Privacy Policy

1. Objective
2. Personal Data: What is Collected, How it is Collected, and Purpose of Collection
3. Purpose of Use of Personal Data
4. Use of Cookies/Similar Technologies, Log Files and Web Beacons
5. Treatment of Personal Data
6. Data Sharing
7. Covid-19 - Item Applicable to Employees and Visitors
8. Rights of the Holder
9. Practices Everyone Should Follow
10. Changes to This Statement
11. Contact




1. Objective
Since privacy is important to everyone, Sabará Group is committed to respecting it in relation to any personal information we need to collect.
This privacy statement applies to all employees, suppliers, partners and customers, and aims to give the guidelines defined and applied by Sabará Group in the treatment of your personal information.
This policy has a broad scope and covers all collection and/or processing of personal information, through various channels such as websites, applications, social networks, sales and events, or processing of data provided by partners, customers and suppliers for the provision of services.
Our privacy policy is based on the ethics and values observed by Sabará Group and meets the General Law of Personal Data Protection (LGPD) - LAW No. 13,709, OF AUGUST 14, 2018 and the Brazilian Civil Rights Framework for the Internet - LAW No. 12,965, OF APRIL 23, 2014, which establishes principles, guarantees, rights and duties for the use of the Internet in Brazil.
By selecting the privacy statement checkbox, you consent to the information stated here.
For a better understanding of this privacy statement, we suggest you check the terms in the Glossary section.




2. Personal Data: What is Collected, How it is Collected, and Purpose of Collection
Depending on the type of Holder (employees, suppliers, partners and customers) and how this Holder interacts with Sabará Group, several categories of information are collected, as follows

  • • Personal contact information: Any information provided for the purpose of contact, such as name, postal address, e-mail address, business address, social networking details, and phone number
  • • Account login information: Any information that is required to give access to a specific account profile to access our services. Examples include e-mail address, username, password in unrecoverable format and/or security question and answer, among others to access services provided by us
  • • Technical information about your computer/mobile device: Any information about the computer system or other device you use to access one of our pages, services or applications, the IP address used to connect your computer or device to the Internet, the type of operating system and the type and version of your web browser, among other browsing information
  • • Financial and payment information: Information required to fulfill an order / contract / billing / collection / compensation / refunds. Sabará Group guarantees that its payment processing service ensures that financial and payment information complies with applicable laws, norms and security standards
  • • Sensitive Personal Data: Whenever it is necessary to collect and treat Sensitive Personal Data for any reason, express prior consent is required (for example, Covid-19 prevention, biometrics for facility access or clock in, etc.). If it is necessary to treat sensitive Personal Data for other purposes, these have a legal basis and Sabará Group will provide prior knowledge to the Holder
  • • Personal Data of Children and Adolescents: Whenever it is necessary to collect and treat Personal Data of children and minors, explicit consent will be requested from parents or guardians (for example: health plan and other benefits and or obligations, as well as the consent form for treating personal data that is signed by the minor’s guardian.



3. Purpose of Use of Personal Data
The table describes the purposes for which we collect Personal Data, and the different types of Personal Data we collect for each purpose. Please note that not all of the uses below will be relevant to all individuals.

What we use your Personal Data for

Purpose

Consumer/Customer Service. We use Personal Data to provide consumer/customer service, including responding to inquiries and fulfilling contracts. Requires the use of some personal contact information and information about the reason for the inquiry (for example: order status, technical problem, product or service issue or complaint, and inquiry)

  • • Fulfill contractual obligations and legal obligations;
  • • Improve and develop new products and services;
  • • Be more efficient

Recruitment, selection and admission. Handling of candidate recruitment and selection processes. For those not selected, their data remain in our talent pool for future selection processes. Upon admission, more Personal Data and some sensitive data can be collected (biometrics for access to facilities and time, data for health insurance, information about dependents for benefits).

  • • Perform the selection of candidates
  • • Perform the candidate admission
  • • Fulfill legal obligations

Customer relationship. We use Personal Data for sending information about the company and its products by e-mail marketing.

  • • Promotion of products and news.



4. Use of Cookies/Similar Technologies, Log Files and Web Beacons
4.1 Cookies (Navigation Trackers)
· How and why do we use Cookies? We use Cookies to improve the use and functionality of Sabará Group’s pages and services and to better understand how our visitors use them and the tools and services offered there. Cookies help us to customize Sabará Group’s pages and services to your personal needs, to make it easier for you to use them, to receive satisfaction feedback, and to communicate with you from other locations on the Internet.
· The types of Cookies that can be used in Sabará Group’s pages and services are detailed in this page click here.

 




5. Treatment of Personal Data
Sabará Group may process the Personal Data collected in order to:

  • • Carry out environmental and social responsibility projects and activities
  • • Perform fraud prevention processes
  • • Perform customer service and relationship activities
  • • Sell products and/or services
  • • Grant benefits
  • • Perform recruitment and admission processes and training, to fulfill our labor obligations with professionals/employees
  • • Perform contractual activities with customers and service providers including financial obligations, related to purchased products and/or services
  • • Meet legal and regulatory obligations
  • • Respond to requests from customers, former customers, leads/ prospects
  • • Improve the products and services offered
  • • Comply with the determinations of competent authorities
  • • Celebrate legal processes when required
  • • Notify about the status and possible changes in our products and services
  • • Perform internal operations (financial, accounting, labor, among others), problem solving, data analysis, data integration and consolidation
  • • Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, and violations of applicable policies, contracts, or terms of use
  • • Comply with legal or regulatory obligations, or as required in a judicial proceeding, by any law enforcement or government agency
  • • Perform relationship actions with clients and partners

Termination of Personal Data processing will occur: 

  • • When the purpose for which the personal data were collected is achieved or the Personal Data collected are no longer necessary
  • • When the Data Subject requests the deletion of his/her data in compliance with the legislation in force
  • • When there is a legal determination to this effect

The storage of data and information will be:

  • • For the time required by law and/or compliance with a legal or regulatory obligation
  • • Until the end of the processing of Personal Data, as mentioned above
  • • Complying with the guidelines of the Information Security Policy

Deletion of data and information, when necessary, will be:

  • • Made respecting the other existing legislations
  • • Made in such a way as to eliminate all existing evidence and copies
  • • Performed with established physical or electronic disposal procedures



6. Data Sharing
Sharing of data and information can occur for:

  • • The service providers, to act in the operation and celebration of the contracted services, which will be aware and will have the responsibilities and commitment on the privacy of Personal Data agreed in specific contractual clauses
  • • The banking units, exclusively for contractual or labor transactions are shared with labor and social security agencies (Internal Revenue Service, Social Security National Institute, Caixa Econômica) to comply with the labor legislation.
  • • The regulatory bodies, judicial or administrative authorities where we may share personal information in order to provide the competent authorities with any information they may request regarding the Holder for the investigation of suspected violations of law, or to combat any other suspected breach of our policies and contracts

For cases not foreseen above in which it is necessary to share Personal Data, the Holder of the Personal Data will be asked for express authorization (consent) by sending a notification with information about the sharing.




7. Covid-19 - Item Applicable to Employees and Visitors
As a result of Covid-19 contagion prevention and control measures, Sabará Group and/or the condominium may also collect personal information from its employees, service providers and visitors such as

  • • Status and health background regarding Covid-19
  • • Information about the workplace
  • • Body temperature

This data collection is intended to help reduce the risk of Covid-19 contamination in Sabará Group and condominium facilities.
Thermal measurement takes temperature anonymously and does not retain this information. If the temperature is 37.7 degrees Celsius (100 °F) or higher, you will be denied entry and/or asked to leave the facility.
As determined by the relevant government agencies, Sabará Group will comply with the proper guidelines following the determined legislation that includes the use/obligation of masks or other necessary protections/ controls. Its absence by any person involved prevents access to Sabará Group and to the condominium. * The temperature should be 37.5 °C (99.5 °F) or higher according to internal procedure for suspected and/or confirmed cases.




8. Rights of the Holder
The Holders of Personal Data have, under the law, the rights to:

  • • Confirmation of the existence of treatment of Personal Data
  • • Confirmation of which Holders’ Personal Data are in Sabará Group
  • • Request for the correction of incomplete, inaccurate or outdated data
  • • Deletion of data, when the data is processed on the basis of the data subject’s consent or when the data is unnecessary, excessive or processed in violation of the applicable law
  • • Request for information on possible shared use of data

For security reasons, the request to fulfill these rights may require additional data or information to confirm the identity and authenticity of the Holder.
The Holder can contact the company via e-mail: lgpd@gruposabara.com




9. Practices Everyone Should Follow
Everyone plays an important role in protecting their Personal Data. When creating an online account, a password make sure to set a password that is difficult to crack and never reveal the password to other people. Everyone is responsible for keeping the password confidential and non-transferable.
When using a shared or public computer, never choose the option to remember login ID, e-mail address, login or password, and always make sure you log out of your account. Use any privacy settings or controls that are provided on our site, services or applications.




10. Changes to This Statement
Whenever Sabará Group changes forms and objectives in the collection and processing of Personal Data, this statement will be updated.
Sabará Group reserves the right to make changes to practices and this Privacy Statement at any time.
It is requested that this statement be periodically accessed.




11. Contact
To ask questions about our privacy practices or to make a request, please contact us at: lgpd@gruposabara.com