privacy term

VOTORANTIM CEMENTS

PRIVACY NOTICE FOR CUSTOMERS AND THIRD PARTIES IN GENERAL

A VOTORANTIM CEMENTS prepared this Privacy Notice for Customers, Customer employees, and Third Parties in General to explain to everyone who maintains a commercial or institutional relationship with Votorantim Cimentos how the company, as 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 refer to 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, to the extent necessary for the purposes described below:

• Identification info, such as your name, surname, photo, identity (ID), 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 telephone number, home telephone number, cell phone, and corporate email address and personal email address;
• information about your professional experience, such as your profession, your position, employer, management level, name of the supervisor, name of subordinates, duties, your power to represent a legal entity client;
• data about our communication with you;
• data for credit analysis and conflict of interest analysis, such as personal income tax returns (if applicable), corporate document containing your contact details, corporate shareholding details, proof of income, property details of
  property of the holder, data of the spouse, and data of relationship with any employee of Votorantim Cimentos;
• data about your relationship with Votorantim Cimentos, such as the duration of the contract, dates and times of your meetings or visits to Votorantim Cimentos, your signature
• data reported in a reporting channel or in ethical or anti-corruption investigations, such as irregular practices or those in violation of the Votorantim Cimentos Code of Ethics, reputational reports, data on personal relationships with authorities, news published in the media.

During possible investigations or analysis of conflict of interests, Votorantim Cimentos may deal with limited sensitive personal data about You, mainly data on membership of a political party or trade union organization, only if necessary and in the context of the investigation or investigation
of 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 contracting and in the course of our commercial relationship, through consultants or credit and reputational risk analysis service providers, through reporting, and through public sources.

You are under no obligation to send us any information that we request from You. Depending on the type of information, it may not be possible to continue with a contract or commercial 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 card (if applicable), and we enter into the contract;
• to manage our sales processes, including carrying out billing, delivery and collection;
• to communicate with you, including communications about our commercial relationship, our products, services, events, institutional and marketing communications, and to carry out 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 in Votorantim Cimentos' ethics and anti-corruption channels, and to assess the existence of conflicts of interest in accordance with our internal policies and applicable legislation; It is
• to comply with the law and defend and exercise rights of Votorantim Cimentos and third parties, if necessary.

Why does Votorantim Cimentos need to collect, process and use my personal data and sensitive personal data?

We will process your personal data in strict compliance with applicable legislation, especially Law No. 13.709/18 (General Personal Data Protection Law or “LGPD”). Our personal data processing activities are based on one of the legal bases set out in
LGPD, and this is what we will explain to you below.

We will process your personal data mainly for the management of our commercial and contractual relationship, both in the execution of preliminary procedures and in the execution of a contract, based on article 7, V of the LGPD.

We will also process your data based on our legitimate interests, in accordance with article 7, IX of the LGPD. Our legitimate interest in this activity is to ensure commercial relationships in line with the company's internal policies, and also to promote and support Votorantim's activities
Cements.

In relation to your sensitive personal data, processing will be limited to the hypotheses necessary to investigate an identified reputational risk, to ensure compliance with applicable legislation, in accordance with 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 can Votorantim Cimentos share my personal data?

To achieve the purposes described in this Term, some companies may be involved in processing 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 the 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 billing, logistics, delivery, reputational and credit risk analysis companies, auditors, communication, marketing and events;
• with banks, to carry out payment operations or in the 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 legal obligations 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 processing purposes indicated in this Term, Votorantim Cimentos may share your personal data with third parties, either within the Votorantim Cimentos economic group or independent third parties, to process personal data in accordance with our specific instructions, on behalf of Votorantim Cimentos (“Operators”). The Operators may process data to manage our recruitment base, support IT systems and support the organizational activities of Votorantim Cimentos, and will be subject to contractual obligations to implement technical and organizational security measures to protect personal data and only process data in accordance with Votorantim instructions
  Cements.

Some of the third parties that have access to personal data may be located in other countries or may process data outside 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 that 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 the personal data
implement an adequate level of data protection. We do this, for example, through contractual means, entering into contracts for the international transfer of personal data in accordance with 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 activities described in this Privacy Notice. We do not keep personal data for longer than necessary. But we may, for example, keep your personal data until a statute of limitations has elapsed in the event of any dispute, always based on applicable legislation. We may also maintain limited historical data on your commercial relationship with Votorantim Cimentos, to the extent
permitted by applicable legislation.

In the activities described here, does Votorantim Cimentos make decisions solely based on 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, in accordance with applicable legislation. Such rights must be exercised in order to also protect 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:

1. Right to confirm processing and right to accessYou have the right to obtain confirmation of the existence of the processing activity of your personal data. If Votorantim Cimentos processes your personal data, you have the right to access, that is, to obtain a simplified or complete statement about the categories of personal data processed, the origin of the data and the purposes of the processing. If your personal data is processed based on your consent, or on 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 consent or contract.
2. Right to correctionYou have the right to request the correction of incomplete, inaccurate or outdated data about You.
3. Right to anonymization, blocking or deletionIn certain cases, when your personal data is unnecessary, excessive or is treated in non-compliance with the LGPD, you have the right to request the anonymization, blocking or deletion of this data.
4. Right to data portabilityIn certain cases, as defined and to the extent required by ANPD, and always respecting the commercial and industrial secrets of Votorantim Cimentos, You have the right to the portability of your personal data to another company.
5. Right to deletionIn cases where your data is processed based on your consent, You have the right to request the deletion of such personal data, except in cases where Votorantim Cimentos has the right to retain the data under the terms of the LGPD.
6. Right to information about shared use of dataYou have the right to obtain information about the public and private entities with which Votorantim Cimentos shared your personal data.
7. Right to refuse and revoke consentWhenever we ask for your consent to process your personal data, you have the right to refuse consent. We will always inform you about this right, and about the consequences if you prefer not to give consent to a processing activity.
   Furthermore, 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 up to the date of revocation being validated.
8. Right to petition the ANPDYou have the right to petition Votorantim Cimentos before the National Data Protection Authority – ANPD in relation to your personal data.
9. Right to object to unlawful processingYou have the right to object to any processing activity of your personal data that violates the provisions of the LGPD.
10. 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 affect your interests, including decisions intended 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 doubts, questions or concerns regarding this Privacy Notice, or if You wish to exercise your rights as a rights holder, You may contact the person in charge of Votorantim Cimentos at lgpd@vcimentos.com.

Last updated date: September 10, 2020