Avenue Code

Privacy Policy

We value your privacy. Please review this Privacy Policy to understand how we collect, use,  communicate, and disclose your personal information as a visitor to our website.  

Please note: all information in this privacy notice is applicable to you unless otherwise indicated and  you and Avenue Code are subject to the applicable data protection laws depending on your  residency. 

We will provide additional privacy policies and information to you if we collect or process personal  information under different circumstances so that you remain aware of how and why we are using  such personal information. 

Please note that our website may include links to websites of third parties whose privacy practices  differ from those of Avenue Code; if you provide personal data to any of those websites, your data is  governed by the privacy statements of such websites.

1. How we will use your personal information

Purposes We may collect different kinds of personal information for different purposes, as below  stated:  

(i) To aid in the ongoing operation of our website. 1 

Our web servers may collect the following information to provide analytics and  performance enhancement metrics: (a) IP addresses, (b) operating system details, (c)  location details, (d) browsing details, (e) device and connectivity details, and/or (f)  language settings. 

1 For purposes of the GDPR, the lawful basis for this processing is our legitimate interest in enabling and improving our  website and online services, or your consent, where such consent is requested and obtained.

This information is aggregated to measure the number of site visits, average time spent on  the site, pages viewed and similar information. We then use this information to improve  content, ensure safety and security, and enhance performance and user experience. 

We may also obtain data from third parties including social media networks, when you  grant permission to us to access your data on one or more social media networks through  our website; service providers that help us determine a location based on your IP address  in order to customize offerings and content to your location; and partners with which we  offer co-branded services or engage in joint marketing activities. 

(ii) To answer your inquiries, support requests, and contact requests. 2 

If you contact us with general inquiries, requests for more information about initiatives or  products, or other support inquiries, we may need to collect information about you such  as: (a) personal and contact details, like full name, company, email address; (b)  demographic data; (c) qualifications and profession, and/or (d) the purpose and content of  your messages to us. 

(iii) To manage promotional or marketing subscriptions. 3 

If you sign up to receive promotional or marketing communications from Avenue Code we  may send these communications by email, SMS/text messages, or any other appropriate  method. 

(iv) To administer events and initiatives. 4 

Avenue Code frequently organizes public events and initiatives in-person or online. This  privacy policy applies to both participants and speakers at such events and initiatives,  along with any other supplementary information that participants may provide prior to or  at each event. To facilitate participation in these events and initiatives (including ongoing  communications relaying information about the event or initiative), we may be required to  collect and process a limited amount of information from you, such as your: (a) full name, 

2 For purposes of the GDPR, the lawful basis for this processing is our legitimate interest in providing exemplary customer  service, for the performance of a contract with you or to take steps at your request before entering into a contract with  you, or your consent, where such consent is requested and obtained. 

3 For purposes of the GDPR, the lawful basis for this processing is your consent, where such consent is requested and  obtained. 

4 For purposes of the GDPR, the lawful bases for this processing is our legitimate interest in organizing and hosting  promotional and education events and initiatives, or your consent, where such consent is requested and obtained.

(b) company, job title and business email address, (c) telephone number, (d) location,  and/or (e) pictures and/or video of you. 

You will be informed prior to any picture or video recording at each event or initiative and  made aware of any possibility that your image or likeness will be recorded. At or following  certain events, we may request feedback or additional personal information from you in  order to maintain ongoing communication and to further information about Avenue Code.  In all such instances, we will obtain your consent prior to requesting any additional  personal information. 

We may also obtain attendee lists and other personal information from third party event  organizers if an event is sponsored by Avenue Code. In those instances, the privacy  policies of such third party event organizers to which you provide your personal  information will apply to you. 

(v) To manage, administer and fulfill our contractual obligations. 5 

If you, your employer, or your company enters into a contractual relationship with Avenue  Code (apart from a direct employment relationship between you and Avenue Code), we  may need to process your personal information for purposes of negotiating or establishing  such contractual relationship. The personal information we collect at this time will usually  be limited to your name, business contact details and job title in order to enter into and/or  fulfill our obligations under the contract, such as providing or obtaining services.  

We may also process such personal information for related tasks such as accounting,  auditing, reporting (to government regulators and authorities) and to comply with all  applicable regulations. 

(vi) To promote the Avenue Code brand, products, initiatives and values through marketing  and other communications. 6 

Avenue Code has a strong interest in promoting its brand, products, initiatives and values.  We may send you marketing communications through different channels, such as email,  texts, phone calls or regular mail, and to do so, we may use your contact details that were  

5 For purposes of the GDPR, the lawful bases for this processing may be for the performance of a contract with you or to  take steps at your request before entering into a contract with you, our legitimate interest in providing services to your  company or employer, legal obligation, your consent, where such consent is requested and obtained. 6 For purposes of the GDPR, the lawful bases for this processing is for Avenue Code’s legitimate interest in promoting its  brand, products, initiatives and values, or you consent, where requested and obtained.

previously collected at an event, a query sent by you, or through the navigation on our  websites.  

We may also obtain your personal information from third parties, such as business  partners, data brokers, social networks, publicly available sources and marketing  companies. In such cases, we will also comply with any additional restrictions imposed by  the source of the data. If required by applicable legislation, we will ask for your consent  separately before sending any marketing communications.  

If we use your name, statements, image, likeness, or recordings of you to promote the  Avenue Code brand and activities, we will obtain your prior consent before using such  personal information. 

You can opt-out of receiving such communications at any time by responding directly to  such communications, by clicking the unsubscribe link at the bottom of any emails, by  contacting our security team at dpo@avenuecode.com, or by any other method provided from time to time in relation to such communications. 

Disclaimer We will only use your personal information for the purposes for which we collected it or  for another reason that is compatible with such original purpose. Prior to using your personal  information for any unrelated purpose, we will notify you and explain the legal basis for such  unrelated purpose. Please note that we may process your personal information without your  knowledge or consent, in compliance with the above rules, where this is required or permitted by  law.

2. How we will share your personal information

With whom We may share your personal information with third parties, including third-party service  providers and our affiliates in other countries. Please note that we require all third parties to respect  the security of your personal information and to abide by all applicable data security laws. We do not  allow our third-party service providers to use your personal data for their own purposes.  

Where required by law, we will request your consent before transferring your personal information  to third parties that are not affiliates of Avenue Code. 

Under all circumstances, Avenue Code will not buy or sell your personal information from or to any  third party. Avenue Code does not use your personal information for any reason other than for a  legitimate business purpose. 

Circumstances We may share your personal information with third parties: (a) Where required by  law; (b) Where it is necessary for one of the activities mentioned above or (c) Where we have another

legal, legitimate basis in doing so. 

Third parties may use your personal information for the following activities: (a) Hosting and other  internet services; (b) Data storage and analytics; (c) Marketing research and campaign management;  (d) Event organization; (e)As part of government audit or enforcement as required by law. 

Affiliates We may share your personal information with the following affiliates as part of our regular  reporting activities on company performance, in the context of a business reorganization or group  restructuring exercise, for system maintenance support and hosting of data and when it is required to  do so in order to perform one of the activities listed above. Avenue Code requires all of its affiliates to  take appropriate security measures to protect your personal data in line with our policies.

Legal Name: Avenue Code Desenvolvimento de Software Ltda.
Address: Rua Antonio de Albuquerque, 330, 4th Floor, Belo Horizonte, Minas Gerais, Brazil
Legal Name: Avenue Code S.A.
Address: 1000 Peel Street, Ste. 320, Montreal, QC, H3C 1B3 Canada
Legal Name: Avenue Code B.V.
Address: Piet Heinkade 55, Suite 11.19, 1019 GM Amsterdam

3. How we will keep your information safe

Technical Measures and Strategies to Protect your Data We have put in place appropriate technical,  organizational and security measures to prevent your personal data from being accidentally lost, used  or accessed in an unauthorized way, altered or disclosed.  

In addition, we limit access to your personal data to those employees, agents, contractors and other  third parties who have a business need to know. They will only process your personal data in  accordance with our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected data security breach and will notify you  and any applicable regulator of a suspected breach where we are legally required to do so.

4. How long we will keep your information

Storage Rules We will only retain your personal information for as long as necessary to fulfill the  purposes we collected it for, including for the purposes of satisfying any legal, accounting, or  reporting requirements.  

To determine the appropriate retention period for personal information, we consider the amount,  nature and sensitivity of the personal information, the potential risk of harm from unauthorized use  or disclosure of your personal information, the purposes for which we process your personal  information, and all other relevant legal requirements. 

In some circumstances we may remove all identifying aspects of your personal information so that it  can no longer be associated with you such that we may use the information without further notice to  you.

5. Data Privacy Rights

Your Rights You are entitled to the rights listed below. 

Request access to your personal data. You have a right to receive a copy of the personal  information we hold about you. 

Request correction of the personal data that we hold about you. We will correct any  incomplete or inaccurate information we hold about you subject to your request. 

Request erasure of your personal data. You may ask us to delete or remove personal data  where there is no good reason for us to continue processing or holding it. You may also ask us  to delete or remove your personal data where you have exercised your right to object to  processing (see below). 

Disclosure regarding the sale of personal information or use for business purpose. You have  a right to receive from us information about the categories of personal information and  sources from which we have collected such personal information from you. Likewise, you have  a right to receive information about the categories of third parties we disclose personal  information. 

Object to processing of your personal data. Although we may have a legitimate interest (or  the legitimate interest of a third party) to process your personal information, you may object  to such processing under certain circumstances. 

Request to restrict the processing of your personal data. You may ask us to suspend the  processing of your personal information under certain circumstances, including to establish the information’s accuracy or the reason for processing it.

Right to withdraw consent. If you have consented to Avenue Code’s collection, processing  and transfer of your personal information for a specific purpose, you have the right to  withdraw your consent for that specific processing at any time. To withdraw your consent,  please contact our security team at dpo@avenuecode.com. Once we have learned of your  consent withdrawal, we will no longer process your information for the purpose or purposes  you originally agreed to, unless we have another legal basis for doing so. 

Data portability. You may ask us to provide you with the personal information we hold about  you in a structured, commonly used and machine-readable format or to transmit the personal  information that you have provided to us to another party. 

Automated decision-making. The right not to be subject to a decision based solely on  automated processing that produces legal effects concerning you or similarly significantly  affects you. 

Right to non-discrimination. Avenue Code will not discriminate against you in any way or  under any circumstance for exercising your rights. 

To ensure our compliance under such circumstances, we may need to request specific information  from you to help us confirm your identity and your right to make such a request.

6. Data Transference

If you are a resident of the European Union (“EU”), we may transfer your personal information to one  or more countries outside the EU in order to perform one of the activities listed above (see “How we  will use your personal information “). If the European Commission has not issued an adequacy  decision regarding any country to which we transfer your personal information, we have put in place  the appropriate measures to ensure that your personal data will be secure. If you require further  information about these protective measures, you can request it from our security team at  dpo@avenuecode.com.

7. How to contact us

If you are a resident of the European Union (“EU”), we may transfer your personal information to one  or more countries outside the EU in order to perform one of the activities listed above (see “How we  will use your personal information “). If the European Commission has not issued an adequacy  decision regarding any country to which we transfer your personal information, we have put in place  the appropriate measures to ensure that your personal data will be secure. If you require further  information about these protective measures, you can request it from our security team at  dpo@avenuecode.com.

8. Changes to this Privacy Policy

We reserve the right to update this privacy notice at any time and will provide you with an updated  privacy notice if we make any substantial changes to our privacy policies. We may also notify you  separately from time to time about the processing of your personal information.