Supplemental Privacy Notice for Residents of Brazil
Updated: January 2025
Table of Contents
- Introduction
- Lawful Basis for Processing Personal Information
- Storage of Personal Information Outside Brazil
- Your Rights to Your Personal Information
- Complaints Regarding Our Privacy Practices
- How to Make a Rights Request
I. Introduction
This Supplemental Privacy Notice (“Supplemental Policy”) is part of and supplements the GeorgeTom Inc. (hereafter, “GeorgeTom,” “we,” “us,” “our,” or the “Company”) Privacy Policy and further describes how GeorgeTom collects, uses, and shares Personal Information. This Supplemental Notice applies to the Company’s online and offline information gathering and dissemination practices in connection with the Company’s website (the “Site”) and Personal Information we may collect or receive through other means. This Supplemental Notice applies only to Personal Information collected about consumers in Brazil pursuant to Article 3 of the Brazilian General Data Protection Law (“Law No. 13,709/2018” or “LGPD”).
The Company serves as the data controller of Personal Information collected and processed through its Site. We can be contacted at:
Chief Legal Officer
GeorgeTom Inc.
PO Box 158067
1906 Glen Echo Road
Nashville TN 37215
Email: privacy@candaceowens.com
II. Lawful Basis for Processing Personal Information
Our lawful basis for processing Personal Information collected and covered by this Supplemental Notice will depend on the nature of information collected and the purpose of processing that information as described in the chart below.
| Types of Personal Information | Purpose of Processing | Lawful Basis |
| Contact Information (e.g., name and email address) | Communicate and manage our relationship with you | Legitimate Business Purpose |
| Date of Birth | Marketing analytics and offerings Develop, improve, and provide content and services to you related to our website | Consent |
| Gender | Marketing analytics and offerings Develop, improve, and provide content and services to you related to our website | Consent |
| Device/Internet information (such as computer, device, and connection information, including IP address, browser type, operating system, website usage data, etc.) | Cybersecurity Marketing analytics and offerings | Legitimate Business Purpose |
| Geolocation | Marketing analytics and offerings Develop, improve, and provide content and services to you related to our website | Consent |
III. Storage of Personal Information Outside Brazil
Personal Information collected by us through the Site will be processed in the United States. Visitors and users of the Site acknowledge that Personal Information provided and collected through our Site will be stored in the United States.
IV. Your Rights to Your Personal Information
In certain circumstances and in accordance with applicable local laws, you have rights under data protection laws with respect to your Personal Information. You have the right to (i) confirmation of whether your data is being processed; (ii) access to your data; (iii) correction of incomplete, inaccurate, or outdated information; (iv) anonymization, blocking, or deletion of unnecessary, excessive, or information not processed according to LGPD’s provisions; (v) portability of information to another service or product provider, upon express request, subject to commercial and industrial secrets; (vi) deletion of information processed based on your consent; (vii) information of public and private entities with which we share data; (viii) information about the possibility to refuse providing consent to a personal information processing activity and the respective consequences, when applicable; (ix) right to object to certain types of processing; and (x) right to withdraw consent.
V. Complaints Regarding Our Privacy Practices
If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority. However, we would appreciate the opportunity to address any concern that you may have by emailing us at privacy@candaceowens.com.
VI. How to Make a Rights Request
A. Instructions for Submitting a Rights Request to Us
If you wish to exercise any of the rights summarized above, you can do so in one of the following ways:
Click on this link to complete and submit the referenced web form; or
Reach us by email or U.S. mail at:
Chief Legal Officer
GeorgeTom Inc.
PO Box 158067
1906 Glen Echo Road
Nashville TN 37215
Email: privacy@candaceowens.com
Upon receiving a verifiable request, we will confirm receipt of the request and respond within 15 days or less.
B. Verification Of the Person Making a Consumer Rights Request
Of course, we need to be reasonably sure that the person making the request is you! So, we may need some information from you to verify that you are the person whose Personal Information you are asking to know about or to delete. Accordingly, the verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify whether you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
