Privacy Policy
I. Introduction
- Hello! Thank you for your visit. We appreciate your interest in InternetLab. InternetLab (“Lab”, “We” and “Our”) is an association, a non-profit civil entity that promotes academic debate and knowledge production in the fields of law and technology, especially in the field of the Internet. One of our objectives is to raise awareness about the protection of personal data in today’s connected world.
- As a research center focused on digital topics, we believe that privacy and data protection are everyone’s fundamental rights. For this reason, this Privacy Policy (“Policy”) was created to reaffirm our commitment to (i) the security of your data, (ii) transparency in our data processing activities and (iii) your autonomy in managing your data.
- This Policy is applicable to the various environments in which InternetLab collects and processes personal data and is aimed at the following categories of personal data subjects (“you”, “your”)
- Visitors of InternetLab’s website: individuals who visit Lab’s website and subscribe to our newsletter (“semanário” and monthly newsletter);
- Participants in academic research: individuals who participate in academic research conducted by InternetLab and its national and international partners;
- Legal representatives: individuals who act as legal representatives of partners of InternetLab projects;
- Participants in events: researchers, speakers, interested parties or any individual who takes part in events organized by InternetLab
- If you have any questions or require any further clarification, please contact us at dpo@internetlab.org.br . In case you do not approve the content of this Policy, You may choose not to use InternetLab’s website. In this case, we recommend that You do not browse this site and do not interact with the activities carried out by InternetLab.
II. Our guiding principles
5. In our activities, we are guided by 03 (three) main guidelines. These are:
a. The data belongs to the data subject: the data provided to InternetLab belongs to You. As such, we always work for your benefit
b. We follow good practices concerning the processing of your data: InternetLab follows the applicable legislation, especially Law 13.709/2018 (General Data Protection Law – “LGPD”) and Law 12.965/2014 (“Marco Civil da Internet”)
c. We follow good practices concerning the ethical conduct of research: we encourage research and academic production for the production of knowledge in the field of law and Internet, always in line with ethical rules that guide the development of research in the country and the promotion or defense of human rights.
III Who are we?
6. InternetLab is a non-profit civil society entity governed by its Bylaws. As a research organization, we understand that our role as the controller and processor of personal data will depend on our attributions in partnerships. At all times, we seek to protect this data by employing technical and organizational security procedures.
IV. What data does InternetLab collect and how is it used?
7. Throughout our activities or participation in our surveys, You may, through forms, emails, contracts, data connection or interviews, provide data directly to InternetLab, which will be stored in our systems. We may also collect data made public by the data subject on social networks or made publicly available on the websites of courthouses or of others. In addition, we may obtain data from the authorized access to content from partner institutions.
8. The following are examples of our data collection and of the purpose of our processing:
Data collected to carry out our activities
| Purpose of processing | Data processed |
| We process data for the subscription and unsubscription from the “Semanário” and from the monthly newsletter | Name and email |
| We process data to compile statistics on access to content in our publications | Name, e-mail address and content-related data, such as date and time of registration, e-mail opening and unsubscription |
| We process personal data relating to registration to our events | Name, e-mail address, institution and professional occupation |
| We process the personal data of participants in our events, either to identify them, contact them or select them for lectures | Name, gender, race, ethnicity, e-mail or phone number |
| We process personal data to record our events | Name, gender, race, ethnicity, e-mail or phone number |
| We process personal data to record our events | Recording of the content provided by the speakers during the events promoted by InternetLab, as well as full name, nationality, ID numbers, and profession |
Data collected when accessing our website
| Purpose of processing | Processed Data |
| We collect device browsing data to improve the usability of the site. | IP address; information on the device used to access the site; geolocation data; technical data, such as browser information, URL, network connection, provider, mouse and keyboard events |
| We collect data related to the activities carried out by You on our site for the development of new functionalities, improvement of the site, statistical analysis of use and performance. | Activities carried out while You access our site |
| We may process information from visitors or partners who send us inquiries via our contact channel on the website. | Full name, email, subject, phone number and message. |
Data collected for the academic research we carry out
| Purpose of processing | Processed Data |
| We collected personal data in the researches carried out through interviews | Name, date of birth, address, personal preferences and habits, gender, sex, race, ethnicity, political opinion, as well as other data that may be established in specific Terms of the research |
| We may process personal data through Web Scraping research on social networks | ID, username, racial/ethnic origin, political and ideological positions, sex, gender, text published on social networks, date and time of publication, total likes and retweets obtained, address of tweets/posts/comments. |
| We may process personal data through Web Scraping research on social networks | Ad library data: ad text, ad publication date, ad circulation period, ad expenditure range, advertiser’s Facebook page ID, who paid for the ad, ad reach value range, demographics of people reached by the ad (age range and gender) and Federative Units (UFs) reached by the ad. |
| We can process personal data through research that analyzes rulings and decisions made available on court websites | Data contained in a court decision, such as the Court of Justice, registry number, case number, name of the rapporteur, the plaintiff/appellant and the defendant/appellee, racial/ethnic origin, political and ideological positions, sex, gender, as well as other data that can be established in specific terms of the research. |
| We may process personal data in the research we carry out in partnership with private companies and other research institutions | Gender, race, ethnicity, region, city, state, education, political position, contact information and information on the use of apps, as well as other data that can be established in specific terms of the survey. |
| We may process the personal data of electoral candidates for the purposes of conducting research | Candidate’s name, education, ID Number, age, gender, race, ethnicity, date of birth, party to which he/she is affiliated, office being contested, Federative Unit (UF), amount of declared expenses, assets, description of declared expenses, total votes obtained, final election status (elected or not elected), made available by the Superior Electoral Court (TSE). |
V. Sharing of personal data
a. Purposes of our sharing of personal data:
9. InternetLab may share your personal data with third parties, within the limits of the law or your consent, where applicable. Such sharing is intended to achieve the following purposes:
i. Sharing for research: InternetLab can share the data described in the third table of topic 4 with partner institutions. The aim of these partnerships is to make research feasible, which, depending on the case, may need the support of other entities for funding or to maintain the database. Whenever possible, the data will be anonymized or pseudonymized.
ii. Sharing to improve our users’ browsing: InternetLab may share data such as IP, device resolution, device type, operating system, browser, location, browser language, mouse and keyboard events, referral URL and access logs with technology companies. This sharing is intended to assist InternetLab in decision-making processes/improving the navigation of our users;
iii. Sharing to assist with information security services, as well as to analyze technical and operational problems and to assist with our needs and obligations linked to our activities: InternetLab may share data from its systems with partners in order to allow for technical troubleshooting, anti-fraud and security related to our activities, including our sharing with contracted third parties that provide cookie services or other activity monitoring technologies, as well as contracted cloud service providers, email marketing, document signing, among others;
iv. In addition to the sharing mentioned above, InternetLab may share your data to meet the demands of public authorities or court orders: InternetLab may share your personal data to respond, to the extent strictly necessary, to requests from judicial, administrative or arbitration authorities (e.g. court order, search warrant or subpoena).
b. Sharing to the degree and extent of your consent:
10. The sharing of InternetLab’s user and research participant data with our partners is essential to carry out our academic and information content production activities. Where necessary under applicable law, InternetLab will obtain your specific consent for sharing with such partners.
VI. How is data stored in InternetLab?
a. Storage form and precautions
11. InternetLab adopts the best security and privacy practices to ensure the integrity and confidentiality of your personal data. It therefore uses technologies such as access control, backup security, two-factor authentication, among others, always seeking to comply with the best practices in the market.
12. We would point out, however, that no process is completely secure and without risk of failure, so we have implemented specific protocols in the event of security incidents in order to minimize damage to the holders of personal data. In this sense, whenever necessary, we will notify personal data security incidents to the National Data Protection Authority (ANPD) and to the data subjects involved.
b. For how long is personal data processed by InternetLab?
13. Personal data will only be kept for as long as it is considered useful for the purposes for which it was collected. More specifically, we will keep personal data for at least as long as it is valid:
(i) research and interest in our research findings and methodology;
(ii) our contractual relationship, five years after its dissolution;
(iii) our obligations contained in law or regulations, being deleted as soon as the legal and/or regulatory obligation to store them ceases (e.g. Marco Civil da Internet, art. 15);
(iv) when deemed necessary for the defense of InternetLab in judicial, administrative or arbitration proceedings;
(v) until You request the deletion of Your data when processed on the basis of Your consent, unless one of the hypotheses provided for in art. 16 of the LGPD applies.
14. Your data may be deleted by InternetLab as a result of a decision by a competent authority.
15. InternetLab points out that You may request the deletion of your data in cases where it is processed with your consent (subject to the provisions of art. 16 of the LGPD) or in cases where data is processed unnecessarily, excessively or in breach of the LGPD.
VII. International transfer
16. InternetLab may transfer certain personal data abroad, as long as it is necessary to carry out research, to fulfill our activities or to carry out any activities described in this Policy. By agreeing to this Policy, You declare that you are aware that the processing of your personal data may take place outside Brazilian territory. Therefore:
a. In carrying out our activities, we always seek to enter into partnerships guaranteeing a high level of security in the storage of information, establishing contracts that respect the terms of this Privacy Policy and the applicable personal data protection legislation.
b. We may also store your personal data – always for the period necessary to fulfill the purposes described in this Policy or for our study, as a research body, guaranteeing, whenever possible, the anonymization of personal data – on servers located outside national territory, including, but not restricted to, cloud computing servers that follow international standards for the processing and security of personal data.
c. Whenever our research involves the international transfer of personal data, and this transfer is not indicated during the collection of personal data or in this document, we will provide You with all the necessary information regarding this personal data processing activity. In addition, where necessary, we may obtain specific consent to enable certain international transfers.
VIII. Users’ rights in the use of their data
a. Rights of the subject of personal data
17. You may, at any time, exercise your rights as a data subject by means of official communication to InternetLab through the channels dpo@internetlab.org.br or andre.houang@internetlab.org.br. We emphasize that these rights must be expressly requested by the data subject or their legal representative, so that InternetLab will seek to comply with your request as long as its ownership is proven. We are committed to complying with these rights, which is why we have detailed the content of each of them and how You can exercise them. Know your rights:
| Right | What does this right mean? |
| Right to be informed | You have the right to be informed about (i) the purpose, form and duration of the processing; (ii) the shared use of data with public and private entities; (iii) the possibility of not providing consent and its consequences; (iv) the identification and contact information of InternetLab. |
| Right to confirmation | You can confirm whether we process your personal data, i.e. whether we collect, process, use, store or share your data. |
| Right of access | The law ensures that the data subject has the right to access their personal data, which can be done in a simplified format, when answered immediately, or by means of a full statement, within fifteen days of the data subject’s request. within fifteen days of the date of the data subject’s request. |
| Right to rectification | This right is based on the principle of data quality, which ensures the processing of accurate, clear and up-to-date data. You can therefore request that incomplete, inaccurate or outdated data be corrected. When rectified data is shared with third parties, we will endeavor, whenever possible, to inform them of the need to update the data. |
| Right to anonymization, blocking, data deletion and objection | You can request the anonymization, blocking, deletion or opposition of your personal data when it is unnecessary, excessive or processed in breach of the LGPD. We recommend that your request states the reasons why You believe your data is being processed in breach of personal data protection legislation. We will then be able to get back to You with more precise information and answers regarding the facts in question. |
| Right to withdraw consent | You may freely revoke your consent to certain data processing at any time by expressly stating so. Please note that the request to revoke your consent does not include a request to delete the data processed with your consent, nor does it affect the lawfulness of our processing carried out prior to your request. We recommend that you make an express request for the deletion of data processed based on your consent. |
| Right to review automated decisions | In the case of decisions based solely on the automated processing of personal data, You may request a review of the decision if it affects your interests. |
| Right to petition | You have the right to lodge possible complaints regarding your data with the controller and with the ANPD. |
b. How and when to exercise your rights?
18. Should you wish to exercise any of your rights or still have any questions, our Data Protection Officer will receive your request via e-mail to dpo@internetlab.org.br. Based on your direct request, free of charge and at any time, InternetLab will strive to respond to your request within a reasonable time. In some cases, there may be legitimate reasons for InternetLab not to respond to a request, such as the existence of an obligation to retain data, either to comply with legal or regulatory obligations, or to enable the defense of InternetLab or third parties in disputes of any kind. We will inform You of this and try to resolve any doubts. Count on us!
IX. Cookies
19. The website may use cookies and/or similar technologies. It is therefore important that You are aware of InternetLab’s policy in this regard.
a. What are cookies and similar technologies?
20. Cookies are a standard feature of websites that allow small amounts of data to be stored on your computer or mobile device about your visit to a particular website. Cookies help Lab learn, for example, which areas of the website are useful to You and which areas need to be improved.
21. Thus, You can choose to accept the use of cookies and similar technologies, in general, by changing the settings of Your browser or by changing the specific settings of the website. However, if You disable them, Your experience with the website may be reduced and some features may not work as expected.
b. What cookies and similar technologies can be used by the website?
22. Below, we indicate the different types of cookies and similar technologies that may be used by us.
Essential cookies: allow you to browse the site and use its features. Without them, the site will not perform as well as intended, and it may not even be possible to use certain features.
Preference cookies: these collect information about your choices and preferences, and allow InternetLab to remember your language and other local settings, as well as to customize the site according to your preferences.
Analytical cookies: collect information about your use of the site and allow InternetLab to identify general patterns of use of the site. This information is only used to analyze platform traffic and performance, and not to identify your individual information.
c. How to manage these cookies and similar technologies?
23. You can refuse or accept cookies from the website at any time by changing your browser settings or by changing specific website settings. Information on the procedure to be followed to enable or disable cookies can be found on your Internet provider’s website via the help screen, or via the following links: Chrome; Firefox; Microsoft Edge; Internet Explorer. We reiterate, however, that if cookies are disabled, not all features of the website will work as intended.
X. Changes to the Privacy Policy
24. Internetlab may change this Privacy Policy at any time, and the version in force and available on this website will always be the most recent. Whenever any relevant condition of this Policy is changed, the new version will be posted on this website.
XI. Applicable law and jurisdiction
25. This Privacy Policy is governed by Brazilian law. Any dispute related to this Policy shall be submitted to the Courts of the Judicial District of São Paulo, State of São Paulo, unless otherwise provided by law.