PRIVACY POLICY

GENERAL INFORMATION AND PRINCIPLES

At LEGION SCHOOL S/A, privacy and security are priorities. We are committed to the transparency of personal data treatment for our users/customers. Therefore, this Privacy Policy establishes how the collection, use, and transfer of customer or other individuals’ information who access or use our website is carried out.

By using our services, you understand that we will collect and use your personal information as described in this Policy, under the provisions of the Federal Constitution of 1988 (art. 5, LXXIX; and art. 22, XXX — included by EC 115/2022), Data Protection laws (LGPD, Federal Law 13,709/2018), consumer protection provisions of Federal Law 8078/1990, and other applicable Brazilian legal norms.

Thus, LEGION SCHOOL S/A, hereinafter referred to simply as LEGION SCHOOL, registered under CNPJ/MF under n.º 44.130.667/0001-84, as the Data Controller, undertakes to comply with this Privacy Policy.

TERMS AND DEFINITIONS For the understanding of this Policy, we must consider the following definitions and terminologies:

Purpose: Personal data processing can only occur after a clear purpose is defined, duly described in this document or another that integrates it.

Adequacy: Processing must be restricted to the defined purpose and must not occur in a manner incompatible with that purpose.

Necessity: Processed data must be restricted to the minimum necessary for the defined purpose.

Cookies: Files containing small data parts shared between a technological device and a web server to improve the user experience and enable error identification.

Personal data: Information related to an identified or identifiable natural person.

Anonymized data: Data related to the data subject that cannot be identified, considering the use of anonymization at the time of its processing.

Deletion: Exclusion of data or set of data stored in a database, regardless of the procedure employed.

Database: A structured set of data, established in one or more locations, physically and/or electronically.

Controller: The natural or legal person, public or private, responsible for decisions regarding Personal Data Processing.

Processor: The natural or legal person, public or private, who processes Personal Data on behalf of the controller.

Processing: Every operation carried out with Personal Data throughout its life cycle, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, or information control, modification, communication, transfer, dissemination, or extraction.

Blocking: Temporary suspension of any processing operation, through the storage of personal data or the database.

LEGION SCHOOL: It is the company LEGION SCHOOL S/A, registered under CNPJ/MF under n.º 44.130.667/0001-84.

Website: It is the site https://legionarynft.com/ available for access to the Legionnaire NFT waiting list.

PURPOSE OF PERSONAL DATA PROCESSING By using the website, you agree to the collection, storage, and processing of data necessary for the correct functioning of the waiting list, as well as for enabling the benefits that will be released with the acquisition of the NFT. This data is processed in accordance with applicable laws and regulations, including the General Data Protection Law (LGPD). The Personal Data processed by LEGION SCHOOL has specific purposes and is supported by legal bases. This Privacy Policy maps and details all the purposes and legal bases we use for the processing of personal data.

Purpouse

Legal Basis

Conducting studies and statistical analysis on the use of the NFT, as well as the involved platforms, such as www.otsafe.com.br, aiming for service improvements and optimization.

Execution of the contract and LEGION SCHOOL’s legitimate interest in providing its services.

Sending communications related to benefits, such as updates, notices, notifications, and technical support.

Execution of the contract and LEGION SCHOOL’s legitimate interest in providing technical support and keeping users informed about NFT updates.

Compliance with legal, regulatory, and judicial obligations, such as issuing electronic invoices and responding to requests from competent authorities.

Legal obligation.

LEGION SCHOOL’s legitimate interest in improving its services and ensuring the best experience for users.

Provide access and inform the use of future benefits to those who sign up for the waiting list to acquire NFTs.

HOW AND WHICH PERSONAL DATA ARE COLLECTED

LEGION SCHOOL uses the data it collects to operate, maintain, and provide the features and functionalities of the NFT, as well as its benefits, to analyze how it is being used, diagnose technical services or issues, maintain security, personalize content, and remember information to help you access your account.

LEGION SCHOOL is committed to treating information legally classified as Personal Data in compliance with applicable legislation, including, but not limited to, Federal Law No. 13,709/2018 (General Data Protection Law). As the Processor of Personal Data, it will process Personal Data solely to achieve the purposes defined by the Terms and Conditions of Use and this Privacy Policy.

The System collects, stores, and processes the data provided by you when signing up for the waiting list on the website https://legionarynft.com/. Among these data are Personal Data such as:

  • Name;
  • Email;

All collected data will be used only for the purpose of providing the contracted service, being used only by authorized employees and collaborators of LEGION SCHOOL. The collected information will not be shared with third parties, except when necessary to fulfill legal obligations or to allow you to access the benefits associated with the NFT.

DATA SHARING

LEGION SCHOOL will share your provided Personal Data with the following third parties to enable and facilitate the use of the benefits associated with the acquisition of the Legionnaire NFT.

OTSAFE — INTERMEDIACAO DE NEGOCIOS LTDA, a private company, registered under CNPJ/MF under n.º 33.333.103/0001-22, headquartered at R. João Manoel, 243, sala 01 – São Francisco, Curitiba – PR, 80510-250

In addition to these, LEGION SCHOOL may share the collected Personal Data with third parties, such as service providers acting on its behalf, such as hosting providers, technical support, and payment processors. The sharing of this data will occur in LEGION SCHOOL’s legitimate interest in providing its services efficiently and securely.

DATA STORAGE AND SECURITY

LEGION SCHOOL adopts appropriate security measures to protect the collected personal data, including encryption, access control, and monitoring of activities in the System.

Personal data will be stored for the time necessary to fulfill the purposes and legal bases described in this Privacy Policy, being deleted when they are no longer necessary or when requested by the data subject.

Furthermore, LEGION SCHOOL commits to adopting measures to ensure the protection of personal data in the event of security incidents, such as data leaks or unauthorized access, by adopting all possible practices.

STORAGE TIME

LEGION SCHOOL commits to storing Personal Data only for the time necessary for the purpose defined in Chapter 3 of this Policy or for the time required by law or applicable regulation.

After the storage time ends, LEGION SCHOOL commits to deleting personal data or anonymizing it according to the LGPD norms and requirements.

In some cases, LEGION SCHOOL may store personal data for longer periods, such as to comply with legal or regulatory obligations or for the exercise of rights in judicial, administrative, or arbitration processes.

LEGION SCHOOL may perform backups of data between its servers, and it may even remove them from the System server and store them for the time limit described below for the following data:

Stored Data

Time Limit until Deletion

Logs and history of integrations performed on the Site.

01 (one) year from the interaction on the Site.

Name and Email

02 (two) years from the interaction on the Site.

In cases where personal data is no longer necessary for the originally defined purpose, LEGION SCHOOL commits to securely and permanently eliminate them. Additionally, if the data subject requests the deletion of their personal data through the email legionary@legionarynft.com, LEGION SCHOOL will make every effort to comply with the request, provided it does not conflict with other legal or regulatory obligations. The data subjects of the Personal Data processed and collected by LEGION SCHOOL have the following detailed rights:

RIGHTS OF THE DATA SUBJECT 

Right of access: The data subject has the right to obtain clear and accurate information about the processing of their personal data by LEGION SCHOOL, as well as access to the personal data in question; 

Right to rectification: The data subject has the right to request the correction of incomplete, inaccurate, or outdated personal data being processed by LEGION SCHOOL.

 Right to erasure: The data subject has the right to request the deletion of their personal data processed by LEGION SCHOOL, provided there is no legal reason preventing such deletion. 

Right to portability: The data subject has the right to receive their personal data in a structured, commonly used, and machine-readable format, for their own use or to be transferred to another data controller. 

Right to object: The data subject has the right to object to the processing of their personal data by LEGION SCHOOL, in certain circumstances, such as, for example, in the case of processing for marketing purposes. 

Right to information: The data subject has the right to be informed by LEGION SCHOOL about the processing of their personal data, in a clear and adequate manner. To exercise these rights, the data subject can contact LEGION SCHOOL through the email legionary@legionarynft.com.

To comply with the General Data Protection Law, we have our Data Protection Officer’s assistance channel, who will respond within the legal period provided by law.

The contact for the Data Protection Officer is: legionary@legionarynft.com, and our Data Protection Officer is Alfred Alves.

In the case of processing your Personal Data for direct marketing purposes, the data subject may object to this activity at any time; in this case, we will no longer process your Personal Data for such marketing purposes.

USE OF COOKIES LEGION SCHOOL uses cookies on its Site to collect access information, such as IP address, browser type, and operating system used, pages accessed, browsing time, among other data. This information is collected for statistical analysis and improvements in the Site’s performance.

By accepting this Privacy Policy, the data subject agrees to the use of cookies by LEGION SCHOOL. The user can, at any time, configure their browser to block the use of cookies or receive a notice when a cookie is sent. However, it is important to note that disabling cookies may affect the quality of access and use of the LEGION SCHOOL Site.

UPDATE OF THE PRIVACY POLICY LEGION SCHOOL reserves the right to update this Privacy Policy periodically to ensure it complies with changes in applicable legislation and best practices in Privacy and Data Protection. Whenever there is an update to the Privacy Policy, LEGION SCHOOL will inform its users and data subjects through its website or other appropriate communication means.

Users and data subjects should regularly review this Privacy Policy to be aware of LEGION SCHOOL’s privacy and data protection practices. The continued use of the site after any changes to this Privacy Policy will be considered acceptance of the changes.

This Privacy Policy is in its version 1.0 published on December 12, 2023.