>


GENERAL PRIVACY AND DATA PROTECTION NOTICE – CBMM

Companhia Brasileira de Metalurgia e Mineração - (CBMM) - a private legal entity registered under the CNJP No 33.131.541/0001-08, headquartered  in Córrego da Mata, s/No, Caixa Postal no 08, CEP 38.183-903, in Araxá, in the Estado de Minas Gerais, understands as extremely relevant the electronic records and other personal data left by you Data Subject  when using the several websites and services of CBMM, serving this Private Policy in order to regulate in a simple, transparent and objective manner, which personal data are obtained, as well as when and in which way they can be used.

This Policy applies to Services related to any of CBMM’s brands and activities, understanding as such all those listed on CBMM’s official websites, including all its products. 

The current Policy is aimed at CBMM’s clients and the general public and covers how we process these people’s personal data.  If you are a CBMM employee, collaborator or supplier, or if you are participating in any project or specific activity with CBMM, you may consult the respective privacy notice made available by CBMM. 

In case of additional questions or requests, you may contact our Data Protection Officer (DPO) through the link https://cbmm.com/pt/privacy-policy/direitos-dos-titulares or email  dpo@cbmm.com.

In order to better illustrate the way we process data, we present a summary of our Privacy and Personal Data Protection Policy.
 

This Policy may be updated by CBMM at any time upon notice on the website and/or by email, if the Data Subject has chosen to receive communications from CBMM.

 

1.DEFINITIONS

In case of doubts about the terms used in this policy, we suggest consulting the table below:

Personal Data
Sensitive Personal Data
Data Subject
Processing
Anonymization
Any data that identifies or allows to indirectly identify the Data Subject.
Special category of Personal Data related to racial or ethnic origin, religious belief, political opinion, union membership or religious, philosophical or political organization membership, data related to health or sexual life, genetic or biometric of the natural person.
Natural person to whom the Personal Data refers to, processed by CBMM, such as former, present or potential customers, employees, contractors, business partners and third parties.
Any operation performed with the Personal Data, such as those referring to: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, diffusion or extraction.
Process through which the Personal Data loses the possibility of direct or indirect association with an individual considering the reasonable and available technical means at the time of processing.

2. WHAT PERSONAL DATA WE USE
CBMM may collect the information actively inserted by the Data Subject at the time of contact or registration as well as information collected automatically when using the Services and the network, such as identification of the commercial establishment used, IP with date and time of connection, among others. 

There is, therefore, the processing of two types of Personal Data: (i) those provided by the Data Subject themselves; (ii) those collected automatically by CBMM.

i. Personal Data provided by the Data Subject: CBMM collects all Personal Data actively entered or forwarded by the Data Subject when getting in contact or accessing CBMM’s portals, such as full name, email, date of birth, city, state, when filling out forms in the Services by the Data Subject, in addition to other Personal Data actively provided by the Data Subject when contacting CBMM. Regardless of which Personal Data the Data Subject actively provides to CBMM, we will only use those effectively relevant and necessary for achieving the purposes declared to them on a case-by-case basis. 

ii. Personal Data collected automatically by CBMM: CBMM also collects a series of information automatically, such as: characteristics of the access device, browser, IP (with date and time), IP origin, information about clicks, accessed pages, searching terms entered in our portals, among others.  For such collection, CBMM will use some standard technologies, such as cookies, pixel tags, beacons and local shared objects, which are used with the purpose of improving the Data Subject browsing experience on the Services, according to their habits and preferences.

It is possible to disable them through your internet browser settings or in the Cookies Policy, as well as on our website. The Data Subject must be aware that, if these technologies are disabled, some features offered by the website, which depend on the processing of the referred data, may not work properly. 

The Data Subject may access, update and supplement their Personal Data, as well as request the deletion of their Personal Data collected by CBMM, by contacting our Officer through the link  https://cbmm.com/pt/privacy-policy/direitos-dos-titulares or email cdpo@cbmm.com. We will make every effort to reply to you in the shortest possible time, respecting the deadlines established by law. 

CBMM does not process, for the general purposes set forth herein, Sensitive Personal Data, given that, in the remote and specific cases in which it does so, the processing is based on specific terms previously made available to the Data Subject , upon their specific consent or based on clear legal authorization.

 


3. HOW WE USE DATA
The processing of data by CBMM has as its main purposes the establishment of a contractual relationship or the management, administration, provision, expansion and improvement of the Services to the Data Subject, adapting them to their preferences and tastes, as well as the creation of new services and products to be offered to Data Subject. 

CBMM may centralize the Personal Data collected, which may be used in other Services related to all of CBMM’s brands, respecting the purposes set forth herein and the Data Subject consent, whenever required by law.

In some cases, CBMM may also carry out Personal Data processing whenever necessary to comply with legal or regulatory obligations. 

In addition, CBMM may also process Personal Data based on its legitimate interest (or the legitimate interest of another company in the group), always within the limits to what is expected by the Data Subject, and never at the expense of their interests, rights and fundamental freedoms.  

Additionally, the information collected may be, upon the Data Subject consent, used for advertising purposes, such as sending information about CBMM’s brands, products, promotions and discounts, as well as disseminating events or conducting surveys related to its activities.  

If the Data Subject no longer wishes to receive CBMM’s advertising newsletter, they can contact CBMM at any time, through the link  https://cbmm.com/pt/privacy-policy/direitos-dos-titulares or email:  dpo@cbmm.com

 


4. HOW WE USE COOKIES 
Cookies are files or information that may be stored on your devices when you visit CBMM’s websites or use its online services. Generally, a cookie contains the name of the website that originated it, its lifetime and a value, which is randomly generated.

CBMM uses cookies to facilitate use and better adapt its pages to the interest and needs of Data Subject, as well as to compile information about the use of its websites and services, helping to improve its structures and contents.  Cookies may also be used to speed up your future activities and experiences on our portal.  They may be consulted by clicking 
here.


What do they do? 

Types of cookies

 


Necessary

These cookies are essential for CBMM pages to load properly and allow you to browse our websites and use all features. 



Preferences

These cookies allow CBMM pages to remember your choices to provide a more personalized experience.  They also allow Data Subject to watch videos and use social tools, comment fields, forums, among others.



Statistic

These cookies help us to understand how visitors interact with CBMM pages, providing information about the areas visited, the time spent on the website and any problems encountered, such as error messages.



Marketing

These cookies are used to provide content which is more relevant and of interest to the Data Subject. They can be used to present targeted advertising or to limit their placement on CBMM pages.  They also allow measuring the effectiveness of a CBMM advertising campaign. 

In addition, these cookies may be used to indicate to CBMM the pages of the websites that the Data Subject visited and to enable CBMM to share this information with third parties, such as contracted advertising agencies.

 

After the Data Subject consents to the use of cookies, when using CBMM pages, the website will temporarily store a cookie on their device to remember this in the next session.  

At any time, the Data Subject may revoke their consent in relation to the cookies stored by clearing the navigation data on their internet browser. 

Finally, we remind you that, if the Data Subject does not accept certain cookies from CBMM pages, some services may not work optimally.


5. WHO WE WILL SHARE DATA WITH
CBMM is an economic group that works in partnership with various companies in Brazil and worldwide, whose listing is available here.  This way, CBMM may share information collected through its pages or by contacting the Data Subject, in the following cases:

i. With other companies of the CBMM group, incorporated or operating in any country, which undertake to use the information for the same purposes indicated in this Policy. 

ii. With partner companies and suppliers, in the development of Services aimed at the Data Subject. 

iii. With authorities, government entities or other third parties, for the protection of CBMM’s interests in any type of conflict, including lawsuits and administrative proceedings.

iv. In case of transactions or corporate changes involving CBMM, in which case the transfer of information will be necessary for the continuity of the Services; or,

v. Upon court order or by request of administrative authorities that have legal competence for its request. 


Additionally, it is possible that some of the transfers indicated above take place outside of Brazil, notably to countries where the business group operates, at which time, CBMM undertakes to do so only to countries which provide an adequate level of Data Protection to the provisions of applicable law or upon the use of guarantees and safeguards, such as specific clauses, standard clauses, global corporate standards, among others; as well as upon specific consent of the Data Subject or the observance of the other hypotheses authorized by law and regulated by the National Personal Data Authority.

 

6. HOW WE KEEP DATA SECURE

CBMM uses reasonable market and legally required means to preserve the privacy of the Personal Data collected. This way, it adopts various technical and administrative security measures capable of protecting Personal Data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication or any other form of inappropriate or unlawful processing.

In addition to the technical efforts, CBMM also adopts institutional measures aimed at Personal Data protection, so that it maintains an information security and privacy governance program applied to all its activities and governance structure, which is constantly updated.  

Although CBMM makes its greatest efforts to preserve privacy and protect Personal Data of Data Subject, no information transfer is totally secure. Therefore, CBMM cannot fully guarantee that all information it receives and sends will not be subject to unauthorized access perpetrated through methods developed to improperly obtain information. 

For this reason, we encourage Data Subject to take appropriate measures to protect themselves, such as, keeping confidential all access credentials (usernames and passwords), being certain that such information is personal, non-transferable and of the sole responsibility of the Data Subject.

 

7. RETENTION OF INFORMATION COLLECTED

In order to protect the Data Subject privacy, Personal Data processed by CBMM will be deleted (i) after the expiration of the retention period established for the processing of those Personal Data; (ii) when the data are no longer useful for the purposes for which they were collected; or (iii) the Data Subject requests its deletion, unless its maintenance is expressly authorized by applicable law or regulation, or when its maintenance is based on a legal basis that justifies its retention.

However, information may be kept for complying with legal or regulatory obligation, transfer to a third party - provided that Personal Data Processing requirements are respected - and exclusive use by CBMM, including for the exercise of its rights in lawsuits and administrative proceedings.

 

8. YOUR RIGHTS

In compliance with the applicable regulations, regarding Personal Data Processing, CBMM respects and guarantees the Data Subject the possibility of submitting requests based on the following rights:

i. confirmation of the existence of Processing;

ii. access to the Personal Data;


iii. editing of incomplete, inaccurate or outdated Personal Data;

iv. anonymization, blocking or deletion of Personal Data which are unnecessary, excessive or processed in violation of the law;

v. portability of Personal Data to another service of product supplier, upon express request by the Data Subject; 

i. deletion of Personal Data processed based on the Data Subject consent;

ii. obtaining information about the public and private entities with whom CBMM shared their Personal Data;

iii. information about the possibility of not providing consent, as well as of being informed about the consequences, in case of refusal;

iv. revocation of consent;

v. opposition to Processing carried out in the event of waiver of consent, if not in compliance with the law.

These rights may be exercised by sending a request to our Officer through the link  https://cbmm.com/pt/privacy-policy/direitos-dos-titulares or email  dpo@cbmm.com, for further evaluation and adoption of other measures by CBMM.

The Data Subject is aware that the exclusion of essential information for the management of their account with CBMM will imply the termination of their registration, with consequent cancellation of the Services provided.

CBMM will make every effort to fulfil such requests in the shortest possible time and according to the complexity of each case.

Finally, the Data Subject must be aware that their request may be legally rejected, either for formal reasons (such as the inability to prove their identity) or legal (such as the request to delete Personal Data whose maintenance by CBMM is authorized by law).

 

9. LEGISLATION AND JURISDICTION

This Policy will be governed, interpreted and executed in accordance with the laws of the República Federativa do Brasil, especially the General Law of Personal Data Protection - LGPD (Law no 13.709/2018), regardless of the Laws of other states and countries, being the jurisdiction of Araxá, in the State of Minas Gerais, competent to resolve any doubts arising from this document.

Updated on november 2021.