Data Controller
NAME: Club Med Brasil S/A
CNPJ: 03.010.384/0001-11
ADDRESS: Rua Lauro Muller, 116, room 4201, Torre do Rio Sul Botafogo - Rio de Janeiro - RJ - ZIP Code: 22290-160
At Club Med Brasil, we value your trust in sharing your personal data with us and recognize that you may want to know how we handle this information.
This Privacy Notice ("Privacy Notice") is intended for all those who visit or in any way access or interact with the digital portal https://www.clubmedlive.com.br owned and operated by Club Med Brasil ("Club Med Brasil").
This Privacy Notice sets out the terms under which Club Med Brasil may carry out operations ("Processing") with your Personal Data ("Personal Data"), serving to provide full transparency regarding the way in which these Processing activities are carried out.
1. MAIN CONCEPTS
Before we delve into the main subject of this Notice, we would like to clarify some important concepts for your understanding of this material.
For the purposes of understanding, when we refer to "We," "we," or "Club Med," we are referring to Club Med Brasil S/A, which will act as the data controller, as it has the capacity to determine the means and purposes of the processing of personal data.
When we refer to "personal data," we mean all information that somehow identifies you or makes you identifiable, such as your name, ID, CPF, among other information.
The "processing of personal data" is any operation that Club Med performs with your personal data, such as activities related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation, or control of information, modification, communication, transfer.
When we mention "You" or "you," we are referring to the artists who use the Club Med Live platform.
As Controllers of some of your personal data, we present this Privacy Notice to provide transparency so that you have accurate information about how your personal data will be processed.
2. WHEN DOES THE PRIVACY POLICY APPLY?
This privacy policy informs about the ways in which we obtain, process, and use your data when:
- You visit the Club Med Live platform;
- You sign up on the Club Med Live platform.
3. WHAT PERSONAL DATA IS COLLECTED AND HOW?
Your personal data may be collected in the following ways:
- Data provided through the interaction of the data subject with the Club Med Live Platform or through filling out the registration on the Club Med Live platform.
The following data is collected:
Registration data
- Full name
- Document (CPF or Passport)
- Date of birth
- Photo (optional)
Contact data
- Email address
- Residential address
- Telephone
Professional data
- Artistic name
- Audience type (adult or family)
- Languages
- Biography
- Repertoire
- Performance type
- Group composition
- Backline and materials
- Artist's website
- YouTube channel
- Vimeo channel
- Facebook page
- Instagram
- Presentation video on YouTube/TikTok
- Press release
Activity data
- Connection IP address
- Cookies
There is also the possibility of requesting registration data for the purpose of identifying and accommodating the artist and their companions.
Although you may choose not to disclose certain information, this decision may deprive you of some of the services and features we offer. The essential information for the provision of our services and features is identified.
Registration data
- Full name
- Date of birth
- CPF or passport
- Telephone
4. WHAT COOKIES DOES CLUB MED LIVE USE?
4.1. What is a cookie?
When you use the platform, Club Med may place a file called a "cookie" on your device (computer, tablet, etc.) through your browser.
Cookies are files or information that can be stored on your devices when you visit the platform. Generally, a cookie contains the name of the site that originated it, its expiry time, and a randomly generated value.
Cookies allow your computer to be identified during your next visits to the platform. Therefore, each time you visit the platform, data from your previous visit may be retained.
Club Med Brasil uses cookies to facilitate use and better tailor the platform to your interests and needs, as well as to compile information about the use of our sites and services, helping to improve their structure and content. Cookies can also be used to speed up your activities and future experiences on the platform.
4.2. What cookies does Club Med Live use?
The Club Med Live platform uses, in particular, the cookies listed in the appendix of this Policy.
A) Cookies necessary for the provision of requested services.
Club Med may use strictly necessary cookies for the provision of requested services or information, in particular:
- Session identifier cookies;
- Authentication cookies;
- Performance cookies (such as cache);
The data collected by statistical cookies is not combined with other data processing operations and is only used to compile anonymized statistics.
These cookies do not allow tracking your navigation to other sites or pinpointing your geographic location accurately.
You can simply refuse cookies, especially statistical cookies (see "Disabling Cookies" below).
B) Tracking and customization cookies
Some cookies make it possible to analyze, optimize, and customize your navigation on the platform and even provide more relevant content of your interest. These cookies are only installed with your prior and express consent.
- Third-party cookies
While browsing the platform, cookies issued by third parties (communication agencies, audience measurement companies, personalized advertising providers, etc.) may allow them, during the period of validity of the cookies, (i) to collect browsing information related to the devices when consulting the platform and (ii) to determine the advertising content that could be tailored to your interests. The issuance and use of cookies by third parties are subject to the cookie management policies of such third parties.
5. FOR WHAT PURPOSES ARE PERSONAL DATA PROCESSED?
The above-mentioned personal data will be processed for the following purposes:
- Execution of contracts: The above-mentioned personal data will be processed for the operationalization of the partnership between the artists who register on the platform and Club Med;
- Organization of accommodation: When the partnership is established, the data will be processed to facilitate the accommodation of the artist and their accompanying person(s);
- Responding to your requests: for information related to the partnership, accommodation, and/or your personal data;
- Compliance with legal and regulatory obligations: we are required by law to retain certain basic access log data, including but not limited to the IP address of the originating connection, with date and time. This data is retained for a period of 6 (six) months;
- Provision of technical support: We may use, for example, technical information collected from your device to facilitate the support process and provide technical assistance in case of bugs or malfunctions in the platform. We also use the collected data, mainly but not exclusively, usage data of the platform and technical information from your device to improve the service itself by adding features or improving other aspects of it and its navigability.
6. WITH WHOM DO WE SHARE THE COLLECTED DATA?
When necessary, we may share your data with companies of the Club Med Group and operators and service providers who participate, directly or indirectly, in the development of Club Med Live activities, especially in the execution of the services provided by the platform.
Once the data is collected by the platform, Club Med Brasil can only share it in the following situations:
- With other companies of the Club Med Group, regardless of whether they are located in Brazilian territory, in order to achieve the same purposes related to this Privacy Notice, especially to provide the services offered and serve our Users;
- With partner companies, when necessary or relevant to the execution of Club Med Brasil's business activities, including but not limited to technical support to maintain the availability of the platform.
- To protect the interests of Club Med Brasil in any conflict or dispute, even if judicial, administrative, or arbitration;
- In the event of changes or corporate transactions involving Club Med Brasil, if sharing the data is necessary for the regular continuation of the platform's services;
- With administrative and/or judicial authorities, upon a court order to that effect or a request from authorities that have legal competence for it.
7. WHAT ARE THE RIGHTS OF THE DATA SUBJECTS AND HOW TO EXERCISE THEM?
We take your rights seriously. At any time, you have the possibility to exercise your rights regarding the processed data by making a prior request. Below are your rights regarding personal data:
- Confirmation of the existence of processing: obtain confirmation of whether your data is being processed;
- Access to data: obtain details of the personal information used by us;
- Data correction: correct, complete, or update your data;
- Anonymity or blocking of unnecessary data: request that your data be restricted or deleted, in cases where this request does not restrict our rights to keep the data as permitted by law;
- Data portability to another provider: the portability of your data will depend, necessarily, on the definitions presented by the national authority, safeguarding Club Med's interests and trade secrets protected by law;
- Information on data sharing: request information about the entities with whom we share your data;
- Information about not providing consent: the absence of providing consent may make it impossible to provide some of our program-related services.
- Withdrawal of consent: Club Med Brasil provides an easy option to withdraw consent (opt-out) applicable in situations where it is requested;
- Objection to processing: if you believe that your personal data is being processed in violation of the law, you can object to such processing;
- Deletion: At any time, you can request the deletion of your personal data by accessing the "my account" or "change password" tab. It is possible that, after requesting the deletion of your account on the platform, some data will remain stored for the purpose of fulfilling legal obligations or protecting the legal interests of Club Med Brasil or its business partners. However, if you request the deletion of your information, the remaining stored data will be used strictly to prove compliance with legal obligations by Club Med Brasil.
If you encounter any difficulty in exercising any of the rights provided in this Privacy Notice, please contact us via email at dpo.br@clubmed.com.
You can make any request you wish through our Data Protection Officer Communication Form.
All requests received will be processed free of charge and will be subject to a prior assessment of your identity and the feasibility of compliance in order to comply with any legal obligations that may prevent the complete fulfillment of the requests of data subjects.
8. WHAT SECURITY MEASURES ARE IMPLEMENTED?
Club Med is committed to ensuring the integrity and reliability of the data entrusted to it, especially by taking all necessary physical, organizational, and logistical measures to prevent any alteration or destruction of such data, particularly by ensuring secure access only to authorized personnel for processing.
We strive to implement security measures to protect our systems and databases. Among the security measures we have adopted are data encryption, information access control, use of firewalls, and implementation of an internal information security policy, software solution architecture with intrusion prevention, and use of HTTPS.
However, despite our best efforts, considering the nature and architecture of the internet, which includes elements that are beyond our control, it is impossible to guarantee that malicious agents will not be able to access or misuse personal data, as it is an inherent risk of using computer systems. For this reason, we encourage you to take appropriate technical security measures, such as keeping your access credentials (usernames and passwords) confidential and browsing on secure networks.
9. WHAT IS THE STORAGE PERIOD FOR PERSONAL DATA?
The data collected through the Platform will be automatically deleted when it is determined that they are no longer useful for the purposes that justified their collection or upon request of the data subject, as explored in item 7 of this Notice.
Regardless of any request, the data may be stored by Club Med Brasil for the prescriptive period related to the legal relationship with the Partner, for the period necessary for contractual negotiation that requires compliance with any legal or regulatory obligation, or occasionally for transfer to third parties, provided that the requirements of item 5 above are respected.
Thus, data related to access records to the Platform (date, time, and IP records) will generally be stored for a period of 6 months, in compliance with the Brazilian Internet Civil Rights Framework. Data collected through cookies will be stored for a maximum period of 90 days, and other personal data will be stored for 3 years from the last interaction of the User with the Platform or with Club Med Brasil, in compliance with the Civil Code.
10. DATA PROTECTION OFFICER (DPO)
Club Med Brasil has a Data Protection Officer (DPO) responsible for the processing of personal data, ensuring the best guidelines and practices when handling your personal data. The DPO is also the communication channel between Club Med Brasil and you regarding all matters related to the protection of your personal data in our activities. If you have any questions or requests, please contact the DPO via email at dpo.br@clubmed.com.
11. ARE YOUR DATA SUBJECT TO INTERNATIONAL TRANSFER?
We inform you that your personal data will not be transferred outside of Brazil. Our infrastructure (including backup servers) is located in Brazil.
12. LEGISLATION AND JURISDICTION
This Notice shall be governed, interpreted, and enforced in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13.709/2018, regardless of the laws of other states or countries, and the courts of the city of Rio de Janeiro, State of Rio de Janeiro, shall have jurisdiction to settle any disputes arising from this document.
13. REVIEW OF THE PRIVACY POLICY
Club Med reserves the right to modify this Policy, particularly if there are changes in the applicable legislation. Any modifications will be displayed on this page.
Updated version as of March 20, 2023.
Appendix I - List of Cookies
The platform uses 4 (four) cookies, including 3 (three) primary session and security cookies, and 1 (one) cookie when the User clicks on "remember me."
The cookies used are:
1. Remember_web (Used for "Remember me" at the time of login)
2. Club_med_talents_session (User browsing session)
3. XSRF-TOKEN (Security)
4. laravel_cookie_consent (Obtaining consent)