SCHULZ S.A., enrolled in the CNPJ under no. 84.693.183/0001-68, headquartered at Rua Dona Francisca, No. 6.901, Distrito Industrial, in the city of Joinville, State of Santa Catarina, Zip Code 89.219-600 (referred to as “SCHULZ or SCHULZ AUTOMOTIVA“), reaffirming its commitment to protect the personal data of customers, suppliers, resellers, distributors, users of its websites (“WEBSITES”):
This POLICY originates from recognizing the importance of the protection that should be applied to personal data, especially in virtual environments, considering that the information collected during the USER’s access, as well as issues involving IT security, are relevant topics to SCHULZ.
By entering into a relationship with SCHULZ, the DATA SUBJECT accepts all of the terms and conditions contained in this POLICY and agrees with it. Therefore, it is very important that the DAT SUBJECT reads the POLICY and understands it.
In case of question(s), the DATA SUBJECT should contact the service channels listed at the end of this document.
CONCEPTS USED IN THIS POLICY:
This POLICY adopts, among others, technical concepts provided for in the applicable legislation, especially those contained in the LGPD. For the purpose of better understanding, the main concepts used are the following:
- Personal Data:any information related to an identified or identifiable individual, that is, information that identifies a person directly, such as: full name, CPF/SSN, RG/ID No., photograph; or that identifies them indirectly, such as: email address, IP, residence, date of birth, etc.
- Sensitive Personal Data: information that reveals more intimate characteristics of the data subject and that could cause some discriminatory treatment, such as racial or ethnic origin, religious conviction, political opinion, participation in trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to an individual.
- Data Subject or User: individual related to the personal data.
- Controller: an individual or legal entity, governed by public or private law, responsible for decisions concerning the processing of personal data.
- Operator:an individual or legal entity, governed by public or private law, responsible for processing personal data on behalf of the controller.
- Officer (“DPO”): person appointed by the Controller and Operator to act as a communication channel between the Controller, the data subjects and the National Data Protection Authority (NDPA).
- Processing: any and all operations performed with personal data, whether by the Controller or the Operator, such as, collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.
RESPONSIBLE FOR PROCESSING:
SCHULZ shall act as Controller of personal data when the processing is related to its own and its subsidiary companies’ activities in accordance with the applicable regulations.
In some cases, SCHULZ may act as the Processor of the personal data, in which case it will process the personal data within the strict limits of the agreement entered into with the data Controller.
HOW DOES SCHULZ COLLECT PERSONAL DATA?
- Data provided by the DATA SUBJECT:
This category covers all personal data voluntarily provided by the DATA SUBJECT in physical or digital environments of SCHULZ, such as, for example, sending your resume to apply for a job position or filling out a registration on one of our websites.
- Data collected or generated by SCHULZ, cookies and other relevant information:
When interacting with the SCHULZ WEBSITES, some of the USER’s data may be collected in the background such as information about their browsing preferences and consumption interests corresponding to the products viewed.
This type of data will be collected using indirect collection technologies called cookies. For more information see the Cookies and Similar Technologies section of this Policy.
WHAT DATA IS COLLECTED AND WHAT ARE THE PURPOSES OF THE PROCESSING PERFORMED BY SCHULZ?
|AT WHAT POINT CAN DATA BE COLLECTED?||WHAT DATA?||PURPOSE?|
|Business relationships with customers||Name, phone, and email||Interactions with customer representatives (e.g., directors, managers, buyers) necessary to the business relationship, such as preliminary contacts, quotations, financial adjustments, satisfaction surveys|
|When the USER contacts SCHULZ via the contact sections of the websites||Name, email, CPF/SSN, phone, city, state, country||Receive requests from the USERS and provide appropriate service|
|Answering questions, receiving complaints, compliments and suggestions|
|Sending the USER informative emails related to SCHULZ’s operation that may be of interest to them such as product launches, promotions, invitations to events, etc.|
|When the USER contacts SCHULZ via the “Contact – Code of Ethics” section of schulzsa.com||Name, email, phone, city, state, country (schulzsa.com)||For handling reports and complaints related to the SCHULZ Code of Ethics and Business Conduct|
|To receive news, information and advertisements in the “E-mail Alert” section of ri.schulzsa.com||Name, email, company, and profile (ri.schulzsa.com)||The registration on the SCHULZ AUTOMOTIVA website is intended to send the USER news related to the Company’s operation that may be of interest to them. Regarding the SCHULZ Investor Relations website, registration is for the purpose of receiving information and news from the Investor Relations area|
|When the USER contacts SCHULZ via the “Contact IR” section of ri.schulzsa.com||Name, phone, email, and whether the person is a Schulz shareholder||For matters related to the Company’s business, such as balance sheets, publications, and other announcements|
|Browsing on SCHULZ websites (background data processing)||Pages with which the USER interacted; type of device and browser used; Internet protocol (IP) address; average time of visit; geographical location||Understanding user browsing behavior and how the website is being used in order to improve and customize its functionality|
|Displaying to the USER content and marketing materials from SCHULZ’s operation that may be of interest to them|
|Tracing consumer profiles for product enhancement and development|
|Perform statistical analysis for marketing campaign development|
|During visits to SCHULZ environments||Name, ID, CPF/SSN, and Images (photos and videos)||Internal security management and access to the Company’s facilities|
|Property security and physical protection of the data subject|
|Perform visitor registration|
|Identification of person at facilities, photograph, issuance of temporary badge|
|In which case sensitive data may be processed|
|Completion of questionnaire with questions related to covid-19 and body temperature measurement||Questions regarding contact with infected people, whether the person has symptoms of covid-19 and what is their temperature||Sanitary control against covid-19|
|Protection of the people who circulate in the Company (employees, clients, suppliers, service providers, among others)|
- Data provided by Applicants:when you apply for a job position in a selection process at SCHULZ, your data will be handled as follows:
|AT WHAT POINT CAN DATA BE COLLECTED?||WHAT DATA?||PURPOSE?|
|When filling out the registration/resume in the “Contact – Work with Us” section on the schulzsa.com website and the registration in the “Contact – Work with Us” section on the schulzautomotiva.com.br website||Name, CPF/SSN, date of birth, gender, country of birth, marital status, have or not children, ID No., voter registration No., driver’s license No., height, ZIP Code, address, district, city, state, father’s name, phone, mobile, additional phone, desired role/position, desired internship, course completion year, if the person has already worked at SCHULZ, if the person has disabilities, if they use any device or equipment, level of education, name of the course, institution, year of completion, which languages they speak, whether they have any extracurricular courses, computer skills, professional experience already acquired (company name, position, admission date, dismissal date, last salary, main activities, reason for dismissal, whether or not it is the current job), social media profiles on platforms such as: Facebook, Instagram and LinkedIn, if someone referred them and other information about the applicant, such as business trips and volunteer work, for example||Carry out the selection process of USERS interested in filling a job position at SCHULZ|
|Conduct the hiring process for selected applicants|
|Carry out the selection, admission, and adaptation of working conditions to the special needs of the applicant (in the case of people with special needs)|
SHARING DATA WITH THIRD PARTIES:
SCHULZ may share personal data with third parties where necessary in order to:
- Conduct satisfaction surveys, in order to improve products and greater customer satisfaction;
- Send the USER informative emails with marketing material that may be of interest to them, informing about product launches, promotions, invitations for events, etc.;
- Publish posts on social media, in order to promote products, promotions and events, interacting with customers;
- Confirmation of the authenticity of the registration made on the WEBSITES, in which case these third parties may contact the DATA SUBJECT to confirm;
- Credit analysis;
- Ensure the secure flow of credit card data when making payments (gateways);
- Market research, consumer profile analysis, sending advertising campaigns, marketing, etc.;
- Data storage and processing (storage providers, cloud software);
- Generation of payment slips, collection, audits, providing support, exercising rights in legal proceedings;
- Sending goods (products and/or gifts) via carriers;
- With authorities and public agencies or private bodies in the performance of typically public activities to comply with a legal determination or obligation, such as information shared with tax authorities, compliance with court orders or orders from the National Data Protection Authority.
SCHULZ may also process and share data with its subsidiaries, affiliates, branches, and related companies in compliance with applicable data protection regulations for legitimate purposes or whenever necessary for: (i) fraud prevention, registration control and its proper identification; (ii) credit risk analysis; (iii) or for the provision of services that benefit SCHULZ’s customers as a whole.
DATA TRANSFER TO OTHER COUNTRIES
SCHULZ may conduct international data transfers with other countries such as the United States of America and countries in the European Union and Latin America in order to carry out certain processes that make up the operation such as storing information on international servers, managing sales and resales, etc.
Cookies, tags, pixel, or similar technologies (herein generically referred to as “Cookies”) are small files sent by the website to the device, which are stored in the browser used by the Data Subject, with information related to their interaction with the website. This information allows the website to recognize the Data Subject and create their behavioral profile.
The most common functions of cookies are to enable and personalize browsing, to target marketing, and to conduct statistical surveys to guide companies’ market strategy. Cookies in general can be classified as follows:
- Strictly necessary cookies: ensure the smooth and proper operation of our website. Cookies that do not identify you and cannot be deactivated without impairing or even making it impossible for our website to function;
- Performance cookies: store anonymous information such as visit volume, most visited sites, and other statistical information to manage the operation and improvement of our website. These cookies do not identify the User and can be deactivated, however their deactivation may affect the proper operation of our website;
- Functionality cookies: enable the website to offer enhanced and customized functionality for you. Disabling these cookies may hinder some functionality of our website. These cookies collect information that can identify the User and can be disabled;
- Advertising cookies: use some of your information and target personalized content for you according to your own browsing preferences. These cookies collect information that can identify the User and can be disabled; and
- Third-party cookies: these are cookies placed by partners, such as Facebook and Google, that collect information from the User when they visit our website, so that these partners can advertise our advertising materials on their platforms when you use them. These cookies collect information that can identify the User and can be disabled.
The cookies that can be found on the website can be managed in the settings of the internet browser used by the Data Subject. To this end, we provide the cookie management link of the most popular browsers on the market (the addresses may vary depending on the browser version):
RIGHTS OF PERSONAL DATA SUBJECTS:
By means of the e-mail email@example.com the personal data subject may request:
(i) confirmation of the existence of data processing;
(ii) data access;
(iii) correction of incomplete, inaccurate, or outdated data;
(iv) anonymization, blocking, or deletion of unnecessary, excessive data or data processed in non-compliance with LGPD provisions;
(v) portability of the data to another service or product provider, subject to compliance with commercial and industrial secrets;
(vi) deletion of personal data processed with your consent;
(vii) information of public and private entities with which SCHULZ has had shared use of data;
(viii) revocation of consent;
(ix) request a review of decisions made solely on the basis of automated processing of personal data affecting their interests, including decisions intended to define their personal, professional, consumer and credit profile or aspects of their personality.
It is worth emphasizing that the request will be answered by the legal deadline, however, if there are legal grounds, the request may be partially answered or even denied, in which case the necessary clarifications will be provided.
HOW LONG WILL SCHULZ STORE PERSONAL DATA?
SCHULZ will keep the personal data stored for as long as is necessary to fulfill the purposes for which it was collected.
Once the purpose has ceased to exist, the data will generally be deleted or anonymized, unless there are grounds to store the data for legitimate purposes as defined by law, to comply with legal or regulatory obligations, or to exercise or protect SCHULZ’s rights.
RECOMMENDATIONS TO THE USERS:
The USERS are responsible for:
(i) Keeping all their credentials (IDs, tokens, logins, and passwords) secret and not sharing them with third parties;
(ii) Not providing information such as bank or financial passwords via e-mail or WhatsApp, as SCHULZ does not request this information;
(iii) Report to SCHULZ any and all suspected or observed violations of this POLICY, such as unauthorized access to their account, suspicious purchases, etc.;
(iv) Provide SCHULZ with true and complete information and keep this information up to date at all times;
(v) Should they wish to exercise any rights in relation to their personal data, they should contact SCHULZ via the email firstname.lastname@example.org;
(vi) Adopting cyber security measures in mobile devices and computers employed in the use of the WEBSITES, such as updating antivirus, firewalls, passwords;
(vii) Refraining from using the website for any unlawful or unauthorized processing of personal data of third parties;
(viii) Not paying any bank payment slips supposedly sent by SCHULZ without first making sure of the document’s authenticity by checking the amount, barcode, financial institution, and payee.
Any litigations will be submitted to the jurisdiction of the District of Joinville, State of Santa Catarina, to the exclusion of any other, however privileged it may be.
For any matter relating to the processing of personal data, SCHULZ can be contacted via its Data Protection Officer (DPO) at the contacts below:
Name: André Ribas Böhler
Address: Rua Dona Francisca, nº 6.901-A – 89.219-600
Industrial District, Joinville, Santa Catarina
For other issues, requests should be directed to the “Contact Us” channel indicated on the respective WEBSITES.
This document was prepared in accordance with current legislation, in particular, Law No.13,709/18 (Brazilian Personal Data Protection Act or LGPD), Law No. 8,078/90 (Consumer Defense Code or CDC) and Law No.12,965/2014 (Brazilian Civil Rights Framework for the Internet or MCI).
SCHULZ may change this POLICY at any time as it deems appropriate. In such cases, SCHULZ will notify by means of a prominent announcement on its own WEBSITES.