EXTERNAL PRIVACY NOTICE

Last update on 14.04.2022

CELUPA INDUSTRIAL CELULOSE E PAPEL GUAIBA LTDA. (“CELUPA”) understands and values ​​the importance of the privacy of the holders and, therefore, we constantly work to ensure the protection of all personal data we process.

These efforts, however, must be based on a culture of trust and transparency with you. As such, we have created this Privacy Notice (“Notice”) to help you understand what information we collect from you, why we collect it, and how we share it. In addition, we also inform you here about your rights regarding this information and how to exercise them with CELUPA.

In case of doubt, we provide an appropriate contact channel at the end of this Notice. Please don’t hesitate to contact us.

1. DEFINITIONS

Personal Data: Any information that identifies or could identify an individual. For example, name, date of birth, marital status, personal registration number, e-mail, cell phone, home address, bank account, physical, economic, cultural or social characteristics, among others.

Person in Charge of Personal Data Processing (“Manager”): Person appointed to act as a communication channel between CELUPA, the data subjects and the National Data Protection Authority (“ANPD-Brazil”).

Treatment: Any operation with personal data, including collection, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, updating, communication, transfer, sharing and extraction of personal data.

 

2. WHAT PERSONAL DATA DO WE COLLECT YOU?

The information we collect about you is only that compatible and necessary to enable your relationship with us, for example, as a customer, provider or supplier of products or services, employee of a business partner, user of our website, among others.

Grouped into categories, this data can be:

Identification information, such as your name, ID, personal registration number, gender, age, date of birth, marital status, nationality, among others;

Information that helps us to contact you, such as your home address, zip code, phone number, mailbox and e-mail;

Financial information, such as checking account, financial statements, bank statements, registration status with the Federal Revenue, among others;

Professional information, such as profession, place of work, position, professional history, academic qualification, diplomas and other qualification certificates, among others;

Behavioral information, such as consumption or professional profile, pattern of use of social networks, sociographic background, among others;

Attributes associated with your electronic devices, such as access provider, operating system, internet protocol (“IP”) address, browser, date and time of access, pages viewed, among others;

Sensitive data, such as regarding your health, racial and/or ethnic origin, religion, opinion or political affiliation, among others;

Information concerning your image, such as photos and videos.

3. HOW DO WE COLLECT YOUR PERSONAL DATA?

The information we handle about you may have been provided to us directly by you, by third parties, collected automatically, or come from public databases.

3.1. Provided Directly by You

Since the beginning of your relationship with us, you voluntarily provide us with information about you, for example, by contacting us through the telephone number (+55 51) 2101-1100 or how much you apply through the “Work with us” form for a of our employment opportunities.

3.2. Obtained from Third Parties

In some specific cases, we may also obtain some personal data from you through third parties, such as information from your employer, for example when you represent them in a partnership with us, or from the “Reclame Aqui” platform.

3.3. Automatically

From time to time, we may also automatically collect data from the electronic devices you use to access our website, for example, in order to improve and personalize your browsing experience. Some of this data may be collected through cookies or similar technologies, as we will explain in a specific topic below.

3.4. Publicly Available

Finally, we may collect information from you that is publicly available, including, but not limited to, social networks such as Facebook, Instagram and Twitter, and coming from Brazilian Institute of Geography and Statistics.

4. HOW DO WE USE YOUR PERSONAL DATA?

The personal data we collect about you is used for the following purposes:

4.1. Fulfill the Purpose for Which the Data Was Provided

We process your personal data to meet the purpose for which you provided them to CELUPA or for other purposes compatible with these and informed to you at the time of collection of your data. For example, we may process your personal data to enable your participation in the selection processes for our job vacancies, or even to enable you to purchase one of our products on behalf of your company or your employer.

4.2. Comply with Our Legal or Regulatory Obligations

We may also use your personal data to comply with our obligations imposed by law, regulations of government agencies, tax authorities, the Judiciary and/or other competent authority. For example, to issue invoices for the sale of our products.

4.3. Enable the Necessary Activities for Our Operations

Based on our legitimate interest, we will also be able to process your personal data to enable our daily activities, always observing the limits of your expectations and never at the expense of your fundamental rights or freedoms. For example, to monitor our customers’ satisfaction and thus improve the quality of our products.

4.4. Avoiding Fraud and Ensuring Your Safety

Caring for your (and third-party) security, we may also process your personal data to control access to our facilities and prevent identification fraud in this access.

4.5. Advertising

We may use your data to create target audience segments and thus promote our products more appropriately.

4.6. Performing a Contract You Have Entered into with Us, or Performing Pre-Contractual Diligence

For example, if you are a self-employed service provider, we may process your personal data to enable you to perform your work and for us to pay your fees.

4.7. Allow the Regular Exercise of Our Rights

Finally, even after your relationship with us ends, we may process some of your personal data to comply with our legal or regulatory obligations, or even to exercise our rights guaranteed by law, including as evidence in judicial, administrative or arbitrations.

5. WHAT ARE COOKIES AND HOW DO WE USE THEM?

Cookies are small text files that we may store on your electronic devices when you visit our website. We use this tool for different purposes, such as customizing your browsing experience, understanding how our website is used and to refine the content we promote through it. Aggregated into groups, we list all these purposes below:

Cookie Type

What do they do?

Required

These cookies are essential to enable the proper functioning of our website, as well as to allow you to make use of all the functionalities available on it.

Performance

These are cookies that help us understand how visitors interact with our website, providing information about the areas visited, the time spent on the website and any problems that may be encountered.

 

Functional

These are cookies that allow our website to remember your previous choices, such as navigation language. They are responsible for providing a personalized experience.

Marketing

These are cookies used to provide more relevant content specific to your interests. They can also be used to present advertising with greater targeting or to limit the number that it is served. Also, they allow the measurement of the effectiveness of a launched campaign.

At any time, you can disable cookies in your browser settings. However, your opposition to the necessary cookies could impair or render your browsing experience unusable.

6. WITH WHOM WE SHARE YOUR PERSONAL DATA?

Depending on the relationship you establish with CELUPA, we may share your personal data with public bodies, the Judiciary, business partners, financial institutions, other companies in our economic group, service and/or infrastructure providers, agencies advertising and publicity, legal advice, among others. In all these cases, whenever feasible, we use contractual instruments to ensure that third parties who receive them guarantee them adequate protection.

Occasionally, it is possible that the third party with whom your data is shared is located outside Brazil, for example, in Germany. In this case, we will give preference so that this international transfer takes place only to countries that have a level of security similar to that provided for by Brazilian law, or when the National Data Protection Authority so authorizes. If this is not possible, we will use appropriate contractual clauses and prior audits, in order to ensure that third parties who receive your personal data comply with the protection standards required by Brazilian law.

For more information about the public and private entities with whom we may share your personal data, please contact our Supervisor through the channel for exercising your rights indicated in topic 8 below.

7. HOW DO WE KEEP YOUR DATA SECURE?

We adopt strict policies and procedures that determine how personal data should be treated here at CELUPA. These rules aim to ensure the proper and lawful processing of the personal data we hold.

In addition, we also adopt numerous technical measures to keep your personal data safe and protected from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any other form of inappropriate or unlawful treatment, always in light of the rules applicable data protection and information security regulations.

As an example of some of the measures we take are:

Control of access to folders and systems;

Policy for using strong passwords to access our systems and database;

Periodic backups;

Periodic review of the inventory of employee access to our systems;

Segregation of functions policy and monitoring of risks of segregation of functions and critical access in our ERP system.

8. HOW CAN YOU EXERCISE YOUR RIGHTS?

Whatever your relationship with CELUPA, we guarantee that all your rights relating to the processing of your personal data will be respected. These rights include, but are not limited to:

Find out if we carry out any processing with your personal data and, if this is the case, know what data we process;

Correct incomplete, inaccurate or outdated data when necessary;

Request the anonymization, blocking or deletion of unnecessary, excessive data or that, by chance, has been treated in breach of the law;

Request data portability to another supplier of products or services;

Request the deletion of data collected and used based on your consent;

Obtain information about the public or private entities with which we share your data;

When the processing activity requires your consent, you can refuse consent. In that case, we will inform you of the consequences of that decision; and

When the processing activity requires your consent and you choose to provide it, you may revoke it at any time.

To exercise your rights, please contact our Supervisor, through the email address (privacidade@melitta.com.br).

In specific cases, it is possible that your request will not be granted. In these cases, we will explain the reasons that justified the non-attendance. For example, requests involving personal data and/or documents of other holders will not be met, except through a power of attorney, parental authority or other hypothesis that authorizes the exercise of the right of another holder by you.

9. QUESTIONS

In case of doubts, suggestions or requests regarding this Notice, please contact our Supervisor, through the email address (privacidade@melitta.com.br).

10. UPDATE OF THIS NOTICE

In order to ensure our commitment to transparency with you, this Notice may be changed at any time. Therefore, we recommend that you check it periodically.