Privacy Policy

1. General information and definitions

Incentivare Brasil Viagens e Turismo Ltda. values ​​your privacy and created this Privacy Policy to demonstrate its commitment to protecting your personal data, in accordance with the General Data Protection Law (LGPD) and other laws that deal with the subject, as well as to describe how your privacy is protected by Incentivare Brasil Viagens e Turismo Ltda., when collecting, processing and storing your personal information.

1.1 Definitions

  • Holder: All individuals who will use or visit the Incentivare Brasil Viagens e Turismo Ltda. Website or Applications, or who will directly or indirectly use the services offered by Incentivare Brasil Viagens e Turismo Ltda., over 18 (eighteen) years of age or emancipated and fully capable of performing acts of civil life or those absolutely or relatively incapable who are duly and legally represented or assisted;
  • Personal Data: Means any information provided or collected by Incentivare Brasil Viagens e Turismo Ltda., by any means, even if public, that identifies or that, when used in combination with other information processed by Incentivare Brasil Viagens e Turismo Ltda., identifies an individual;
  • Purpose: The objective that Incentivare Brasil Viagens e Turismo Ltda. wishes to achieve from each act of processing personal information;
  • Necessity: Justification for which it is strictly necessary to collect personal data, to achieve the purpose;
  • Legal Basis: Legal basis that makes the processing of personal data for a previously defined purpose by Incentivare Brasil Viagens e Turismo Ltda. legitimate;
  • Consent: We process your personal data based on your consent. Consent is the express and unequivocal authorization granted by the holder of the personal data for Incentivare Brasil Viagens e Turismo Ltda. to process your data for a previously described purpose, in which the legal basis required for the act requires express authorization from the holder.

This policy applies, in general, to all Users and potential Users of the services offered by Incentivare Brasil Viagens e Turismo Ltda., including Users of the websites or other means operated by Incentivare Brasil Viagens e Turismo Ltda., and summarizes how Incentivare Brasil Viagens e Turismo Ltda., may collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, eliminate, evaluate or control the information, modify, communicate, transfer, disseminate or extract the data collected, including personally identifiable information, in accordance with the applicable legal bases and all privacy and data protection laws in force.

2. Collection and use of personal data

The holder is aware that he/she provides his/her information consciously and voluntarily through forms, e-mail, or any other means of obtaining data used by Incentivare Brasil Viagens e Turismo Ltda.

When registering, filling out a form or providing personal data by any other means, certain personal data requested will be kept confidential and will be used only and exclusively for the purpose that motivated the provision of the data.

3. Information we process

Incentivare Brasil Viagens e Turismo Ltda. may collect and process the customer’s personal data for the purposes described in this Privacy Policy. The types of personal data that we will process throughout the provision of services may include:

 

  • Registration information: In order to purchase packages or individual services, travel agencies may share with us some registration data, such as full name, identification document number or passport number in the case of international travel, contact telephone number, email address, date of birth, gender, address, mother’s name, among other necessary identification data;
  • Additional information: In order to proceed with the purchase of some services, some additional data may be requested for credit analysis and subsequent completion of the contract. Such data includes a scan of an identification document with signature (for example, ID or driver’s license), nationality, profession, position, monthly income, whether you own property, proof of residence, among other data;
  • Payment Processing and Banking Information: Incentivare Brasil Viagens e Turismo Ltda. may work together with third-party companies for online payment management, financing, among others to process purchases and acquisition of products and services made by you through travel agencies. It is important that you are aware that such companies may collect and store your information and data, including bank details and credit card details;
  • Information about other people: If you purchase a travel package for yourself and a companion(s), you must provide the necessary information so that the travel agencies can also provide the services to the companion. In this case, it is your responsibility to inform the other person that you will share personal data with service providers for this purpose, and this processing is subject to this Privacy Policy and the policies of the other providers involved;
  • Preference information: We may also receive information about your preferences and travel plans, including meal orders, seat selection, information about your frequent flyer/hotel/car rental program and airline class options, baggage and tickets. Everything provided for in this item will be considered as “Personal Information”;
  • Supporting Documentation in Case of Refund or Fine Review: In the event of an event that prevents the customer from using the contracted services, the customer may share information and supporting documents of such occurrence with travel agencies, which may reveal sensitive data of their own or third parties. Such documents may include, but are not limited to, health certificates, death certificates, birth certificates, among others, depending on the specific case. Travel agencies may share such documents with Incentivare Brasil Viagens e Turismo Ltda.;
  • Customer service: Should you need to contact the customer service department and/or our data protection area, via chat, phone calls and/or email, please be aware that Incentivare Brasil Viagens e Turismo Ltda. may collect the personal information necessary to fulfill your request and contact you using the contact information you have provided, as well as collect information about your communications with Incentivare Brasil Viagens e Turismo Ltda.

The personal data processed by Incentivare Brasil Viagens e Turismo Ltda. may vary depending on the service or service package contracted by the customer and the specificities and preferences that the customer may report or request.
In addition to the personal data mentioned above, we may receive information about the status of the trip, stay and consumption details at the accommodation from partners that are part of the provision of the services (e.g. airline, hotel, car rental company, etc.) for payment processing purposes. We may also process the data of children or adolescents to provide the services. In such cases, Incentivare Brasil Viagens e Turismo Ltda. undertakes to process such personal data in the best interest of the child or adolescent and exclusively for the provision of the services. According to current legislation, one of the parents or legal guardians must consent to the processing of the personal data of such data subjects. If such consent is not provided, Incentivare Brasil Viagens e Turismo Ltda. will not be able to process the personal data and, consequently, will not be able to provide the service to such data subjects. In other words, refusal to consent makes it impossible to provide the services in full in relation to the child or adolescent.

4. Sharing personal information

Incentivare Brasil Viagens e Turismo Ltda. may share the personal data collected with third parties, in the following situations and within the limits required and authorized by law:

  • With its customers and partners when necessary and/or appropriate for the provision of related services;
  • With companies and individuals contracted to perform certain activities and services on behalf of Incentivare Brasil Viagens e Turismo Ltda.;
  • With suppliers and partners for the provision of services contracted with Incentivare Brasil Viagens e Turismo Ltda. Such suppliers may be airlines, car rental companies, hotels around the world, amusement parks, companies that provide services for receiving and directing customers to the travel location, among others. Thus, we may share your personal information with these third parties or other business partners necessary for the purposes of providing the services;
  • For administrative purposes such as: research, planning, service development, security and risk management;
  • When necessary due to a legal obligation, determination by a competent authority, or court decision.

Incentivare Brasil Viagens e Turismo Ltda. has no control over the data protection practices that these suppliers, which are necessary for the provision of value-added services, have. Therefore, it is recommended that you check their respective privacy policies to understand how these suppliers will treat your personal data.

In addition to the above suppliers, Incentivare Brasil Viagens e Turismo Ltda. may use third-party service providers to help provide its own services. In this case, such providers will not have any decision-making power over personal information that they process on our behalf (Incentivare Brasil Viagens e Turismo Ltda.) independently.

Incentivare Brasil Viagens e Turismo Ltda. may share your personal data with third parties, including government agencies, in order to respond to investigations, legal proceedings, lawsuits or to investigate, prevent or take action regarding illegal activities, suspected fraud or situations involving potential threats to the physical safety of any person or if otherwise required by law.

If Incentivare Brasil Viagens e Turismo Ltda. is involved in a merger, acquisition or sale of all or a portion of its assets, your personal data may be shared with the acquiring company or person. In circumstances where the identity of the controller of your personal data changes as a result of any transaction, you will be notified of any choices you may have regarding your personal data.

Incentivare Brasil Viagens e Turismo Ltda. may share certain non-personal information (data that does not identify our users individually) with third-party service providers, trusted partners or approved researchers, in order to better understand which advertisements and services may interest you, to improve the overall quality and effectiveness of its services or their services, or to contribute to academic research.

5. Transfer of personal data outside Brazil

We may transfer personal data of data subjects to service providers located abroad.

If the data subject participates in a trip and/or event organized by Incentivare Brasil Viagens e Turismo Ltda., to a destination outside the country, it will be necessary to transfer their personal data so that the suppliers can provide such services.

Incentivare Brasil Viagens e Turismo Ltda. is authorized to process personal data regardless of the data subject’s consent and may transfer personal data to other countries provided that, alternatively:

(I) The country is classified as having an adequate level of data protection assigned by the ANPD or the transfer is authorized by the ANPD;

(II) Until there is a list of countries with an adequate level released by the ANPD, the country is classified by the European Commission, through an adequacy decision, as a country with an adequate level according to the GDPR criteria;

(III) The international personal data processing agent offers FGV at least one of the safeguards below:

  • Codes of Conduct regularly issued or binding corporate rules approved by the European Commission;
  • Standard Contractual Clauses issued by the ANPD or the European Commission;
  • Seals and Certificates of compliance or adequacy to the protection of personal data granted by entities recognized by the ANPD or the European Commission.

(IV) Obtain explicit and highlighted consent from the holders of personal data to carry out international transfer operations of such data, with prior information on the international nature of the operation and highlighting that the country does not have an adequate level of recognized data protection or that there are no safeguards for the compliance of the processing agent, as the case may be.

In cases where Incentivare Brasil Viagens e Turismo Ltda. is authorized to process personal data based on consent, Incentivare Brasil Viagens e Turismo Ltda. may transfer personal data to other countries provided that it obtains explicit and highlighted consent from the holders of personal data to carry out international transfer operations of personal data, with prior information on the international nature of the operation.

6. Retention of personal data

Incentivare Brasil Viagens e Turismo Ltda. strives to ensure that personal data is kept as up-to-date as possible and that unnecessary or excessive data is deleted or made anonymous whenever and as soon as possible.
In general, the data subject’s personal data will be retained for the time necessary to fulfill the purpose for which it was collected.

Incentivare Brasil Viagens e Turismo Ltda. may retain the data subject’s personal data for the period corresponding to the duration of any applicable legal limitation period after the end of the relationship with the data subject. Thus, it will be possible to store and maintain the data subject’s personal information and data while there is a relationship/link with the data subject, and/or to comply with legal obligations.

The processing of the data subject’s personal data will end when it is verified:

  • That the purpose for which the personal data was collected has been achieved or that the personal data collected is no longer necessary or relevant to achieve the specific purpose desired;
  • A statement from the data subject to this effect, especially in cases where Incentivare Brasil Viagens e Turismo Ltda. receives the data subject’s consent for a specific processing of personal data, if any, or in the event of a legal determination.

In such cases, except for the cases established by applicable legislation or by this Privacy Policy, personal data will be deleted or anonymized by Incentivare Brasil Viagens e Turismo Ltda., so that the data completely loses the ability to identify the holder of the original data.

7. Rights of personal data holders

Incentivare Brasil Viagens e Turismo Ltda., in the context of its personal data processing activities, reinforces its commitment to respect the rights of personal data holders, namely:

  • Right to confirmation of the existence of processing: The holder of personal data may question Incentivare Brasil Viagens e Turismo Ltda., whether processing operations are being carried out regarding their personal data;
  • Right of access: The holder of personal data may request and receive a copy of all personal data collected and stored;
  • Right to correction: The holder of personal data may request the correction of personal data that is incomplete, inaccurate or outdated;
  • Right to deletion: The holder of personal data may request the deletion of their personal data from databases managed by Incentivare Brasil Viagens e Turismo Ltda., unless there is a legitimate reason for their maintenance, such as a possible legal obligation to retain data.

In the event of deletion, Incentivare Brasil Viagens e Turismo Ltda. reserves the right to choose the deletion procedure to be used, committing to use a method that guarantees security and prevents data recovery:

  • Right to data portability: The data subject has the right to request that his/her personal data be transferred to another service provider, which must be done in a structured, commonly used and machine-readable format, as technically feasible;
  • Right to request the suspension of unlawful processing of personal data: At any time, the data subject may request that Incentivare Brasil Viagens e Turismo Ltda. anonymize, block or delete his/her personal data that has been recognized by a competent authority as unnecessary, excessive or processed in non-compliance with the provisions of the LGPD.
  • Right to revoke consent: The data subject has the right to revoke his/her consent. However, it is emphasized that this will not affect the legality of any processing carried out prior to withdrawal.

Changes to this Privacy Policy

This privacy policy is a dynamic tool and may be updated periodically to ensure that the information provided complies with the General Data Protection Law (LGPD). In this sense, Incentivare Brasil Viagens e Turismo Ltda. reserves the right to change this privacy policy at any time, by publishing the updated version on our website.

In the event of significant changes to the privacy policy, the customer may receive a notice to that effect or be notified through official communication channels.

 

São Paulo, Maio de 2022