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PRIVACY AND DATA PROTECTION NOTICE


1. WHY DO WE ESTABLISH A PRIVACY AND DATA PROTECTION NOTICE?

This Privacy and Data Protection Notice aims to inform data subjects about the measures used by the Bertolini Group for the collection, storage, use, or any other processing of personal data carried out on Bertolini Group websites.

The Bertolini Group is committed to privacy and the protection of personal data, which is why it establishes with data subjects the commitment to respect Brazilian Data Protection and Privacy Legislation – Law No. 13,709/2018.


2. WHO CONTROLS YOUR PERSONAL DATA?

The Bertolini Group, through its parent company, BERTOLINI S/A, registered under CNPJ 87.556.650/0001-04, has its administrative headquarters at Rua Pedro Dalla Costa 565 Annex Building I – Pradel Neighborhood, in the municipality of Bento Gonçalves/RS, Brazil, ZIP Code 95.708-260, and acts as the controller of your personal data on this website. The Bertolini Group is composed of the following companies:

a) BERTOLINI TUBOS – CNPJ 87.556.650/0013-30, Rua Pedro Dalla Costa, 565 Pavilion A, Pradel neighborhood, in the municipality of Bento Goncalves/RS; ZIP Code: 95.708-260;

b) EVVIVA BRANCH – CNPJ 87.556.650/0014-10, Rua Pedro Dalla Costa, 565 Pavilion B, Pradel neighborhood, in the municipality of Bento Goncalves/RS; ZIP Code: 95.708-260;

c) BEROLINI MÓVEIS DE AÇO – CNPJ 87.556.650/0015-10; Br-259 Highway, No. 51 Pavilion A, Santa Helena, in the municipality of Colatina/ES.

d) STORAGE SYSTEMS BRANCH – CNPJ 87.556.650/0016-82, Br-259 Highway, No. 51 Pavilion B, Santa Helena, in the municipality of Colatina/ES.

e) LOGBER LOGISTICS AND CARGO TRANSPORT LTDA. – CNPJ 12.157.760/0001-96; Rua Pedro Dalla Costa, 3162 Annex Building I, Pradel neighborhood, in the municipality of Bento Gonçalves/RS; ZIP Code: 95.708-260;

The Bertolini Group processes your personal information to fulfill our legal, statutory, and contractual obligations and to provide our products and services. We will never collect any unnecessary personal data from you and will not process your data in any way other than as specified in this notice.

This Privacy and Data Protection Notice does not apply to third-party apps or websites that you may use, including any app or website linked to our services. Please review the terms and policies of third-party websites or apps before using or contracting them.

By clicking the accept button, you declare that you are aware of the terms and conditions of this Privacy and Data Protection Notice, giving your free, informed, and unequivocal consent to the processing of your personal data for the purposes determined herein.


3. DATA COLLECTED BY THE BERTOLINI GROUP

The information we collect on this website depends on the interaction you will have with our website, which is why we inform below the data we collect and the reason why we do it. The data collected by the Bertolini Group are:

• Name;

• Email;

• Full address;

• Cell phone number;

• Business phone number;

• Area of operation;

• Company of operation;

• Position;

• CPF (Brazilian taxpayer registry);

• Profession;

• Institution and/or affiliated company.

• Profile ID

• User password

• Cookies (as per cookie policy, at this link https://www.bertoliniarmazenagem.com.br/en/politica-de-cookies


4. HOW WE COLLECT PERSONAL DATA

a) Through Data Collection Forms

When provided by data subjects, personal data is collected, stored, used, and processed by the Bertolini Group through this website when they perform the following actions:

• Providing information for website registration;

• Contact Form for sending messages on the website;

• Newsletter registration form;

• Contact Form for sending Budget and Scheduling;

• Form for sending Service Quotation;

• For the formalization of product purchases;

• Contact form for online order tracking;

• Through the WhatsApp contact button;

• Sending resume and job application registration;

Data subjects are responsible for the accuracy of the data provided to the Bertolini Group. When providing personal data of third parties, data subjects must ensure that they have authorization to do so, with the Bertolini Group not being responsible for this act.

b) Through Google Analytics

We use Google Analytics to analyze visitor behavior on the Bertolini Group website. The data collected is used to track the number of visits, where our visits come from, the average time visitors spend on the site, devices used for access, among others. We also use some of this data for marketing purposes, including remarketing or demographic and interest reports.

To change how Google Analytics collects and uses your personal information, you can install the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

c) Information we collect from other sources

We may collect personal information about you from other sources, such as service providers and partners, when they have legal permission to share your personal information with us. For example, if you register for our services from another website, the website may provide us with your personal information.


5. HOW WE USE YOUR PERSONAL DATA

The Bertolini Group will not disclose, share, or sell your data without your consent, unless required by law. We retain your data only for as long as necessary and for the purposes specified in this notice. Whenever you consent, we will provide you with promotional and marketing offers; consent for this offer can be withdrawn at any time.

The Bertolini Group does not collect sensitive personal data through its website. If data subjects voluntarily decide to provide sensitive personal data, such as in message fields, data subjects expressly consent to the processing of this data in accordance with what is described in this Privacy and Data Protection Notice.

Sensitive personal data eventually collected by other means by the Bertolini Group will be processed for the specific purpose informed and authorized by data subjects.

During the use of the Bertolini Group website, if data subjects are directed, via link, to another website, data subjects should ensure the privacy policy of the website they are visiting. The Bertolini Group is not responsible for the collection and use of personal data and the content of third-party websites.


6. PURPOSE OF THE USE OF PERSONAL DATA

The Bertolini Group undertakes to use the personal data collected from data subjects for the following purposes:

• Conducting statistics on the activities and behavior of data subjects;

• Adding content to the website and Bertolini Group activities;

• Dissemination of Bertolini Group content, as well as events organized and/or promoted by the Bertolini Group;

• Administration of registrations for events organized and/or promoted by the Bertolini Group;

• Meeting user subscriptions to news clipping available on the website;

• Registration of data subjects on the mailing list;

• Acquisition of Bertolini Group products;

• Sending institutional communications;

• Promotion of institutional marketing;

• Recruitment of professionals and/or interns;

• Safeguarding rights and obligations related to the legitimate interests of the Bertolini Group;

The legal basis for the processing of personal data is consent for the collection, storage, and processing of data subjects' personal data to meet the purposes proposed by the Bertolini Group and is voluntary. If data subjects decide not to consent to the data collection, the only consequence will be the non-provision of services and/or facilities proposed by the Bertolini Group.

For the acquisition of Bertolini Group products, the legal basis is that necessary for the execution of a contract or preliminary contract procedures.

When browsing this website, the Bertolini Group will not process the personal data of its data subjects without their consent, except in legal cases where it is necessary or mandatory, including:

• compliance with legal or regulatory obligations;

• contract execution;

• regular exercise of rights in judicial, administrative, or arbitration proceedings;

The Bertolini Group ensures that it does not commercialize the personal data of data subjects. However, the personal data of data subjects may be shared with external agents, contracted by the Bertolini Group, to perform technical services and/or support the group's activities, exclusively to achieve the purposes stipulated herein.

In respect of the personal data of data subjects, the Bertolini Group requires external agents to process the data in accordance with their own confidentiality and security parameters, observing this Privacy and Data Protection Notice.


7. USERS' RIGHTS

Acting as controller regarding the personal data of Bertolini Group website users, the General Data Protection Law establishes a series of rights of the data subject against the controller; which are as follows:

• confirmation of the existence of treatment;

• access to data;

• correction of incomplete, inaccurate, or outdated data;

• anonymization, blocking, or deletion of unnecessary, excessive, or data processed in violation of this Law;

• data portability, respecting commercial and industrial secrets;

• deletion of personal data processed with the consent of the data subject;

• information about public and private entities with which the controller has shared data;

• information about the possibility of not providing consent and the consequences of refusal;

• withdrawal of consent.

Data subjects may also object to the processing of data for legitimate reasons, as well as request the anonymization, blocking, or deletion of data that they deem unnecessary and/or excessive.

If desired, data subjects can request their removal from the Bertolini Group website mailing list, ceasing to receive any informational emails.

To exercise their rights, data subjects must send an email or letter with their request to the addresses provided below in item 11 Contact Information (below).

If we receive a request from you to exercise any of the rights above, we may ask you to verify your identity before we fulfill the request to ensure that your data is protected and kept safe.


8. DATA STORAGE

The Bertolini Group securely stores the personal data of data subjects collected only for the necessary period to carry out the operations established herein, in compliance with Brazilian legislation, including the Marco Civil da Internet, which determines the storage of records of access to internet applications for a period of 6 (six) months.

Customer-related data is stored for the duration period stipulated in the contract and/or in the General Contracting Conditions of the company.

In the case of storing data processed as a result of the newsletter, the Bertolini Group will store the data provided for this purpose until the respective unsubscribe request from the data subject.

Data storage will respect this Privacy Notice and/or any agreements entered into with data subjects. However, data may be stored for a longer period for legal reasons or by court order.

The data processed for website access (cookies) are listed in the cookie notice, as per the link https://www.bertoliniarmazenagem.com.br/en/politica-de-cookies

It is important to note that the Controller may be obliged to retain Personal Data for a longer period on all occasions when it is required to do so to comply with a legal obligation or in compliance with an order from an authority.

Once the storage period expires, or when the User revokes their consent, Personal Data will be DATA SUBJECTS should be directed to the Officer identified above. The Officer is duly authorized by the BERTOLINI GROUP to provide clarifications and/or take measures related to the processing of personal data by the Bertolini Group.


9. SECURITY

The Bertolini Group is committed to the security of user personal data processing through the implementation of advanced information technology mechanisms, which adopt technical, physical, and logical security procedures commonly used in the market. The adoption of such procedures aims to protect personal data against loss, misuse, alteration, destruction, or leakage.

Any member of the Bertolini Group who has access to the collected information is informed about its confidential nature and is committed to acting in accordance with this Policy.

Data subjects' information is stored encrypted. Information is protected with SSL (Secure Socket Layer) technology so that, when traveling between our servers to the user's computer, this data remains confidential. This technology aims to prevent information from being transmitted or accessed by third parties.

Data subjects must adopt the necessary preventive measures when using the internet, including the use of antivirus software, personal access passwords, and other technical and managerial measures, in order to avoid failures, intrusions, or other inconveniences in accessing the tools provided by the company. The Bertolini Group will not be responsible for any damages resulting from the exclusive fault of data subjects and/or third parties.


10. DATA PROCESSING OFFICER AND CONTACT INFORMATION

The identity and information of the Data Processing Officer of the Bertolini Group are as follows:

Officer: Sheila Pastore

Email: dpo@bertolini.com.br

Any complaints or communications from DATA SUBJECTS should be directed to the Officer identified above. The Officer is duly authorized by the BERTOLINI GROUP to provide clarifications and/or take measures related to the processing of personal data by the Bertolini Group.


11. CHANGES TO THIS NOTICE

This Privacy and Data Protection Notice may be modified at any time, upon prior communication through the Bertolini Group website (https://www.bertolini.com.br).

Version 3 – May 2024.