Privacy Policy

This document is the property of NextStream, and its use or distribution is strictly prohibited 2 without prior written authorization. This Privacy Policy (“Policy”) was created to demonstrate the commitment of DIGITAL DC BRASIL LTDA., a company registered with the CNPJ/ME under No. 19.291.041/0001-02 (hereinafter referred to as “NextStream,” “we,” “us,” or “our”), to the security and privacy of the information collected from users, who are the data subjects of their personal data (“Data Subject,” “User,” or simply “you”), as well as to help data subjects make informed decisions about their privacy.

This Policy explains the general conditions for the collection, use, storage, and other forms of processing and protection of personal data on our website https://nextstream.com/ (“Site”), in accordance with the Brazilian legislation currently in force regarding privacy and personal data protection, including, but not limited to, Law No. 12,965, of April 23, 2014, and Decree No. 8,771, of May 11, 2016 (“Brazilian Internet Civil Rights Framework”), and Law No. 13,709, of August 14, 2018 (“General Data Protection Law” or “LGPD”).

To maintain direct contact with you, NextStream has appointed a Personal Data Protection Officer to manage a communication channel:

Data Protection Officer: Renato de Barros Correia
Contact: dpo@nextstream.com

This Privacy Policy may be updated or amended at any time, and any changes will be prominently disclosed on our Site.

By using our Site, you freely, informedly, unequivocally, expressly, and fully agree to this Policy. We recommend that you read it carefully.

1. TARGET AUDIENCE

This Privacy Policy applies to individuals who:
✓ Access our Site
✓ Register on our Site

2. WHAT IS THE PROCESSING OF PERSONAL DATA

Personal data is any information related to an identified or identifiable natural person. The processing of personal data (or data processing) means any operation carried out with such data. For example: the collection of your data, use, access, processing, storage, deletion, communication, and transfer.
Por exemplo: coleta de seus dados, utilização, acesso, processamento, armazenamento, eliminação, comunicação e transferência.

3. WHO CONTROLS YOUR DATA

When you access our Site, NextStream acts as the data controller for the processing of your personal data, in accordance with applicable legislation and as described in this Policy.

4. INFORMATION WE MAY COLLECT

Important: You are not required to provide us with your information; however, if certain requested information is not provided, you may not be able to access some features. In addition to the data, you provide to us, information will be automatically collected whenever you interact with our Site. Such information is generally not identifiable; however, when combined with other data in a way that allows it to be associated with you, it will be treated by NextStream as personal data.

Within the limits permitted by applicable legislation, NextStream may process the following personal data provided by you:

Please note that the personal data listed above will be collected by NextStream and subsequently processed only to the extent necessary to achieve the purposes set forth herein.

We do not intentionally collect, store, or otherwise process personal data that is excessive or unnecessary for the purpose for which it was collected, nor do we collect sensitive personal data (such as data relating to racial or ethnic origin, religious beliefs, political opinions, trade union membership, or membership in religious, philosophical, or political organizations, health or sexual orientation, as well as genetic data), or data of children and adolescents. Therefore, we ask that you refrain from sharing such data with us. If we become aware that such data has been inadvertently collected or processed, it will be deleted from our records.

5. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The classification of the legal basis for the data stored and processed by NextStream, as listed in Section 4, is determined by an analysis of the specific context in which such data is collected.

The data processed by NextStream tends to be collected only:

6. SHARING OF PERSONAL DATA

When necessary to achieve the purposes described in Section 4, NextStream may share your personal data with the third parties listed below, to ensure the proper provision of the services offered, the secure storage of your personal data, and an improved experience with NextStream. Whenever data sharing occurs, it will be conducted within the limits and purposes of our business, in compliance with the purpose of processing the personal data and in accordance with applicable legislation. Accordingly, your data may be shared with:

7. RIGHTS OF PERSONAL DATA SUBJECTS

In accordance with and within the limits of applicable legislation, you, as a personal data subject, may contact us to exercise your rights, in order to request:

Your request may be submitted free of charge via the email address dpo@nextstream.com.br. We will review your request and respond as promptly as possible, in accordance with the timeframes and terms set forth in applicable legislation. If it is not possible to comply with your request immediately, we will inform you of the factual and legal reasons that prevent us from doing so.

NextStream is not responsible for the accuracy, truthfulness, authenticity, completeness, or timeliness of the data provided by the Data Subject. It is the sole responsibility of the Data Subject to provide information that is accurate, true, authentic, complete, and up to date.

8. HOW WE STORE AND PROCESS PERSONAL DATA

NextStream adopts technical and administrative security measures to keep all stored data secure, through internal guidelines, confidentiality clauses, and strict access controls, ensuring that our employees have access only to the data strictly necessary to fulfill the specific purposes described in Section 4. Specifically, regarding data collected through our Site, such data is stored, processed, and protected in accordance with best practices for hosting and data processing.

Nevertheless, the Data Subject should be aware that no internet security system is fully guaranteed against unauthorized intrusions, and NextStream’s commitment is limited to adopting protection measures that are reasonable and recommended in accordance with the current state of the art.

9. INTERNATIONAL TRANSFER OF PERSONAL DATA

NextStream will carry out the international transfer of your data to other countries or international organizations only when strictly necessary to achieve the purpose that led to the processing of your personal data, prioritizing, whenever possible, storage on servers located in Brazil.

However, as a global company, we may store your personal data in different locations and/or territories where we or our service providers and suppliers are located or maintain servers.

When your personal data is transferred outside Brazil by NextStream, we will adopt appropriate measures to ensure an adequate level of protection for your personal data, in accordance with the requirements of applicable data protection laws, including, when necessary, through the execution of appropriate data transfer agreements with third parties.

NextStream may, through the adoption of appropriate measures and safeguards for the protection of Personal Data, carry out international transfers of Personal Data for the purposes set forth in this Policy, including:

• Service provision and contract performance: to process your registration and enable access to the operations of your suppliers, service providers, and/or clients, as well as to ensure compliance with contracts and other commercial agreements, guaranteeing access to NextStream’s services and those of its strategic partners;
• Security: to enable the adoption of security measures and protocols for fraud prevention;
• Rights and obligations: to ensure compliance with NextStream’s legal and/or regulatory obligations, as well as the regular exercise of rights in judicial, extrajudicial, administrative, or arbitration proceedings.
• Specialized services: such as the use of cloud-based data storage and/or processing services or servers located in other countries.

Personal Data may be transferred to and processed in different countries, as necessary and limited to the purposes described above, including countries where NextStream’s partners, suppliers, service providers, and/or clients are located or operate, such as Argentina, Spain, Peru, Chile, and Mexico.

When necessary and as applicable, in accordance with the purposes set forth above, the international transfer of Personal Data will be carried out by NextStream in a secure manner, based on the mechanisms provided for in the LGPD and applicable regulations, in particular: (i) transfers to countries or international organizations that provide a level of protection for Personal Data deemed adequate under the LGPD and other applicable regulations, as recognized by an adequacy decision issued by the ANPD; or (ii) through the adoption of standard contractual clauses, in accordance with applicable regulations; or (iii) for the fulfillment of a legal or regulatory obligation, the performance of a contract or preliminary procedures related to a contract, or the regular exercise of rights in proceedings. Without prejudice, NextStream may also adopt other additional international transfer mechanisms provided for in the LGPD and other applicable regulations.

If an international transfer of Personal Data occurs, it will be carried out for the period necessary to fulfill the purposes set forth in this Policy and in any contracts and/or agreements entered into with partners, suppliers, service providers, and/or clients. This period may vary depending on the nature of the data transferred and the applicable legal requirements.

10. DATA RETENTION PERIOD

We store and retain your information: (i) for the period required by law; (ii) until the end of the processing of personal data, as described below; (iii) for as long as necessary to preserve NextStream’s legitimate interests, as applicable; and (iv) for as long as necessary to safeguard the regular exercise of NextStream’s rights in judicial, administrative, or arbitration proceedings. Accordingly, we will process your data, for example, during applicable statutory limitation periods or for as long as necessary to comply with a legal or regulatory obligation.

The processing of personal data will be terminated in the following cases:
a) When the purpose for which the Data Subject’s personal data was collected has been achieved and/or the collected personal data is no longer necessary or relevant to achieve such purpose;
b) When the Data Subject withdraws their consent or exercises their right to request the termination of processing and the deletion of their personal data, and does so;
c) When there is a legal determination to that effect.

In accordance with the principle of necessity, certain data submitted through the Site may be deleted from our records through routine record maintenance. We are not required to retain personal data indefinitely and disclaim any liability arising from or related to the destruction of such personal data.

Upon the termination of the processing of your personal data, or upon expiration of the applicable retention period, except as provided by applicable law or this Privacy Policy, such data will be deleted from NextStream’s database. If deletion is not immediately possible, the data will be securely stored and isolated from any further processing until deletion becomes possible.

11. COMMUNICATION POLICY

We seek to avoid sending unsolicited emails, limiting our communications with you to matters that are relevant or of your specific interest.

If you prefer not to receive our communications anymore, you may request to unsubscribe through the unsubscribe link included in the email or message received (opt-out), or by contacting us at dpo@nextstream.com.br.

You should be aware that various fraudsters attempt to use well-known brands to obtain personal information such as passwords and financial data. NEXTSTREAM WILL NEVER REQUEST YOUR FINANCIAL INFORMATION VIA EMAIL OR BY PHONE. IN THE EVENT OF ANY OTHER SUSPICIOUS ACTIVITY, PLEASE SEND YOUR QUESTION OR ALERT BY EMAIL TO dpo@nextstream.com.br.

12. LINKS TO OTHER WEBSITES

Our Site may contain links or frames to other websites. Such links or frames are intended to provide additional benefits to the content and services offered to the User.

We clarify that the inclusion of such links on our Site does not mean that NextStream is aware of, agrees with, or is responsible for the content of such links or frames. It is important to emphasize that our objective is solely to provide links or frames to reputable and trustworthy companies. NextStream is not responsible for the information, products, or services obtained by the User on such websites, nor for the commercial practices and privacy policies adopted by those companies, and NextStream shall not be held liable for any losses, damages, or lost profits incurred as a result of the use of such resources.

To the extent that linked websites are not part of our Site, we do not control, recommend, or endorse such websites or their content, products, services, policies, or privacy practices. We do not have access to the personal data collected and processed by them, nor to their advertising, cookie, and terms of use policies. Therefore, we recommend that you carefully review the relevant documents of third-party websites.