This Policy aims to demonstrate the commitment of TVRT, registered in the CNPJ/ME under No. 21 920 006/0001-57, headquartered in Comercio de Café Street, 346, Industrial Reinaldo Foresti, Varginha – MG – Zip Code: 37.026.530. (“We”), with your privacy and protection of your Data, clearly and in accordance with applicable laws.
This Policy describes the main rules about the Treatment of your Personal Data, when:
(i) You make use of our functionalities through our digital environments, such as, but not limited to, the website available at the link www.tvrt.com.br (“Website”); or
(ii) You interact with us outside of our digital environments, and for all purposes of this Policy our physical and digital environments are collectively referred to as the “TVRT Environments”.
In order to access and use the functionalities offered in TVRT Environments, You represent that You have read this Policy fully and carefully and are fully aware of the terms herein concerning the Treatment of Personal Data, in accordance with the conditions specified below.
We are always seeking to offer you services and features as efficiently as possible, constantly updating ourselves for this. For this reason, this Policy may be adjusted at any time, and it is up to You to check it whenever possible.
ABOUT THE DATA WE COLLECT
1. How we collect data: Data, including Personal Data, may be collected when You submit or interact on TVRT Environments and services, which includes:
Registration Data: full name, date of birth, email, phone number, farm information.
We collect the data to: 1-identify and authenticate you, 2-fulfill the obligations arising from the use of our services, including for compliance with legal and regulatory provisions, 3-ensure the portability of registration data to another controller in the same branch of our operation, complying with the obligation of Article 18 of the General Law of Protection of Personal Data, 4- promote your contact with us and manage your questions and requests. 5 – to expand our relationship, informing you of new features, functionality, content, new projects, news, events.
Digital identification data: IP address and Logical Source Port / Device (operating system version)/geolocation /date and time stamps each action you perform / Which screens you have accessed / Session ID / Cookies /Video footage captured on CCTV
We collect the data to: Identify and authenticate you / security monitoring of our TVRT environments / comply with legal record keeping obligations established by the Marco Civil da Internet – Law 12,965/2010 / comply with legal and regulatory obligations.
2.2. data required. Many of our services are directly dependent on some Data provided in the table above, mainly Registration Data. If You choose not to provide some of this Data, we may be unable to perform some of our services and functionalities on Our Environments.
2.3 Updating and Veracity of the Data. You are solely responsible for the accuracy, truthfulness or lack thereof with respect to the Data that You provide, or for its outdatedness. You are responsible for ensuring the accuracy or keeping the Data up to date.
2.3.1 Accordingly, We are not obliged to process or handle any of your Data if there is reason to believe that such processing or handling could bring us into breach of any applicable law, or if You are using Our Environments for any
illegal, unlawful or unethical purposes.
2.4 Database. The database formed through the collection of Data is owned by us and is our responsibility, and its use, access and sharing, when required, will be within the limits and for the business purposes described in this Policy.
2.5 Technologies employed. We use the following technology(s):
(ii) Google Analytics, for the registration of non-identifiable navigation data in order to measure and monitor the performance of the Site.
2.5.1 All technologies used will always respect the current legislation and the terms of this Policy.
2.6 We may use only automated decisions that impact You. If you have any questions about the automated decision process, please contact us through our Customer Service Channels, pursuant to section 7.4. of this Policy.
HOW WE SHARE DATA AND INFORMATION
3.1 Data Sharing Options. The Data collected and the activities recorded may be shared, always respecting the sending of the minimum information necessary to achieve the purposes:
(i) With competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, requisition or court order;
(ii) Automatically, in case of corporate movements, such as mergers, acquisitions and incorporations; and
(iii) With partner companies and service providers necessary for the execution of our services and functionalities, always requiring from such organizations the compliance with the security and data protection guidelines, as per item 4.5 of this Policy.
3.2 Anonymization of Data. For the purposes of market intelligence research and disclosure of data to the press, when applicable, the data provided by You will be shared in an anonymized form, that is, in a way that does not allow your identification.
HOW WE PROTECT YOUR DATA AND HOW YOU CAN PROTECT YOUR DATA
4.1 Measures we take. We use our best efforts to maintain the privacy and security of information by taking technical, physical, and administrative security measures:
(i) Technical measures, such as, for example, transmission of Personal Data via secure web page, storage of Data on electronic media that maintain high security standards, use of system whose access is controlled;
(ii) physical measures, such as restricted access to authorized persons maintained at facilities, use of market security tools; and
(iii) Administrative measures, including the adoption of security policies and standards, training and awareness work for employees, signing of confidentiality agreements.
4.2. precautions You should take. It is very important that You protect your Data from unauthorized access to your computer, account, or password, and make sure You always click “logout” when terminating your browsing on a shared computer. It is also very important
important that You know that we will never send electronic messages requesting confirmation of data or with attachments that can be executed (extensions: .exe, .com, among others) or links for eventual downloads.
4.3 Access to Personal Data, proportionality and relevance. Internally, the Personal Data collected are accessed only by duly authorized professionals, respecting the principles of proportionality, necessity and relevance to the objectives of our business, in addition to the commitment to confidentiality and preservation of your privacy under this Policy.
4.4 External Links. When You use our digital environments, You may be led via link to other portals or platforms, which may collect your information and have their own Data Treatment Policy.
4.4.1 It is up to You to read the Privacy and Data Treatment Policies of such other websites or platforms outside of our online environments and it is your responsibility to accept or reject them. We are not responsible for the Privacy and Data Treatment Policies of third parties nor for the content of any websites or services linked to environments other than our own.
4.4.2 Partner Services. We have business partners who, from time to time, may offer services through functionalities or websites that can be accessed from our digital environments. The Data provided by You to these partners will be their responsibility, and subject to their own
and will therefore be subject to their own data collection and use practices.
4.5 Third Party Processing at our direction. Where third party companies process on our behalf any Personal Data that we collect, they will comply with the conditions set out herein and with the information security standards, as applicable.
4.6 Communication by e-mail. To optimize and improve our communication, when we send an email to You we may receive a notification when they are opened, provided that this possibility is available. It is important that You be aware that emails are only sent from the domain: TVTR (email@example.com / firstname.lastname@example.org )
HOW WE STORE YOUR PERSONAL DATA AND ACTIVITY LOG
5.1. The Personal Data collected and activity logs are stored in a secure and controlled environment for a minimum period of time to fulfill the purposes of the performance of our services and functionalities.
5.2. longer storage periods. For auditing, security, fraud control, and rights preservation purposes, we may retain a record of your Data for a longer period of time where required by law or regulation.
5.3 The Data collected may be stored on our servers located in Brazil, as well as in a cloud computing environment, which may require the transfer and/or processing of such Data outside Brazil.
5.4 Recording logs. We may also keep records of CCTV recordings for short periods in accordance with our physical environment monitoring and security policies to protect You, our employees and Our Environments.
WHAT YOUR RIGHTS ARE AND HOW TO EXERCISE THEM
6.1 Your Basic Rights. You may request confirmation of the existence of Personal Data Processing, in addition to the exhibition or rectification of your Personal Data, through the Customer Service Channels, pursuant to section 7.4 of this Policy.
6.2 Limitation, opposition and deletion of data. Through the Customer Service Channels, You may also request:
(i) Limit the use of Your Personal Data;
(ii) to object to and/or withdraw consent to the use of your Personal Data, where applicable; or
(iii) request the deletion of your Personal Data collected by Us.
6.2.1 If You request the deletion of your Personal Data, it may occur that the Data needs to be kept for a period longer than the request for deletion, pursuant to article 16 of the General Personal Data Protection Law, for: (i) compliance with a legal or regulatory obligation, (ii) study by a research body, and (iii) transfer to a third party (subject to the data processing requirements set out in the same Law). In all cases, the Personal Data shall be anonymized to the extent possible.
6.2.2 Upon expiration of the maintenance period and legal necessity, Personal Data will be deleted using secure disposal methods, or used in an anonymized form for statistical purposes.
INFORMATION ABOUT THIS POLICY
7.2 Inapplicability. If any part of this Policy is deemed unenforceable by a Data Authority or court, the other conditions will remain in full force and effect.
7.3 Electronic Communication. You acknowledge as valid, effective and sufficient all communication issued by Us and sent by e-mail (to the addresses informed by You), SMS, instant messaging applications or any other digital form, whether for the disclosure of any matter relating to the services we provide, your Data, as well as any other matter that we deem relevant to the provision of our services and features.
7.5 Applicable Law and Venue. This Policy shall be interpreted according to the Brazilian legislation, in the Portuguese language, being elected the jurisdiction of the District of Varginha, State of Minas Gerais to settle any controversy involving this document, unless specific exception of personal, territorial or functional competence by the applicable legislation.
8.1. For the purposes of this Policy, the following definitions and descriptions shall be considered for their better understanding:
(i) Anonymization: Use of reasonable and available technical means at the time of Processing whereby a data loses the possibility of association, directly or indirectly, with an individual.
(ii) CCTV: “Closed Circuit Television”. A monitoring and surveillance camera system that sends images in real time to a video recorder and/or monitoring center through a wired or IP-based system.
(iii) Cloud Computing: Or cloud computing, is a service virtualization technology built from the interconnection of more than one server by means of a common information network (e.g. the Internet), with the objective of reducing costs and increasing the availability of sustained services.
(iv) Cookies: Small files sent by the Site, saved on your devices, which store preferences and few other information, with the purpose of personalizing your navigation according to your profile.
(v) Data: Any information entered, processed or transmitted through Our Environments.
(vi) Personal Data: Data relating to an identified or identifiable natural person.
(vii) Automated Decisions Only: These are decisions affecting a user that have been programmed to work automatically, without the need for a human operation, based on automated processing of personal data.
(viii) Data Protection Officer (DPO): Person appointed by Us to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).
(ix) IP: Abbreviation for Internet Protocol. It is an alphanumeric set that identifies the users’ devices on the Internet.
(x) Processing: Any operation performed with Personal Data, such as those related to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of the information, modification, communication, transfer, dissemination or extraction.