CameraPrive.com
Privacy Policy
Last Updated: October 01, 2022
A ONCAM LTDA., a limited liability company headquartered at Rua Apeninos nº 485, conjunto 121, in the City of São Paulo, State of São Paulo, CEP 01533-000, enrolled with the CNPJ/ME under No. 47.864.792/0001-06, (“OnCam”) is the legitimate operator of the website located at the address on the World Wide Web cameraprive.com (“Website”), and TRANSACIONA LTDA. a limited liability company headquartered at Rua Apeninos nº 485, conjunto 123, in the City of São Paulo, State of São Paulo, CEP 01533-000, enrolled with the CNPJ/ME under No. 47.864.922/0001-00 (“Transaciona”), is a company specialized in financial services and means of payment, and provides the Virtual Wallet available on the Website. As defined by law, both companies control Users Personal Data in the context of using the Website and the Virtual Wallet.
1. PRELIMINARY PROVISIONS
1.1. OnCam and Transaciona have jointly developed this Privacy Policy to ensure transparency and protection in relation to the processing of Users Personal Data.
1.2. This policy applies to Personal Data collected through the Website and the Virtual Wallet, for Personal Data collected in Brazil; from Users located in Brazil; and/or whose processing takes place in Brazil. This Privacy Policy provides for our practices for the collection, use, sharing, maintenance, protection, and sharing of Personal Data that may be processed by OnCam and Transaciona.
1.3. The Website may contain links to third-party websites, as well as plug-ins, services, social networks or applications. Access to these links or the permission of such connections may enable the collection or sharing of data about the User by third-party websites. We do not have control over the websites of third parties, so we advise you to read their respective privacy policies before providing any Personal Data.
1.4. The User acknowledges that they are solely responsible and assume all risks arising from the use of their Personal Data by any of these third-party websites, systems, and applications, exempting OnCam and Transaciona from any liability in case of losses caused by the transfer of data and use of these third-party websites, systems or applications.
1.5. CAREFULLY READ THIS PRIVACY POLICY BEFORE USING THE WEBSITE. DO NOT USE THE WEBSITE IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY. The completion of the acceptance box by clicking on an icon "I agree", "Agreed", or another "button" or input field written similarly or using a mouse, keyboard, or other computer device is the equivalent of the User's handwritten signature and binds the User, irrevocably and irreversibly, to the terms of this Privacy Policy.
1.6. This policy may be amended from time to time. Continuing to access the Website and the Virtual Wallet after these changes will constitute the acceptance and authorization of the User regarding these changes, so we advise you to read our privacy policy periodically.
2. DEFINITIONS
2.1. The following terms, when used in this Privacy Policy, shall have the following meaning:
2.1.1. “Virtual Wallet” means the national currency storage and transfer software provided and maintained by Transaciona, available on the Website, through which the User obtains access to certain content, functionalities, and services within the framework of the platform;
2.1.2. “Compliance with the Agreement” means the processing of the User's data when necessary for the fulfillment of a contract to which they are a party or taking of measures at the request of the User before the conclusion of said contract;
2.1.3. “Compliance with Legal Obligations” means the processing of the User's Personal Data when necessary to comply with legal obligations imposed on OnCam and/or Transaciona;
2.1.4. “CameraPrive Contracting Parties” means artists over 18 (eighteen) years of age who have contracted (i) the services offered by OnCam, consisting of the provision of virtual space on the Website, with the purpose of marketing their content to the Users of the platform; and (ii) the payment intermediation services offered by Transaciona, which allow the use of the Virtual Wallet within the platform;
2.1.5. “User Contributions” means messages, photos, videos, audio, or other materials posted, sent, published, displayed, or transmitted during interactions with other OnCam Users and/or Contracting Parties;
2.1.6. “Anonymized Data” means data relating to a holder that cannot be identified, considering the use of reasonable technical means available at the time of its processing;
2.1.7. “Personal Data” means any information related to an identified or identifiable individual, including, but not limited to, the information described in item 3.1 below;
2.1.8. “Sensitive Personal Data” means any information about racial or ethnic origin, religious conviction, political opinion, union membership or organization of a religious, philosophical, or political nature, data related to health or sexual life, and genetic or biometric data when linked to an individual;
2.1.9. “DoNotTrack” means a feature in browsers that allows you to disable the tracking of a User;
2.1.10. “Person in Charge” means the person appointed by OnCam and/or Transaciona to act as a communication channel between any of them, the Users, and the competent authority;
2.1.11. “Legitimate Interest” means our interest in operating and administering our business so that we can offer the User the best and safest experience on the Website, based on any and all possible impacts (positive and negative) on the User and their rights before processing their Personal Data in our Legitimate Interest. We do not use your Personal Data for activities where our interests outweigh the tolerable impact on the User (unless the User gives their consent or is otherwise required or authorized by law to do so). Contact us for more information on how we evaluate our legitimate interests to the detriment of any possible impact on the user with respect to any specific activity;
2.1.12. “Internet” means the system consisting of a set of logical protocols, structured on a global scale for public and unrestricted use, in order to enable the communication of data between terminals through different networks;
2.1.13. “OnCam” means OnCam Ltda., qualified in the preamble, which is the company responsible for the creation, development, and maintenance of the Website, the platform that enables Users to access the content created and marketed by CameraPrive Contracting Parties;
2.1.14. “Website” means the virtual platform available at the electronic address “cameraprive.com”, owned by OnCam Ltda., through which the User may access the content offered by CameraPrive Contracting Parties. This platform can also operate at other electronic addresses. Such electronic addresses are also included in this definition of a Website;
2.1.15. “Transaciona” means Transaciona Ltda., qualified in the preamble, a company specialized in financial services and means of payment, which is responsible for providing the Virtual Wallet and the payment tools available on the Website;
2.1.16. “User” means the user of the platform that uses the Website and the Virtual Wallet to interact with CameraPrive Contracting Parties and to acquire access to the content produced and marketed by them.
2.2. The headings of the clauses are for reference only and do not affect the interpretation of this Privacy Policy.
2.3. Unless otherwise provided for in this Privacy Policy, words in the singular include the plural and vice versa; words in the masculine gender include the feminine, the neutral gender, and vice versa.
2.4. By using the Website and accepting the terms and conditions of this Privacy Policy, the User agrees that OnCam and/or Transaciona may modify this Privacy Policy by advertising through the Website or Platform. The User shall monitor such changes and comply with such provisions and subsequent changes.
2.5. The changes will take effect on the date of the update, indicated at the top of the page. Changes will not have a retroactive effect, and OnCam and/or Transaciona will notify the User of changes to the Privacy Policy whenever commercially reasonable. However, the User must check the Website frequently to ensure that they are aware of its most current version. Upon posting of the changes, the User's use of the Website will mean that the changes have been accepted. If you do not agree with the changes, do not access the Website anymore.
3. DATA OBTAINED FROM THE USER
3.1. There may be the collection, use, storage, and transfer of different types of Personal Data about the User, such data being grouped as follows:
3.1.1. Identification Data includes the first name, surname, username, or other similar identification;
3.1.2. Contact Data includes billing address, email address, and telephone number;
3.1.3. Financial Data includes credit card information;
3.1.4. Transactional Data includes information about payments made by the User and other information about products and services purchased by the User;
3.1.5. Technical Data include IP Address, cookie ID, User login data, browser type and version, time zone and location, ISP name, browser plug-in types and versions, operating system and platform, as well as other device technologies used to access our Website;
3.1.6. Profile Data includes the user name and password, purchases or requests made by the User, their interests, preferences, feedback, and responses to surveys;
3.1.7. Usage Data includes information about how the User uses the Website, products, and services available on the Website, including complete Uniform Resource Locators (URLs); analysis of clicks to, on, or from the Website (including date and time); views or searches by CameraPrive Contracting Parties; views of live streams; page response times; download errors; duration of access to pages; page interaction information (such as scrolling, clicks, and mouseover); and methods used to exit the page;
3.1.8. Marketing and Communication Data includes the User's preferences to receive marketing campaigns from OnCam and our third parties, as well as their communication preferences.
3.2. There may be the collection, use, and sharing of Anonymized Data such as statistical or demographic data for any purpose. Anonymized Data may come from Users' Personal Data but is not considered Personal Data by law considering that this data does not directly or indirectly reveal the identity of the holder. For example, User Usage Data may be aggregated for purposes of calculating the percentage of access to a specific feature of the Website. However, in the remote event that it is possible to identify its holder, directly or indirectly, this data will be treated as personal data, therefore, subject to this Privacy Policy.
3.3. There will be no collection of Sensitive Personal Data from the User (including information about the User's race or ethnicity, religion or philosophies, political opinions, trade union associations, criminal records, health information, and genetic and biometric data), unless the User voluntarily provides it in their profile or through a live transmission.
3.4. If there is a need for us to collect Personal Data for the use of the Website by the User, and the User does not provide it upon request, the Website may not be used.
4. USER DATA COLLECTION METHOD
4.1. We adopt different methods of collecting data from and about the User, including the following forms:
4.1.1. Direct interactions. The User may provide information when filling out forms or communicating with OnCam and/or Transaciona by email or any other means. Such information includes information provided by the User for the creation of their account on our Website or in the Virtual Wallet; purchase credits; the request to send marketing campaigns; requests for information about products or services available on the Website; participation in contests, promotions or surveys; the sending of feedback; and the reporting of problems with the Website and/or the Virtual Wallet;
4.1.2. Automated technologies or interactions. When interacting with our Website, information about the User's equipment, actions, and browsing patterns, as described above, may be automatically collected. Such information is collected through cookies, server logs, and other similar technologies (see Cookies and automatic data collection technologies);
4.1.3. Third parties or publicly available sources. We may receive User Technical Data through (i) business partners such as affiliates of our affiliate marketing program; (ii) analytics providers such as Google; (iii) advertising networks; and (iv) search information providers such as Google and Personal Data and Financial, Contact and Transactional Data of payment service providers.
4.2. The User may provide User Contributions for publication and display in public areas of the Website or transmission to other Users of the Website or third parties. User Contributions are provided by the User at their own risk and although the User may determine their privacy settings relating to User Contributions by logging into their account, there are no perfect or impenetrable security measures. In addition, we cannot control the actions of other Users of the Website or third parties with whom the User chooses to share their User Contributions. Therefore, there is no way to guarantee that User Contributions will not be viewed by unauthorized persons.
5. COOKIES ON THE WEBSITE AND THIRD PARTIES
5.1. The Website uses cookies (as defined in the Cookie Policy) or other automatic data collection technologies to distinguish Users from the Website. With this, we can offer the User a better and more personalized Website, enabling:
5.1.1. Making an estimate of the number of Users and the usage patterns of the Website;
5.1.2. Storing Users' preferences to offer a personalized experience of accessing the Website according to their general interests;
5.1.3. Expediting the searches made by Users;
5.1.4. Recognizing the User when they return to access the Website.
5.2. Importance of Cookies. The User may refuse to accept browser cookies when changing their settings. However, if the User chooses to make such changes, some parts of the Website may become inaccessible and some functions may not function properly. Cookies will not be used by our system only if the User changes the settings of their browser so as not to accept them. For more information about the cookies we use and the purposes for which we use them, please see our Cookie Policy.
5.3. Part of the content or applications of the Website and the Virtual Wallet are provided by third parties, including their own creators. Such third parties may make use of cookies only or cookies combined with web beacons or other tracking technologies to collect information about the User when accessing the Website and the Virtual Wallet. The information thus collected may be associated with the User's Personal Data or there may be the collection of information, including Personal Data, about the User's online activities and on different websites or through other online services. Such information may be used to offer the User marketing content according to their interests (behavior) or another type of targeted content.
5.4. We do not control the operation of third-party technologies or the way the collected data is used. In the event of questions regarding an application or other type of targeted content, the User must contact the responsible third party directly.
6. PURPOSE OF PROCESSING USER'S PERSONAL DATA
6.1. We use the User's Personal Data to process financial transactions, offer products and services of CameraPrive Contracting Parties or partners, communicate with the User, marketing campaigns and promotions or carry out other operations, such as using data to improve and personalize their experience. The following are some examples of how the Personal Data of Users is used:
6.1.1. Presentation of our Website, the Virtual Wallet and information, products, services available, and support at the request of the User (the legal basis of such presentation being the conclusion of a contract between the User and OnCam and between the User and Transaciona, or our Legitimate Interest, more specifically, our economic interest in offering products and services to the User);
6.1.2. Compliance with our obligations and exercise of our rights arising from any contracts entered into with the User, including through the management of the User's Virtual Wallet, or compliance with legal requirements, including through the verification of the User's age (the legal basis for such compliance being the conclusion of a contract between the User and OnCam, between the User and Transaciona or compliance with legal obligations);
6.1.3. Fulfillment of the purposes for which the User provided their information or described at the time the information was collected (the legal basis for such fulfillment being the conclusion of a contract between the User and OnCam, between the User and Transaciona or our legitimate interest, more specifically, our economic interest in offering products and services to the User);
6.1.4. Notification to the User of changes to our Website, existing products, or services (the legal basis of such notification being the conclusion of a contract between the User and OnCam, between the User and Transaciona or our legitimate interest, more specifically, our economic interest in presenting the User with personalized offers);
6.1.5. Guarantee to display the content of the Website efficiently to the User and on their computer (the legal basis of such display being the conclusion of a contract between the User and OnCam, between the User and Transaciona or our legitimate interest, more specifically, our economic interest in improving the Website for CameraPrive Contracting Parties to make products and services available to the User);
6.1.6. Administration of the Website and carry out internal operations, including troubleshooting, data analysis, testing, research, statistics, and studies (the legal basis of such process being compliance with legal obligations or our legitimate interest, more specifically, our interest in administering our business, providing administration and IT services, implementing network security to prevent fraud and in the context of a commercial or corporate reorganization);
6.1.7. Provision of interactive features on the Website and in the Virtual Wallet, such as User Contributions (the legal basis of such process being compliance with legal obligations or our legitimate interest, more specifically, our economic interest in offering products and services to the User);
6.1.8. Protection of the Website, the Virtual Wallet, as well as the employees and operations of OnCam and Transaciona (the legal basis of such process being compliance with legal obligations or our legitimate interest, more specifically, our economic interest in protecting the Website, the Virtual Wallet, as well as the employees and operations of OnCam and Transaciona).
6.1.9. Suggestions and recommendations to Users of our Website about the products and services that may be of interest to them (the legal basis of such a process being our legitimate interest, more specifically, our economic interest in developing our products and services and expanding our business).
6.2. There will also be the use of the User's Personal Data so that we can contact them about the products and services of the OnCam Contracting Parties and third parties, as well as functionalities of the Website and the Virtual Wallet, according to their interest. If the User does not want their data to be used for this purpose, they must change their preferences in their profile. For more information, see Personal Data Usage Preferences.
7. SHARING OF USER'S PERSONAL DATA
7.1. OnCam and Transaciona may share the User's Personal Data with:
7.1.1. Any entity belonging to its corporate groups, including, but not limited to, holding companies, affiliates, subsidiaries, and subsidiaries;
7.1.2. Business partners, suppliers, service providers, subcontractors, and other third parties engaged by OnCam and/or Transaciona that support their respective businesses (such as providers of analysis and search tools that help improve and optimize the Website, the Virtual Wallet, and identity and age verification services). For example, OnCam uses Google Analytics to better understand how customers use the Website (read more about how Google uses user Personal Data here).
7.2. We require, by contract, that the confidentiality of Personal Data disclosed to third parties is maintained and that such data be used only for the contracted purposes.
7.3. OnCam and Transaciona may also share the User's Personal Data with third parties:
7.3.1. In the event of the sale or acquisition of any company or assets, in which case the User's Personal Data may be disclosed to the potential seller or buyer of said company or assets;
7.3.2. To a buyer or other successor in the event of a merger, sale, restructuring, reorganization, dissolution or sale, or transfer of part or all of the assets, in operation or as part of a bankruptcy, liquidation or similar process, if one of the transferred assets is the Personal Data held by OnCam and/or Transaciona;
7.3.3. Compliance with any court decision, law, or action, including in compliance with any governmental or regulatory requirement;
7.3.4. The fulfillment or application of the Terms of Use Agreement, Service Agreement and Other Covenants and other agreements entered into by OnCam and/or Transaciona;
7.3.5. For the protection of OnCam and Transaciona in relation to their respective rights, property or safety of the business, employees, customers, and others. Such protection includes exchanging information with other companies and organizations for cybersecurity, fraud protection, and credit risk reduction purposes.
8. INTERNATIONAL DATA TRANSFER
8.1. OnCam and Transaciona are located in Brazil. For operational reasons, there may be the processing, storage, and transfer of the Personal Data we collect to other countries that adopt different privacy laws, which may or may not be as comprehensive as the laws of Brazil.
8.2. Regardless of the country in which such processing, storage, and transfer take place and regardless of the processing, storage, and transfer requirements imposed by local legislation, we will adopt all necessary mechanisms to ensure that the User's Personal Data receives adequate protection.
8.3. By sending us your Personal Data or registering on our Website, the User authorizes the transfer, storage or processing of their data.
9. OPTIONS FOR USING THE USER'S PERSONAL DATA
9.1. We make our best efforts so that the User has choices regarding the use of their Personal Data, especially with regard to marketing and advertising. We have determined the following Personal Data control mechanisms:
9.1.1. Promotional campaigns. If the User does not want their Contact Data to be used for the promotion of our products and services or the products and services of third parties, the User may disable this option by logging into the Website and adjusting their account preferences in their profile or by sending an email with such a request to support@cameraprive.com. The User may also opt out of receiving marketing communications by responding to any promotional email or clicking on the links provided. Such opt-out does not apply to information provided to OnCam or Transaciona by virtue of any affiliate's operation.
9.1.2. Tracking and advertising technologies. The User may configure their browser to refuse all or some browser cookies or to alert them when websites trigger or access cookies. If the User disables or refuses cookies, some parts of the Website may become inaccessible or may not function properly. For more information about the cookies we use, see our Cookie Policy.
9.2. The Website and the Virtual Wallet may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or plug-ins that trigger third-party features. If the User accesses a link that directs them to any third-party website or triggers a third-party plug-in, they should note that such third parties have their own privacy policies and we have no responsibility or liability with respect to such policies. We strongly advise you to read such policies before submitting Personal Data to such third parties.
10. USER REQUESTS
10.1. The User may access, correct, and change their Personal Data by logging into the Website and accessing their account profile page.
10.2. In addition, the User may request access, correction, or deletion of any Personal Data that has been provided by the email support@cameraprive.com. In some cases, it will only be possible to delete the User's Personal Data by deleting their account. We will not be able to comply with a request to change information if, at our discretion, such change violates any law or legal requirement or adversely affects the accuracy of such information.
10.3. If the User deletes their User Contributions from the Website, copies of their User Contributions may remain visible on cached or archived pages or may have been stored by other Users of the Website or CameraPrive Contracting Parties. Our Terms of Use Agreement and Service Agreement and Other Covenants provide for proper access to and use of the information contained on the Website, including User Contributions.
11. SECURITY OF PERSONAL DATA
11.1. We attach utmost importance to the security of the User's Personal Data. We hire physical security equipment, and electronic security equipment and adopt administrative security measures to protect the User's Personal Data against loss, misuse and unauthorized access, use, alteration, or disclosure. We store all Personal Data provided by the User and use it behind firewalls on servers that adopt security protections. All Personal Data collected is encrypted.
11.2. The protection and security of the User's information also depend on them. The User is responsible for the confidentiality of the password provided to them (or chosen by them) to access certain parts of the Website and the Virtual Wallet. The User must not share their password with other people. We advise caution when providing information in public areas of the Website, such as live chats, which can be viewed by any visitor.
11.3. Unfortunately, the transmission of information over the Internet is not completely secure. Although we use our best efforts to protect User Personal Data, we cannot guarantee the security of Personal Data transmitted to our Website. Any transmission of Personal Data is at the User's own risk. We are not responsible for the circumvention of privacy settings or security measures provided on the Website.
12. RETENTION OF PERSONAL DATA
12.1. The User's Personal Data will only be retained for the time necessary to meet the purposes for which it was collected, including for the purpose of improving and maintaining the Website and the Virtual Wallet, as well as complying with any legal, regulatory, tax, accounting or disclosure requirements. The User's Personal Data may be retained for a longer period in the event of complaints or if we have reason to believe that litigation may be initiated in relation to our relationship with the User.
12.2. The appropriate period of retention of the User's Personal Data will be determined according to the nature and confidentiality of the Personal Data, with the possible risk of damage arising from the unauthorized use or disclosure of such data, for the purpose for which we process the User's Personal Data and whether we will be able to achieve such purpose by other means, and with the applicable legal, regulatory, tax, accounting or other requirements.
12.3. In some cases, the User may request the deletion of their data: see Access and correction of the User's Personal Data above or Cancellation of request below for more information. In some cases, the User's Personal Data will undergo an anonymization process to become anonymous, that is, it can no longer be associated with or identify its owner, including, but not limited to, for research or statistical purposes, in which case we may make use of such information indefinitely without sending notification to the User, since it is not considered, by law, as Personal Data.
13. PRIVACY OF PEOPLE UNDER 18 YEARS OF AGE
13.1. The Website is not directed to persons under 18 years of age, so we do not knowingly collect Personal Data from persons under 18 years of age. If we become aware that we have collected or received, in error or involuntarily, Personal Data from a person under 18 years of age, such information will be deleted. If the User believes that we have collected, by mistake or involuntarily, data from or about a person under 18 years of age, they should contact support@cameraprive.com.
14. NO TRACKING POLICY
14.1. The User may activate the non-tracking privacy preference in their web browser. Through DoNotTrack, the User may inform websites and online services that they do not want information about their access to the pages to be collected over time and on other websites and online services. OnCam and Transaciona undertake to offer the User relevant options regarding the information we collect and that is why we give the User the option of deactivation. However, we do not recognize or respond to DoNotTrack signals as the Internet industry has not yet determined the exact definition of DoNotTrack, what it means to comply with DoNotTrack and what the common approach to responding to DoNotTrack. For more information about DNT, visit www.allaboutdnt.com.
15. USER'S RIGHTS
15.1. The Brazilian User or resident and domiciled in Brazil will have the following rights, under the applicable data protection laws:
15.1.1. Request for access to the User's Personal Data, through which the User will receive a copy of their Personal Data held by us, as well as to verify their its legal processing;
15.1.2. Request for correction of incomplete, inaccurate, or outdated Personal Data;
15.1.3. Request for deletion of Personal Data considered unnecessary, excessive, or processed in violation of the provisions of the law. However, the User should note that it will not always be possible to comply with their deletion request due to specific legal requirements that will be explained, if necessary, at the time of their request;
15.1.4. Objection to the processing of the User's Personal Data. If we are acting in accordance with a legitimate interest (or legitimate interest of a third party) and, due to the User's situation, the User wishes to object to the processing of such information because they believe that such processing impacts their fundamental rights and freedoms. The User also has the right to object to the processing of their personal data for the purposes of direct marketing campaigns. In some cases, we may prove that we have legitimate reasons to process the User's information in a way that overrides their rights and freedoms;
15.1.5. Request for the restriction of processing of the User's Personal Data. With this request, the User may request that the processing of their Personal Data be canceled in the following cases: (a) if the User wnats us to determine the accuracy of the information; (b) if the use of the information is illegal, but without the request for deletion; (c) if the User needs the information to be kept by us, even if it is no longer necessary, to initiate, exercise or defend against litigation; or (d) if the User has contested the use of the information, but after due verification, by OnCam and/or Transaciona, of the presence of legitimate reasons to use it;
15.1.6. Request for the portability of the User's Personal Data to a third party. We will provide, to the User or to the third party indicated by the User, the User's Personal Data in a structured, mechanically readable, and usual format, in which case the User will be solely responsible for any damages caused by that third party to his/her person;
15.1.7. Withdrawal of authorization at any time if the processing of the User's Personal Data occurs with authorization. However, this will not affect the legitimacy of any processing carried out before the withdrawal of the User's authorization. In the event of withdrawal of the User's authorization, it is possible that OnCam and/or Transaciona may not be able to offer certain products or provide certain services to the User. OnCam and/or Transaciona will inform the User if this is the case at the time of withdrawal of their authorization.
15.2. If the User wishes to exercise any of the rights described above, they must contact support@cameraprive.com.
15.3. The User will not be charged any fee to access their Personal Data (or to exercise any of their other rights.
15.4. OnCam and Transaciona may request additional information from the User so that they can confirm their identity and guarantee their right of access to their Personal Data (or the exercise of any of their other rights). We have adopted this security measure to ensure that User's Personal Data is not disclosed to persons who do not have the right to access it. OnCam and Transaciona may also contact the User to request further information regarding their request in order to expedite their response.
15.5. OnCam and Transaciona make an effort to respond to all legitimate requests within one month. Occasionally, this period may be exceeded if the User's request is particularly complex or contains multiple requests. In this case, the User will be notified and kept up to date on the processing of their request.
16. CHANGES TO THE PRIVACY POLICY
16.1. Changes made to our privacy policy will be posted on this page. If such changes significantly modify the way in which we use or process the User's Personal Data, the User will be notified by email at their primary email address registered in their account or by notification published on the homepage of the Website. We advise you to periodically access the Website to check for any updates or changes to our privacy policy.
17. GENERAL PROVISIONS
17.1. This Privacy Policy was written in Portuguese and English. In the event of a conflict between the Portuguese and English versions of this Privacy Policy, the Portuguese version will prevail.
18. CONTACT INFORMATION
18.1. The Website is administered by ONCAM LTDA. Questions, comments, and requests about this Privacy Policy, if related to the Website, should be sent to the email admin@oncam.com.br.
18.2. The Virtual Wallet is administered by TRANSACIONA LTDA. Questions, comments, and requests regarding this Privacy Policy, if related to the Virtual Wallet, should be sent to the email admin@transaciona.com.br.