I.**PRIVACY AND DATA PROTECTION POLICY**
EUROAMERICAN DO BRASIL IMPORTAÇÃO INDÚSTRIA E COMÉRCIO LTDA is committed to ensuring the privacy of personal data collected in the course of its activities, as well as complying with the General Data Protection Law (Law 13.709/18) and other applicable regulations on the processing of Personal Data.
With the aim of establishing the general principles that should govern the processing of personal data and the need to define processes, techniques, and organizational measures appropriate to the legally permitted data processing, EUROAMERICAN has decided to adopt this Privacy and Data Protection Policy.
The General Data Protection Law (LGPD) will always be applicable and will prevail over this Policy and, to the extent that it exceeds the standards of this policy, impose stricter requirements and/or provide greater protection.
EUROAMERICAN recognizes and affirms that it undertakes all necessary efforts to protect the fundamental right to privacy inherent to the data subject, adopting all possible measures, within the best practices and existing solutions.
**1. PURPOSE**
This Privacy and Personal Data Protection Policy aims to define the main rules and procedures for the Processing of Personal Data applicable to EUROAMERICAN, in order to ensure the proper treatment of all data it may have access to as a result of its activities, in alignment with the LGPD and other relevant regulations and legislation.
**2. SCOPE**
This Policy applies to the collection and Processing of Personal Data occurring throughout the National Territory.
This Policy encompasses all types and categories of Personal Data processed by EUROAMERICAN, including Sensitive Personal Data that may be accessed as a result of its activities.
**3. Basic Concepts: What Do I Need to Know to Understand This Policy?**
To simplify your reading, we present some useful definitions for its interpretation:
A) PERSONAL DATA: Data relating to a natural person, which is capable of identifying them within a given context. Some examples of personal data: Name, CPF, RG, address, mobile phone number, email, etc.
B) SENSITIVE DATA: Any information about racial or ethnic origin, religious belief, political opinion, union membership, or affiliation to a religious, philosophical, or political organization, data concerning health or sexual life, genetic or biometric data, when linked to a natural person.
C) DATA SUBJECT: You: the natural person to whom the Personal Data refers, who may be a client, service provider, partner, consumer, among others.
D) PROCESSING: Means any operation performed with personal data, such as those related to: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction of personal data.
E) LEGAL BASES: Legal grounds that authorize EUROAMERICAN to process personal data: it may be your consent, the necessity to fulfill a contract we have with you, or the fulfillment of a legal obligation, for example.
F) CONSENT: The basis that authorizes the Processing of Personal Data based on the free, informed, and unequivocal expression of the Data Subject’s agreement to the Processing of their personal data for a specific and informed purpose by EUROAMERICAN.
G) LEGITIMATE INTEREST: A basis that allows Personal Data to be processed (even without your consent), whenever the use of this data is necessary to meet EUROAMERICAN’s or third parties’ legitimate interests.
H) COOKIES: Small files we transfer to your browser or device (such as mobile or tablet) that allow us to recognize your browser or device and know how and when EUROAMERICAN’s pages and products are visited, as well as how many people access our sites.
I) THIRD PARTIES: Refers, but is not limited, to any natural or legal person with whom EUROAMERICAN has a relationship or will have a relationship, service providers, suppliers, partners, third parties hired or subcontracted.
J) DATA PROTECTION OFFICER or “DPO” means the person designated by EUROAMERICAN and the Data Processor to act as a communication channel with data subjects and the National Data Protection Authority (ANPD).
**4. COLLECTION AND USE OF PERSONAL DATA**
Personal Data collection will only be carried out for specific, explicit, and legitimate purposes, and data processing for other purposes is prohibited.
Personal Data, including Sensitive Personal Data, will be obtained strictly in the form provided by law. Whenever necessary, the explicit Consent of the Data Subject will be obtained clearly and unequivocally. The Data Subject has the right to information about the processed data, except when its provision is impossible or requires disproportionate effort from EUROAMERICAN.
EUROAMERICAN does not request or process sensitive personal data unless necessary for the strict fulfillment of its activities and, in such cases, they will be requested and processed in accordance with legal requirements.
Personal data will be retained for as long as necessary to fulfill the purposes for which they were collected or to comply with legal and contractual obligations.
If you have any questions about this point, please contact us. We will be happy to assist you through our contact channels provided at the end of this policy and can explain more about how, when, and why we use your Personal Data.
**What types of personal data are collected? How is your personal data used?**
Data processed by EUROAMERICAN:
1. Registration data, such as:
– name, date of birth, gender, RG, CPF, driver’s license, and personal photo;
– residential and commercial address;
– residential, commercial, and mobile phone numbers;
– email.
2. Data about third parties, such as:
– affiliation, representatives, represented individuals, guarantors, counterparties, attorneys, collaborators, partners, or beneficiaries of products and services.
3. Information about your devices, such as:
– advertising ID and technical device information;
– device connection data;
– device identification, device usage.
4. Information accessed to deliver a feature, such as:
– browsing habits information, such as:
– pages and features accessed in our digital environments;
– pages and applications that originated access to our digital environments.
EUROAMERICAN uses personal data in accordance with the legal bases provided by the General Data Protection Law (LGPD), for purposes related to the performance of its activities, such as:
a) Carrying out our activities, providing our services, and supplying our products in our relationship with you;
b) Understanding our clients and offering products more suited to their needs and profile;
c) Ensuring the security of our clients, partners, and other stakeholders, as well as our own;
d) Preventing and mitigating risks;
e) Complying with legal, regulatory, and self-regulatory obligations;
f) Complying with judicial, administrative, and arbitral orders and decisions;
g) Protecting your rights, EUROAMERICAN’s rights, and third parties’ rights;
h) Maintaining, creating, and improving our activities;
i) Promoting events, conducting sponsorships, and other activities and initiatives.
**5. SECURITY AND DATA SHARING**
EUROAMERICAN has implemented appropriate technical and organizational measures to protect personal data against unauthorized access, loss, accidental or unlawful disclosure, or destruction. EUROAMERICAN conducts periodic security assessments to ensure the effectiveness of these measures.
All security measures are continuously monitored in accordance with technological advancements and the latest resources.
Personal data collected by EUROAMERICAN will be shared with third parties when necessary to fulfill the established purposes and comply with legally determined obligations, ensuring the confidentiality and security of such data.
**6. WHAT ARE OUR RESPONSIBILITIES AND HOW DO WE PROTECT YOUR PERSONAL DATA?**
Our responsibility is to take care of your Personal Data and use it for lawful purposes, as described in this Policy. To ensure your privacy and the protection of your Personal Data, we
adopt security practices appropriate to our market, using encryption techniques and other information security systems.
We work to protect the privacy of your Personal Data, but unfortunately, we cannot guarantee complete security. Unauthorized third-party access to your account, hardware or software failure beyond EUROAMERICAN’s control, and other factors can compromise the security of your Personal Data. Therefore, your actions are essential to maintaining a secure environment for everyone.
If you identify or become aware of anything that compromises the security of your data, please contact us through our Data Protection Officer (DPO) whose contact channels are below.
**7. RIGHTS OF DATA SUBJECTS**
When the processing of personal data is based on consent, data subjects have the right to revoke it at any time free of charge.
The data subject can exercise these rights by contacting the Data Protection Officer (DPO) at the email [email protected].
Whenever you exercise your rights, EUROAMERICAN may request some additional information to verify your identity, aiming to prevent fraud. We do this to ensure the security and privacy of the data subject. Also, some requests may not be immediately answered, but EUROAMERICAN commits to responding to all requests within a reasonable time and always in compliance with applicable law.
**8. COOKIES AND TRACKING TECHNOLOGIES**
EUROAMERICAN may use cookies or similar technologies on its website, when applicable, to improve the user experience and obtain statistical information about the site’s use.
Additionally, information such as: IP address, geographic location, referral source, browser type, visit duration, pages visited, among others, is automatically collected by the software.
We use this information to understand and analyze trends, administer the site, learn about user behavior on the site, improve our communications and services, and gather information about our user base as a whole.
**9. CONTACT AND PRIVACY POLICY UPDATE**
EUROAMERICAN reserves the right to periodically update this Privacy Policy.
To ask questions or make comments about this Policy and our privacy practices or to make a request, please contact us at [email protected].
Date of the last update of this policy: 18.06.2024