PRIVACY POLICY

1.PURPOSE

The Vancouros Group is concerned about the privacy of those with whom it relates and devotes all its care into Personal Data Treatment. For this reason, Vancouros Group has a Privacy Policy which aims to establish minimum guidelines to those who treat Personal Data on behalf and in the name of Vancouros Group and on the guidelines related to the protection of Personal Data.

 

2.DEFINITIONS

For the purposes of this Privacy Policy, the terms defined below of the capital letters, whether in the singular or plural, shall have the following meanings:

Treatment Agents: The Controller and the Operator;

Anonymization: use of reasonable technical means available at the time of treatment, whereby a data loses the possibility of association, directly or indirectly, to an individual;

National Personal Data Protection Authority (ANPD): is the body of the federal public administration of Brazil, with attributions related to the protection of Personal Data, for privacy and enforcement of compliance with the General Law of Protection of Dados (LGPD) in all national territory;

Database: Structure set of Personal Data, established in one or more locations, on electronic or physical support;

Blocking: temporary suspension of any treatment operation, by keeping the Personal Data or the Database;

Vancouros Group: Vancouros Indústria e Comércio de Couros Ltda.,its subsidiaries and the companies associated with it and controlled and/or managed by it;

Consent: free, informed and unambiguous manifestation by which the Holder agrees to the Treatment of his Personal Data for a specific purpose;

Controller: physical or legal person, public or private, to whom the decisions relating to the Treatment of Personal Data are responsible;

Anonymized Data: The Owner's report that cannot be identified, considering the use of reasonable technical means and available at the time of its Treatment;

Personal Data: information related to identified or identifiable natural person;

Sensitive Personal Data: Person´s race or ethnic origin, religious conviction, political opinion, union membership or organization of a religious character, philosophical or political, personal data concerning a person´s health and sex life, genetic or biometric data, when it is linked to a natural person;

Device: computer, tablet, smartphone or other mobile device, or any other means by which it is possible to access the websites of Vancouros Group;

Elimination: deletion or stored data set in Database, regardless of the procedure employed;

In charge:Person indicated by the Controller and the Operator to act as a communication channel between the Controller, the Data Holders and the ANPD, sendo o Encarregado also known, in the English language, by the acronym DPO;

Legitimate Interest: legal basis that authorizes the treatment of personal data when the use of these is necessary to serve legitimate interests;

General Data protection law (LGPD): Law No. 13,709 of August 14, 2018, which provides for the treatment of Personal Data, including in digital media, by a natural person or by a legal entity under public law or deprived, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the personality of the natural person;

Operator: natural or legal person, under public or private law, who carries out the Treatment of Personal Data on behalf of the Controller;

Research Body: body or entity of direct or indirect public administration or legal entity of law deprives the non-profit legally constituted under Brazilian laws, with its registered office and forum in the country, which includes in its institutional mission or in its social or statutory objective the basic or applied research of historical, scientific character, technological or statistical;

Holder: natural person to whom the Personal Data that are the object of Processing refer;

International Transfer of Data: transfer of Personal Data to foreign country or international body of which the country is a member;

Treatment: all operation performed with Personal Data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction;

Personal Data Protection Impact Report: The Control's description of personal da treatment processes that can pose risks to civil liberties and fundamental rights, as well as measures, safeguards and risk mitigation mechanisms;

Reversal: relink an anonymized data, by any means or technique, to an identifiable individual;

Shared Use of Data: communication, diffusion, international transfer, interconnection of Personal Data or Personal Treatment shares of personal database by public bodies and entities in compliance with their legal powers, or between these and private entities, reciprocally, with specific authorization for one or more treatment modalities permitted by these public entities, or between private entities.

 

3.OBJECTIVE

The purpose of this Privacy Policy is to define the requirements and procedures necessary to ensure the compliance of Vancouros Group with the laws and regulations dealing with the Protection of Personal Data, establishing the minimum guidelines to employees, collaborators, business partners and third parties on the legitimate Treatment of Personal Data.

 

4.PUBLIC

This Privacy Policy applies to those who treat Personal Data on behalf and name of the Vancouros Group, which is an enforceable standard and reflects the corporate governance of the Vancouros Group regarding the Treatment of Personal Data.

 

5.CONTENT

  1. Scope

This Privacy Policy covers any and all Personal Data Treatment performed by Vancouros Group, regardless of the medium, whether physical or electronic, the public, whether external or internal, and the purpose of the Treatment performs.

 

5.2.Sources of Personal Data

his Privacy Policy appliesto the Personal Data collected by Vancouros Group through the following information described below and from the following sources:

  1. Vancouros Group platforms: comprise the websites and applications facing the employees, collaborators, business partners and Vancouros Group consumers, with own domains and URLs, as well as those facing third parties in general, including B2C e-commerce apps and minisites on third-party crowded into social network such as Facebook, Instagram, LinkedIn, Vagas.com, Reclame aqui and YouTube;
  2. e-mails, text messages, forms and other electronic messages: comprise all electronic communications established between the Data Holder from Vancouros Group;
  3. offline registration forms: printed or digital forms or similar forms in which are collected personal data, such as, for example those sent by Post Office, presented in contests, promotions and events, employee registrations, collaborators, suppliers, clients, business partners, lists of plaintiffs in administrative and judicial proceedings and any other lists, forms or registers drawn up in the legitimate interest of Vancouros Group, including the documents delivered to the ordinances and receptions of Vancouros Group through carriers, as well as the collection of visitors Personal Data, carried out by the porters and/or receptionists of Vancouros Group;
  4. Automated interactions or with Control of third parties: are cited in this category, for example, collected data through interactions with ads of Vancouros Group on third-party websites or interactions occurred through social networks; Data obtained through market research, promotional partners, public sources; Data obtained, shared or transferred due to mergers, acquisitions, incorporations, splits, joint ventures, or on the grounds of other institutes of the right of companies;
  5. contracts or pre-contractual forms: this category includes personal data present in the identification of individuals who appear or may appear in contracts, of various species, signed or to be signed Vancouros Group.

 

5.3.Typology of Personal Data

The Personal Data collected from Vancouros Group are classifiable in at least any of the following species:

  1. personal and contact information derived from, registrations, contracts, lists, public sources, third-party sources controllers or any other sources suitable and strictly necessary to achieve lawful and legitimate purposes of Vancouros Group, such as, for example, for the performance of contracts and legal obligations, exercise of the right to petition, to meet your legitimate interest, hiring employees who have directed their curriculum to any of the group companies, etc.;
  1. login and account information;
  2. demographic information and interest profile;
  3. Information of technical nature about access devices to Vancouros Group websites and applications;
  4. automated information on the use of Vancouros Group platforms;
  5. pmarket surveys and third-party feedback;
  6. content voluntarily generated by the Holders themselves, from channels such as "Journalist's Register", "Work with Us", helpline, sending emails, "Contact Us", "SAC" and others;
  7. information originated from platforms administered by third party’s controllers;
  8. financial and payment information.

 

5.4.Essential Principles of Personal Data Treatment

All and any Treatment of Personnel by the Vancouros Group must be strictly necessary to comply with a lawful purpose, or, in other words, for a purpose that is provided for in any of the legal bases described in Art. 7 of the LGPD. In the table below, some examples are summarizing of lawful purposes and the legal bases that authorize, on a case-by-case basis, the Treatment of Personal Data by Vancouros Group:

PURPOSE OF THE TREATMENT OF DADOS PERSONAL

LEGAL BASES THAT AUTHORIZE PERSONALS TREATMENT

(i) Provided goods or services requested by the Data Subject customer

Providing consent by the holder (Art. 7, item I, lgpd)

(ii) Manage contracts in which the Holder do or come be part

Execution of contract or preliminary procedures related to contract (art. 7, item V, LGPD)

 

(iii) Comply with labor, administrative, accounting, tax and other legal obligations

Compliance with legal or regulatory obligation (Art. 7, item II, of the LGPD)

(iv) Use anonymized Data aggregate form for market research purposes and other commercial initiatives, including the use of automated tools, in the interest of the data controller, controller and third parts

Necessary to attend the legitimate interests of the Control ofr or third parties (art. 7, item IX, of the LGPD);

(v) Manage administrative or judicial proceedings and procedures, of which the Holder may be a part

egular exercise of rights of those in judicial, administrative or arbitral proceedings (Art. 7, item VI, LGPD)

(vi) Mergers, acquisitions, acquisitions, joint ventures, and other transactions involving legal institutes of the law of the companies that compose the Group

Compliance with legal or regulatory obligation (art. 7, item II, of the LGPD); Necessary to attend the legitimate interests of the Controller or third parties (Art. 7, item IX, LGPD)

 

 

In any case, including for any processing processes that may be added to this Privacy Policy, this document is consistent with the following principles to be followed during the personal data process on behalf of and name of Vancouros Group:

  1. Minimization: when processing Personal Data, the Vancouros Group must limit itself to the minimum data necessary to carry out its purpose;
  2. Purpose: for the Treatment of Personal Data be legitimate, Vancouros Group must inform the Holder for what specific purposes the Processing will be carried out;
  3. Adequacy: The Treatment must be compatible with the purpose informed to the Holder by Vancouros Group;
  4. Necessity: The Treatment may becarried out only as necessary for the accomplishment of legitimate purposes and previously informed to the Holder;
  5. Free access: the Holder may, in an easy and freeway, consult Vancouros Group regarding the form and duration of the Treatment of his Personal Data;
  6. Data quality: the personal stored by Vancouros Group must be up-to-date, clear and accurate;
  7. Transparency: All information on how personal data is processed should be clear, accurate and easily accessible. The Holder must know which data are being treated by Vancouros Group and for what purpose;
  8. Security: The Vancouros Group must take all technical and administrative measures of information security, able to protect personal data from unlawful access, destruction, loss, alteration, transmission or dissemination;
  9. Prevention: The Vancouros Group must adopt measures to prevent the occurrence of damage due to personal da treatment, such as periodic audits, training, etc.;
  10. Non-discrimination: it is expressly forbidden to perform Personal Data Treatment for discriminatory and/or abusive purposes;
  11. Responsibility and accountability: it is Vancouros Group commitment to effective measures and capable of proving compliance with and compliance with protection of personal data and effectiveness of these measures.

 

5.5.Disclosure and transmission of personal data

Personal information may be disclosed or transmitted whenever necessary for compliance with legal or regulatory obligation, for the regular exercise of rights in contracts or judicial and administrative proceedings of which the Vancouros Group is a party or interested party or, furthermore, to meet the legitimate interests of its own or third parties, such as, for example, in cases of credit protection or for marketing and remarketing purposes; such may also be disclosed or transmitted if there is a judicial or administrative decision of a competent authority.

Without prejudice in other ways authorized by law, the data and personal information may be disclosed or transmitted to third parties in the following cases:

  1. Disclosure by the Vancouros Group itself : in order to comply with certain legal and regulatory obligations, it is necessary to disclose, for example, reports, minutes, statements of publication in official journals, extracts of contracts, sales statements, among other of documents originated in Vancouros Group itself, whose contents will contain the personal information of people whose participation and qualification were essential for the practice of the act or for the preparation of the documents;
  2. Subsidiaries, branches and foreign members: in the legitimate interest of the Vancouros Group, but also to comply with certain legal and regulatory obligations or even to promote the execution of contracts, the Vancouros Group may transfer personal information between subsidiaries and branches, as well as to companies that make up the corporate framework of certain companies of the Group. In the latter case, having International Transfer, if the country of destination does not provide adequate degree of protection of the Personal Data, it is up to Vancouros Group to prove the guarantee of compliance with the principles of protection of the transfer, the specific consent and highlighted for the transfer, informan of the prior holder on the international character of the operation, clearly distinguishes it from other purposes. In these cases, Vancouros Group will collect the Holder's consent through a specific consent form.
  3. Employees and business partners: in order to fulfill duties or contracts in related form or arranged in contractual networks, the Vancouros Group may disclose or transfer personal information to third parties. In this case, Vancouros Group will carry out.

Register, however, that Vancouros Group cannot be responsible for the Treatment of personal information controlled by third parties, even if they are your collaborators or business partners, being solely responsible for:

  1. Add its current contracts signed with your providers and service providers, so that, in accordance with this Privacy Policy, they comply with their respective Treatments of data to the guidelines of Vancouros Group;
  2. Investigate and denounce and, within its private competences, contractual and legal, penalize employees, collaborators and / or business partners who make improper use of data and personal information processed by Vancouros Group.
  3. Commit to the education and continuous training of its employees, in relation to the governance of data and the ethical use, responsible and legitimate for the personal data and information processes by Vancouros Group.
  4. Order emanating from a judicial or administrative authority: if the competent judicial and/or administrative authority is ordered to disclose, open, breach of confidentiality or the transfer of data or personal information of any individual or group of individuals whose data is in the possession of Vancouros Group.
  5. Institutes of corporate law: data and personal information may be disclosed, shared or assigned in cases concerning business law, such as in case of judicial recovery, bankruptcy, mergers, acquisitions, incorporations, joint ventures, opening of subsidiaries, branches, etc.; having the International Transfer of Data in the case in question, the guarantee of compliance with the principles of protection of the transferred data and the specific and prominent consent for the transfer, with prior information of the Holder on the international nature of the operation, clearly distinguishes it from other purposes.

5.6.Data Retention Time

The data and personal information must be kept as long as necessary to exhaust the legitimate purposes for which they were collected and, in having the normative provision on the subject, must be kept for the minimum time provided for by law.

 

5.7.Rights of Data Holders

The Personal Data Holder may request from the Company:

  1. Access: unless otherwise provided by law, the individual enjoys the full right to access, review and request copies of the information that Vancouros Group holds about him, as well as on the source of his own information; this right may be exercised only by the Owner himself or by his attorney, juts send the request , instructed with a copy of your civil identification and, if applicable, also the power of attorney, to the following addresses: dpo@vancouros.com.br or Avenida dos Expedicionários, nº 469, Centro, Rolândia/PR, CEP 86.600-091,to the care of the "Charge of the protection of the data “of the Vancouros Group";
  2. Rectification, portability and exclusion: in cases of proven alteration of its Personal Data or the existence of possible errors in the records of Vancouros Group, it is the Right of the Holder to request Vancouros Group the corresponding rectification. You are also entitled to the portability of our data and information. The exclusion of the Personal Data, in turn, may have its extent limited by the fulfilment of legal or contractual obligations; similarly, in the legitimate interest of Vancouros Group, some data may be kept even after your deletion request, in order to provide, for example, strictly necessary contacts and future accesses;
  3. Withdrawal of consent: Whenever consent is the applicable legal basis and where technically possible, Vancouros Group websites and applications will contain banners, pop-ups and redirect links to some "Consent Management Form" through which the Holder may, in the most granular way possible, customize the consents ceded to the Group, including exercising its right of revocation to some consent previously given.
  4. Right of petition: pursuant to Article 18, §1 of the LGPD, it is the Right of the Holder to file a complaint with the ANPD body, whenever it has an unresolved demand by Vancouros Group's Charge or feels harmed in any of its rights due to the Treatment of its and personal information.

 

5.8.Sensitive Personal Data

This Privacy Policy adopts as rule of non-treatment of Personal Data considers sensitive, such as Personal Data on racial or ethnic origin, religious belief, political opinion, membership to a trade union or the organization of a religious, philosophical or political nature, of the health or sexual life, genetic data or biometric, unless strictly necessary to:

  1. detection and prevention of crimes;
  2. compliance with specific laws and regulations, having as rule the use only in aggregate form, whenever legal, logistical and technically possible and the adoption of anonymization of data whenever possible;
  3. regular exercise of rights in contracts or proceedings, having as a rule the subsidiarity, i.e., only if there is no other means of respecting or exhausting other equally effective means for the fulfilment of the same purposes;
  4. prevention of fraud and security of the Holder and its data, having as rule the subsidiarity, that is, only if there are no existing or exhaust s other means equally effective for the fulfillment of the same purposes;
  5. compliance with an order emanating from a competent judicial or administrative authority;
  6. legitimate interest of the Vancouros Group, in cases in which corporate policies of inclusion, access, non-discrimination, non-violence, etc., so require, having as rule the anonymization and use only in the aggregate form of the generated data, staying prohibited reversal under any justification;
  7. protection of the life or physical safety of the Holder or third party, having as rule the subsidiarity, i.e., only if there are no other means equally effective forthe fulfillment of the same purposes.

In all cases, including when there is anonymization, specific and detached consent of the individual is applied, which will be previously collected by Vancouros Group;

 

5.9.Data of minors or civilly incapacitated persons

If, in order to comply with legal or contractual obligations, or even in the regular exercise of rights in judicial, administrative or arbitration proceedings it is necessaryto deal with the Personal Data of minors or incapacitated persons, these must be dealt according to the following rules:

  1. always in the best interest of the minor or incapables;
  2. only having specific consent and highlights of the data by one of the parents or by the legal guardian (guardian, cure, etc.), provided that its properly identification;
  3. using assistive and inclusive technologies, when of necessary for the consent of the parents or legal guardian to be unequivocal;

 

6.GENERAL PROVISIONS

The Personal Data Holder declares to be fully aware of his rights and in the most appropriate way to exercise them, declaran to be informed that:

  1. In cases of violation or suspected violation of this Privacy Policy may be reported to Vancouros Group through the following contacts: dpo@vancouros.com.br/ alberto@vancouros.com.br or Avenida dos Expedicionários, nº 469, Centro, Rolândia/PR, CEP 86.600-091, to the care of the "Responsible for the protection of Vancouros Group;
  2. questions, suggestions or comments about this Privacy Policy may be forwarded to:dpo@vancouros.com.br/ alberto@vancouros.com.br or Avenida dos Expedicionários, nº 469, Centro, Rolândia/PR, CEP 86.600-091, tothe care of the “Charge of the protection of the dados" of the Vancouros Group.;
  3. pursuant to Article 18, §1 of the LGPD, knows its right to file a complaint with the ANPD body.

The Vancouros Group points out that this Privacy Policy and the internal policies of the Vancouros Group correspond to an integrated set of and inseparable norms. When the potential conflicts between Vancouros Group internal rules and guidelines are observed, employees must guide their conduct considering the most restrictive standard/guideline.

All duties and responsibilities provided for in this Policy become part of Vancouros Group guidelines.

This Privacy Policy may be revised or amended at any time by Vancouros Group without previous notice. Its validity depends solely on its publication on the platforms of Vancouros Group. This version of the Privacy Policy entered into force on the date of its publication on the Vancouros Group website, i.e., on May 9TH, 2022.

The present Privacy Policy must be interpreted in accordance with Brazilian law, being elected the forum of the Holder’s domicile, in Brazil, so that any controversies related to this Privacy Policy are resolved, unless there is specific personal, functional or territorial competence related to the applicable legislation.

If case the Holder is not domiciled in Brazil, the disputes related to this Privacy Policy must be proposed exclusively in the Forum of the District of the city of Rolândia / PR, renounce the Holder to any other.

Finally, Vancouros Group recommends that, if after reading this Privacy Policy, have been in doubt about any of its provisions, be contacted through the following service channels presented below, which operate on weekdays, from 09am to 6pm: