personal information outside of the Brazilian territory in the following cases:
• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect Your life or physical security or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
DEFINITIONS AND LEGAL REFERENCES
Personal Data (or Data). Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data. Information collected automatically through the Services (or third-party services employed in the Services), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Services) and the details about the path followed within the Services with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User. The individual using the Services who, unless otherwise specified, coincides with the Data Subject.
Data Subject. The natural person to whom the Personal Data refers.
Data Controller (or Owner).
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Services. The Data Controller, unless otherwise specified, is 2Be Live of the Services.
The Services. The means by which the Personal Data of the User is collected and processed.
Service. The service provided by the Services as described in the relative terms (if available) and on this site/application.
European Union (or EU). Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Legal information. This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).