Unlock/Matchmaking Privacy Policy

General Information and Definitions

Omelete Company is a business group comprised of various entertainment companies. It values user privacy and has created this Privacy Policy to demonstrate its commitment to protecting your privacy and personal data, in accordance with the Brazilian General Data Protection Law (LGPD) and other applicable legislation. This policy also aims to transparently describe how Omelete Company protects your privacy when collecting, processing, and storing your personal information.

 

1.1 Definitions

User: All individuals who access or use the Site(s) and/or Application(s), aged 18 or older, or legally emancipated and fully capable of performing civil acts, or those who are legally represented or assisted.

Personal Data: Any information provided and/or collected by Omelete Company and/or its group companies, by any means, whether public or not, that: (I) identifies or, when used in combination with other information processed by Omelete Company, identifies an individual; or (II) through which the identification or contact information of a natural person can be derived. Personal Data may exist in any media or format, including electronic or computerized records as well as paper-based files. Personal Data does not include business phone numbers, business mobile numbers, business addresses, or business emails.

Data Processing: Any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control, modification, communication, transfer, dissemination, or extraction.

Purpose: The objective that Omelete Company seeks to achieve by processing personal data.

Necessity: Justification for the strict need to collect personal data to fulfill the intended purpose, avoiding excessive data collection.

Legal Basis: The legal justification that legitimizes the processing of personal data for a specific purpose by Omelete Company.

Consent: The express and unequivocal authorization given by the User, the data subject, allowing Omelete Company to process their personal data for a previously described purpose that requires explicit authorization.

This policy applies to all current and potential Users of UNLOCK CCXP and outlines how Omelete Company and its group companies may collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, delete, evaluate, control, modify, communicate, transfer, disseminate, or extract collected data, including personal identification information, in accordance with applicable legal bases and all current privacy and data protection laws.

By accessing and/or using Omelete Company’s websites, the User declares they are at least 18 years old and legally capable of accepting the terms and conditions of this Privacy Policy and the Consent Agreement for all legal purposes, or have authorization from a guardian to do so.

If the User does not meet the above description and/or disagrees, even partially, with the terms and conditions of this Privacy Policy, they should not access and/or use the services provided by Omelete Company, including its websites and platforms.

2. Collection and Use of Personal Information

The User acknowledges that they provide information knowingly and voluntarily through registration forms.

When the User registers and/or completes forms provided by Omelete Company or browses its platforms and websites, certain requested Personal Data will be kept confidential and used only for the purpose for which it was provided, as outlined in the table below:

Platform	Personal Data Category	Purpose	Legal Basis
Unlock Registration / Matchmaking	Full Name, Preferred Name, Email, Mobile Number, Password, Phone, Gender, Birthdate, Full Address, CPF, Professional Data, Profile Picture (upload), Billing and Investment Information of Legal Entity	Required for registration and interaction within the platform, personalization of user experience, networking, and sending marketing emails about events, promotions, and other activities of the Omelete Company Group. Information may be visible to other users.	Contract Execution; Controller’s Legitimate Interest; Consent
Website Browsing and Platform Usage	Behavioral Data	Collected through cookies, pixels, and algorithms to tailor advertising based on user interests and personalize the user experience via content recommendation engines.	Controller’s Legitimate Interest

Automatic Data Collection: When accessing our website, some information is automatically collected to enhance user experience and navigation, enable market intelligence analysis, and deliver targeted advertising. Examples include city of access, system used, referring site, visited pages, access time and duration, and device information.

No personally identifiable data is collected automatically without user consent. Automatically collected data cannot identify the user and is typically stored in browser cookies.

Disabling cookies may impair user experience.

3. Sharing and Processing of Personal Information

Omelete Company does not share Personal Data collected on its websites with mailing list brokers without your express consent.

Matchmaking Platform and Data Sharing: By registering for and using the matchmaking platform, the User explicitly consents to the visibility of their personal data (as outlined in the purpose table) to other platform participants. This is essential for the platform’s goal of facilitating professional connections, meeting scheduling, and networking opportunities.

The User is free to choose what information to display publicly and may delete such data via their platform account at any time.

Omelete Company is committed to transparency and security and applies appropriate technical and administrative measures for data protection.

Omelete Company is a business group including brands such as Omelete, CCXP, Gaules, The Enemy, BIG (gamescom latam), Baiano, GameXP, and Chippu (more at www.omeletecompany.com/sobre). By providing personal data to one of these brands, you consent to its sharing within the group and may receive communications from them. You may withdraw consent anytime via unsubscribe links or by contacting our DPO – Ana Angélica Espinheira D’Aguiar – dpo@omeletecompany.com.

Omelete Company may also disclose Personal Data in the following cases, within the limits of applicable law:

• To clients or partners for service delivery (e.g., artist search filters);
  
  
• To contractors and service providers;
  
  
• To group companies;
  
  
• For internal administrative purposes (research, planning, development, risk management);
  
  
• Due to legal obligations, orders from authorities, or court decisions.
  
  

We currently share data with NAVEGG - NVG PARTICIPAÇÕES LTDA, for data intelligence services. By accepting this policy, you agree to their privacy policy: https://www.navegg.com/br/politica-de-privacidade.

4. Legal Grounds for Disclosure

Omelete Company may disclose Personal Data to public authorities, consultants, or other third parties when necessary:

• To comply with legal requirements or court orders;
  
  
• To prevent or address suspected or actual illegal activities;
  
  
• To enforce contracts;
  
  
• To protect the safety of services, users, or the public;
  
  
• In case of mergers, acquisitions, or dissolution.
  
  

Omelete Company will notify Users of such disclosures unless prohibited by law or court order.

5. Security of Personal Information

All Personal Data is stored on Omelete Company servers or secure third-party cloud environments. Our systems follow legal requirements for data protection and apply encryption for data in transit.

Despite our best efforts, no security system is foolproof, and Users understand that absolute security cannot be guaranteed.

6. Data Retention

We store Personal Data only as long as necessary for the purposes it was collected or as required by legal or contractual obligations.

We perform regular assessments to determine appropriate retention periods based on data type, purpose, and legal considerations.

7. Legal Basis for Processing

We process Personal Data based on:

• Express and unequivocal consent;
  
  
• Contract execution or negotiation;
  
  
• Legitimate interest, provided it doesn’t infringe User rights.
  
  

Examples include: complying with laws, defending rights in legal processes, managing business operations, enhancing customer relationships, and facilitating economic opportunities.

Users may withdraw consent at any time, which may result in the termination of services provided by Omelete Company.

Questions about legal bases can be directed to our DPO at dpo@omeletecompany.com.

8. User Rights: Access and Control

Users may:

• Request deletion of data;
  
  
• Edit or correct data;
  
  
• Object to or limit use of data;
  
  
• Request a copy of their data.
  
  

Requests can be made by contacting our DPO at dpo@omeletecompany.com and will be evaluated under applicable laws.

We may retain data in compliance with Article 16 of the LGPD for legal, regulatory, or statistical purposes, or to protect our rights.

9. Policy Updates

This Privacy Policy is effective as of 09/10/2019 and may be updated on Omelete Company’s website. If you have questions, contact our DPO.

10. Contact

Data Protection Officer: Ana Angélica Espinheira D’Aguiar
Email: dpo@omeletecompany.com

11. Jurisdiction and Mediation

This policy is governed by Brazilian law. Any disputes shall be resolved in the jurisdiction of São Paulo.

In case of incidents involving Personal Data, Omelete Company reserves the right to appoint JUSPRO – Justiça Sem Processo as the Mediation Chamber under Article 52, §7 of the LGPD.