LATICÍNIOS TIROLEZ (“TIROLEZ“), recognizing the importance of the security and protection of personal data, as well as the privacy of its customers’ information, takes measures to protect such information in all its operations and implements rigorous policies and procedures.

This Privacy Policy informs you, who visits the website or provides data, regardless of its nature, about TIROLEZ‘s privacy practices and indicates the choices you can make regarding the collection and use of your Personal Data.

What you need to know before reading this privacy notice.

For the purposes of this Privacy Policy, personal data means any data that refers to a natural person, whenever there is the possibility of you being identified, directly or indirectly.

By accepting the terms of this Privacy Policy, you give your consent to TIROLEZ to process your personal data, sensitive or not, as described below.

Personal Data:

All personal information that allows your identification, such as your name, email, phone, among others;

Sensitive Personal Data:

Personal data related to racial or ethnic origin, religious belief, political opinion, affiliation with a union or organization of a religious, philosophical, or political nature, data related to health or sexual life, genetic or biometric data, when linked to you;

Processing of personal data:

Any operation performed with personal data, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.

In this regard, Personal Data of Legal Entities are not, in principle, considered Personal Data.

Premise and condition for sending your personal data to TIROLEZ

By accessing and/or using the website, you:

Declare to be at least 18 (eighteen) years old and have full and express capacity to accept the terms and conditions of this Privacy Policy for all legal purposes.

Declare that you fit the description above and fully agree with what is described in this Privacy Policy.

If you do not fit the description above and/or do not agree, even in part, with the terms and conditions contained in this Privacy Policy, you should not access and/or use the services offered by TIROLEZ, as well as the websites and applications operated by it.

1. Rights of the personal data subject

When you are the data subject, that is, the natural person to whom the personal data that is the subject of processing refers, rights provided by laws will be guaranteed, as follows.

It is important to emphasize that, for the exercise of any of your rights, we will need to use your personal data to process the request and provide you with a response.

Confirmation of the existence of processing
Request confirmation that TIROLEZ processes personal data.

Access to personal data
If you wish, request the list of personal data that TIROLEZ has in its files.

Correction of data
If you wish, request the correction of incomplete, inaccurate, or outdated personal data.

Anonymization, blocking, or deletion of data
If you wish, you have the right to request anonymization (a process that makes data impossible to be linked to an individual), blocking, or deletion of data when you believe they are “unnecessary, excessive, or processed in non-compliance” with the LGPD.

Important: There are situations in which this right cannot be exercised, such as when TIROLEZ needs to keep the data to comply with a legal or regulatory obligation.

Data portability
The data subject may request data portability, i.e., the transfer of their personal information to another service or product provider.

In this case, an explicit request is required, following regulations that will be established by the National Data Protection Authority (ANPD), which is not yet in operation.

In addition, portability does not include data that has already been anonymized by the controller – anonymized data, in fact, are outside the scope of the LGPD.

Elimination of data processed with consent
If you have consented to the processing but have changed your mind and no longer want the company to process your personal data, you can request the deletion of that data.

Important: There are situations in which this right cannot be exercised, such as when TIROLEZ needs to keep the data to comply with a legal or regulatory obligation.

Information about data sharing
You can ask TIROLEZ to inform you with whom it is sharing your personal data, both with private and public entities, which will be expressly named.

Information about the possibility of not giving consent
You have the right to be informed about the possibility of not giving consent and the consequences if consent is denied.

This is the case, for example, of a user who is asked to consent or not to the use of cookies on a website. If non-consent will harm the browsing experience or prevent access to some tools, the user must be informed of this.

Revocation of consent
You can, at any time, request the revocation of the consent previously given to TIROLEZ to process your personal data.

Important: In this case, a specific request will be required, as there are situations in which TIROLEZ needs to keep the data to comply with a legal or regulatory obligation.

Other rights
In addition to the 9 main rights of data subjects provided in Article 18, the LGPD mentions others, such as:

• The right of the data subject to complain to the ANPD and consumer protection agencies against the controller;

• The right to object to processing carried out without consent if it does not comply with the law.

It is important to note, however, that no right is absolute, and there are situations in which companies may not be able to meet the data subject’s requests, and they must indicate the reasons, such as compliance with legal or regulatory obligations.

2. Processing of personal data

As already mentioned in this Policy and provided for in the legislation, the processing of personal data is any operation performed with personal data, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.

TIROLEZ has as a rule not to collect sensitive data, except in extraordinary cases that will be treated considering the relevant legal bases in force.

To achieve its purposes described in this policy, TIROLEZ generally does not need data from children (under 12 years old) and adolescents (from 12 to 17 years old).

Therefore, you can contact us if you believe that we have collected sensitive information, or even from a child or adolescent by mistake or without intention.

2.1 Legal bases for the processing of personal data

TIROLEZ, in attention, will only process your personal data when you provide it to us or when it is obtained automatically and indirectly, as will be described throughout this Policy.

Regardless of how your data is obtained, TIROLEZ will process the data considering the following legal bases, which include:

1. Consent: when you give us your consent;
2. Contract: when processing is necessary to enforce or carry out a contract with you;
3. Compliance with a legal or regulatory obligation;
4. Exercise of our rights;
5. Protection of life or physical integrity (yours or third parties);
6. Legitimate interests: to ensure the quality of our products, improve them, conduct internal analyses, as well as support, carry out, and promote our activities (ensuring the prevalence of the rights and fundamental freedoms of the data subject).

If you wish, your consent can be revoked, in whole or in part, at any time, through a formal request. The revocation of consent will not affect the legality of the processing of your personal data prior to the revocation request, or the legality of maintaining the processing of your personal data based on another legal basis.

2.2 Sensitive personal data

Sensitive data are considered those related to racial or ethnic origin, religious belief, political opinion, affiliation with a union or organization of a religious, philosophical, or political nature, data related to health or sexual life, genetic or biometric data.

By accepting this policy, you agree not to voluntarily send us sensitive data, and if done, considering the awareness and acceptance of this document, the sending of the information itself will characterize “Consent” to process it for the purpose of the originally established contact.

2.3. Personal data of children and adolescents

TIROLEZ, whenever it becomes aware that personal data of a child has been collected, will make reasonable efforts to ensure that there is consent from at least one of the parents or legal guardians for the processing. Please contact us if you believe we have collected information from a child or adolescent by mistake or without intention.

In general, to achieve the purposes described in this Policy, we do not need to process personal data of children (under 12 years old) and/or adolescents (individuals between 12 and 17 years old).

3. Sources of personal data

As a rule, we will collect personal data when you provide it to us or authorize us to obtain it from third parties. We may also obtain them independently, from public sources, or as described in this Policy.

Source of Automatically and Indirectly Collected Data

1. Simple Navigation on the Website and Applications, intended for customers, consumers, partners, and other interested parties in TIROLEZ products through cookies and other tracking technologies;
   Cookies (text files containing small amounts of data that are transferred to your device, or more precisely, to the browser you use on the device, when you visit a website);
   To learn more about Cookies, consult the Tirolez Cookies Policy: https://tirolez.com.br/politicas
2. Interactions on the pages we maintain on social networks;
3. Ads: Interactions with our advertising (e.g., if there is interaction with ads, even on a third-party website, TIROLEZ may receive information about that interaction);

To learn more, read the chapter “Third-Party Sites” of this policy.

Source of Directly Collected Data

1. Filling out an electronic form on the website in the “Contact” field (“Contact Us,” “Become a Customer”, “Work with Us,” and “Export”);
2. In case of doubts, complaints, suggestions, compliments, contacts for commercial purposes, or other contacts related to the TIROLEZ Customer Service through the form on the website, electronic message (WhatsApp), phone, or email;
3. Text messages, emails, and other electronic messages;

4. Third-party website

It is important to be aware that on our website and social media, there may be links to third-party sites, which are beyond TIROLEZ‘s control, such as partner stores (online or physical), advertisers, and other business partners of TIROLEZ, among other third parties.

If you access these websites or use the services made available on them, we recommend that you carefully analyze how these third parties treat personal data before using their sites, applications, or services, as this Policy does not apply to the processing of data by third parties.

In addition, TIROLEZ‘s pages on social networks are also subject to the privacy policies of the respective networks, in addition to this Policy.

In the case of a selection process for candidates (“Work with Us”), access can be made through a link available on our website, which will redirect you to a third-party recruitment and selection platform, where you can enter your personal data, resume, academic records, professional experience, references, among other information, which will be collected and stored by such platform and shared with us for the purpose of conducting selection processes.

5. Transfer of data to third parties

To achieve the purpose and need described, we may share your personal data with third parties, mostly suppliers and service providers, who are involved in activities inherent to these purposes.

In addition to the mentioned third parties, data may be transferred to public bodies, financial institutions, and other relevant third parties, including other companies within our economic group and our successors in the event of an acquisition, merger, or other corporate transaction.

In situations where data is transferred to third parties, TIROLEZ, whenever possible, enters into a personal data processing agreement with the suppliers and/or service providers who have access to your personal data, so that such third parties ensure a level of data protection compatible with what is provided in this Policy and with applicable law.

6. Processing time and storage of personal data

TIROLEZ may retain your personal data to comply with legal or regulatory obligations, to protect our rights if it is of our legitimate interest (provided it is allowed by applicable law), or if personal data are archived in our backup and support systems to ensure their security.

In this sense, your personal data will be processed and stored:

1. For a period sufficient to achieve the purposes for which they were collected;
2. For a period determined by applicable law;
3. Until you request the revocation of your consent given to us for the processing/storage of your personal data, as applicable.

7. Changes to our policy

Data protection measures accompany technological advances, which is why our Personal Data Privacy Policy will be adapted to follow this evolution.

Therefore, whenever the Personal Data Privacy Policy undergoes any changes, the new version will be published and made available on our website. We emphasize that you can contact us at any time, requesting the most updated version of our Personal Data Privacy Policy. In any case, you should check this page regularly to learn more about the status of this Privacy Policy.

8. Contact

If you have any questions or concerns regarding this Personal Data Privacy Policy, our practices of collecting and using Personal Data, or a possible violation or breach of the confidentiality of Personal Data or privacy, you can contact us through our website or via email at protege.dadopessoal@tirolez.com.br.