PRIVACY POLICY AND PERSONAL DATA PROTECTION
Your privacy and the protection and confidentiality of your personal data are very important to us. Therefore, it is our office’s policy to ensure the security of any and all personal information and data that may be provided to the office and / or collected on our website www.tfd.com.br
SECTION 1 – GENERAL INFORMATION
This Privacy Policy and Protection of Personal Data contains information about the collection, use, storage, treatment and protection of the personal data of users and visitors to our website, with the purpose of demonstrating absolute transparency on the subject and clarifying to all interested parties. about the types of data that are collected, the reasons for the collection and how the data subjects can manage or delete their personal information.
This website is maintained and operated by TFD – Terminal Full Dealer Representações e Serviços Ltda, a private legal entity, registered with CNPJ / ME under the number 17.386.015/0001-32 with headquarters at Rua da Paz, nº 1601 cjto 415, Chácara Santo Antonio , São Paulo / SP, CEP 04713-002, here simply called “TFD”.
This document was prepared in accordance with the General Law for the Protection of Personal Data (LGPD), Law No. 13,709 / 2018 and with the Marco Civil da Internet, Law No. 12,965 / 14, and may be updated periodically as a result of any regulatory change and / or operational of our website, which is why we invite all users to consult this Privacy Policy and Protection of Personal Data periodically.
THE PERSONAL DATA COLLECTED (HOW DO WE COLLECT IT? WHAT DATA DO WE COLLECT? HOW DO WE USE IT?)
We collect and use some personal data that belongs to those who use our website. In doing so, we act as the controller of that data and, as such, we are subject to the provisions of the LGPD.
We take care of the protection of your personal data and, for this reason, we make this Privacy Policy and Protection of Personal Data available to everyone, a document that contains important information, fundamentally about: (i) who should use our website; (ii) what data we collect and what we do with it; (iii) your rights in relation to your personal data; and (iv) how to contact us.
Who should use our site
Our website must be used by people over 18 (eighteen) years of age.
Data we collect and reasons for collection
Our website collects and uses some personal data from our users, in accordance with the provisions of this section.
From these data, we can identify the user and the visitor, in addition to ensuring greater security and well-being to their needs.
When a user and visitor accesses the pages of our website, their information on interaction and access may, eventually, be collected to ensure a better experience for the user and visitor. This data can deal with the keywords used in a search, the sharing of a specific document, comments, page views, profiles, the URL from which the user and visitor come from, the browser they use and their access IPs, among others, which may eventually be stored.
The personal data of the user and visitor collected and stored by our website is intended, among others, to improve our services offered; facilitate, streamline and fulfill the commitments established between users and visitors and our office; improve the browsing experience, understanding how users and visitors use the site; offering relevant content, considering the particularities of our industry; eventually, allowing user and visitor access to certain exclusive content for registered users; and, in general, provide the parties with legal certainty.
2.1. Personal data provided expressly by the user
We collect the following personal data that our users may spontaneously provide us when using our website: (i) full name; (ii) telephone; and (iii) e-mail.
Eventually, we also collect: (iv) professional data (eg name of the company in which the user works, position, corporate email and telephone number), when so shared by the user in his message and / or in the subject of communication in our “contact” tab.
The collection of said data occurs, exclusively, in the optional filling of the contact form by the user.
Our website does not require the mandatory filling of any documents and / or forms, nor the provision of any personal data on a mandatory basis. The sending of personal data by the users of the site is a faculty of these, if they want to contact us by digital means.
Finally, as explained in the previous topic, for the purpose of optimizing the navigation of users and visitors to our website, we can collect data related to access to the pages of our website, keywords used in the search, recommendations, comments, interaction with other profiles and users, followed profiles, IP address, etc.
2.2. Sensitive data
Sensitive data will not be collected from our users, thus understood those defined in articles 11 and following of the LGPD. Thus, there will be no data collection on racial or ethnic origin, religious conviction, political opinion, union membership or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, among other data considered sensitive.
2.3. Cookies
Cookies refer to text files sent by the website to the user and visitor’s computer and which are stored on it, with information related to navigation on the website. Such information is related to the access data, such as location and time of access, and is stored by the user and visitor’s browser so that we can read it later, in order to personalize the services of the site, improve navigation, understand the interaction of user with website etc.
Cookies do not allow any file or information to be extracted from the user’s or visitor’s access device, and it is not yet possible for them to have access to personal information that has not come from the user or the way he uses the data. site resources.
The user and the visitor of our website must express knowledge about the use of a navigation data collection system through the use of cookies, accepting it or not, according to the cookie banners displayed on the website.
Site cookies
These are small text files that are automatically downloaded to your device when you access and browse our website. They basically serve to identify devices, activities and user preferences.
Cookies on our website are sent to the user or visitor’s computer or device exclusively by the website itself.
Cookie management
The user will be able to oppose the registration of cookies by the website, if he only deactivates this option in his own browser. More information on how to do this in some of the main browsers used today can be accessed from the following links:
Internet Explorer:
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Safari:
https://support.apple.com/en-us/guide/safari/sfri11471/mac
Google Chrome:
https://support.google.com/chrome/answer/95647
Mozila Firefox:
https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-que-os-sites-usam
The deactivation of cookies, however, can affect the availability of some tools and functionalities of the website, compromising its correct and expected functioning. Another possible consequence is the removal of user preferences that may have been saved, damaging their experience.
2.4. Collection of data not expressly provided
Eventually, other types of data not expressly provided for in this Privacy Policy and Protection of Personal Data may be collected, provided that they are provided with the user’s consent or, even if the collection is permitted based on another legal basis provided by law.
2.5. Sharing personal data with third parties
We do not share your personal data with third parties. Despite this, it is possible that we do so to comply with some legal or regulatory determination, or, still, to comply with some order issued by public authority.
2.5.1. Personal data collected from third parties
We may also receive personal data, indirectly, through third parties who have the legitimacy to share it with us, who may be our business partners, suppliers, advertising networks, social networks such as Facebook, Instagram, Twitter and LinkedIn, service providers. research information, third parties that enable the functionality of signaling and integration of social networks or other users and visitors. We may also receive some personal data from third parties from our customers, in connection with the provision of our services. This data will only be used for the purposes set out in this Privacy Policy and Protection of Personal Data and we recommend that the owners also access the policies of these third parties to understand how their personal data are treated by them.
2.6. How long your personal data will be stored
The personal data collected by the website are stored and used for a period that corresponds to what is necessary to achieve the purposes listed in this document and that considers the rights of its owners, the rights of the website controller and the applicable legal or regulatory provisions.
Once the periods of storage of personal data have expired, they are removed from our databases or anonymized, except in cases where there is the possibility or the need for storage due to legal or regulatory provision.
LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
A legal basis for the processing of personal data is nothing more than a legal basis, provided for by law, that justifies it. Thus, each operation of processing personal data must have a corresponding legal basis.
We treat the personal data of our users and visitors mainly in the following cases: (i) with the consent of the holder of the personal data; (ii) for the fulfillment of a legal or regulatory obligation by the controller; (iii) for the regular exercise of rights in judicial, administrative or arbitration proceedings; (iv) when necessary to serve the legitimate interests of the controller or third parties; and (v) execution of a contract between TFD and the user and / or visitor, including communications between the company and the user and / or visitor.
3.1. Consent
Certain operations for the processing of personal data carried out on our website will depend on the user’s prior agreement, who must express it in a free, informed and unambiguous manner.
The user may revoke his consent at any time, and, if there is no legal possibility that allows or requires the storage of data, the data provided by consent will be excluded.
In addition, if desired, the user may not agree to any operation of processing personal data based on consent. In these cases, however, it is possible that you may not be able to use any functionality of the website that depends on that operation. The consequences of a lack of consent for a specific activity are reported prior to treatment.
3.2. Compliance with legal or regulatory obligation by the controller
Some personal data processing operations, especially data storage, will be carried out so that we can comply with obligations provided for by law or other regulatory provisions applicable to our activities.
3.3. Legitimate interest
For certain personal data processing operations, we rely exclusively on our legitimate interest, notably when the consent of the holder is very difficult to obtain, the consent of the holder may be considered unnecessary and when there is minimal impact on the holder and a justification for your use of the data.
To analyze the feasibility of using the legal basis of legitimate interest, we always do the proportionality test, whose objective is to balance, on the one hand, the interests of our company, and, on the other, the rights of the holder of personal data.
As an example, TFD uses this legal basis to send necessary communications due to our contract with customers and / or information relevant to the maintenance of our relationship with the user and visitor or to update their personal data and information in our records .
3.4. Execution of our contract
To help us answer your questions and manage your demands; allow the maintenance and updating of the registration of users and visitors, as well as the execution, access and use of our dictation and for their interaction with us; and make service to the user and visitor viable.
SECTION 4 – RIGHTS OF USERS AND SITE VISITORS
The user and the visitor to the website have the following rights, conferred by the LGPD: (i) confirmation of the existence of treatment; (ii) access to data; (iii) correction of incomplete, inaccurate or outdated data; (iv) anonymization, blocking or elimination of unnecessary, excessive or treated data that does not comply with the provisions of the law; (v) portability of the 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; (vi) elimination of personal data processed with the consent of the holder, except in cases provided for by law; (vii) information from public and private entities with which the controller shared data use; (viii) information about the possibility of not providing consent and about the consequences of the refusal; and (ix) revocation of consent.
It is important to note that, under the terms of the LGPD, there is no right to delete data processed on the basis of legal bases other than consent, unless the data is unnecessary, excessive or treated in non-compliance with the law.
4.1. How the holder can exercise his rights
The holders of personal data processed by us may exercise their rights by means of a request to that effect, via email, with confirmation of delivery and reading, addressed to the responsible person indicated in Section 7 of this Privacy Policy and Protection of Personal Data.
In order to ensure that the user who intends to exercise his rights is, in fact, the holder of the personal data object of the request, we may request documents or other information that may assist in their correct identification, in order to safeguard our rights and the rights of third parties. This will only be done, however, if absolutely necessary, and the applicant will receive all related information.
SECTION 5 – SECURITY IN THE PROCESSING OF PERSONAL DATA
We employ technical and internal organization measures to protect the personal data collected on our website, including in situations of alteration and destruction of that data. The measures always take into account the nature of the data, the context of collection, the purpose of the treatment, the damage that a possible violation could generate to the holder, always adopting the highest available on the market.
Thus, TFD adopts all measures that are within its power to protect the personal data of users and visitors to its website, among which we highlight the use of the Wix platform, protected with SSL / TLS systems, which are types of digital security that allow encrypted communication between a website and a browser. Thus, the company’s website allows its users and visitors to safely browse and send information, including with the HTTPS protocol.
However, even if we adopt everything in our power to prevent security incidents, it is possible that there may be a problem motivated exclusively by a third party – such as in the case of hacker or cracker attacks or even in the case of the user’s sole fault , which occurs, for example, when he himself transfers his data to a third party. Thus, although we are generally responsible for the personal data we process, we are exempt from liability in the event of an exceptional situation such as these, over which we have no control whatsoever. In any case, in the event of any type of security incident that may generate significant risk or damage to any of our users, we will communicate those affected and the National Data Protection Authority (ANDP) about what happened, in accordance with the provisions of the Law. General Data Protection.
Since we do not control the security of the internet, we will not be responsible for the security of the information you choose to communicate online while you are browsing and transmitting data, including for any loss of data during transmission. Thus, since it is not possible to guarantee the complete security of the data transmitted to us or through our website, we recommend and ask that you be careful and attentive with the form of transmission and with the choice of the personal data that is shared with us or, further, with any third parties.
SECTION 6 – CHANGES TO THIS POLICY
We reserve the right to modify, at any time, the provisions contained herein, especially to adapt them to any changes made on our website, either by making new features available, by suppressing or modifying those already existing, as well as for purposes of compliance with legislation.
Whenever there is a change, this Privacy Policy and Protection of Personal Data will be updated on our website, allowing its full knowledge by all users and visitors, without prejudice to any notification to them, by email or other appropriate format. .
SECTION 7 – HOW TO CONTACT US?
To clarify any doubts about this Privacy Policy and Protection of Personal Data or, in general, about the personal data we process, please contact us at the email address tfd@tfdbrasil.com.br
This Personal Data Protection and Privacy Policy was last updated in May 2021