Privacy Policy

Marluvas Equipamentos de Segurança Ltda. cares about your privacy and the protection of your personal data. This document explains how and for what purposes we use your personal data, what your rights are, and how you can exercise them.

1. TO WHOM DOES THIS NOTICE APPLY?

This Notice is intended for individuals external to Marluvas who, in some way, interact with the company.

2. TO FACILITATE YOUR READING

To help you better understand the information provided in this Notice, we present below the definition of some terms that may be found throughout the document:

Personal data: is information related to a natural person that can identify the person or make their identification possible. Examples of personal data that can allow your identification include: name, CPF (Brazilian individual taxpayer ID), telephone number, email, among others.

Processing: is any form of use we may make of your personal data, including, but not limited to, the following activities: collection, storage, consultation, use, sharing, transmission, classification, reproduction, deletion, and evaluation.

Controller: a natural or legal person, public or private, who is responsible for decisions regarding the processing of personal data. Marluvas acts as the Data Controller in all processing mentioned in this Notice.

Data Protection Officer (DPO): an employee or service provider responsible for supervising the application and reviewing this Notice, as well as suggesting changes, guiding the correct use of personal data for the performance of their duties, monitoring the occurrence of information security incidents, and proposing a budget for this purpose.

Data Subject: is you, the natural person to whom the personal data refers.

3. WHAT PERSONAL DATA DO WE PROCESS AND HOW DO WE USE IT?

The personal data that will be processed depends on how you interact with Marluvas and the purpose of the processing. We only collect the data truly necessary to achieve our objectives and use it only for the purposes for which it was collected.

That said, we can classify the personal data processed by Marluvas as follows:

Category of personal data Examples
Identification data Name; CPF; RG (Brazilian identity document); CNH (Brazilian driver's license); address; signature, etc.
Contact data Email; telephone, etc.
Personal characteristic data Age; gender; date of birth, etc.
Curriculum data Professional history; completed courses, etc.
Video and image recordings/data CCTV images; photos; videos, etc.
Public and/or publicized data Data available for public access.

Processing purposes Categories of data processed
Recruitment and selection: for selecting new employees. Identification data; contact data; personal characteristic data; curriculum data.
Talent pool: curriculum database of unselected candidates. Identification data; contact data; personal characteristic data; curriculum data.
Video monitoring and surveillance — CCTV: for asset and workplace security. Video and image recordings/data.
Customer credit analysis: credit analysis for proposing payment methods. Identification data; public data.
Supplier analysis: preliminary analysis of supplier suitability. Identification data; public data.
Supplier contact: for communication with suppliers. Identification data; contact data.
Accounts receivable: management of payments received by the company. Identification data.
Loyalty program: registration of sales representatives in a loyalty program. Identification data.
Service provider registration: for registration and payment management. Identification data; contact data.
Client salesperson awards: registration of client company salespersons for payment of awards for sales of Marluvas products. Identification data; contact data.
Fairs and events: capturing data of potential clients at events. Identification data; contact data.
Scheduling and delivery of goods: scheduling transportation and delivery of goods to clients. Identification data; contact data.
Return of goods: return of goods by clients. Identification data.
Quotations and purchases: for making quotes and purchasing materials. Identification data; contact data.
Landing page: for capturing potential clients. Identification data; contact data.
Email marketing: for sending to potential clients. Identification data; contact data.
Image bank: for use in marketing. Identification data; contact data; personal characteristic data.

Considering the categories of personal data used, below are the main personal data processing activities carried out by Marluvas. If you have any questions or would like to know more, please contact our DPO.

4. SHARING OF PERSONAL DATA AND INTERNATIONAL DATA TRANSFER

In the performance of our activities, we may share and/or co-use your data with some partner organizations. Furthermore, in certain situations, we also have the duty to transmit some information to public authorities, such as in cases of notifications, inspections, among others, as provided by law.

Some of our partners have servers located in other countries, which means that international transfer of your personal data may occur.

Below are some situations in which we may share and/or co-use your personal data:

Reason for sharing and/or co-use Is there international data transfer? If so, to which country?
We use third-party tools for administrative use in daily work activities, such as text editors, spreadsheets, and email. Yes. USA
We may use third-party messaging tools for communication with external individuals who maintain a relationship with Marluvas. Yes. USA
We use tools for marketing purposes. Yes. USA
We use a whistleblower channel through the services of an external company. No
We work with partner companies to support our technological infrastructure. Yes. USA

If you have any questions or would like to know more, please contact our DPO.

5. WHAT ARE YOUR RIGHTS AS A PERSONAL DATA SUBJECT?

In compliance with the personal data protection regulations in Brazil, Marluvas guarantees everyone the possibility of submitting requests based on the rights listed below:

• Confirmation of the existence of processing;
• Access to data;
• Correction of incomplete, inaccurate, or outdated data;
• Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• Data portability to another service or product provider;
• Deletion of personal data processed with the data subject's consent;
• Information about public and private entities with whom we share your data;
• Information about the possibility of not providing consent and the consequences of refusal;
• Withdrawal of consent;
• Objection to processing carried out based on one of the hypotheses of consent waiver, in case of non-compliance with the provisions of this Law.

These rights may be exercised directly by you or by someone representing you, upon presentation of a power of attorney. To request one of the rights listed above, simply send an email to our Data Protection Officer at the email address below:

Data Protection Officer: Genesis Marques Leôncio
Contact: dpo@marluvas.com.br

To prevent fraud, we may request identity confirmation before evaluating the granting of these rights.

6. HOW LONG WILL PERSONAL DATA BE STORED?

Your personal data will only be stored for the time necessary to fulfill the purposes for which it was collected, unless there is another reason for its maintenance, such as, for example, to comply with legal, regulatory, and contractual obligations.

Furthermore, to define the ideal retention period, we conduct a technical evaluation, taking into account legal aspects and your rights.

As an example:

• Contractual information will be stored in our database while our contract is active and, after the termination of the contractual relationship, may be retained for the prescription period of 10 years, in accordance with the Civil Code, art. 205.
• Credit analysis: 1 year from the consultation.
• Communication with suppliers/service providers via email: 10 years from the end of the contract for eventual regular exercise of rights in proceedings, in accordance with the Civil Code, art. 205.

If you have any questions or would like more details, please contact our DPO.

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

Marluvas uses appropriate technical and organizational measures to protect your personal data against improper or illegal processing, as well as to prevent accidental loss, destruction, or damage to information.

Personal data is stored on equipment protected with specialized software and redundancy, and is physically and logically accessible only to a limited number of employees. Only individuals with legitimate reasons will have access to your personal data.

8. HOW TO DISCUSS PERSONAL DATA WITH MARLUVAS?

If you believe that your personal data has been processed in a manner incompatible with this Notice or have questions about how we process your personal data, please contact our DPO:

Data Protection Officer: Genesis Marques Leôncio
Contact: dpo@marluvas.com.br

9. CHANGES TO THE PRIVACY NOTICE

Seeking to improve our services and the way we operate, this Privacy Notice may undergo updates to reflect the improvements made. Therefore, we recommend periodically visiting this page so that you are aware of the modifications implemented.

Date of last update: December 06, 2024.
Version: 01

December 06, 2024.