Hello! This Privacy Policy demonstrates the commitment of RENKIN - SOLUÇÕES DIGITAIS LTDA., a limited liability company, registered with the legal entity identification number 39.977.496/0001-93, headquartered at Avenida Angêlo Piva (“Tongue Tie App”) with the protection of personal data of its Users, presenting the treatment of the data of all those who register in the Tongue Tie App in a simple and transparent way, available at: https://tonguetieapp.com (“Platform”).
The functionalities made available on the Platform are intended for Users over 18 (eighteen) years old. Any accesses made by individuals under 18 (eighteen) years should only be performed under the monitoring of their legal guardians.
The Platform is intended for partners of the Tongue Tie App ("Users"), who will be able to simplify the management of laboratory exams and patient data by using the app, including the storage of these data for easy consultation by the User.
To use the Platform, the User must be previously registered, where information and data will be requested, which are specified and for the purposes highlighted in this Policy.
By registering on the Platform, the User declares that they have read this document carefully and thoroughly, being fully aware of the treatment of personal data for the purposes presented. If you have any questions about the operation of the platform or other conditions of the service, access our Terms and Conditions of Use.
Some explanations to facilitate the understanding of the document:
Whenever the Tongue Tie App indicates an article without naming its corresponding law, it is because the article belongs to the list of articles of the Brazilian General Data Protection Law (LGPD, Lei Geral de Proteção de Dados). To make this reading more enjoyable, the Tongue Tie App decided to suppress the repetition of the name of the law.
To better understand the policy context, consult this glossary.
Personal data: information related to an identified or identifiable natural person.
Holder: the natural person to whom these personal data refer, the object of treatment; in this case the Users.
Controller: person, whether natural or legal, who is responsible for decisions regarding the treatment of personal data.
Operator: natural or legal person, under public or private law, who does the treatment of personal data on behalf of the controller.
ANPD: Autoridade Nacional de Proteção de Dados (Brazilian Data Protection Authority).
Anonymization: use of reasonable and available technical means at the time of treatment, whereby data inserted lose the possibility of association, directly or indirectly, with an individual.
Consent: free, informed, and unambiguous statement by which the holder agrees with the treatment of their personal data for a specific purpose.
Treatment: any operation performed with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication , transfer, diffusion, or extraction.
Elimination: deletion of data or data set stored in a database, regardless of the procedure employed.
Cookies: text files sent and stored in your browser in order to recognize, track, and temporarily store your browsing history.
What personal data does the Tongue Tie App collect?
The Tongue Tie App collects the following personal data when using the Platform and/or when the User submits them in other interactions with the Tongue Tie App, and includes the following categories and purposes highlighted below
| Data collection | Collection Purposes |
|---|---|
| Registration data | |
| Full name |
Identifies the User and Authenticate their access on the Platform. Makes our services available to Users, complying with the agreed obligations. We contact the User to inform about new features and news related to the Platform. |
| Payment data | |
|
Allows the User to access restricted areas of the Platform. Makes our services available to Users, complying with the agreed obligations. This allows us to charge a monthly fee for your subscription service. |
|
| Credit Card Information | |
| Name printed on Credit Card | |
| Billing address | |
| Digital Identification Data | |
| Source IP and Logical Port |
Allows the User to access restricted areas of the Platform. Complies with legal obligations of record keeping established by the Marco Civil da Internet (Brazilian Civil Rights Framework for the Internet - Law 12.965 / 2014). Monitors and guarantees your security and the security of the Platform during your access. |
| Records of actions taken | |
| Accessed Screens | |
| Session ID | |
| Cookies | |
The Personal Data collected above are essential for the provision of services by the Tongue Tie App, if the User chooses not to provide any of the Data listed, they may be unable to fully enjoy the services available on the Platform.
The Tongue Tie App is not responsible for the information that the User provides, and the User must provide legal, authorized, and true information.
If the User accesses the Platform accredited by third party applications (such as Google or Facebook), the Tongue Tie App will import their personal registration data, treating it for the purposes informed.
Personal Data of Third Parties Inserted in the Platform
During the use of the Platform, the User may insert Data from third parties that are under their control, and shall be responsible for the origin, lawfulness, and validity of this Data, and must use them only with the knowledge or (when applicable) consent of the holder, responding for these holders, third parties, or the Tongue Tie App for any damages caused as a result of non-compliance with these terms and conditions. The Tongue Tie App, in turn, will only treat these data in accordance with the purpose of the Services provided, having no decision-making power over the use of these or making any value judgments about their content, merely following the User's guidelines.
The User may, at any time, include, change, or delete their Personal Data, and must follow the procedures informed on the Platform for this.
The User is informed that they are solely responsible for the fulfillment of all requests from the Holders whose Personal Data are under their control and are inserted in the Platform, exempting the Tongue Tie App from any responsibilities in this regard, and must communicate whenever necessary to the Tongue Tie App about an eventual need for exclusion or limitation in the treatment of this Data.
If the Tongue Tie App directly receives any requests from the holders or from judicial and administrative authorities regarding the treatment of the Personal Data of third parties entered by the User on the Platform, it will communicate the User so that the user can perform the necessary procedures in view of the said request, being able to carry out the action required by court or administrative order if necessary.
How do we store your data and how long is it stored?
The Data is stored on Google's servers, located in Brazil and abroad, following the necessary information security parameters in order to guarantee the confidentiality and integrity of your Data. We may also use cloud storage services (“cloud services”) for the storage of the Data, and eventually it may be necessary to transfer or process this Data outside of Brazil.
The Tongue Tie App only stores your Data for the necessary period of time for the fulfillment of its purpose, for the duration of the contract, under the terms of Art. 9, item II of the LGPD, or by legal obligation. As soon as the treatment is completed, the Tongue Tie App guarantees the deletion of the personal data of its users in the form of article 16 of the LGPD. Likewise, the user may request the deletion of their personal data based on article 18, item VI of the LGPD.
Please note that even after requesting exclusion, some Data may have to be kept for a period of time in order to comply with legal obligations, as demonstrated below:
- 5 (five) years under the terms of Articles 12 and 27 of the Consumer Protection Code
- 6 (six) months in relation to Digital Identification Data, pursuant to Article 15 of the Marco Civil da Internet (Brazilian Civil Rights Framework for the Internet - Law 12.965 / 2014).
The storage time may be longer for auditing procedures, compliance rules, or if specific legislation so require.
Data Sharing Assumptions
To fulfill the purpose of providing services, we may share some of your Data in the following circumstances:
- For validating the means of payment and payments made.
- In case of corporate movements that occurred in the Tongue Tie App, such as merger, acquisition, and incorporation.
- With competent judicial, administrative, regulatory, or governmental authorities, whenever necessary due to legal determinations, requirements, or court orders.
The Tongue Tie App guarantees that the treatment of your personal data by third parties will be carried out with the minimum information necessary to achieve its purpose, as well as having the same level of protection as required by law.
How do we guarantee the protection of your Data and how can Users protect themselves?
In compliance with articles 2, item I and articles 46 and 50, the Tongue Tie App guarantees that it adopts security measures in order to guarantee the complete integrity and confidentiality of the Personal Data inserted within the scope of the Platform. Unfortunately, as no system is 100% (one hundred percent) secure, the Tongue Tie App recommends that the User creates robust passwords, alternating between letters, numbers, and special characters, reinforcing the applicable security level.
It is also important that the User does not share their access data, passwords, or other information with third parties. We also recommend that the devices used for access are protected with a password and that the User always end navigation or log off the device as soon as it is finished using the Platform.
It is also especially important that the User knows that electronic messages asking for confirmation of data or with attachments that can be executed (extensions: .exe, .com, among others) will not be sent by the Tongue Tie App or links to any downloads, as well as confidential information, such as a credit card number, will not be required when using the Platform.
When using the Platform, the User may be taken, via a link to other portals or environments, which may collect their information and have their own Data Treatment Policy.
It is up to the User to read the Privacy and Data Treatment Policies of such portals or environments outside our Platform, and it is their responsibility to accept or reject them. The Tongue Tie App is not responsible for the privacy and data processing policies of third parties or for the content of any websites, content or services linked to environments other than those of the Platform.
What are the Holders’ Rights?
The Brazilian General Data Protection Law established rights to the holder of personal data in its article 18, such as the rights to:
- Access: the right to be informed and to have access to their personal data being treated by the Tongue Tie App.
- Rectification: the right to update or change their outdated, incomplete, or incorrect personal data.
- Portability: the right to request that personal data being treated by the Tongue Tie App be transferred to another controller.
- Elimination: the right to have their personal data deleted by the Tongue Tie App.
- Anonymization: the right to request that excessive personal data to be treated are anonymized or suspended.
- Revocation: the right to revoke their consent for the purposes of the treatment of personal data when applicable.
- Information on the impacts of the revocation: the right to be informed about the consequences of the relationship with the Tongue Tie App and to execute a specific treatment purpose when applicable.
- Opposition: the right to object to the treatment of personal data.
It is important to note that if the User withdraws consent for the treatment of essential data to achieve an intended purpose, certain features of the Platform may be unavailable.
For the User’s and our own security purposes, we may request additional identity validations to fulfill their rights.
In keeping with the principle of transparency, the Tongue Tie App provides the following email address so that the holder can exercise their rights by contacting our Data Supervisor:
Without prejudice to the above, the User may also send requests or complaints regarding the treatment of their personal data to the official channel of the Agência Nacional de Proteção de Dados (National Data Protection Agency).
We also remember that the Tongue Tie App is only responsible for the fulfillment of the rights of the Platform Users and in relation to the data provided for the purposes established in the data table of this Policy.
How does the Tongue Tie App use Cookies?
The Tongue Tie App uses cookies to improve the experience of its Users on the Platform
Cookies can be divided into Session Cookies, which are temporary Cookies that will remain on your device until the User finishes browsing and Persistent Cookies, which are Cookies that remain on your device until deleted (the time the Cookie will remain on device depends on the duration of the "lifetime" of the specific cookie and the settings of the browser used).
The cookies used by the Tongue Tie App, as well as the purpose of use and their expiration time, can be defined below:
| Cookie | Validity | Objective |
|---|---|---|
| what-intent | Session Cookie. | Cookie used to identify which device the user accessed the Platform from. |
| @@scroll# | Session Cookie. | This cookie is used to verify the use of the Platform by the user. |
| i18nextLng | Persistent Cookie: Expires when deleted by the User. | Cookie used to determine the User's language preference. |
| _gat | Persistent Cookie: Expires in one day. | This Cookie is associated with Google Analytics, which analyzes the number of visitors. |
| _gid | Persistent Cookie: Expires in one day. | This Cookie stores statistical data on how visitors use the site. |
| _ga | Persistent Cookie: Expires in two years. | This Cookie stores statistical data on how visitors use the Platform. |
| collect | Session Cookie. | This Cookie is associated with Google Analytics, which analyzes the number of visitors. |
| IDE | Persistent Cookie: Expires in one year. | This Cookie is associated with Google services and is used for advertising advertisements. |
| test_cookie | Persistent Cookie: Expires in one day. | Cookie used to check whether the user's browser supports cookies. |
| VISITOR_INFO1_LIVE | Persistent Cookie: Expires in 179 days. | This cookie tries to estimate the user's network quality when playing YouTube videos integrated in the Platform. |
| YSC | Session Cookie. | This Cookie records a unique ID that keeps statistics of which YouTube videos the User has viewed on the Platform. |
| yt-remote-cast-installed | Session Cookie. | This Cookie stores the user's video preferences on the Platform using the videos provided by Youtube. |
| yt-remote-connected-devices | Persistent Cookie: Expires when deleted by the User. | This Cookie stores the user's video preferences on the Platform using the videos provided by Youtube. |
| yt-remote-device-id | Persistent Cookie: Expires when deleted by the User. | This Cookie stores the user's video preferences on the Platform using the videos provided by Youtube. |
| yt-remote-fast-check-period | Session Cookie | This Cookie stores the user's video preferences on the Platform using the videos provided by Youtube. |
| yt-remote-session-app | Session Cookie | This Cookie stores the user's video preferences on the Platform using the videos provided by Youtube. |
| yt-remote-session-name | Session Cookie | This Cookie stores the user's video preferences on the Platform using the videos provided by Youtube. |
The user will have the opportunity to manage their cookie preferences through the browser’s configurations and settings. If the user so wishes to exclude or refuse certain cookies, they declare their awareness that such an act may compromise the optimization of the functionalities of the website that use this technology as a basis.
Disabling the Cookies used can impact the experience on the Platform, for example, the User may not be able to visit certain areas of one of our pages or may not receive personalized information when visiting a page.
Final considerations
The violation of any clause established in the terms of use and in our cookie policy may result in the suspension of access or, depending on the severity, it will result in the immediate exclusion of the registered user, an administrative measure used by the Tongue Tie App to avoid the violation of its rights or the rights of third parties.
The Tongue Tie App reserves the right to change this Policy at any time by its own means and intended purposes, and the User is responsible for checking the versions of the policy whenever accessing the Platform.
In case of any doubts, the User may contact the Tongue Tie App through the channels below:
This Policy will be interpreted in accordance with the Brazilian law, in the Portuguese language, and the jurisdiction of the District of the Capital of the State of São Paulo will be elected to settle any issues or problems involving this document, unless specific proviso of personal, territorial, or functional competence by the applicable legislation.
By clicking Accept and Agree with the Privacy and Cookies Policy, the user is completely and unrestrictedly accepting its terms.