Version updated on June 15, 2021
Hello, if you want to understand how we collect, store, use, share and delete your Personal Data, you’ve come to the right place. Depending on what actions you carry out on the Platform, certain specific rules may apply to you. So please read the information below carefully.
This Policy may be modified, replaced, or removed at any time without prior notice. If you do not agree to a new version of this Policy, you must stop using your Hotmart account. This Policy and its respective updates supersede any proposals, contracts, prior understandings, and agreements, verbal or written, that may exist between you and Hotmart, especially those relating to privacy or personal data.
- In order to make this Policy easier to read, we provide a Glossary at this link, which lists the meaning of expressions, in capital letters, in the Hotmart Terms, as well as in this or any other Hotmart Policies. In addition, it’s important that you understand the specific meaning of the following three expressions used in the context of privacy protection and written in the Terms, in this Policy, or any other Hotmart Policies without capital initials:
“Personal data" - means any information that identifies the User or makes it possible to identify them. Therefore, as generic as it may seem, personal data can be any information that identifies you directly, or any information that works as a piece of the puzzle leading to your identification.
“Processing" - as well as the verb "to process," means any operation performed on personal data, such as those relating to the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, treatment, filing, storage, deletion, deletion, evaluation, control, modification, communication, transfer, dissemination, or extraction.
1. PERSONAL DATA PROCESSED BY HOTMART
Personal Data. The Personal Data processed by Hotmart may vary depending on the type of interaction the User has with the Platform. This personal data may be collected directly from the User, obtained through third parties, or collected automatically. The personal data may include: (a) registration information, such as email, full name, address, phone, and cellphone number, National ID, Driver’s License, profile picture and passport numbers; and (b) banking information, such as the name of the financial institution in which the User has a bank account, account number, type of account, branch, IBAN and credit card information, including the holder’s name, expiration date, and CVV number.
- 1.1. Personal Data Collected Directly from the User. Hotmart may collect personal data directly from you relating to registration and banking information.
- 1.1.1. “Offline" Interaction. Hotmart may collect personal data when you interact with Hotmart by means other than accessing the Platform, such as when you attend an event organized by Hotmart or by a third party whose activity is contractually linked to Hotmart.
- 1.1.2. Optional fields. The Platform makes certain fields available for optional completion. These fields are highlighted as optional and are intended to improve the customization of the content made available to the User.
- 1.1.3. Public Data. Hotmart considers certain personal data to be public because it can be seen by anyone, on and off the Platform, even if that person doesn’t have an account on the Platform. Information that you enter in the fields highlighted with the "public data" notice is considered public data. You, other persons using the Platform, and Hotmart itself may provide access to or send public data to anyone on and off the Platform. You may also view, access, re-share, or download public data through third-party tools, such as search engines, APIs, and offline media, or through applications, websites, and other third-party Services.
- 1.2. Personal data obtained from third parties. Hotmart may have access to certain personal data through third parties, such as registration or banking information. This happens, for example, when Hotmart - as a result of compliance with legal or regulatory obligations - needs to consult databases maintained by third parties, which allow the analysis of credit restrictions, anti-fraud analyses and other risk management analyses integrated to the Platform.
- 1.2.1. Hotmart also collects registration information through third parties when you link, connect or login to the Platform through a Third-Party Service (e.g. Facebook).
- 1.2.2. Hotmart may also have access to registration information through third parties for registration in events, surveys, advertising campaigns, and other activities organized by such third parties whose activity is contractually linked to Hotmart.
- 1.3. Personal data automatically collected when accessing the Platform. Personal data is automatically collected when you access the Platform, even if you do not have an account. This information may include the following examples:
- 1.3.1. Payment transaction information: the payment instrument used, the transaction’s date and time, payment amount, expiration date of the payment instrument, billing postal code, IBAN information, address, and other details related to the payment transaction.
- 1.3.2. Access or use information: pages and content you view, ad searches, frequency of Platform use, browser information, connection data, purchase, and browsing history.
- 1.3.3. Log data and device information: details about how you have accessed and used the Platform (including the links accessed), IP address, access times and dates, hardware and software information, device information, device event information, exclusive identifiers (e.g., Hotmart ID), crash data, cookie data and the pages you viewed or interacted with before and after accessing or using the Platform.
2. PERSONAL DATA PROCESSED BY HOTMART ON BEHALF OF THIRD PARTIES
- 2.1. Processing of Personal Data at the Request of Third Parties. Certain personal data is processed by Hotmart at the request of third parties. Hotmart processes such personal data following rules formalized with these third parties by means of written agreements. For example, a Producer may request, through the Platform, additional personal data from the Buyer. The types of Personal Data collected on behalf of the Producer may vary depending on the Producer’s specific instructions.
- 2.2. The processing of Personal Data related to Hotpay Services. Hotmart may also process certain personal data on behalf of third parties when you choose to use Hotpay Services. In transactions relative to the Hotmart Card, Hotmart may collect the card number, cardholder name, expiration date, CVV number, National ID, Individual taxpayer number) and payment transaction information on behalf of a payment institution and the credit card company.
- 2.3. Responsibility for the processing of Personal Data by third parties. The third parties referred to in the previous items are also processing agents responsible for the personal data in the context of offering their products and services.
3. THE PURPOSES OF PERSONAL DATA PROCESSING
- 3.1. Purpose of processing the User's Personal Data. Hotmart uses personal data for the following purposes:
- 3.1.1. Provide and develop the Platform:
- Link your Hotmart account with third-party social networks
- Customize the Platform according to your browsing experience
- Conduct analysis and studies related to behavior, interests, and demographics
- Improve the Platform
- Save your purchase history
- Update registration
- Send messages, account updates, and notifications
- Perform User support activities
- Allow the User to publish their content
- Disclose User content through the means available on the Platform
- 3.1.2. Provide and optimize advertising and marketing activities
- Event registration
- Send newsletters
- Send communications via email, SMS, or phone recordings
- Send educational materials or ebooks
- Carry out media campaigns with a focus on advertising and promotions
- Manually send lists with media vehicles (Facebook and Google)
- Send communication, such as e-mail marketing, remarketing, and other advertising campaigns in media channels
- Analyze browsing behavior to optimize the Platform and offer products and services
- 3.1.3. Enable Hotpay Services
- Perform payment-related communication, such as sending transactional emails
- Participate in agreements with the card companies
- Issue e-currency
- Accredit and issue payment instruments
- Manage payment accounts
- Convert physical currency into e-currency
- Perform the remittance of funds
- 3.1.4. Maintain a secure environment
- Perform authentication on the Platform
- Verify the authenticity of the data and documents provided, including by means of processing and cross-checking
- Send announcements
- Perform analysis activities to prevent fraud, security incidents, and abuse on the Platform
- Registration verification
- Content verification
- 3.2. Purposes of the processing of visitor Personal Data. Hotmart may collect personal data from visitors to the Platform for the following purposes:
- Media campaigns focused on advertising and promotions
- Send communication, such as email marketing, remarketing, and other advertising campaigns in media channels
- Analyze your browsing behavior on the Platform
- Event registration
- Send newsletters
- Send communications via email, SMS, or phone recordings
- Send educational materials or ebooks
LEGAL BASES FOR THE PROCESSING
- 4.1. Legal Bases. The processing of personal data, carried out by Hotmart, is always founded on a legal basis provided for in the applicable laws. The legal bases used by Hotmart may vary depending on the context of the processing. Below are the legal bases used by Hotmart:
- 4.1.1. Consent. When the User manifestly agrees to the processing of personal data, for example, when the User agrees to receive newsletters, advertising communications, or surveys. This consent may be revoked at any time by the User.
- 4.1.2. Compliance with a legal or regulatory obligation. When Hotmart is obliged to process personal data due to a legal or regulatory obligation, for example, when Hotmart uses third-party tools to perform credit assessments of Users. In this scenario, there may be automated decisions to analyze the possibility of advancing amounts on the Platform.
- 4.1.3. Execution of the Agreement or procedures related to the Agreement. When Hotmart is required to process personal data due to the applicable Agreement between Hotmart and the User.
- 4.1.4. Regular exercise of rights in legal, administrative, or arbitration proceedings. When there’s a need to process personal data due to a lawsuit, administrative or arbitration proceeding
- 4.1.5. Legitimate interest. When Hotmart decides to proceed with the processing of personal data after careful analysis involving the assessment of the purpose and need for the processing to the User, the User's expectation regarding the processing of the personal data, and the preparation of the necessary legal documentation. This legal basis is used when Hotmart sends, for example, a newsletter related to the User's interests, considering their interaction with the Platform. In this case, Hotmart always provides the User with the option to cancel the receipt of such communications.
5. PERSONAL DATA RETENTION PERIOD
- 5.1. Processing Period. The personal data is processed by Hotmart until at least one of the assumptions described below has been reached. These are:
- The achievement of the processing purpose
- The personal data is no longer necessary or pertinent to the achievement of the specific intended purpose
- Termination of the Agreement with the User for whatever reason
- Exercise of the User’s right to revoke consent, in the hypotheses that the processing of personal data was performed based on this legal basis
- Eventual penalty applied by the body responsible for caretaking, implementation, and inspection of the compliance with the applicable law, or by other competent bodies
- 5.2. Retention of Personal Data. In certain situations, Hotmart and third-party may retain residual personal data even after the processing of the personal data has ceased due to compliance with a legal or regulatory obligation, or in circumstances where Hotmart or such third parties have a legitimate purpose. In such cases, the personal data will be stored in a secure place with restricted access and for the time necessary to comply with the legal or regulatory obligation, or the end of Hotmart and the third parties’ legitimate purpose.
6. SHARING PERSONAL DATA
- 6.1. Sharing. Hotmart may share personal data with third parties. These third parties enter into a written agreement with Hotmart and are aware of their responsibilities at each stage of the processing, in particular, their duty to implement security measures that meet the requirements of the agreement and applicable laws. Sharing may occur, for example, in the situations described below.
- 6.1.1 User Consent. When you give your consent, we share your information as described at the time of consent - such as when you consent to personal data being sent to third parties to allow participation in events.
- 6.1.2 Compliance with the law, damage prevention, and security. When there’s a need to share personal data with third parties in order to: (a) prevent fraud (such as money laundering risk analysis), which may involve automated decisions; (b) check the list of Users with restrictions; (c) authenticate forwarded documentation; (d) enable support services; (e) prevent illegal activities; (f) proceed regarding disputes between Users; (g) proceed regarding internal investigations relative to any conduct that may violate the rules of the Terms or Hotmart Policies.
- 6.1.3 Hotpay Services. Personal data is also shared with third parties when the User, in some way, makes use of the Hotpay Services, in particular when the User opts for the Hotmart Card. Personal data, including the User’s card number, will be shared with the credit card company and the payment institution. The purpose of sharing this is to process the payment, make the card services available, prevent, detect and investigate any fraud or restriction lists, facilitate the resolution of disputes involving refunds or chargebacks.
- 6.1.4 Response to legal requests. In certain cases, if necessary, Hotmart may provide the data collected to official bodies and entities that intervene in the investigation or resolution of disputes between Users, or between Users and third parties, such as bodies of the Judiciary Branch, arbitration courts, or competent administrative authorities.
- 6.1.5 Between Companies linked to Hotmart. Sharing of personal data may occur between Hotmart's parent companies, subsidiaries, affiliates, or companies under common control to enable the Hotmart Services.
- 6.1.6 Service Providers. Hotmart may also share your personal data with third parties involved in financial, accounting, and legal advisory activities, non-profit activities, and potential investors, as well as third parties involved in providing data backup services, cloud-computing providers or conducting analytical studies.
7. INTEGRATIONS AND THIRD PARTIES
Hotmart, in certain cases, may link third party services to the Platform through application programming interface (APIs), such as the YouTube API. These third-party services are outside the scope of Hotmart's services and are not part of the Platform, and are subject to different terms and conditions, such as YouTube's Terms of Service and Google's Privacy Notice. Hotmart is not responsible for these services and, when you interact with them, you are providing your personal data directly to them.
8. INTERNATIONAL TRANSFERS
- 8.1 International Transfers. Hotmart and third-parties may transfer your personal data to countries other than the one where you are located. In such case, the international transfer of personal data will be to a country that provides an adequate level of personal data protection. Hotmart and third-parties shall take the measures required by law to ensure that such personal data is protected and that the transfer is carried out in accordance with one of the transfer mechanisms provided for by applicable law.
9. RIGHTS REGARDING YOUR PERSONAL DATA
- 9.1 Requests: You may submit a request related to your rights under applicable law. These rights may include the request of confirmation of personal data processing, access to personal data, and rectification of personal data, which must be done by using this form.
- To speak with our personal data protection officer, please contact us by using this form.
- Whenever Hotmart is acting on behalf of a third party, and you decide to seek compliance with one of your rights from Hotmart, we may, under certain circumstances, comply with such a request, if applicable.
- If you wish to unsubscribe from receiving newsletters, emails, phone calls, or SMS advertising, you can do so through the link provided in the communications themselves.
- 10.1 Security Measures. Hotmart employs security, technical and organizational measures necessary to protect personal data. The efforts are aimed at mitigating risks of destruction, accidental or illegal loss, changes, unauthorized disclosure or access, or any other form of illegal, unauthorized, or inappropriate processing. To this end, Hotmart relies on strict restricted access controls, based on the least privilege, to information technology systems to protect personal data against possible security incidents.
11. PROCESSING THE PERSONAL DATA OF MINORS
- 11.1. Personal Data of Minors. Hotmart doesn’t knowingly collect or solicit personal data from anyone under the age of 13. If we become aware that the personal data of a minor under the age of 13 has been collected, we will cancel the account created on the Platform and delete the personal data, only keeping personal data that is intended to prevent a new registration attempt.
12. CONTACT INFORMATION
For Users located outside the European Union:
Launch Pad Tecnologia, Serviços e Pagamentos Ltda.
Avenida Assis Chateaubriand, nº 499, Bairro Floresta
Belo Horizonte, Minas Gerais, Brazil
For Users located in the European Union:
Amsterdam, The Netherlands