PRIVACY NOTICE FOR CLIENTS AND THIRD PARTIES IN GENERAL
A VOTORANTIM CEMENT prepared this Privacy Notice for Clients, Clients' employees, and Third Parties in General to explain to everyone who maintains a commercial or institutional relationship with Votorantim Cimentos how the company, as the controller of personal data, will collect, process, store and use information about you, and what your rights are in relation to this information.
When we say “Votorantim Cimentos” or “We”, we mean the VOTORANTIM CIMENTOS S / A.
What categories of personal data does Votorantim Cimentos collect about me and for what purposes does Votorantim Cimentos use this data?
“Personal data” means any information relating to You. Votorantim Cimentos will collect, process and use the following categories and types of personal data about You, as necessary for the purposes described below:
- Identification info, such as your name, surname, your photo, identity (RG), professional identity, CPF, nationality;
- personal information, such as date and place of birth and gender;
- contact details, such as your corporate address, home address, corporate phone number, home phone number, cell phone and corporate email address and personal email address;
- information about your professional experience, such as your profession, position, employer, management level, supervisor's name, subordinates' names, attributions, your power of representation of a corporate client;
- data about our communication with you;
- data for credit analysis and conflict of interest analysis, such as individual income tax returns (if applicable), corporate document that contains your contact details, shareholding data, income proofs,
property of the holder, data of the spouse, and data of relationship with any employee of Votorantim Cimentos;
- data on its relationship with Votorantim Cimentos, such as duration of the contract, dates and times of your meetings or visits to Votorantim Cimentos, your signature
- data reported in the reporting channel or in ethical or anti-corruption investigations, such as irregular practices or in violation of the Votorantim Cimentos Code of Ethics, reputational reports, data on personal relationships with authorities, news published in the media.
During any investigations or analysis of conflicts of interest, Votorantim Cimentos may deal with limited sensitive personal data about You, mainly data of affiliation to political party or union organization, only if necessary and in the context of the investigation or investigation
conflict of interest or reputational risk.
Your personal data may be collected through the information You submit to Votorantim Cimentos as part of the formalization of our hiring and in the course of our business relationship, through consultants or credit analysis and reputational risk service providers, through complaints, and through public sources.
You are under no obligation to send us any information we request from You. Depending on the type of information, it may not be possible to proceed with a contract or business relationship with Votorantim Cimentos.
We will collect and use your Personal Data for the following purposes:
- to manage our business relationship, to provide products to You or your company, register your company as a customer, supplier or service provider, approve line
credit (if applicable), and we enter into the agreement;
- to manage our sales processes, including billing, delivery and collection;
- to communicate with you, including communications about our business relationship, our products, services, events, institutional and marketing communications, and to conduct research;
- to manage visits and meetings, and to organize events;
- to analyze business expectations, from customers, how they use our products, demand, for internal planning;
- to investigate complaints on Votorantim Cimentos' ethics and anti-corruption channels, and to assess the existence of conflicts of interest in accordance with our internal policies and applicable law; and
- to comply with the law and defend and exercise rights Votorantim Cimentos and third parties, if necessary.
Why does Votorantim Cimentos need to collect, process and use my personal and sensitive personal data?
We will treat your personal data in strict compliance with the provisions of the applicable legislation, especially Law No. 13.709 / 18 (General Law on Protection of Personal Data or “LGPD”). Our personal data processing activities are based on one of the legal bases provided for in
LGPD, and that’s what we’ll explain to You below.
We will treat your personal data primarily for the management of our commercial and contractual relationship, both in the execution of preliminary procedures and in the execution of contracts, based on Article 7, V of the LGPD.
We will also process your data based on our legitimate interest, pursuant to Article 7, IX of the LGPD. Our legitimate interest in this activity is to guarantee commercial relations in line with the company's internal policies, and also to promote and support Votorantim's activities
In relation to your sensitive personal data, the treatment will be limited to the hypotheses necessary for the investigation of identified reputational risk, to ensure compliance with the applicable legislation, under the terms of article 11, II, (a).
Finally, if necessary, Votorantim Cimentos may process your personal data to comply with the law and exercise the rights of Votorantim Cimentos or third parties, under the terms of article 7, II and VI, and article 11, II, (a) and (d) .
I understand - but with whom will Votorantim Cimentos be able to share my personal data?
To achieve the purposes described in this Term, some companies may be involved in the treatment activities, and for this purpose Votorantim Cimentos may share your personal data with third parties, as indicated below. However, under our internal policies, we
we limit third parties who have access to personal data to what is necessary. For the purposes described here, we may share your personal data:
- with companies providing support services to Votorantim Cimentos, including collection, logistics, delivery, reputational and credit risk analysis, auditors, communication, marketing and events companies;
- with banks, to operate payment operations or in case of financing;
- insurance companies, in relation to risks insured by Votorantim Cimentos;
- with regulators, authorities and other third parties, if necessary to comply with a legal obligation or to exercise the rights of Votorantim Cimentos or third parties;
- with acquiring companies, in the context of an acquisition or other asset sale transaction or corporate transaction involving Votorantim Cimentos;
- with operators. To the extent necessary for the purposes of treatment indicated in this Term, Votorantim Cimentos may share your personal data with third parties, whether from the Votorantim Cimentos economic group or independent third parties, to process personal data according to our specific instructions, on behalf of Votorantim Cimentos (“Operators”). Operators will be able to process data for the administration of our recruitment base, support for IT systems and support for Votorantim Cimentos' organizational activities, and will be subject to contractual obligations to implement technical and organizational security measures to protect personal data and to only process data according to Votorantim instructions
Some of the third parties that have access to personal data may be located in other countries or may process data outside of Brazil. The level of data protection in the other country may not be equivalent to the level of protection in Brazil. Therefore, we will only transfer your personal data to countries where the National Data Protection Authority (“ANPD”) has decided to have an adequate level of protection, or we will take effective measures to ensure that all recipients of personal data
implement an adequate level of data protection. We do this, for example, by contract, by entering into contracts for the international transfer of personal data in accordance with the standard clauses, in compliance with the provisions of the LGPD.
How long will Votorantim Cimentos keep my personal data?
We will keep your personal data for as long as necessary for the activity described in this Privacy Notice. We do not keep personal data for longer than necessary. But we can, for example, keep your personal data as long as no statutory period has elapsed in the event of a possible dispute, always based on the applicable legislation. We may also maintain limited historical data on your business relationship with Votorantim Cimentos, as
permitted by applicable law.
In the activities described here, does Votorantim Cimentos make decisions solely on the basis of automated processing of personal data?
No, Votorantim Cimentos does not make decisions solely based on the automated processing of your personal data in the activities described in this Term.
What rights do I have in relation to my personal data?
Every holder of personal data has rights in relation to this data, under the terms of the applicable legislation. Such rights must be exercised in a way that also protects the industrial and commercial secrets of Votorantim Cimentos and third parties, as well as fundamental rights of third parties. According to the LGPD, you have the following rights in relation to your personal data:
- Right of confirmation of treatment and right of accessYou have the right to obtain confirmation of the existence of the processing of your personal data. If Votorantim Cimentos treats your personal data, you have the right of access, that is, to obtain a simplified or complete statement about the categories of personal data processed, the source of the data and the purposes of the processing. If your personal data is processed based on your consent, or in a contract signed between You and Votorantim Cimentos, You also have the right to obtain a full copy of the personal data that is processed based on the consent or the contract.
- Right of correctionYou have the right to request correction of incomplete, inaccurate or outdated data about You.
- Right to anonymization, blocking or eliminationIn certain cases, when your personal data is unnecessary, excessive or treated in non-compliance with the LGPD, You have the right to request anonymization, blocking or deletion of that data.
- Right to data portabilityIn certain cases, as defined and to the extent required by the ANPD, and Votorantim Cimentos' commercial and industrial secrets are always respected, you have the right to port your personal data to another company.
- Right to disposalIn cases where your data is processed based on your consent, You have the right to request the elimination of such personal data, except in the cases in which Votorantim Cimentos has the right to retain the data under the terms of the LGPD.
- Right to information on shared use of dataYou have the right to obtain information about the public and private entities with which Votorantim Cimentos shared the use of your personal data.
- Right to refuse and revoke consentWhenever we ask for your consent to treat your personal data, you have the right to refuse consent. We will always inform you of this right, and the consequences if you choose not to consent to a treatment activity.
In addition, whenever You consent to the processing of your personal data for a specific purpose, You may revoke your consent at any time, with all processing activities carried out until the date of revocation being validated.
- Right to petition before the ANPDYou have the right to petition Votorantim Cimentos before the National Data Protection Authority - ANPD in relation to your personal data.
- Right to object to illegal treatmentYou have the right to oppose any activity of processing your personal data that violates the provisions of the LGPD.
- Right to review decisions based solely on automated processingYou have the right to request a review of decisions made solely on the basis of automated processing of personal data that affects your interests, including decisions designed to define your personal, professional, consumer and credit profile or aspects of your personality.
To exercise any of these rights, please contact us as indicated in the item below (Who can I contact regarding this matter?).
Who can I contact regarding this matter?
If You have any questions, concerns or concerns regarding this Privacy Notice, or if You want to exercise your rights as a rights holder, You can contact the Votorantim Cimentos Officer through email@example.com.
Last updated date: September 10, 2020