On this page you will find details of our Privacy Policy, in which we describe our actions involving the collection, use and transfer of personal data. The security of our customers, users, partners and employees is one of the pillars of our work. Therefore, when using Elos you are protected by our Privacy Policy and agree to accept it in full.
Also read our Política de Information Security and the Terms of use do Elos.
We use personal data to:
Note that in cases where Elos is integrated with a system administered by third parties (such as learning environments of educational institutions), data is collected and transferred from that system to Elos. Consequently, the responsibility for users' personal data is shared with that third party. We are always available to assist in taking measures that enhance the protection and security of our users' personal data; simply contact us through one of our official service channels.
DEFINITIONS:
In this instrument, we understand the expressions below according to the following definitions: MCONF: MCONF TECNOLOGIA LTDA, a limited liability company, registered with the CNPJ under No. 17.466.795/0001-20, headquartered in the city of Porto Alegre, State of Rio Grande do Sul, at Avenida Ipiranga, nº 321/301, CEP 90160-092, provider of the services offered by the PLATFORM, the PORTAL, and the IMMERSIVE.
PLATFORM: Software in a cloud computing format called ELOS, available on a website, offered by MCONF and owned, operated, and under the responsibility of MCONF, where USERS, SUBSCRIBER USERS, and THIRD-PARTY USERS can view and use the services offered by MCONF in the ELOS software, based on permissions established in accordance with the plans and/or contracts set forth in this document and its respective complementary documentation.
PORTAL: Software in a cloud computing format called ELOS PORTAL, available on a website, offered by MCONF and owned, operated, and under the responsibility of MCONF, where all USERS and SUBSCRIBER USERS can view and use the services offered by MCONF in the PORTAL software, based on permissions established in accordance with the plans and/or contracts set forth in this document and its respective complementary documentation. Its purpose is to manage the access of USERS and SUBSCRIBER USERS to the PLATFORM, as well as to manage their registrations.
IMMERSIVE: Software in a cloud computing format, called ELOS IMMERSIVE, available on a website, offered by MCONF, where some USERS of different types can view and use the services offered by MCONF in the IMMERSIVE software and, in some cases, in the PLATFORM software, based on permissions established in accordance with the plans and/or contracts set forth in this document and its respective complementary documentation. Its purpose is to mediate the access of USERS of different types to the PLATFORM, in addition to offering its own resources for interaction between said USERS.
USER: An individual or legal entity with an active and valid registration in the PORTAL and with permission to access the resources offered therein, as well as access to the PLATFORM and its features, as provided in this document.
SUBSCRIBER USER: A type of USER who deliberately chooses to subscribe to the services of the PLATFORM and/or the PORTAL in their premium version, upon full agreement to pay the monetary amounts informed on the official website of the PLATFORM or, on exceptional occasions and dealt with directly with MCONF, agrees to the values established in specific agreements duly recorded by contract and/or email.
THIRD-PARTY USER: An individual or legal entity who uses the PLATFORM and/or the IMMERSIVE based on a business definition of a SUBSCRIBER USER or a USER. The agreements established between THIRD-PARTY USERS and SUBSCRIBER USERS or USERS do not involve procedures with MCONF. A THIRD-PARTY USER will not be registered in the PORTAL to access the PLATFORM or the IMMERSIVE. The responsibility for granting and managing the access of a THIRD-PARTY USER to the PLATFORM or the IMMERSIVE lies with the SUBSCRIBER USER or USER.
CONTENT: Any and all digital files, in any format supported by the PLATFORM, and made available therein, as well as all images and texts produced or reproduced by all types of USERS during the use of the PLATFORM and/or the PORTAL and/or the IMMERSIVE.
DATA PROCESSING: Any operation performed by MCONF with the personal data of all types of USERS, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.
LGPD: Lei Geral de Proteção de Dados (BR) 13,709/2018 (General Data Protection Law of Brazil).
DATA PROTECTION OFFICER (DPO): Pedro Henrique Branco de Oliveira, whose contact email is dpo.mconf@silvalopes.adv.br , appointed by MCONF to act as a communication channel between the controller, data subjects, and the National Data Protection Authority (ANPD). Click here to view the appointment letter.
MCONF collects the minimum necessary Personal Data to achieve the purposes for which this data was collected, as follows:
Purpose | Personal Data | Legal Basis |
Registration | Registration Full name, email, CPF or CNPJ, full address, phone number. | Consent |
Service Execution | Profile photo (if provided) and information related to permissions and other identifiers, passed on by the data-controlling institution (e.g., student ID number, classroom/meeting name). | Legitimate Interest |
SUBSCRIBING USERS and USERS accept and agree that the information registered in the PORTAL and/or transmitted by the PLATFORM and/or by the IMMERSIVE may be published and/or provided in accordance with the provisions of this instrument and the stipulations below:
Specifically regarding the automatic subtitle generation feature, available on the PLATFORM, data sharing by USERS of any modality is optional, and their acceptance is requested the first time it is used. To revoke acceptance, simply open the microphone settings and uncheck the subtitle generation feature. Therefore, the use of the PLATFORM and the PORTAL is not conditional on the acceptance of the Terms of Use of the subtitle generation feature.
For the subtitle generation feature to be used, MCONF collects and shares the following data with third-party services: browser language and the speaker's voice data. This data is not stored in MCONF's databases; it is sent in real-time to the service that generates the subtitles displayed on the PLATFORM.
Important additional information:
For details of the feature provided by the third party service, see here.
By accessing and using pages hosted on elos.vc domains and subdomains, all USERS of all modalities, as well as visitors to the aforementioned pages, are subject to our Privacy Policy described here, which includes the generation and use of Cookies. Even after configuring your Cookie preferences, you can review and change them at any time by clicking <!-- OneTrust Cookies Settings link end →" data-wplink-url-error="true" target="_self">Definições de cookies.-->Cookie Settings.
SUBSCRIBING USERS and USERS understand and agree that MCONF may, occasionally, share the following personal data with partners, for the purposes of service provision (legitimate interest), financial, administrative, and compliance with communication routines between MCONF and SUBSCRIBING USERS and USERS:
The above data of SUBSCRIBING USERS and USERS may also be shared with subcontracted companies that perform services related to administrative, financial, and communication routines, such companies being: RD, Conta Azul, Hotjar, PipeDrive, Movidesk, Facebook, Google, E-notas, and Iugu.
Even while using computational infrastructure administered by third parties, MCONF does not authorize the use of information from USERS of any modality by its service providers.
MCONF will have access to THIRD-PARTY USERS' data when such data is necessary for the operation of the PORTAL, the PLATFORM, and the IMMERSIVE, as provided in this term and in its complementary documentation signed between MCONF and the SUBSCRIBING USER or USER who is mediating the THIRD-PARTY USER'S use of the PLATFORM and/or PORTAL and/or IMMERSIVE. MCONF will only use this data for technical and business analyses and support service provision, exempting itself from the obligation to mediate or resolve problems arising from the use of the PLATFORM and/or the PORTAL and/or the IMMERSIVE that are based on agreements entered directly between SUBSCRIBING USERS or USERS and their THIRD-PARTY USERS.
MCONF protects all personal data of USERS of all modalities using technically and economically reasonable standards of care considering current Internet technology, as well as the provisions of the LGPD. USERS of all modalities acknowledge that there can be no expectation of total security on the Internet against website invasion or other irregular acts. Even though MCONF chooses the world's leading data security service providers, MCONF disclaims responsibility for any possible cyber-attack or failure of security technologies that could lead to information being exposed.
MCONF reserves the right to provide the data and information of USERS of any modality, as well as of the entire system used in the PLATFORM, the PORTAL, and the IMMERSIVE, to its technical team, which may be composed of MCONF employees and/or a third-party company, who will be responsible for managing the security and reliability of the PLATFORM, the PORTAL, the IMMERSIVE, and the data of USERS of any modality.
All members of the technical team, whether MCONF employees or a third-party company, will sign a confidentiality agreement, declaring that they are obliged to maintain absolute confidentiality of all commercial, accounting, administrative, technological, infrastructural, technical information, that is, any data mutually disclosed as a result of maintaining the operation and security of the PLATFORM, the PORTAL, and the IMMERSIVE, refraining from using them for their own benefit or that of third parties, committing to ensure that their partners, employees with an employment relationship, and trusted third parties, informed of this obligation, also do so.
USERS of any modality authorize that the data registering their actions within the PLATFORM and/or the PORTAL and/or the IMMERSIVE (such as access days and times and other information about the use of functionalities) be published for other SUBSCRIBING USERS or USERS, as provided in this instrument, aiming mainly at the generation of reports on the use of services offered by MCONF.
Public content provided by the USER of any modality, including but not limited to the profile photo, is the property of the USER.
It is the exclusive competence of the Judiciary and legal bodies of Brazilian territory to duly request MCONF to provide personal data of USERS of any modality who demonstrably disrespect the terms and conditions present in this instrument and the legal provisions applicable to the case, MCONF reserving the right to provide the Judiciary and competent legal bodies with the personal data of USERS of any modality when duly requested.
INTERNATIONAL DATA TRANSFER
MCONF stores its database on third-party servers, contracted for this purpose, which may be located abroad.
In these cases, MCONF guarantees that your Personal Data will only be sent to a country whose National Data Protection Authority considers to have an adequate level of personal data protection, or provided that all requirements set forth in the applicable Brazilian legislation related to international transfer are met. You may exercise any of the rights described herein, at any time, through a free and facilitated procedure. To do so, simply send a request to MCONF via the email dpo.mconf@silvalopes.adv.br .
DATA SUBJECT RIGHTS
You have certain rights inherent to your status as a personal data subject. These rights aim to protect your personal data and safeguard your privacy.
Below is a list of these rights and how you can exercise them:
Data Subject Rights | |
Existence and Access | You have the right to confirm whether we process your Personal Data, as well as to access your Personal Data processed by us, upon requesting and receiving a document containing a full copy of your Personal Data and the respective processing performed with it.
|
Rectification | You have the right to request the correction or update of your Personal Data if you verify that it is incorrect or outdated.
|
Explanation | You have the right to obtain information about the processing performed by us with your Personal Data, such as, for example, what Personal Data of yours is collected, how it is used, with whom it is shared, and why, among other information. This Privacy Policy aims to offer all necessary information to ensure this right is met. If you do not understand any issue addressed here, or identify the omission of any subject, you may request clarification from MCONF. .
|
Erasure | You have the right to request the definitive deletion of your Personal Data from our database, or to request that they be anonymized, or further, to request that the processing of your Personal Data by MCONF be blocked. MCONF will always fulfill your request, except for deletion and anonymization requests, when the maintenance of the Personal Data is necessary for MCONF to safeguard its rights and/or comply with legal obligations. You are aware that in cases of deletion, anonymization, and blocking, you may be unable to access certain features offered by us.
|
Objection | You have the right to object to specific processing of your Personal Data, as well as to withdraw your consent that is tied to a specific processing purpose. In the latter case, MCONF may continue to process your Personal Data if the processing is supported by another legal basis other than consent. In case of objection, MCONF may demonstrate that it processes your Personal Data lawfully.
|
Data Portability | You have the right to request that the Personal Data stored by MCONF about you be sent to you, or sent to third parties you indicate, in a structured and interoperable format, where applicable to the service provided. |
Review of Automated Decisions | You have the right to request a review of decisions that have affected your interests and were made based on automated processing of your Personal Data. Although this prerogative is provided for in legislation, decisions made by MCONF are not automated, so this right is not applicable. |
You may exercise any of the rights described herein, at any time, through a free and facilitated procedure. To do so, simply send a request to MCONF via the email dpo.mconf@silvalopes.adv.br .
CHANGES TO THIS POLICY
MCONF constantly implements updates to its services, and such updates may reflect how your Personal Data is processed. Thus, whenever there are modifications in processing, this Privacy Policy may be altered. Changes may occur at any time and as often as necessary.
For this reason, it is important that you review this Privacy Policy periodically to be aware of these modifications. At the beginning of this Privacy Policy, we indicate the date of the last update.
CONTACT
MCONF is always available to clarify questions related to the processing of your Personal Data. In case of doubts, requests, problems, complaints, or suggestions related to this Privacy Policy, the processing of your Personal Data, or the exercise of your rights as a Personal Data subject, you should send an email to MCONF at the following address: dpo.mconf@silvalopes.adv.br .
The data protection officer for MCONF is SILVA LOPES CONSULTORIA EM COMPLIANCE E CIA LTDA., who can be contacted at the email address indicated above. MCONF will make its best efforts to respond to all emails as soon as possible.
A MCONF empregará os melhores esforços para responder a todos os e-mails no menor espaço de tempo possível.
English 
Português 
Español