Privacy Policy

Wild Thermas Club is committed to complying with the laws that protect the data privacy of customers and the general public. This page is designed to provide information on how we follow data protection standards, what information we collect while you are browsing our communication channels, and how this information is collected, used, and protected by us, in compliance with Law No. 13.709/2018 (General Data Protection Law – “LGPD”). The use of our products and services, as well as our platforms and other available means of interaction, is subject to the acceptance of this Privacy Policy, including regarding our employees.

1. Source of Personal Data

Wild Thermas Club will have access to personal data in the following situations:

Through interaction with a customer: When the Customer provides and enters personal data necessary for the provision of services and use of products provided by Wild Thermas Club.
Interaction with its employees: When its employees and collaborators of any nature use its systems and platforms to fulfill the duties and obligations arising from the contractual relationship they hold.

2. Types of Personal Data and Sensitive Personal Data Collected

Without prejudice to the data commonly collected and processed from its employees for the purposes of their legal relationship, Wild Thermas Club may also collect the following personal data:

Names and contact details: such as first and last name, email address, postal address, telephone number, and other similar types of contact data, such as bank details;
Device information: such as information about your device, including IP address, location, or provider;
Usage information and browsing history: such as information on how the User navigates within our services, their browsing history, and which elements of Wild Thermas Club's services are most used;
Sensitive personal data: Any sensitive personal data eventually collected by Wild Thermas Club will have its purpose informed separately to the User, who must consent for Wild Thermas Club to use it in a specific manner; in case of disagreement, the data will be automatically deleted from Wild Thermas Club's databases.

Wild Thermas Club does not collect data from minors, except with the authorization of parents or guardians. If collected without authorization, as soon as Wild Thermas Club becomes aware, it will immediately delete the collected data, in accordance with the rules of the Terms of Use and this Privacy Policy.

3. Use of Collected Personal Data

When collected, Wild Thermas Club will use personal data to:

Provide and improve contracted services;
Comply with a legal or regulatory obligation;
Administer the relationship with Users;
Set up and manage User accounts;
Provide technical assistance, support, and training to the User;
Contact Users;
Internal research and development purposes and to improve, test, and refine the features and functions of Wild Thermas Club services;
Provide Users with marketing, advertising, and publicity, including from Partner companies of Wild Thermas Club, as permitted by law;
Meet internal and external audit requirements, including Wild Thermas Club's information security obligations;
Send electronic mail messages to: a) perform confirmations or cancellations of requests through the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, inclusions of new data sources, and improvements to the platform;
Exercise Wild Thermas Club's rights, including but not limited to privacy, security, networks, systems, and properties of Wild Thermas Club and/or third parties;
Comply with requests from courts, law enforcement agencies, regulatory bodies, and other public institutions and government authorities, including but not limited to rules in force outside the user's country of residence;
Exercise Wild Thermas Club's rights to defend itself in eventual legal actions, as well as to comply with any legislation or regulation applicable to Wild Thermas Club or third parties with whom we work, and for the proper fulfillment of contracts signed between Wild Thermas Club and its users.

4. Sharing Personal Data with Third Parties

The User accepts and agrees that Wild Thermas Club may share their personal data with the following categories of recipients:

Companies that provide access or are responsible for the registration on which the user is dependent;
Partner companies, such as third-party service providers and other companies that assist us in offering our services or that may take actions on our behalf, protecting our rights, users, systems, and services;
Third parties to whom Wild Thermas Club owes accountability or has authorization for information disclosure by law (e.g., government bodies, regulatory agencies, the judiciary, and other public authorities);
Third parties in order to participate in a sale, merger, acquisition, restructuring, joint venture, assignment, or transfer of part or all of Wild Thermas Club's business, in which case the User's data will be considered an asset and transferred in an eventual negotiation;
Third parties who require the data to protect the rights of Wild Thermas Club;
Any physical or legal person to whom the User requests the portability of their data.

5. International Transfer of Personal Data

Wild Thermas Club does not intend to transfer any personal data of the User collected to outside Brazil. Should the hypotheses below not apply, Users will be previously informed by email, at which time the user may accept or reject the transfer; in case of disagreement, their access rights may be hindered by Wild Thermas Club.

The international transfer of data described in the General Data Protection Law (LGPD) requires the designation of guidelines to be established by the National Data Protection Authority (ANPD); once defined, Wild Thermas Club commits to complying with them in their entirety.

6. Protection of Personal Data

Wild Thermas Club uses appropriate technologies and procedures to protect any personal data collected (including administrative, technical, and physical safeguards) according to the risk level and the service provided. It maintains a legally responsible team for secure data management in line with legal provisions, regulatory requirements, technological changes, and other relevant factors.

Wild Thermas Club employs all reasonable market efforts to ensure the security of its systems and collected data, using highly qualified and reputable Internet providers, database servers, and storage, as well as security certificates (SSL) and protection software against unauthorized access, and standard methods for encrypting and anonymizing collected data.

This Policy represents Wild Thermas Club's effort to safeguard User information. However, due to the nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing stored information; should this occur, Wild Thermas Club will be liable within the limits provided by Law.

Wild Thermas Club shall, within a reasonable period to be defined by the ANPD, communicate to the ANPD and the affected User the occurrence of a security incident that may cause relevant risk or damage, mentioning at least:

A description of the nature of the affected personal data;
Information about the data subjects involved;
Indication of the technical and security measures used for data protection;
Risks related to the incident;
Reasons for delay, if communication was not immediate;
Measures adopted or to be adopted to reverse or mitigate the effects of the loss.

7. Data Processing and Responsibility of Wild Thermas Club

Wild Thermas Club’s processing responsibility is defined as follows:

When dealing with personal data provided directly by its Customers, Wild Thermas Club will be the Processor (Operadora), acting without interference in the processing method indicated by the Controller, but under the terms of the LGPD;
Wild Thermas Club will be the Controller (Controladora) of its employees' Personal Data, processing them based on Contract Execution, Compliance with legal or regulatory obligations, and, in specific situations, Consent.
Wild Thermas Club may adopt different legal bases for different processing of personal data.

8. Term of Personal Data Processing

Wild Thermas Club calculates the retention period of personal data according to the following criteria:

Period necessary to fulfill the purpose of the collection;
When the Customer/User stops using Wild Thermas Club services;
When there is a revocation of consent or a request for deletion of personal data by the Data Subject;
Time necessary to demonstrate compliance with Wild Thermas Club's duties and obligations;
The necessary period provided for by Law, regulations, court decisions, etc.;
Determination by the National Data Protection Authority;
Compliance with a legal or regulatory obligation by the Controller;
Perfect execution of the contract;
Needs related to compliance with the legal system or eventual legal disputes;
Transfer to a third party, provided that data processing requirements in law are respected; or
Exclusive use by the controller, prohibited from access by third parties, provided the data is anonymized.

9. User Rights

Under the Brazilian General Data Protection Law, the User has the following rights regarding the processing of their personal data:

Right of Confirmation: The User may confirm if Wild Thermas Club processes any of their personal data;
Right of Access: The User may make a written request to obtain details of how their information is being used and to have a copy of said information;
Right to Correction: The User may correct or remove any data that is incomplete, inaccurate, or outdated;
Right to Anonymization, Blocking, or Deletion: The User may request the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the purposes for which consent was given;
Right of Erasure: The User may request the deletion of some data, except those that the law authorizes to be preserved;
Right to Information: The User may request information about public and private entities with which Wild Thermas Club shared data, as well as the consequences of not providing consent;
Right to Refuse Marketing: The User may, at any time, request the cancellation of advertisements through the link provided in the marketing emails;
Right of Portability: The User may request that their personal data be transferred to themselves or third parties, except those already anonymized or deleted;
Right to Revoke Consent: The User may cancel any previously granted consent. The User is aware that cancellation will not affect the use or sharing of data performed prior to the revocation request.

These rights are not absolute. To exercise them, the User must contact Wild Thermas Club at: This email address is being protected from spambots. You need JavaScript enabled to view it.. Wild Thermas Club commits to meeting such requests as soon as possible, within a maximum of 15 (fifteen) days, unless a longer period is required due to complexity.

10. Cookies

Wild Thermas Club and its partners may use cookies to manage User preferences, offer targeted advertising, and collect analytical data.

Necessary Cookies: Essential for platform navigation;
Performance Cookies: Collect information on how the User uses the platform to improve experience;
Functional Cookies: Remember User choices (language, ID) for enhanced features;
Advertising Cookies: Track browsing habits for targeted ads.

Wild Thermas Club currently uses necessary and performance cookies. Users can disable cookies through their browser settings.

11. Contact Information

Questions, comments, or complaints regarding this Privacy Policy should be directed to: This email address is being protected from spambots. You need JavaScript enabled to view it..

12. Alterations

This Privacy Policy may be updated at any time. In the event of changes affecting the purpose or duration of processing, the User will be informed via email or the platform 30 (thirty) days in advance.

13. Legislation and Jurisdiction

This Policy is governed by the laws of the Federative Republic of Brazil. The Court of São Paulo is designated to resolve any doubts arising from this instrument.