The “Privacy Policy” you are accessing is part of the Terms and Conditions of Use and describes how NTV – New Television Comunicação S.A. (“MULTIPLIERAPP”), a legal entity registered with the CNPJ under No. 10.942.801/0001-20, with headquarters at Av. Júlio de Sá Bierrenbach, 65, Bloco 2 Sala 717, Barra da Tijuca, Rio de Janeiro, RJ, CEP: 22775-028, in the City of Rio de Janeiro/RJ, collects, stores, uses, processes, associates, protects, shares and treats your personal data, in connection with the Applications and Services governed by the Terms and Conditions of Use.

1. NECESSARY DEFINITIONS

This document has been written in a simple and accessible way, with several examples of the collection and use of Personal Data, precisely so that the USER can understand how we use their Personal Data to offer a safe and comfortable experience while using the Services.

With this in mind, we have systematized the definition of some key terms used in this Policy. In this sense, the words below, when used in the singular or plural, will have the following meanings, without prejudice to other definitions assigned in this Policy and in the Terms of Use.

• Personal Data : is any information relating to an identified or identifiable natural person;
• Sensitive Personal Data: information on racial or ethnic origin, religious belief, political opinion, membership of a trade union or religious, philosophical or political organization, concerning health or sex life, genetic or biometric data.
• USER or Data Subject: is the natural person to whom the Personal Data being Processed refers.
• Processing: is any operation carried out with Personal Data, including, but not limited to, collecting, storing, altering, consulting, sharing, transmitting, accessing or deleting it.
• Legal bases: these are the legal hypotheses that authorize the Processing of Personal Data, such as the consent of the Data Subject, the need to comply with a contract we have with the USER, or compliance with a legal obligation, for example.

In these terms, Personal Data and Sensitive Personal Data will be referred to as “Data” or “Personal Data”.

2. OBJECT

 This Privacy Policy aims to establish, in a clear and accessible manner, the conditions under which MULTIPLIERAPP processes the Personal Data of USERS who use its products and services.

Our commitment is to ensure that Personal Data is processed ethically, securely and in compliance with the General Personal Data Protection Law (Law No. 13,709/2018 – “LGPD”), adopting technical and administrative measures to protect data from unauthorized access, leakage, loss or any form of improper processing.

This Policy applies to all USERS of the MULTIPLIERAPP platform, including third parties who authorize the use of their social networks by other USERS of the platform, unless expressly stated otherwise. The rules set out here complement the Terms of Use of the platform, and it is certain that the concepts defined therein are also applied to this Policy, unless there is a specific provision to the contrary.

3. SCIENCE ON THE PRIVACY POLICY

 3.1. This Privacy Policy is informative in nature and describes in a clear and accessible manner how personal data is handled by MULTIPLIERAPP in the context of the use of its applications, services and functionalities.

3.2. The use of MULTIPLIERAPP’s applications, services and functionalities presupposes that the USER has had access to, understood and is aware of the conditions described herein. If they do not agree, they must refrain from using the Platform.

3.3. The processing of personal data carried out by MULTIPLIERAPP will observe the purposes, legal hypotheses and limits defined in this Policy, in the applicable legislation, especially the General Personal Data Protection Law (Law No. 13,709/2018), and in the Platform’s Terms of Use.

3.4. In the context of its relationship with MULTIPLIERAPP, the USER may also maintain links with other institutions, such as payment intermediaries or integrated social networks, whose performance may be regulated by their own documents. 

4. CONTROLLER AND COMMUNICATION CHANNEL

 4.1. NTV – NEW TELEVISION COMUNICAÇÃO S.A., registered with the CNPJ under No. 10.942.801/0001-20, is the controller responsible for processing the personal data collected and processed in the context of the MULTIPLIERAPP Platform.

4.2. If you have any questions, comments, suggestions or requests regarding the processing of your personal data, or if you believe that your information has been used in breach of this Policy or current legislation, you can contact the Data Processing Officer (DPO) through the following channels:

• In charge: Rodrigo Viana Brandão
• E-mail: [email protected]

5. TO WHOM DOES THIS POLICY APPLY?

5.1. This Privacy Policy applies to all natural or legal persons who interact with MULTIPLIERAPP, including, but not limited to:

• Clients: natural or legal persons who contract the services and products offered by MULTIPLIERAPP, operating channels, making transmissions or using the Platform’s functionalities as controllers of personal data;
• Users: people who interact with MULTIPLIERAPP through channels managed by Clients, including those who authorize the integration of their social networks, have their data processed or access Platform features as third parties;
• Visitors: individuals who access MULTIPLIERAPP websites or applications without authentication or a contractual link.

6. OWNERS’ RIGHTS

 6.1. The holders of personal data processed by MULTIPLIERAPP have the rights provided for in art. 18 of Law No. 13,709/2018 (General Personal Data Protection Law – LGPD). These rights may be exercised upon request to the Data Protection Officer, via e-mail: [email protected].

 6.2. These are the rights of the owners:

 Confirmation of the existence of processing and access to data: the data subject can request confirmation of the processing of their data and, if so, access the respective information.

Correction of incomplete, inaccurate or outdated data: the holder may request that their personal data be corrected. If it is not possible to make the update directly in the application, a supporting document must be sent to MULTIPLIERAPP.

 Anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the law: with justification, the data subject may request measures in relation to data processed in an irregular manner, subject to the legal requirements.

Data portability: the data subject can request the portability of their data to another service or product provider, in accordance with future regulations from the National Data Protection Authority (ANPD), while safeguarding commercial and industrial secrets.

Deletion of data processed on the basis of consent: the data subject may request the deletion of data whose processing has consent as its legal basis. Such deletion will not be applicable when there is another legal basis justifying the processing, as per art. 7 of the LGPD.

 Information on data sharing: the data subject can request information on the public and private entities with which their data has been shared, except in the event of legal confidentiality or impediment.

 Information about the possibility of not providing consent and its consequences: the data subject can be informed about the need for consent and the impacts of refusing it, if applicable.

Revocation of consent: the data subject may revoke the consent previously granted at any time by expressly stating so. Revocation may prevent access to certain functionalities or services, without prejudice to processing based on other legal grounds.

Review of automated decisions: the data subject may request a review of decisions taken exclusively on the basis of automated data processing that affect their interests, under the terms of art. 20 of the LGPD.

7. DATA COLLECTED

7.1. When using MULTIPLIERAPP’s services, whether through the website or the application, the User provides us with information necessary for the operation of the Platform. This data includes registration information, usage statistics and personally identifiable data, essential for the operation of the application and for compliance with legal obligations.

7.2. Personal data is collected in the following cases:

(a) When you access the Platform (website or application);

(b) When contracting or using any service or functionality offered by MULTIPLIERAPP;

(c) While browsing our websites and interfaces;

(d) When interacting with our service channels;

(e) When participating in promotions, campaigns or surveys carried out by MULTIPLIERAPP;

(f) When a third party links their social network account to another user’s channel, with the aim of allowing the retransmission of content through MULTIPLIERAPP.

7.3. Data collection can take place:

(a) Directly by the User at the time of registration;

(b) During the continuous use of the Platform;

(c) Through integration with social networks authorized by account holders, subject to the specific permissions of each network;

(d) From interactions with third parties, such as channel owners, partners, social networks, service providers and public authorities.

7.4. In the case of integration with third-party social networks:

(a) The third party may allow its social media channel to receive broadcasts originating from another user (“channel owner”);

(b) By granting access, the third party authorizes the replication of the content broadcast by the channel owner on its own network;

(c) The channel owner cannot interact on behalf of the third party (e.g. like, comment, delete posts or access messages);

(d) The data collected from this integration includes: username on the network, e-mail address (where available), number of followers and, where applicable, profile picture;

(e) The third party may remove the access granted at any time, either through the Platform itself or directly on the corresponding social network.

7.5. The data collected is used to guarantee the functionality of the Platform, the security of transmissions and the integrity of the system. Below are the main types of data and their respective purposes:

Personal Data	Purposes	Legal basis
Full name, e-mail address, telephone number.	– Registration and identity verification	Contract execution
IP, date/time of access, geolocation, access device	– Logging – Fraud prevention – Information security – Compliance with legal obligations and court orders	Fulfillment of legal obligation and performance of contract
Transactional data, volume of posts, browsing behavior and use of the Platform	– Analytics and statistics – Personalization of the experience – Detection of anomalous patterns	Legitimate interest and/or consent
Information obtained via integrated social networks (user, e-mail, followers, image, comments and interactions on broadcasts and posts made by the platform)	– Enable retransmissions and integration functionalities – Access control and permissions	Execution of contract and Consent (where applicable)

7.6. MULTIPLIERAPP keeps records (logs) of all actions carried out within the Platform, including transmissions, posts and integrations with social networks, both by the channel owner and linked third parties. These logs include: date, time, source account, user, networks used and commands executed – and are kept for auditing purposes, security, compliance with court orders and accountability to the Electoral Court, where applicable.

7.7. MULTIPLIERAPP does not curate or have editorial control over the content transmitted or posted by Users, nor does it access private messages or interact directly on behalf of third parties.

8. SHARING PERSONAL DATA

8.1. The database maintained by MULTIPLIERAPP will not be sold, rented or shared with third parties for commercial purposes, except in the cases provided for in this Privacy Policy or when required by law.

8.1.1. Whenever necessary, the sharing of your personal data will be carried out within the limits and purposes of our business and in accordance with the applicable legislation.

8.2. The sharing of personal data may occur in the following cases, always within the limits and purposes of MULTIPLIERAPP’s business activity, and in accordance with applicable legal grounds:

a) Provision and viability of services

• With technology and infrastructure providers, such as cloud storage providers and hosting services;
• With operational partners, responsible for the application’s technical functionalities, such as integration systems with social networks, broadcast management and usage analysis tools;
• With payment and financial institutions, for the purposes of payment processing, identity verification, fraud prevention and compliance with legal obligations.

b) Integration with social networks and linking third parties

• When a third party authorizes the retransmission of content via their social network account linked to another user’s channel, minimal identifying information from that account (such as username, email, number of followers and profile picture, where applicable) may be stored and processed;
• MULTIPLIERAPP does not actively share this information with external third parties, but may keep technical and operational logs of the use of the system, accessible to authorities upon legal request;
• The permissions granted by the third party derive from specific processes defined by each integrated social network, and it is the third party’s own responsibility to review and revoke such access as desired.

c) Compliance with legal or regulatory obligations

• With public authorities, regulatory bodies and the Judiciary, in particular the Electoral Court, when necessary to comply with court orders, investigations, inspection actions or the exercise of MULTIPLIERAPP’s rights;
• To comply with obligations under Brazilian law, such as the Marco Civil da Internet (Law No. 12,965/2014) and the LGPD.

d) Information security and fraud prevention

• With other financial institutions or companies in the sector, with the aim of mitigating systemic risks, preventing fraud and guaranteeing the security of operations, under the terms of the applicable legislation;
• Data may be shared in pseudo-anonymized format, whenever possible, to preserve the identity of the data subjects.

e) Other hypotheses

• In the event of corporate restructuring, incorporation, merger, spin-off or sale of assets, data may be shared with those involved in the operation, subject to guarantees of confidentiality and continuity of protection obligations;
• With commercial partners and marketing service providers, for prospecting actions, market research or improvements to the Platform, respecting the appropriate legal bases and rights of the holders.

8.3. The sharing of data may have the following purposes, among others:

1. Verify the user’s identity and enable access to services;
2. Complying with contractual, legal or regulatory obligations;
3. Processing payments and mitigating financial risks;
4. Preventing and responding to security incidents, fraud and unauthorized access;
5. To comply with court orders or legal requests;
6. Promoting operational improvements and performance analysis of the Platform;
7. Carry out legitimate marketing activities, where permitted;
8. Produce aggregated and anonymized statistics on the use of services.

9. RETENTION AND DELETION OF PERSONAL DATA

9.1. The Personal Data processed by MULTIPLIERAPP will be stored for the time necessary to fulfill the purposes that justified its collection, under the terms of this Privacy Policy, the Terms of Use and the applicable legislation.

9.2. Even if the holder requests the deletion of their data or cancels their account, MULTIPLIERAPP may keep certain personal data stored for an additional period in the following cases:

1. To comply with legal or regulatory obligations;
2. For the regular exercise of MULTIPLIERAPP’s rights, including in judicial, administrative or arbitration proceedings;
3. To comply with requests from public authorities;
4. To comply with the rules of the Central Bank of Brazil, the Internal Revenue Service and other regulatory bodies;
5. For auditing, security, fraud prevention or incident prevention purposes.

9.3. MULTIPLIERAPP adopts objective criteria to define data retention periods, taking into account:

1. The nature, volume and sensitivity of the data processed;
2. The potential risk arising from misuse or leakage;
3. The purpose of the treatment;
4. The existence of other legal or technical means to achieve the same end;
5. Applicable legal obligations.

9.4. The holder can request the deletion of their personal data through the Multiplierapp portal, logged in area, Account settings. MULTIPLIERAPP will analyze the request, informing which data can be deleted and which should be kept temporarily or permanently, based on the legal hypotheses that justify its retention.  

10. INTERNATIONAL TRANSFER OF PERSONAL DATA

 10.1 MULTIPLIERAPP may transfer Personal Data collected in Brazil to other countries, in particular the United States, due to the use of hosting and technology services based abroad, contracted for the purpose of enabling the operation and security of the Platform.

10.2. Prior to any international transfer, MULTIPLIERAPP ensures that the processing of data will be carried out in accordance with the requirements of Brazilian law, including through the adoption of specific contractual clauses, compliance verification mechanisms, certifications or other valid legal instruments, as provided for in articles 33 to 36 of the LGPD.

10.3. MULTIPLIERAPP declares that, regardless of the place of storage or processing, the processing of Personal Data will follow the principles of the LGPD, respecting the rights of the holders and ensuring adequate technical and organizational measures to guarantee their security and integrity.

10.4. By using MULTIPLIERAPP’s services, the USER understands that their Personal Data may be processed and transferred internationally, including to the United States of America, in accordance with the conditions set out in this Privacy Policy. 

11. INFORMATION SECURITY

11.1. MULTIPLIERAPP adopts strict technical and administrative controls to protect the Personal Data under its responsibility, in order to guarantee the confidentiality, integrity and availability of the information collected and stored.

11.2. Among the measures adopted are: user authentication, data and transaction encryption, access controls and network segmentation, prevention and detection of unauthorized access, protection against malicious software, periodic security tests, traceability mechanisms, and regular backups.

11.3. Security also depends on the conduct of the users themselves. It is the USER’s responsibility to adopt safe practices, such as not sharing passwords and keeping their devices safe from unauthorized access.

11.3.1. If the USER identifies any indication that their Personal Data has been compromised, they must immediately notify MULTIPLIERAPP by e-mailing [email protected] or through the service channel on the website.

11.4. MULTIPLIERAPP is not responsible for the security of Personal Data entered by the USER on third-party websites or services. In such cases, the holder must observe the privacy policies and security measures adopted by such third parties.

12. CHANGES IN POLITICS

12.1. This Privacy Policy may be updated at any time, whenever there is a need for legal, regulatory or operational adaptation.

12.2. MULTIPLIERAPP undertakes to notify the owners, through official channels (such as e-mail or notice on the Platform), whenever there are relevant changes to the content of this Policy.

12.3. Continued use of the services after publication of the new version will be interpreted as acknowledgement of the new Policy. If you have any questions, please contact the service channel indicated in this Policy.

13. ADDITIONAL POLICIES

 By connecting any account to MULTIPLIERAPP, you agree to the privacy policies of the corresponding media or social networking platform:

• YouTube – https://policies.google.com/privacy
• YouTube – https://www.youtube.com/t/terms
• YouTube – https://security.google.com/settings/security/permissions
• Facebook – https://www.facebook.com/privacy/policy

To delete your stored data from Google, you can revoke MultiplierApp’s access to your data directly via the Google security settings page at https://security.google.com/settings/security/permissions.

The above list is for your reference only. If you cannot find in this list the media or social networking platform you have connected to MultiplierApp, please visit the website for the Terms of Use and Privacy Policy of each platform.