Privacy Policy

LATICÍNIO TIROLEZ (“TIROLEZ”), recognizing the importance of the security and protection of personal data, as well as the privacy of its customers’ information, adopts 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 relating to a natural person, whenever there is a possibility of YOU being identified, directly or indirectly.

By accepting the terms of this Privacy Policy, you consent to TIROLEZ processing your personal data, whether sensitive or not, in the ways described below.

So, in summary, let’s see.

Personal Data:
All personal information that allows your identification, such as your name, CPF (Brazilian tax identification number), email, phone number, among others.

Sensitive Personal Data:
Personal data relating to racial or ethnic origin, religious beliefs, political opinions, membership in a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to YOU.

Processing of personal data:
Any operation performed with personal data, such as: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;

Therefore, Personal Data of Legal Entities is not, in principle, considered Personal Data.

By accepting the terms of this Privacy Policy, you consent to TIROLEZ processing your personal data, whether sensitive or not, in the ways described below.

PREMISE AND CONDITION FOR SENDING YOUR PERSONAL DATA TO TIROLEZ

By accessing and/or using the website, YOU:

– declare that you are 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 meet 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 PERSONAL DATA SUBJECTS

When YOU are the data subject, that is, the natural person to whom the personal data being processed refers, you will be guaranteed rights provided for by law, as set out below.

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

a) Confirmation of the existence of treatment:
Request confirmation that TIROLEZ processes personal data.

b) Access to personal data
If you wish, you can request a list of the personal data that TIROLEZ holds in its files.

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

d) Anonymization, blocking or deletion of data
If you wish, YOU have the right to request the anonymization (a process that makes data impossible to link to an individual), blocking or deletion of data when you believe that it is “unnecessary, excessive or processed in violation” of the LGPD (Brazilian General Data Protection Law)
Important: there are situations in which this right cannot be exercised, such as when TIROLEZ needs to retain the data to comply with a legal or regulatory obligation.

e) Data portability
The data subject may request data portability, that is, 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 ANPD (National Data Protection Authority), which is not yet operational.
Furthermore, portability does not include data that has already been anonymized by the controller – anonymized data, incidentally, falls outside the scope of the LGPD (Brazilian General Data Protection Law).

f) Deletion of data processed with consent
If YOU consented to the processing, but changed your mind and no longer want the company to process your personal data, YOU can request the deletion of this data.
Important: There are situations in which this right cannot be exercised, such as when TIROLEZ needs to retain the data to comply with a legal or regulatory obligation.

g) Information on data sharing
YOU can request information from TIROLEZ to inform you with whom it is sharing your personal data, both with private and public entities, which will be expressly named.

h) Information about the possibility of not providing consent
YOU have the right to be informed about the possibility of not providing consent and what the consequences are 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 not consenting would harm the browsing experience or prevent access to certain tools, the user must be informed of this.

i) Revocation of consent
YOU may, at any time, request the revocation of the consent previously granted for TIROLEZ to process your personal data.
Important: In this case, a specific request will be necessary, given that there are situations in which TIROLEZ needs to retain the data to comply with legal or regulatory obligations.

j) Other rights
In addition to the 9 main rights of data subjects provided for in its article 18, the LGPD mentions others, such as:
The right of the data subject to file a complaint against the controller with the ANPD (National Data Protection Authority) and consumer protection agencies.
The right to object to treatment carried out without consent, if it is not in accordance with the law.

It is important to emphasize, however, that no right is absolute and that there are situations in which companies may not be able to meet the holder’s requests, and should indicate the reasons – such as, for example, compliance with legal or regulatory obligations.

  1. PROCESSING OF PERSONAL DATA

As already mentioned in this Policy and stipulated in the legislation, the processing of personal data is any operation performed with personal data, such as: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;

TIROLEZ’s policy is not to collect sensitive data, except in extraordinary cases that will be handled considering the relevant legal bases in current legislation.

TIROLEZ, in order to achieve the purposes described in this policy, 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 we have collected sensitive information, or information from a child or adolescent, by mistake or unintentionally.

2.1 LEGAL BASES FOR PROCESSING PERSONAL DATA

  • TIROLEZ will only process your personal data when YOU provide it to us or when it is obtained automatically and indirectly, as described throughout this Policy.
  • Regardless of how your data is obtained, TIROLEZ will process the data considering the following legal bases:
  • i. Consent: when you give us your consent;
  • ii. Contract: when processing is necessary to enter into, or perform, a contract with you;
  • iii. Fulfillment of a legal or regulatory obligation;
  • iv. Exercising our rights;
  • v. Protection of life or physical safety (yours or that of a third party);
  • vi. Legitimate interests: to guarantee the quality of our products, to improve them, to carry out internal analyses, as well as to support, perform and promote our activities (ensuring the prevalence of the fundamental rights and freedoms of the data subject).

If YOU wish, your consent may be revoked, in whole or in part, at any time, by means of a formal request.

Revoking your consent will not affect the legality of processing your personal data prior to the requested revocation, nor the legality of continuing to process your personal data based on another legal basis.

2.2 SENSITIVE PERSONAL DATA

  • Sensitive data includes data relating to racial or ethnic origin, religious beliefs, political opinions, membership in a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data.
  • By accepting this policy, YOU agree not to voluntarily send us sensitive data and, if you do so, considering your knowledge and acceptance of this document, the sending of the information itself will constitute “Consent” to process it for the purpose of the contact originally established.

2.3 Personal Data of Children and Adolescents

  • Whenever TIROLEZ becomes aware that a child’s personal data has been collected, we will make reasonable efforts to ensure that there is consent from at least one parent or guardian for the processing. Please contact us if you believe we have collected information from a child or adolescent by mistake or unintentionally.
  • In general, to achieve the purposes described in this Policy, we do not need to process personal data of children (under 12 years of age) and/or adolescents (persons between 12 and 18 years of age).
  1. 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.

  • Data Sources Collected Automatically and Indirectly:
  • vii. Simple navigation on the website and applications, intended for customers, consumers, partners and others interested 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 that YOU use on the device, when YOU visit a website)
  • To learn more about cookies, please consult Tirolez’s Cookie Policy: LINK
  • viii. Interactions on the pages we maintain on social media;
  • ix. Advertisements: Interactions with our advertisements (e.g., if there is interaction with advertisements, even on a third-party website, TIROLEZ may receive information about that interaction).
  • To learn more, read the “Third-Party Sites” chapter of this policy.
  • Source of Data Collected Directly:
  • x. Completion of the electronic form on the Website in the “Contact” section (“Contact Us”, “Become a Customer”, “Careers” and “Export”);
  • xi. For questions, complaints, suggestions, compliments, commercial inquiries, or other inquiries regarding Tirolez Customer Service, please use the form on the website, send an email (WhatsApp), call, or email.
  • xii. Text messages, electronic mail (E-mail) and other electronic messages;
  • xiii With your consent, we use your data (name, email, phone number, date of birth, marital status, whether you have children, product preferences) to personalize communication, segment campaigns, perform marketing automation, analyze your behavior, and improve our products and services.
  • xiv Relationship Actions: For sending press kits, information about product launches, and other marketing initiatives.
  • xvi Market Analysis and Distribution: We share data such as your location (address) and products of interest with our network of distributors to identify regional demand and indicate the nearest distributor to serve you.

3.1 WHAT DATA IS PROCESSED

During your experience on our website, we may collect different types of personal data provided directly by you or automatically for verification, monitoring, and control purposes. See below what personal data we may collect and in each situation:

Registration data:

  • Full name;
  • CPF number;
  • Email address:
  • Mobile phone number;
  • Date of birth;
  • Full address.

Financial and product delivery information:

  • Collection and delivery address;

Transactional data:

  • Registration data;
  • Product type;
  • Quantity;
  • Value of the merchandise (per unit);
  • Total value of the purchase or transaction;
  • Nature of the financial transaction;
  • Bank account information and other means used;

Browsing data:

  • IP address;
  • Information about the device used for browsing;
  • Products and categories searched or viewed;
  • View count;
  • Pages visited on other websites;
  • Cookies, web beacons, or similar tracking technologies.

Usage data:

  • Geolocation;

Interaction data:

  • If you used any contact channel to speak with us, the data and recording of the call or contact may be stored;
  • If you have interacted with our brands on social media, we may collect personal data that you provide directly or that is generated from the contact made.

Other information that may be collected:

  • Information about you that you have made public or that is publicly available;
  • Information we collect from third parties, such as additional information about your registration data (name, parentage, date of birth, CPF [Brazilian tax identification number], telephone number, address, among others), scores generated by credit agencies, whether you are part of any list of Politically Exposed Persons (PEPs) or any alert list (such as OFAC, CSNU and other international lists), among others;
  • Copies of documents you have submitted, such as proof of address, bank details, a copy of an identity document, or a selfie, are generally used to verify your registration or validate your identity.
  • Important: Information collected and shared by third parties acting as Data Controllers is not subject to this Privacy Policy and is not the responsibility of TIROLEZ.
  1. THIRD-PARTY WEBSITE

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

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

Furthermore, TIROLEZ’s social media pages are also subject to the privacy policies of the respective networks, in addition to this Policy.

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

  1. TRANSFER OF DATA TO THIRD PARTIES

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

In addition to the aforementioned 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 guarantee a level of data protection compatible with that provided for in this Policy and with applicable legislation.

  1. PERSONAL DATA PROCESSING AND STORAGE TIME:

TIROLEZ may retain your personal data to comply with legal or regulatory obligations, to protect our rights, if it is in our legitimate interest (provided that it is permitted by applicable law), or if the personal data is stored in our backup and support systems to ensure its security.

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

  • i. For the period sufficient to fulfill the purposes for which they were collected;
  • ii. For a period specified by applicable legislation;
  • iii. Until YOU request the revocation of your consent given to us for the processing/storage of your personal data, as applicable.
  1. Changes to our policy

Personal data protection measures keep pace with technological advancements, which is why our Personal Data Privacy Policy will be adapted to reflect 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 would like to emphasize that YOU may contact us at any time to request the most up-to-date 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.

  1. CONTACT

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