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PRIVACY AND PROCESSING OF PERSONAL DATA POLICY

Welcome to the Sempre Engenharia Privacy and Personal Data Processing Policy.

Sempre Engenharia e Representações LTDA, registered with the CNPJ No. 69.066.108/0001-83, Address at Rua Treze de Maio, No. 1633, Floor 14°, Bela Vista, São Paulo - SP, ZIP CODE 01.327-905.

         This Policy is intended to demonstrate to you who visit and browse our website, with transparency, that we follow all the rules for the protection of your personal data and, consequently, we protect your privacy.

          If you have any difficulty understanding the content of this Policy, please feel free to contact our Encarregado de Dados (DPO) atdpo@sempreengenharia.com.br.

        We will be incredibly happy to answer all your questions.

          After reading this policy, which will always be available for your consultation, you will be aware of which personal data we will collect or any type of data processing (any activities related to personal data, such as collection, sharing, etc.) of personal data.

          If you, for any reason, do not agree with the terms of this Policy, we ask you to stop accessing the website and let us know what annoyed you.

          We always want to bring a better user experience to our website and our customers.

DICTIONARY OF DEFINITIONS

          For a better understanding of this Policy, the following definitions should be considered:

Cookies: small files sent to your browser or devices that store your preferences and other information about how and when our site is visited, as well as how many people access them.

Personal Data or Data: is data relating to a natural person, which are capable of identifying him or making him identifiable. For example: Name, email, Brazilian Identification number, personal preferences, IP address, geolocation, etc.

Sensitive Personal Data: are any Data on racial or ethnic origin, religious conviction, political opinion, membership in a union or organization of a religious, philosophical, or political nature, data relating to health or sexual life, genetic or biometric data, when linked to an individual.

Encarregado ou Data Protection Officer (DPO): the person appointed by Sempre Engenharia to act as a communication channel between us, the Owners of Personal Data and the Autoridade Nacional de Proteção de Dados - ANPD.

Applicable legislation: all legislation that deals with privacy and protection of Personal Data, especially Law No. 13.709/2018, Lei Geral de Proteção de Dados Pessoais – LGPD.

Policy: is this privacy and data processing policy.

Owner of Personal Data: it is you, the natural person to whom the Personal Data refer, whether as a user, customer or business partner.

Data Processing: any operation performed with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, diffusion, or extraction.

Dictionaty of Definitions
What data can be collected?

WHAT DATA CAN BE COLLECTED BY US?

          How We Collect Data. When using our website, we will collect some Personal Data, as follows:

 What do we collect?

What do we collect for?

Fale com a Sempre - Contato

Name

E-mail

Phone

(i)          Conducting your service;

(ii)         Scheduling meetings or any other action that is of interest to you after sending the contact message; and

(iii)        Expanding our relationship, keeping you always updated on our news and news.

Work with us

Resume (name, e-mail, phone, and address)

(iv)         Evaluating your application for vacancies and opportunities at Sempre Engenharia.

Be our supplier

E-mail

Name

(v)          Establishing commercial partnerships and work together on new projects.

Digital Identification Data

Source IP Address and Logical Port

Device (operating system version)

Geolocation

Cookies

(vi)          Complying with legal record-keeping obligations established by Law No. 12.965/2014, Marco Civil da Internet (The Internet Civil Framework).

(vii)        Protecting you by performing fraud prevention, in addition to complying with legal and regulatory obligations.

          By accessing our website, these will be the only data collected by us.

          However, as we proceed with your service and verify the need to collect other data for the provision of our services, you will be duly informed.

          About the data provided by you.Always pay attention to the data you provide us, as you are solely responsible for the accuracy, veracity, or lack thereof concerning to the Data you provide. If any changes have occurred, you need to let us know so that we can update them.

          Database. With the collection of your data, we make a database that will always be our property, so that its use, access, and sharing, when necessary, will be made within the limits and business purposes described in this Policy.

          About the technologies we use. We use the following technologies:

 

(i) Cookies, Cookies, it is up to you to configure your internet browser to allow or not their use. We recommend that you do not block “cookies” at this time, as we only use them to identify access and, if you block them, your access may be interrupted;

 

(ii) Among others that are used only for the development and maintenance of our application, which does not collect any information directly from your mobile device without authorization.

          Also, we emphasize that we do not use any type of solely automated decision that could impact you.

HOW DO WE SHARE YOUR DATA?

          We always avoid sharing the data you provide. However, data sharing in some cases is essential, as in the following:

  

(i) With law enforcement officials, administrative, or governmental authorities, whenever there is a legal determination, request, or order in this regard;

(ii) CWith the company's internal areas, which are under this Policy;

(iii) With our suppliers and business partners, with whom we sign contractual obligations for the security and protection of personal data. Vendors include data and server hosting companies; registration, authentication, and validation companies; advertising, marketing, digital and social media tools; research companies;

(iv) Automatically, in case of corporate changes, such as mergers, acquisitions, and incorporations.

         If you have any questions about who we share your Personal Data with, please contact by email at dpo@sempreengenharia.com.br and we will be happy to help.

How do we share your data?

HOW DO WE PROTECT YOUR DATA?

         In addition to providing the service with excellence, Sempre Engenharia insists on carrying out all other collateral activities with great zeal, such as the protection of personal data.

          So, rest assured that we know very well how to protect your data and keep your privacy intact.

          We will never ask you for passwords or any other type of authentication by any means whatsoever.

          If you receive any requests, stay tuned and let us know so we can help.

How do we protect yout data?

HOW CAN YOU ALSO PROTECT YOUR DATA?

          Don't forget, you are also responsible for the confidentiality of your Data.

          Please be aware that sharing passwords and access data violates our Policy and may compromise the security of your Data.

          If you notice or become aware that the security of your device (notebook, cell phone, computer) has been compromised, be sure to contact the DPO (dpo@sempreengenharia.com.br) and let us know what happened.

          Also pay attention when accessing other platforms, because unfortunately, we are not responsible for the Privacy Policies of these other environments.

          As we use social networks and instant messaging applications, there are icons of the mentioned environments on our website, which can take you directly there.

          Therefore, be very careful and carefully read the Policies of these other platforms so that you are not surprised by any violation of your rights.

How can you also protect your data?

HOW DO WE STORE YOUR DATA?

          We store your Data collected and activity records (logs) in a safe and controlled environment, for the time necessary for the purposes already informed in this Policy.

          We use our servers located in Brazil and also servers in the cloud, and there is, occasionally, the processing of personal data outside Brazil.

          Don't be alarmed, because these data processing with foreign companies comply with the applicable laws, maintaining compliance equal to what we do in Brazil or even more rigorous than what is stated in the General Data Protection Law.

         We only store your Data for as long as is necessary to fulfill the purposes for which it was collected or to comply with any legal and regulatory obligations or for the preservation of rights.

          As an example, the Digital Identification Data (activity records/access record) will be stored for at least 6 months, in compliance with the provisions of art. 15 of the Marco Civil da Internet (Civil Rights Framework for Internet).

          Shutting down maintenance terms and legal necessity, the Data will be deleted using safe disposal methods.

How do we store your data?

WHAT ARE YOUR RIGHTS? UNDERSTAND HOW TO EXERCISE THEM!

          The Lei Geral de Proteção de Dados Pessoais – LGPD brings several rights related to your Personal Data, so that you can exercise them easily, as long as you contact the DPO via the contact email already provided in this Policy.

          Your rights are as follows:

(i) Confirmation and access: If you want to know, you can request confirmation about the existence of the Processing of your Personal Data and access them, by requesting copies of records we have about you.

(ii) Correction: If your Data is incomplete, inaccurate, or out of date, you can request a correction.

(iii) Anonymization, blocking, or deleting: You may request the anonymization of your Data so that it can no longer be related to you. You may also request the blocking of your Data, temporarily suspending the possibility of processing for certain purposes or even the deletion of your Data.

(iv) Portability: If you wish, you can request your Data in a structured and interoperable format (data in a transparent way that can communicate with another system), to transfer them to a third party, respecting our intellectual property and our business secrets.

(v) Sharing information: Also respecting our intellectual property and business secrets, you may request information about third parties (commercial partners, etc.) with whom we share your Data.

(vi) Opposition: you may object to the Processing of your Data if you do not agree with any purpose.

          Whenever you make a request, to exercise its rights, Sempre Engenharia will possibly request additional information to prove its identity, seeking to prevent fraud.

          We promise to respond to your request within a reasonable time and always comply with the law.

          We may fail to meet your requests in the following cases:

(i) If the application violates our intellectual property or trade secret;

(ii) When there is a legal or regulatory obligation to retain Data; and

(iii) When it is necessary to retain the Data to enable our defense or that of third parties in disputes of any nature.

What are your rights and how to exercise them!
Further information

FURTHER INFORMATION

          You are aware and acknowledge that we may change the contents of this Policy at any time.

         Minor changes are always necessary, however, if there is any relevant update, we will notify you through the contact information you provide us.

          This Privacy Policy will always be available for consultation.

          If any point of this Policy is deemed unenforceable by the Autoridade Nacional de Proteção de Dados - ANPD or the courts, the other conditions will remain in full force and effect.

          Again, please, feel free to ask us any questions you may have.

          Our Data Manager will be available to assist you at the following addresses:

DPO: Castro & Del Grande Advogados

Contact e-mail: dpo@sempreengenharia.com.br

Mailing address: 1633 Treze de Maio St., 14th floor - Bela Vista, São Paulo - SP

          This Policy will be interpreted according to the Brazilian legislation, in the Portuguese language, and the court of your domicile will be elected to settle any controversy involving this document, except for specific reservations of personal, territorial, or functional competence by the applicable legislation.

Last update: [03/10/2022]

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