Privacy Policy

Version updated on October 05th, 2020

Privacy Policy - GDPR

HOTMART respects your privacy and we are committed to taking all the steps in order to preserve it.

Thus, before you accept the Terms of Use from HOTMART, you should acknowledge and accept our Privacy Policy, with clear and complete information about the collection, use, storage, treatment, and protection of your personal data.

Therefore, we strongly recommend that you read and pay close attention to the Privacy Policy before you sign up to, or even browse, the HOTMART websites and platform.

DEFINITIONS

The terms stated in the item DEFINITIONS in the Terms of Use are used in this Privacy Policy with the same meanings.

Whenever the terms below are used in capital letters in this Privacy Policy, they have the same meaning as expressed in the current legislation [1].

Registration data: affiliation, address (including electronic address), PERSONAL qualification, understood as name, surname, marital status, and profession from the User.

Personal data: information relating to the natural person. Considered all data that can be directly or indirectly used to identify a person, for example: name, photos, email, bank details, medical information, geolocation, phone number, posts on social media, computer IP address, etc.

Processing of personal data: every operation made with PERSONA DATA, such as the ones relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, deletion, assessment, or control of information, modification, communication, transference, diffusion, or extraction.

1. COLLECTION OF PERSONAL DATA AND INFORMATION

Firstly, it’s important to highlight that it is indispensable for HOTMART to collect, store, and process personal data from users, in order to make it possible to provide the services through its Platform.

Therefore, it is necessary that you acknowledge and expressly and unequivocally accept the possibility that HOTMART may collect, receive and store, automatically, Personal Data and information in its servers about the activities from the users’ browsers, including geolocation, IP addresses, cookies, or other identifiable character sequences, and other information from the transactions made through the Platform.

Also, some personal data is necessarily collected by HOTMART to make it possible to execute the service agreement (Terms of Use) with the Users, as well as the legitimate interest in allowing the operations of the Platform.

Moreover, it is worth reminding you that, to make use of the tools offered by HOTMART, you must sign up to the Platform and, to do so, you must inform your complete name, date of birth, an identification number (such as id number, taxpayer’s identification number, or corporate tax number), phone number, and email address, as well as creating an access password for your exclusive use.

You are aware that is it your responsibility to provide true, exact, precise, updated and complete information when you sign up to access the Platform. We remind you that providing incomplete or false information constitutes a crime under the law and can lead to severe penalties to those who provide it.

2. CONTROL OF REGISTRATION DATA BY THE USERS

Each user holds control over the Registration Data in the profile created at HOTMART, being able to access such data and change it by using his or her login and password. We remind you that login and password are individual and known only by the user, who shall ensure the confidentiality of such data. HOTMART is not held responsible for the manner in which the User uses such data. The users may update their Registration Data with HOTMART through the HOTMART Platform.

3. COLLECT AND USE OF PERSONAL DATA AND INFORMATION COLLECTED

The Personal and Registration Data collected, as well as any other information collected, may be used in the communication between our team and you, in notifications about your activity with HOTMART tools, as well as system alerts and notifications.

Moreover, the Personal Data and Registration Data collected, as well as any other information and access registration to the HOTMART tools may be stored, treated, processed, and used by us with the following purposes:

enable the provision of services offered by HOTMART in an effective and efficient way, allowing the operationalization in a fast and safe manner;

help, whenever necessary and appropriate, that the Users (Producers, Affiliates, and Buyers) communicate amongst themselves, especially in cases of eventual disputes relating to CONTENT quality, delay in the delivery of CONTENT, Copyright, and Intellectual Property;

carry out analyses and studies relating to behavior, interest, and demography of Users, with the intent of understanding their demands and needs, in order to provide more adequate, efficient, and interesting services, improving the experience of usability of the HOTMART tools;

improve our commercial and marketing strategies, in order to make the services offered better; send Users, through messages, information relating to the products, services, advertisement, promotions, banners, and news from HOTMART.

3.1. Personal Data and User Rights

We highlight that it is the right of the user to receive clear and complete information, whenever formally requested, about personal data that is eventually collected and/or processed by HOTMART. For more detailed information on how data is collected, the use of cookies and similar tools, access our Cookie Policy.

Besides, the USERS may contact HOTMART to exercise their rights of exclusion, rectification, correction and restriction of use related to their personal data, as well as providing their personal data requested in a correct, structured and common formatting, whenever ensured by applicable legislation.

The Users may also exercise their rights and present complaints to the competent data protection authorities to act in their jurisdiction.

For the exercise of any of their rights linked to personal data eventually collected and processed by HOTMART, as well as to send questions about this issue, USERS should contact HOTMART via the email address gdpr@hotmart.com.

Users whose personal data has been collected and processed based on given consent, may, at any point in time, withdraw it, without affecting the legality of the collection and processing carried out by HOTMART during this period. Personal data collected under a legitimate interest on the part of HOTMART or needed to execute an agreement may be the object of inquiry via the email address gdpr@hotmart.com.

If the User withdraws their consent or requests the deletion of data collected and processed based on the legitimate interest and/or need to execute an agreement, the USER recognizes and accepts, from this moment on, that HOTMART will not be held responsible for any loss and/or damage caused to their personal data if the USER decides to withdraw consent.

It’s important to highlight that some personal data must, under legal obligation imposed to HOTMART by competent authorities, be kept in our files for a minimum period legally determined, even if the USER requests its deletion and/or change. To exemplify, data linked to fiscal documents, financial documents, individual or corporate taxpayer’s numbers, full name, and others necessary to identify a certain financial, tax, or fiscal operation will be kept by HOTMART even if its deletion has been requested.

In addition, even after the termination of the agreement and consequently of the User's account, HOTMART may maintain your personal data (in part or in full) in order to be able to address and resolve issues and fulfill user requests, as well as to allow the Platform account to be reactivated if requested. HOTMART will maintain this data for up to two (2) years, unless Users formally request the deletion of the data prior to the end of this period. In this case HOTMART will delete the data within 30 days of the User's request.

We stress, once again, that it is essential for HOTMART to collect, store, and process personal data from USERS, in order to make it possible to provide the services offered through its Platform.

Nevertheless, we guarantee to our Users to make our best efforts to keep all the personal data collected duly safe, protected, and confidential, however unfeasible it may be to ensure the complete inviolability of data in case of external attacks and system failure.

In such cases, we are committed to inform the USERS of the occurrence and which data has been breached, in the principle of transparency and trust that principle of transparency and trust that must always guide the relationship between HOTMART and its Users.

Please note that by withdrawing your consent and/or requesting the termination of your account on the Platform, you will be responsible for deleting, within a reasonable and appropriate timeframe, all third party data and information you have received and/or stored by virtue of the use of the Platform and its technological tools, while observing, under your sole and exclusive responsibility, the applicable data protection legislation.

3.2. User’s Responsibilities in Relation to the Protection of Data Collected

If the USER utilizes the HOTMART Platform, it means that they are likely the owner of a business that makes use of HOTMART services to sell their products. In relation to the customers’ personal data, collected by the Users and eventually delivered to HOTMART, we act as data processing entities and comply with the legal obligations related to the protection of personal data.

However, in this context, the USERS are perceived ad data controlling entities, as they are responsible for the collection of personal data from their customers. Thus, the USERS agree and recognize that they are exclusively responsible for completely respect the applicable data protection legislation, especially GDPR, is the customer whose data was collected is in a country in the European Union.

In relation to HOTMART suggesting certain features that may make it easier for the USERS to comply with the legislation on the protection of personal data, such as warning messages of data collection, Users recognize that HOTMART does not act in, nor does it offer, legal consulting services, therefore not holding any responsibility in this sense. HOTMART strongly recommends that the USERS seek legal and technical advice to make sure they are in conformity with the applicable laws and norms for their business, especially the ones that concern the protection of personal data.

4. STORAGE AND PROTECTION OF PERSONAL DATA COLLECTED

All the Personal Data from Users collected and processed as stated in this Privacy Policy will be stored in our database and processed until the moment in which the User withdraws their consent for us to do so. All remaining data, as specified above, will be kept for as long as necessary in order to serve the purpose it was originally collected for. We can also retain information as stated in the law.

The Data collected by HOTMART will be stored in safe databases, with the best practices, with access restricted only to employees with the appropriate credentials, who must keep the confidentiality of such information and not make use of it inadequately.

HOTMAT may store and process Personal Data collected, and other information collected in a server located in Brazil or abroad.

5. DISCLOSURE OF PERSONAL AND REGISTRATION DATA COLLECTED TO THIRD PARTIES

You accept that HOTMART may disclose Personal and Registration Data, such as complete name and electronic address, to the Buyer, Affiliate, and Producer in case of breach of Terms of Use that may incur in damages to other HOTMART Users or to third parties.

Likewise, you accept that, in an attempt to avoid illegal activities, in cases of suspicion of fraud, disputes, complaint about the Content or any indication of foul play by the Users, including the dissemination of SPAM and situations involving potential threats to the physical well-being of an individual, the Personal and Registration Data of Users involved can be provided to the harmed parties. In certain cases, if HOTMART deems necessary, it can provide the data collected to the bodies and institutions intervening in the investigation of resolution of disputes between Users or between Users and third parties, such as: insurance companies, arbitration awards, and other competent administrative bodies.

You accept that HOTMART may share, with Producers, Affiliates, and other commissioned partners, Personal and Registration Data from the Buyer, such as email, complete name, identification number (id number, taxpayer’s identification number, or corporate tax number), date of birth, telephone number and home address, for cases in which they have set up, in the Platform, to receive data from the purchases (including subscription) and developments (possible status of a purchase).

You also agree that HOTMART may share Personal and Registration Data collected with the providers of third-party services to HOTMART, with the intent of allowing the development of their respective activities and ensure the improvement of services and operations of the Platform, for instance, but not limited to, services such as: data backup, fraud-prevention services, service provision of emails and databases, issuing of invoices, amongst others. In this case, HOTMART demands from all service providers with which we share users’ Personal Data, to include in their contracts, clauses that ensure the protection and confidentiality in processing data.

You agree, moreover, that in an eventual business operation that involves the restructuring of the corporate group to which HOTMART is part, as well as the acquisition or selling of stocks and assets, the Personal Data may be considered one of the commercial assets to be transferred. In these cases, HOTMART may transfer the Personal and Registration Data if the company is bought or merged with (an)other company(ies).

Excluding the hypothesis stated in this Privacy Policy, the Personal and Registration Data, collected directly in the Platform, as well as the access registration to the Platform (ID address, date, time, and time zone) and the data relating to the transactions made through the Platform, may only be released to a third-party in the following cases:

  • by a request or specific authorization by the user him/herself;
  • in compliance with court order.

6. RETENTION OF PERSONAL AND REGISTRATION DATA AFTER TERMINATION OF ACCOUNT

You may terminate your account with HOTMART at any moment, by accessing Platform Setup, being ineffective any other means to achieve this end. Notified of the User’s request, in the terms of item 3.1 above, HOTMART will then proceed to definitively exclude the Personal and Registration Data provided by the User throughout the duration of the relationship with HOTMART, which may take up to 30 (thirty) days. The access registration (IPs), if there are any, will be discarded after 180 days of storage, in the terms of the current legislation.

7. SPAM

We are against all and any practice that promotes SPAM of any kind and we are committed to ensure that every message sent by the Platform are in the interest or are important to the respective recipient. Moreover, at any moment, the user may also choose to stop receiving messages from HOTMART by changing his or her preferences for receiving emails, or terminating his or her account, just like stated in the item above.

In the same manner, we ask our users not to practice any SPAM, that they make sure that the messages sent are always in the best interest of the recipient, being aware that the non-compliance with the good practices of the Internet may lead to the termination of the offender’s account in the HOTMART Platform, according to what is stated in the Terms of Use, as well as the release of Registration Data, stated in the terms of this Privacy Policy.

8. CHANGES TO THIS PRIVACY POLICY

HOTMART reserves the right to, at any moment, change this Privacy Policy by updating its content according to the needs of technological improvement or its functionalities.

When changes are made to the Privacy Policy, HOTMART will inform its users via an email or through a publication in a featured area in the Platform and will request you to acknowledge and accept the altered Policy Privacy.

If you continue to use the tools offered by HOTMART after the communication of changes in the Privacy Policy, this will mean and will be considered unambiguous consent and irrevocable and irreversible acceptance of all the terms and conditions in the altered Privacy Policy.

To view and access Hotmart’s Data Processing Agreement that is a part of the Terms of Use and Privacy Policy, just click here.

For any clarification and further information about this Policy Privacy, please contact us at suporte@hotmart.com, with “Privacy Policy” in the subject line.

  1. GDPR – General Data Protection Regulation – established by EU Regulation nº 2016/679; Brazilian Civil Rights Framework for the Internet – established by Brazilian Law 12965/2014.

Privacy Policy - LGPD

This Policy incorporates Hotmart’s Terms of Use. You should read the following conditions carefully, because they contain important information about the privacy and protection of your personal data. The handling of personal data is a condition for using the Hotmart Platform. It is not possible to offer the Platform’s features without having access to this personal data. This Policy and its respective updates shall prevail over all policies, proposals, contracts, prior understandings and agreements, verbal or written, which may exist between the parties dealing, directly or indirectly, with the subject of privacy.

INTRODUCTION

(I) The solutions contained on the Hotmart Platform (or simply “Platform”) are provided by LAUNCH PAD TECNOLOGIA, SERVIÇOS E PAGAMENTOS LTDA. (“Hotmart”), a private legal entity, registered with the Corporate Tax Number (CNPJ/MF - Brazil) under No. 13.427.325/0001-05, headquartered in Belo Horizonte/MG, at Rua Bernardo Figueiredo nº 33, 1º andar, Bairro Serra - CEP 30.220-140, Belo Horizonte – MG. In cases where purchases made by Buyers or Producers outside Brazil, part of the solutions will be directly provided by HOTMART B.V.a Dutch company with headquarters in Singel, at 542, 1017 AZ Amsterdam, The Netherlands, registration No. 60335777 (jointly, (“Hotmart”, “our” and “we”) and also subject to the specific HOTMART B.V. Privacy Policy.

(II) This Privacy Policy ("Policy") aims to establish the rules on (a) how and for what purposes the personal data is processed by Hotmart; (b) with whom such personal data may be shared; and (c) how Users can manage their personal data.

(III) Hotmart reserves the right, at any time, to change this Privacy Policy, updating its content according to the needs for technological improvement or of its features.

(IV) Whenever there is any change to the Privacy Policy, Hotmart will communicate its Users, alternatively, by publication in a prominent area on the Platform, by email, or by any other way that allows us to communicate with you. In the same manner, you should check this Policy’s updated version every time you visit the Hotmart Platform.

(V) If you do not agree with the new Privacy Policy terms, you must cease using the Platform.

(VI) This Policy’s official language is Portuguese. Any version in another language is a translation provided as a courtesy. In case of conflict due to interpretation, the version in Portuguese shall prevail for personal data processed by Hotmart.

1. GENERAL INFORMATION

1.1. Types of Users: Hotmart Platform Users are Producers, Affiliates and Buyers, as defined in the Terms of Use.

1.2. Forms of Data Processing: Hotmart’s processing of personal data will vary according to your behavior. The Hotmart Platform has a few features, among them are:

1.2.1. Hotpay: Payment platform made available to Producers so that Buyers can make purchases of Content or Services inside and outside the Platform (such as the "card machines" in physical stores). Hotpay also consists of a payment account, in which Producers can manage their balance resulting from their sales through the Platform. Hotmart will create an account for the Buyers, so that they can manage their purchases, if they wish to. A transactional email will be sent to Buyers confirming their purchases and payment details. In certain situations, and at the Buyer’s request, Hotmart will not send the transactional email. In these cases, sending it will be the responsibility of the Producer and/or Affiliate.

1.2.2. Producer Account Management: The platform used by Producers, in order to submit and control the Content. Affiliates can also use the Producer Account Management tool to manage the content they promote.

1.2.3. Hub: The area through which Buyers can manage subscriptions and purchases, by means of a password sent after the purchase of the Content.

1.2.4. Club: The area through which Producers make their Content available for sale to their Buyers, creating a members' area for the delivery of the Producers' content.

1.2.5. Display: Area through which the Producers make their Products available for sale via the Hotmart website.

1.3. Offer of Content: Our Platform has been developed to allow offers of content in various digital formats (video, audio, text, software, etc.) to be made to Buyers, created by or licensed to Producers by third parties ("Content”).

1.4. Tools: Among other activities, we collect personal data to provide Users with tools to provide, manage, offer, purchase and access the Content, depending on their performance on the Hotmart Platform.

1.5. Sharing with third parties: Through this Policy, we want to be transparent about what personal data about you we collect and use on the Platform. We remind you that some of your personal data is shared with third parties for the effective operation of the Platform.

2. DATA FROM MINORS UNDER THE AGE OF 13

2.1. Processing the personal data of minors: We do not collect or knowingly request personal data from minors under the age of 13. Users under the age of 13, or teenagers between 13 and 18, who are not duly emancipated or who are not properly represented or assisted by their parents or legal guardians, should not try to register to access the Platform, or send us any personal data. If we become aware that we have collected personal data from a minor outside these circumstances, we will cancel the account created on the Platform and delete the personal data, only keeping personal data with the purpose of avoiding another registration attempt.

3. PERSONAL DATA PROCESSED BY HOTMART

3.1. Buyer Registration Data: (a) Full name; (b) Email; (c) Password; (d) Other information that the Buyer wishes to add.

3.2. Registration Data for Events, Newsletter and / or Hotmart Relationships: (a) Name; (b) E-mail; (c) Other information that Hotmart may request for Events, Newsletter and / or Relationship.

3.3. Producer and Affiliate Registration Data: (a) Full name; (b) Email; (c) Password; (d) Date of birth.; (e) Address.; (f) Telephone; (g) Cell phone; (h) ID (i) Copy of ID (j) Country of residence; (k) Information referring to monthly income; (l) Other information that Producers and/or Affiliates wish to add (such as photo or profile description).

3.4. Payment Information: (a) Credit card information (including card number, name of the holder, validity and CVV code); (b) ID number (for the issuance of bank payment slip).

3.5. Support Data: (a) Name; (b) Email; (c) Subject; (d) Current country; (e) Language of the reply. At your discretion, you may submit other types of documents, information and/or data to Hotmart Customer Support ("Supplementary Documents"). Hotmart may request Supplementary Documents that will assist in the service.

3.6. Producer and/or Affiliate Support Data: (a) Name; (b) Email linked to the Payoneer account; (c) Proof of Residence; (d) Bank Receipt; (e) Email of partners and former partners. At their discretion, Producers and/or Affiliates may submit other types of documents, information and/or data to Hotmart Support ("Supplementary Documents"). Hotmart may request Supplementary Documents that will assist in the service.

3.7. Activity Data: (a) Platform use frequency; (b) Browser information; (c) Connection information; and (d) Purchase history, if the Buyer has an account.

4. HOTMART ACTING AS AN OPERATOR

4.1. Hotmart as an Operator Under certain circumstances, Hotmart collects certain personal data from Buyers according to instructions from third parties, and processes the personal data on behalf of these third parties. Below, we describe a few examples:

4.1.1. Data collected on behalf of Producers: Producers may request, through the Platform, additional personal data from Buyers at the time of purchase in order to provide the Content to the Buyers. The personal data requested may include, for example: (a) Name; (b) Email; (c) Address, with the submission of proof of residence; (d) ZIP code; (e) ID number; (f) Phone No.; (g) Instagram Profile; (h) Purchase history, if the Buyer has an account; (i) Country of residence.

4.1.2. Data collected for payments: Information necessary for processing transactions made via Platform, in which Hotmart acts as the operator of the respective financial institutions: (a) Credit card information (including card number, name of the holder, validity and CVV code); (b) ID number.

4.1.2.1. Data collected for international transactions: Information necessary for international transactions via Platform. This personal data is collected and shared with Hotmart B.V. for the operationalization of Hotmart B.V. activities. The personal data collected may include, for example: (a) Full Name; (b) ID number; (c) Credit Card Identification; (d) Transaction Code; (e) Country of Residence; (f) Amount Calculated.

4.1.2.2. Credit Card information: The credit card information collected through HotPay is in no way stored on the Platform, nor can it be passed on to Producers, who are not the controllers of this information.

4.2. Producer Control: Whenever Hotmart acts as an operator,this personal data will be transferred to the Producers and will be under their control. Therefore, Hotmart will not be responsible for the processing of this personal data by Producers. However, should Users request access to their personal data, we may, under certain circumstances, comply with such requests, if applicable.

4.3. Producer Statement: Producers state and acknowledge being the effective controllers of the Buyer's personal data, in the context of offering your products and services taking into account that in these cases, the Producer is the one who determines how the personal data of their customers (Buyers) is processed. Thus, the Producers acknowledge that they are solely responsible for fully respecting the applicable legislation on personal data protection, especially the LGPD (General Personal Data Protection Law).

5. PURPOSE OF HOTMART’S COLLECTION AND PROCESSING OF PERSONAL DATA

Data
Purpose
Buyer Registration Data
  • Register;
  • Link their Hotmart account to third-party social networks;
  • Identify Platform Users, including text messaging (SMS) or email;
  • Purchase Content;
  • Allow access to the Content;
  • Manage payments and subscriptions;
  • Send text messages (SMS) or email with transaction information, such as: Content access link, bank payment slip, due date notification, among others
  • Perform support activities;
  • Perform activities of fraud prevention analysis on the Platform;
  • File purchasing history;
  • Authenticate Users upon the submission of supporting documents.
  • Adjust the structure of events according to the Buyer’s special needs, an activity to be carried out by the Producer (Controller) or on his/her behalf;
Event Registration Data, Newsletter and/or Hotmart Relationship
  • Carry out registration in Events;
  • Sending Newsletters;
  • Sending Communications;
  • Sending Educational Material;
  • Media campaigns focused on advertising and promotions.
Producer and Affiliate Registration Data
  • Register;
  • Link their Hotmart account to third-party social networks;
  • Identify Platform Users, including text messaging (SMS) or email;
  • Allow User access (Producers and/or Affiliates) on the Platform, by means of identify authentication;
  • Check the authenticity of the information and documents provided by Users (Producers and/or Affiliates), including through processing and cross-checking
  • Provide services to Users;
  • Contact Users, when necessary;
  • Send communications;
  • Perform payment-related communication, such as sending transactional emails, allow access to the Content for Buyers and other related information;
  • Send email marketing, advertising and promotional email exclusively to Producers and/or Affiliates
  • Allow Producers and/or Affiliates to manage their account and balance;
  • Allow the purchase of Content by using the balance in the Producer’s payment account;
  • Operate the purchases of Content when Buyers or Operators are not located in Brazil;
  • Authenticate Users upon the submission of supporting documents;
  • Perform support activities;
  • Authenticate Users upon the submission of supporting documents; and
  • Customize User registration on the Platform.
Payment Information
  • Management of payments;
  • Authenticate Users upon the submission of supporting documents;
  • Management of purchase payments when Buyers or Producers are not located in Brazil, through Hotmart BV;
  • Perform activities of fraud prevention analysis on the Platform.
Support Data (Buyers, Producers and/or Affiliates)
  • Perform User support activities in order to meet the requested demands;
  • Registration verification;
  • Content verification;
  • User identity verification;
  • Update Producers registration on the Platform.
Activity Data
  • Customize the Platform according to the Producer and/or Affiliate’s experience;
  • Perform analysis and studies related to Producer and/or Affiliate behavior, interests and demographics;
  • Sending communications, such as email marketing, remarketing and other advertising campaigns on media channels.
  • Authenticate Users upon the submission of supporting documents;
  • Constant Platform improvements;
  • Store purchasing history.
  • Navigation analysis, including on the Display, to optimize the Platform and offer Products and Services.

6. COOKIES

6.1. Use of “Cookies”: When you access the Platform, we may use "Cookies" to recognize Users profiles and customize their experience on our Platform, as well as the services and other content available on the Platform.

6.2. What are “Cookies”? “Cookies” are small text files transferred to the User's device that help identify Users.

6.3. “Cookie” functionality: Certain features are only available through the use of Cookies. If the User disables or refuses this function, the use of the Platform or services may be limited or impossible.

6.4 “Cookie” Policy: For more detailed information on how personal data is collected, the use of cookies and similar tools, please visit our Cookie Policy.

7. EXCLUSION OF PERSONAL DATA

7.1. Retention Period: All User personal data process in accordance with this Policy will be maintained by Hotmart for as long as necessary for the respective purposes. We may also retain information as required by law or regulation or for the regular exercise of rights, or under circumstances where Hotmart or third parties have a legitimate purpose.

7.2. Requests for Exclusion: You may delete your Hotmart account at any time by accessing the Platform Settings, with the use of any other means to achieve this goal being ineffective. In this case, we may retain information as required by law or regulation or for the regular exercise of rights, or under circumstances where Hotmart or third parties have a legitimate purpose.

8. SHARING PERSONAL DATA

Hotmart may share your personal data with third parties, as described in the table below:

Data Shared
With whom?
Purposes for sharing
Registration Data and Activity Data (Users)
Companies and employees in Hotmart’s group
  • Provision of the services offered by the Platform.
  • Management of purchases when Buyers or Producers are not located in Brazil.
  • Improvement of the Platform’s features and of the services provided by Hotmart.
Registration Data and Additional Buyer Data
Information requested by Producers in order to provide the services
  • The Content made available by the Producer (Important: In this case, the sharing results from Hotmart's role as the Operator of the indicated Data)
Payment Information and Buyer Registration Data
Financial Institutions (Payment Information)
  • In this case, the sharing results from Hotmart's role as the Operator of the indicated Data.
  • Process payments made through the Platform for the purchase of Content. Sending confirmation of the purchase made through the Platform.
Buyer, Producer and Affiliate, Events, Newsletter and Relationship Registration Data; Payment Data; Support Data (Buyer, Producer and/or Affiliate); Activity Data
Judicial or governmental authorities
  • For compliance with requests made by judicial or governmental authorities, as provided in applicable law or regulation.
Buyer, Producer and Affiliate, Events, Newsletter and Relationship Registration Data; Payment Data; Support Data (Buyer, Producer and/or Affiliate); Activity Data
Financial, Accounting, Legal Consultants and Potential Investors
  • For analysis by the Hotmart business group.
  • For the eventual sale and/or acquisition of shares and assets.
  • For the restructuring of the Hotmart business group.
User Registration Data, Payment Data and Activity Data of Users and Visitors
Service Providers
  • Allow the development of Hotmart’s activities.
  • Allow the improvement of Platform services and operations, such as, but not limited to data backup, email and database service providers, invoice issuance services, among others.
  • Fraud prevention services to prevent illegal activities, disputes, complaints about the Content or any indication of illegality committed by Users, including the dissemination of SPAM and situations involving potential threats to someone's physical security. In certain cases, if deemed necessary, Hotmart may provide the data collected to bodies and entities that will intervene in the investigation or in the settling of disputes among Users or between Users and third parties, such as insurance companies, arbitration courts, and other competent administrative bodies.
  • To authenticate forwarded documents.
  • To Check lists of users with restrictions and allow customer support services.
  • Conduct analytical studies.
  • Processing and storage of personal data.
  • Sending communications, such as email marketing, remarketing and other advertising campaigns on media channels.

9. HOTMART SPARKLE INTEGRATION

9.1. Platform Linking: Users may link their Hotmart Account to an account on Hotmart Sparkle, Hotmart’s social network. To do so, Users can access Hotmart Sparkle with the same email and password used to access their Hotmart Account. From your first access on Sparkle, your personal data will be linked. Hotmart Sparkle may collect and process other types of personal data for other purposes, as described in the Hotmart Sparkle Privacy Policy.

10. INTERNATIONAL TRANSFERS

10.1. If your personal data is transferred to another country during the provision of services or an operation between Hotmart companies of the same economic group or the third parties described above, we (and the third parties, where applicable) will take the measures required by law to ensure that your personal data remains protected, and that such transfer is carried out in accordance with one of the transfer mechanisms provided for in the Brazilian LGPD (General Personal Data Protection Law).

11. RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

11.1. Rights and Guarantees: Users have rights and guarantees regarding their personal data. We provide mechanisms, which are detailed below, so that Users have clarity and transparency in exercising their rights. Whenever necessary, our team is ready to analyze any requests.

11.2. Rights provided in the LGPD: Pursuant to the General Personal Data Protection Law (Law 13.709/2018 in Brazil –) (“LGPD”), you have the right to:

  1. Confirm that we have carried out the processing of your personal data;
  2. Access your personal data;
  3. Request the correction of incomplete, inaccurate or outdated personal data;
  4. Request the anonymization, blocking or deletion of unnecessary, excessive or processed personal data that is not in accordance with the provisions of the LGPD;
  5. Request the portability of your personal data to another service or product supplier, observing our commercial and industrial secrets, after regulation by the Brazilian National Data Protection Authority;
  6. Request the deletion of personal data processed with your consent, except in the cases of conservation of personal data provided for in the LGPD;
  7. Request information about with whom we share your personal data;
  8. Request information about the possibility of not providing your consent and the consequences;
  9. Revoke your consent to the processing of your personal data, when processing is carried out based on your consent;
  10. Express disagreement to processing that violates the LGPD.

11.3. Additional Information: Before we respond to a request for the aforementioned exercise of the rights, we may ask you to provide us with information to confirm your identity.

12. SPAMMING:

12.1. Our Position: We are against any practice that promotes SPAMMING of any kind, and we are committed to ensuring that the messages sent by the Platform are always of interest or importance to their recipients. In addition, at any time, Producers can also choose to stop receiving Hotmart promotional emails by adjusting their preferences for receiving emails or canceling their account.

12.2. Hotmart Guidelines: In the same manner, we also ask our Users not to SPAM, to make sure that the messages sent are always of the recipients’ interest, being aware that failure to observe good Internet use practices may lead to the cancellation of the User's account on the Platform, as defined in the Terms of Use, as well as the disclosure of Registration personal data, under the terms of this Privacy Policy.

13. INFORMATION SECURITY

13.1. Data Storage: Personal data collected by Hotmart will be stored in secure databases, within the best practices, with restricted access only to employees with the proper credentials, who are obliged to maintain the confidentiality of the information and not use it inappropriately.

14. INFORMATION AND QUESTIONS

14.1. Questions about the Policy or Your Personal Data:If after reading this Policy you have any questions or would like to submit a request regarding your personal data, you can contact our privacy team or the person responsible through this form.