Privacy Notice

TELAR ENGENHARIA E COMÉRCIO SA, with its principal place of business in the city of São Paulo, state of São Paulo, Avenida Angélica, nº 2510, 2º Andar, Conj.22, Zip Code 01.228-200, registered with the CNPJ under nº 62.570.320/0001-34 (“TELAR”), is committed to respecting the privacy of the users of its website (“Users”), as well as the protection and security of their data.

This Privacy Notice (“Notice”) aims to clarify to the User what data is collected, as well as to set forth the applicable rules for the collection, processing, storage, use, sharing and deletion of the collected data, in accordance with the laws in force, mainly the General Personal Data Protection Law (Federal Law 13.709/2018).

TELAR recognizes that the privacy of Users is very important and, therefore, takes all possible measures, within the best practices and existing solutions, to protect it.

This document has been written in a simple and accessible way, precisely so that Users can read and understand how we use the data.

The Data Protection Officer (DPO) is responsible for conducting and guiding TELAR, aiming to the permanent compliance with data protection standards.

With this notice, we aim to be as transparent as possible about the processing of your personal data. If you would like more information or exercise any of the rights described below, please contact our DPO, Mr. Paulo Roberto Lima Bezerra, by e-mail [email protected].

1. INFORMATION WE COLLECT

1.1.      Information provided by the User – Information provided by the User by completing the forms available on the website of the TELAR or sending messages by e-mail, the TELAR will collect those of personal identification, such as name, e-mails, positions, CPF and RG numbers, addresses, telephone numbers, profession, establishment and/or related company.

1.2.      Website navigation information – When accessing the website of the TELAR, a ‘cookie’ may be installed in the User’s browser. In this case, information such as IP address, geographic location, referral source, browser type, duration of visit and pages visited may be collected. Cookies are used to facilitate the use of the website to the User, adapting it to their interests and needs. The User may, at any time, disable or delete cookies, as well as the collection technologies, in the settings of their browser and in the device’s operating system settings. However, the choice made may reflect on certain features of the website, which may not operate as ideally expected.

1.3.      Contact history – A TELAR stores User information in the cloud (“cloud computing”) that was collected through contacts made over the phone and/or in person and/or via email.

2. WHAT WE USE THE INFORMATION

2.1. User data may be collected, stored, disclosed and processed by TELAR for the following purposes:

a) Provide marketing communications and inform Users about news and information related to the TELAR company’s business and services, including new works, updates and general business news;

b) Customize the content and website functionality;

c) Generate statistical data for informational or commercial purposes;

d) Analyze usage profile information;

e) Recruit professionals;

f) Respond to questions prepared by the User and sent to e-mails [email protected] and [email protected];

g) Processing and maintain databases that store personal data;

h) Fulfilling contractual obligations;

i) Review and improve the information, content and features made available on the website and to prevent any potential interruptions, such as cyber-attacks;

j) Analyze and report website traffic, marketing and usage; and

k) Other purposes, as set forth in this Policy.

2.2.      Eventually, we may use data for purposes not provided for in this Notice, but that are within its legitimate expectations, in accordance with the legislation in force. The eventual use of data for purposes that are not provided for in this Notice, but we only process personal data as long as they are necessary and adequate for the purposes on which the collection is based, always observing the legal bases of the treatment. Thus, we may keep the data for compliance with legal or regulatory obligation, regular exercise of right, legitimate interest or with your consent.

3. ABOUT DATA ACCESS AND STORAGE

3.1. Without prejudice to item 4 below, access to Users’ personal information will be restricted only to employees of TELAR, and among these, only people with specific internal authorizations to do so. Eventually, if the provision of information results from actions created in partnerships, the partners explicitly identified will also have access to the information. Except as otherwise provided by law, no User’s personal data may be publicly disclosed with the User’s prior and express authorization.

3.2. TELAR stores User data on its own servers and/or those of contracted partners, located in Brazil and/or abroad, in addition to servers in the cloud (“cloud computing”), so that the transfer and processing of Users’ personal data outside of Brazilian territory.

3.3. TELAR will store the User’s personal data and information for the period necessary for the purposes described in this Policy, for the period predetermined by law or until when necessary for the maintenance of the legitimate interests of the SCREEN, compliance with legal or regulatory obligations, contract performance and regular exercise of rights in judicial, administrative or arbitration proceedings.

4. ABOUT DATA SHARING

4.1. TELAR may share Users’ personal data with partners and third parties, as reasonably necessary for the purposes set forth in this Notice and for the proper provision of services, subject to the provisions below..

4.2. TELAR reserves the right to provide the User’s data and information, including interactions, if legally required to do so or if expressly authorized by the User.

4.3. TELAR guarantees that it does not commercialize Users’ personal data; however, such data may be shared with external agents, contracted by SCREEN for the performance of technical and/or support services to its activities, which will always be performed within the limits set forth by the General Law for the Brazilian General Data Protection Law (“LGPD”).

4.4. TELAR may also share User data with its service providers, branches, affiliates, subsidiaries, parent corporation or agents and IT servers, located in Brazil or abroad, exclusively for the purposes set out in this Notice and within the limits set forth in the LGPD.

4.5. If necessary, TELAR may transfer Users’ data to countries and companies that provide a level of protection similar to that provided for in Brazilian laws and will take the necessary measures to ensure that such data are secure, as required by Brazilian law.

5. SECURITY MEASURES

5.1. To ensure the protection of User data, TELAR uses security measures aligned with the technical and regulatory standards of the market, in order to avoid unauthorized access and accidental and/or illegal situations of processing, loss, destruction and/or alteration of said data.

5.2. Security measures are continuously improved and adapted, according to the update of the applicable technology, observing the best market practices in this regard.

5.3. Users should adopt all preventive measures necessary for the security of their data while using the internet, including, but not limited to, the use of antivirus systems, personal access passwords and other technical and managerial measures in order to avoid failures, invasions, interceptions or other inconveniences in accessing the tools made available by TELAR, and the TELAR will not be held liable for any damages caused by Users.

5.4. In the event that the TELAR implementing access to the website through “login and password”, the User must maintain the confidentiality of their access credentials, not being able to share them with third parties, being solely responsible for any operations performed through their account. In the event that the User notices any unauthorized use of his/her account, he/she must immediately notify the TELAR.

5.5. The processing of personal data of children and adolescents will also be based on specific legislation (Child and Adolescent Statute), so that, when collecting and processing data from people who fit into these conditions.

6. USER RIGHTS

6.1. The User, as the holder of his personal data (whether their name, email, IP, geolocation, navigation pattern, etc.), has the right to self-determine them. The Internet Civil Framework and other legal legislation already guarantee that the User has clear information about the collection, use, storage and protection of personal data on the internet (article 7, VIII). The General Personal Data Protection Law (LGPD) expands these rights (Article 18).

6.2. The User’s rights are:

a) confirmation of the existence of processing;

b) access to data;

c) correction of incomplete, inaccurate or outdated data;

d) anonymization, blocking or deletion of unnecessary or excessive data;

e) portability of data to another service or product supplier, upon express request, in accordance with the regulations of the national authority, subject to commercial and industrial secrets;

f) deletion of personal data processed with the User’s consent;

g) information from public and private entities with which the controller shared data use;

h) information about the possibility of not provide consent and about the consequences of the refusal;

i) revocation of consent; and

j) review of automated decisions.

6.3. Users may exercise their rights by means of a written communication sent to the e-mail: [email protected], indicating the subject: “Subject – Rights of the holder” and specifying:

a) Full name, CPF number and e-mail address and, if applicable, of its representative;

b) Right you wish to exercise;

c) Date of the User’s order and signature;

d) Document(s) that may demonstrate or justify the exercise of the right exercised by the User.

6.4. The provision of the data mentioned above is necessary for the TELAR can confirm that the person exercising these rights is in fact the data subject or a person who is authorized to act on their behalf.

6.5. The rights mentioned here are not absolute and do not always apply to all cases, given that, many times, the TELAR may be subject to laws and regulations that prevent it from acting in accordance with the User’s wishes. However, the TELAR undertakes to make the necessary efforts to honor the rights of Users, as provided for in applicable data protection laws.

7. CHANGE / DELETION OF PERSONAL DATA

7.1. The User may choose not to receive further emails from TELAR, except regarding to emails essential for the continuity of the provision of services or even those that, by legal or regulatory obligation, TELAR need to send to Users.

7.2. It is important to mention that, when complete any form or performing any type of registration again, your e-mail will be reinserted into the contact list of TELAR and, therefore, the cancellation request must be made again if it is in the User’s interest.

7.3. All data collected will be deleted from the servers when the User requests it or when it is no longer necessary or relevant, unless there is any other reason for its maintenance, such as a possible legal obligation to retain data or the need to preserve it to protect TELAR’s rights To change your personal information or delete it from the database, simply send an email to [email protected].

8. CHANGES TO THE PRIVACY NOTICE

8.1. This Notice may be updated at any time. In this way, the TELAR recommends that Users periodically check this page for possible changes. If material changes are made, the TELAR may notify the User through the tools available on the website and/or through the contact means available in its database. If the User does not agree with the rules set forth herein, he/she must refrain from using the website. In addition, the continued use of the website after the publication of the changes will imply agreement with the PRIVACY NOTICE.

This Privacy Notice was last modified on May 25, 2022.