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Policy of use and privacy

1.           Introduction

As a Data Controller and as responsible for the processing of your personal data, Sencinet respects your privacy and is committed to complying with the requirements of national and international laws on the privacy and protection of personal data that may apply to you, as well as to this document, which describes how we treat your personal data, your rights and the means you have to seek information.

 

1.1.       Our responsibility

Whether you are a customer, supplier, Sencinet partner, or just a visitor to our Portal, we will act as the "controller" of your personal data whenever we collect it. And what does that mean? It means that we determine the form and purpose to use your personal data.

In addition, we need to clarify what your rights are and offer you the appropriate means to exercise them. Therefore, below you already find the contact channel with the Data Protection Officer of Sencinet.

 

1.2.       Data Protection Officer

You can contact our Data Protection Officer to request your rights, request information and clarify questions.

Name: PDK Advogados

Contact Email: dpo@sencinet.com

 

1.3.       Your responsibility

•            Read this document, because it is linked to your rights in the face of the activities of processing personal data;  and

•            If you are our customer, partner or contractor, please also check our contractual instrument, which may contain information and details about how we treat your personal data;  and

•            In the event that you provide us with personal data from third parties, or in the event that third parties provide us with your personal data, we will only use it for the specific reason why such data was provided. We remind you that you are solely responsible for (i) ensuring, prior to the provision of third party data to Sencinet, the legality of the sharing, (ii) for informing the third party of the terms of this Policy and (iii) for holding  Sencinet from liability relating to the lack of information and/or consent of the third party;

•            By providing your personal information, you authorize us to process it in accordance with this Policy and applicable law.

 

2.           When and how we collect your personal data

Personal data is any information that may identify you or make you identifiable, directly or indirectly. Therefore, Sencinet in  the context of providing its services and products, developing business activities and/or complying with legal obligations may perform processing of personal data. Regarding the way in which the collection of your personal data is performed, it stands out, among others:

•            When you interact with us

We collect personal data when you show interest in our services and/or products, seek information about our company, participate in promotions or other marketing activities, or when you contact us to resolve questions, submit any questions and/or send us your suggestions.

•            When you browse our Portal

We collect personal data when you browse our Portal to statistically understand the most visited pages and identify possible needs for improvements on our website. To learn about your browsing habits and show you advertising targeted to your profile.

•            When we provide our services or provide products

When you request any of our services and/or products, we will collect personal data to meet you efficiently and targeted to your needs.  If you are our supplier, or service provider, we will sometimes need to process personal data to perform our contract.

•            When you apply to work with us in one of our available vacancies

We collect data about you when you apply to work with us in one of our available vacancies.

 

3.           Why do we use personal data?

The General Law on the Protection of Personal Data tells us that we can only use your data for certain reasons and, for this, we will always be protected by a legal basis for our activity. Here are the reasons why we process your data:

 

When you browse our Portal

We collect personal data when you browse our Portal to statistically understand the most visited pages and identify possible needs for improvements on our website. To learn about your browsing habits and show you advertising targeted to your profile.

 

To manage our contractual relationship

For the purpose of managing our contractual relationship, Sencinet may process your personal data, always with the purpose of: (i) managing and monitoring our contractual relationship, (ii) meeting our customers' requests with respect to a request, (iii) monitoring  deliveries and equipment in perfect condition to our customers, (iv) controlling carrier cargo deliveries.

 

When we request data from our suppliers

Sometimes we need to obtain data from our suppliers to obtain the release of professionals to provide face-to-face service on Customer sites and Sencinet sites. Such data is collected and will always be processed for the purpose of complying with our contract.

 

Import and export in operations involving Foreign Trade

When we need to update the system for operations involving Foreign Trade, we will collect and process personal data to comply with our legal obligation to keep the information up to date and obtain authorization for the operation.

 

Release of access to Sencinet's points of presence

When you intend to visit our points of presence, we control access for security and prevention reasons and therefore we will need to collect personal data.

 

To perform integrity assessment

We will process personal     data for analysis of information security, privacy and    protection requirements of the company's personal  data and integrity with which we relate, as well as  its partners.

 

Conduct satisfaction survey with our customers

It is in our interest to know how to collect feedback from our customers about our activities. For this, in order to know the opinion of our customers, we conduct satisfaction surveys. We will collect your consent when we want to post your feedback on our Portal.

 

When you apply to work with us in one of our available vacancies

We collect data about you when you apply to work with us in one of our available vacancies, including for the purpose of validating the information you provide us in an eventual interview for our vacancies. We will maintain a base of resumes for any and future vacancies that may be of interest to you.

 

3.1.       But after all, what are legal bases?

Contract

Data processing is necessary for the performance of a contractual instrument you have with us, such as to deliver our services, products to you or to comply with our contractual obligations, we receive from you services, products and/or other things arising from our contractual relationship, for pre-contractual negotiations as in the event that you are a candidate for one of our available vacancies.

Legitimate Interest

The legitimate interest is valid when the processing of your data is necessary to meet the legitimate interests of Sencinet, such as to support and promote our activities. This legal basis  will  only be valid when  our  legitimate interests  are not exceeded by your rights.

Legitimate interests may involve the following processing activities:

•            Get information about your behavior in our site;

•            Develop marketing campaigns tailored to you, according to your expectations;

•            Send you news about our activities;

•            Measure your satisfaction, through research, with respect to the services provided.

Consent

When we collect the free manifestation by which the data subject agrees  to the processing of your personal data for a particular purpose, such as in the case in which case we request your consent to publish your comments with respect to the performance of our services.

Legal and/or Regulatory Obligation and Exercise of Rights

When the data processing activity is necessary to comply with the obligations provided for by law or in standards that regulate our activities.

 

4.           Your choices and rights

You have control over your information, and may oppose the operations with your personal data, including with respect to the data used for marketing purposes, by “opting out” of any distribution list we may use to reach you. We guarantee that your choice will be preserved.

You can also oppose to the use of your personal information for the purpose of improving our services and products by sending an email to: dpo@sencinet.com

With respect to your rights, you can exercise them through our Contact Channel with the Data Protection Officer by sending an email to:  dpo@sencinet.com

You have the right to confirm whether or not we treat your personal information. If so, you may require access to your personal information, as well as additional information about personal data processing activities, such as:

•            categories of personal data processed about you;

•            the purposes of the activities of processing personal data;

•            retention periods of personal information;

•            and other issues that may clarify data processing activities.

We remind you that in the event of your request, you must prove your identity, presenting your identification document or, in the case of a legal representative, accompanied by a representative instrument with a notarized certificate or certified by means of a digital certificate. In addition,  your demand will be answered within 15 (fifteen) calendar days, counted from the date of receipt of your application (or if there is a higher term permitted by applicable law within this).

Confirmation and Access

Confirmation of the existence or not of activities of processing personal data related to you will take place within 24 hours (twenty-four hours), counted from the receipt of your request (or if there is a higher term allowed by applicable law, within this) that is accompanied by the skilled documentation referred to above. However, for a full statement about the activities of processing personal data and additional information about the activities carried out, we will meet the maximum period of fifteen (or within the upper term, if permitted by applicable law).

Rectification

You have the right to request the correction and rectification of any inaccurate, incorrect or outdated personal data about you.

Opposition

You may oppose to the processing of personal data performed, based on one of the hypotheses of dispensation of consent.

Withdrawal of Consent

You may revoke consents that may be granted. This will make it impossible for us to continue performing operations with your personal data. However, operations carried out up to the date of revocation will remain valid.

Portability

You can also request the portability of your personal data to another organization.  In this case, we will send a copy in CSV so that you can provide them to those rightful. If you request it from us, and it is technically possible, we will transfer your personal information to you. However, we will not do so if portability involves personal data of third parties other than you, being the exclusive request of the data subject.

Exclusion

You have the right to request the deletion of your personal data held by Sencinet, where your data is no longer needed or if it is too data for the established purposes.

Petition

You can file a complaint with the National Personal Data Protection Authority or consumer protection agencies. However, we ask you to contact us in advance in an attempt to resolve your demand.

 

5.           How secure is your data?

We have a team specialized in Information Security, as well as Privacy and Data Protection.

The security of your information is important to us and therefore we have implemented security, technical and administrative measures able to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any form of improper or unlawful processing.

In this perspective, we developed the Privacy and Protection program of Personal Data that considers data governance and offers the necessary comfort to the holders of personal data, through the adoption of Policies, Procedures and Processes adhering to market requirements, taking into account the risks, structure, scale, volume of operations and the particularities of personal data processed by Sencinet.

Among the measures adopted are the inventory of devices, systems and installations according to the risk represented by such technology assets, in addition to a web content filter and traffic analysis (firewall), antivirus and regular audits to ensure the validation of the internal security controls adopted, aiming at a continuous process of improvement in the environment.

And remember:

•            You provide personal data at your own risk: unfortunately, no data transmission is 100% secure;

•            If you believe that your privacy or data has been breached or leaked, please contact the dpo@sencinet.com 

 

6.           Where do we store your data?

The personal data we collect and all our data processing activities are carried out in our offices, on our own servers, as well as on external servers, i.e. third parties who provide service to Sencinet for data storage purposes.

 

7.           How long do we retain your data?

The retention of your personal data, including your records, will comply with the necessary measure to perform the purposes listed above, as well as to fulfill our obligations, such as: when it is necessary to retain your data for matters relating to inspections and legal and/or regulatory obligations, to resolve legal disputes and/or execute our contracts.

 

8.           Sharing data and third parties who process your personal information

We will share personal information when: (i) there is a legal, regulatory or judicial obligation; (ii) request from our customers, always based on a legal basis for this; (iii) respond to requests from public authorities; (iii) by contractual force  and (iv) between the companies of the Sencinet Group, provided that they have a legitimate interest in processing your information, always respecting your rights and offering you mechanisms to opposed the processing of your data, in order to ensure the legality of the operation.

Sencinet  has service  providers who carry out personal  data processing activities on our behalf to assist us in the development of our activities, always as instructed by us.

Our partnerships are signed with companies that undergo a prior assessment of compliance with data protection rules and that we believe are among the best in the market in their respective activities.

We guarantee that your personal information will only be shared by contractual agreement and always in accordance with this Privacy Policy.

 

9.           Cookies

We use cookies as long as you do not choose to disable cookies in your browser settings. Cookies will be issued, collected and archived from your interaction with our website and help us to measure usage metrics of our Portal, as well as observe, statistically, your browsing, in order to improve the browsing experience of users.

We also use cookies to approach you according to your browsing habits, in order to show you advertising adherent to your profile.

To learn more, please visit our Cookie Policy.

 

10.         Making this policy useful to you

Congratulations on reaching the end of our Privacy and Personal Data Protection Policy. We design it to ensure maximum transparency with you, seeking to bring clear and useful language to your understanding.

Feel free to contact us and clarify any questions that may persist, through the following email: dpo@sencinet.com

Be sure to read this Policy as we will post any changes to this page - of course significant changes will be notified by email.

 





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