Privacy Policy

CMV Construções Mecânicas Ltda and the LGPD

On this page you will find:

External Privacy and Data Protection Policy of CMV Construções Mecânicas Ltda
Policy for Responding to Data Subject Requests of CMV Construções Mecânicas Ltda
Public Notice on LGPD Compliance

External Privacy and Data Protection Policy of CMV Construções Mecânicas Ltda

The mission of CMV CONSTRUÇÕES MECÂNICAS LTDA. is to provide industrial solutions that meet customers' needs, with excellence in customer service.

As part of our ongoing efforts to improve, and within the framework of Brazil's General Personal Data Protection Law (LGPD - Law No. 13,709/2020), we have created this External Privacy and Data Protection Policy (“Policy”) to explain how we process the personal data of our employees, customers and suppliers, thereby establishing a relationship of trust, security and transparency with everyone.

Brazil's General Personal Data Protection Law (LGPD) came into force in August 2020 and established legal parameters for everyone handling personal data to carry out their activities without infringing individuals' privacy and data protection.

If you would like to understand our practices regarding how we handle and process your personal information, please read the information below.

1. What information do we collect

CMV CONSTRUÇÕES MECÂNICAS LTDA. may collect, record and use users' personal information in connection with other websites and partners, including, but not limited to, the company name, the name of the person responsible for access, the user company's Brazilian corporate registration number (CNPJ), address, telephone number, interests, activities, length of time the company has been established, and other information.

We limit processing to the minimum data necessary to meet your needs in accordance with the purposes of our contractual relationship.

CMV CONSTRUÇÕES MECÂNICAS LTDA. reserves the right to record your IP address, browser type, device and mobile network operator, geographic location and other user-related data, where necessary.

The information collected and held in our systems includes information that users voluntarily provide through contracts and registration details (personal data, financial data, account data and access data), the issuance of invoices, and information obtained automatically.

The information that customers, suppliers and employees voluntarily provide comprises personal data, financial data, account data and access data entered during the registration process required to establish contractual relationships with us.

Refusing to provide this information will have no consequences other than preventing the user from benefiting from the use of the services.

Regarding the collection and use of your data by the social media platforms on which we maintain profiles, we are aware of their privacy policies, which are public, but we have no influence over how they process the data they collect.

Regardless of the source of the data, processing will be governed by this Privacy Policy.

2. What do we do with the information collected

CMV CONSTRUÇÕES MECÂNICAS LTDA. does not disclose your information publicly or to third parties in a way that could identify you. We always seek to maintain your privacy while you use the service and may use the information provided to conduct analyses and studies, improve the system, or comply with a court order.

The information we process will NOT be disclosed, sold, rented or exchanged with any organization or entity without first notifying the user and obtaining their express consent, except for information required by law or court order.

In certain situations, to provide our services to a high standard, CMV CONSTRUÇÕES MECÂNICAS LTDA. may share some of your personal data with other companies that are our partners or consortium partners and assist us in our activities, such as jointly performed work, software we contract to deliver our services, suppliers or business partners.

These partners will be classified as data processors, as defined by the LGPD, and are required to respect the privacy of your data.

3. What is the purpose of processing your personal data

We process your personal data to provide, promote, improve and develop our services, in accordance with the services you engage us to provide, or to comply with legal or regulatory obligations.

We may also process personal data when necessary to protect our services, detect, prevent and resolve fraud, including handling security incidents, privacy incidents or any other unlawful activity, as well as preventing such activities.

4. Sharing personal data

As previously stated, your personal data may be shared with our partners and suppliers to the extent necessary to ensure the provision of our services, comply with legal and/or regulatory obligations, or fulfill any of the purposes described in this Policy.

These include software providers, cloud hosting services, service providers and other information technology providers for managing your relationship with our company, registration, documentation and related arrangements.

Data may also be shared with correspondents, experts, professional advisers, partner firms in Brazil and abroad, auditors, accountants, translators and financial institutions to assist in providing the contracted services, depending on the needs of the customer, employee or supplier.

We emphasize that sharing will take place through the adoption of appropriate technical and organizational measures aimed at maintaining the confidentiality and integrity of the information.

5. International transfers of personal data

CMV CONSTRUÇÕES MECÂNICAS LTDA. may share your data with partners and suppliers based in other countries, always in compliance with applicable law and in accordance with contractual clauses.

6. Security in the processing of your personal data

CMV CONSTRUÇÕES MECÂNICAS LTDA. uses reasonable industry-standard and legally required measures to preserve the privacy of the data collected and thereby prevent incidents that could put your privacy at risk.

We store the information collected with cloud service providers contracted by us that use their best efforts to preserve the privacy of their customers' data.

We emphasize that, in the event of security incidents that may pose a significant risk or cause significant harm to you or any of our users, we will notify those affected and Brazil's National Data Protection Authority (ANPD) and take the necessary measures.

7. Collection and use of cookies

A cookie is a small text file stored by your browser when you visit a website. Almost all websites use cookie technology. Cookies may store certain information, such as your IP address, information about the content you view, information about the content you provide so that you do not have to enter it again each time you visit our website, and your preferences and settings.

Cookies also help us provide personalized content, make browsing our website faster, and learn more about your visit and use of online services.

Our website uses the following types of cookies:

User storage cookies - Google Analytics;
Security cookies to protect user data against unauthorized access;
Cookies to store access information and personalize advertisements.

7.1. Disabling cookies

You may remove or reject cookies through your browser settings. We recommend following your browser's instructions, which can usually be found in its Settings, Help or Tools sections. Most browsers automatically accept cookies until you change their settings.

If you do not accept our cookies, your experience on our website will be less convenient. For example, we may not recognize your computer or mobile device, and you may need to log in each time you access our page.

8. Retention period

The personal data of our customers, employees and suppliers will be stored for the necessary period and in accordance with the purposes for which it was collected. This data will be retained throughout the relationship with the data subject (customer, employee or supplier) and for the period required to comply with legal, contractual or regulatory obligations.

We undertake to store this data using all necessary and reasonable measures to prevent alteration, loss and unauthorized access, in accordance with applicable law and best practices.

Applications for internships or employment from candidates who are not selected are kept in our database for up to six months from receipt.

9. Privacy by design

CMV CONSTRUÇÕES MECÂNICAS LTDA. reiterates its responsible commitment to processing personal data. Accordingly, in compliance with the LGPD, it adopts privacy by design when designing any information technology system or as a starting point for developing its business projects.

We therefore seek to implement privacy by design principles through proactive accountability in the development of our services.

10. How to contact us

If you have questions or comments regarding this Privacy and Data Protection Policy, please contact us.

Our Data Protection Officer (DPO) is LUCIANA VIEIRA, and her email address is dpo@cmv.com.br.

11. Exercising your rights regarding your personal data

In accordance with applicable law, data subjects may change, update or rectify their personal data, or exercise any other rights available to them, through the communication channel mentioned above: dpo@cmv.com.br.

If your personal data is processed on the basis of your consent, you may withdraw that consent at any time. However, withdrawal of consent (a) will not affect the lawfulness of processing previously carried out, nor will it affect processing performed on the basis of our contractual relationship; and (b) may make it impossible to continue providing the services, in which case you will be asked to cancel the Services as a prerequisite.

We will make all reasonable efforts to fulfill data subject requests as quickly as possible. However, justified circumstances may delay or prevent a prompt response. If there is a delay, we will explain the reasons to you.

Finally, everyone should be aware that certain requests may lawfully be rejected for formal reasons (such as an inability to prove your identity) or legal reasons (such as a request to delete data that our company is entitled to retain). If we are unable to fulfill such requests, we will also provide reasonable explanations.

12. Updates

This Policy may be revised at any time and without prior notice, taking into account applicable law and organizational changes that may occur at any time, in order to maintain its relevance and effectiveness.

This Policy does not replace, modify or extend any other policy that may also govern your relationship with our company.

This Policy was prepared in February 2023, and to date we have not considered any update necessary. If changes are made, they will be recorded here. Accordingly, this is version No. 1.

Policy for Responding to Data Subject Requests of CMV Construções Mecânicas Ltda

1.Purpose

This policy establishes how CMV CONSTRUÇÕES MECÂNICAS LTDA. will respond to requests from personal data subjects exercising their rights.

Brazil's General Personal Data Protection Law (Law No. 13,709/2018 - LGPD), which governs the processing of personal data in physical or digital form by public or private entities, ensures that personal data subjects have the right to submit requests concerning the processing of their data to those who hold it.

In other words, data subjects have the right, through an express request submitted by themselves or a duly appointed legal representative, free of charge and within the time limits and conditions prescribed by regulation, to request a conclusive response from the controller or the entity responsible for processing regarding the following:

a. Access to data held by the controller;
b. Correction of incomplete, inaccurate or outdated data (Article 18, III);
c. Anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the LGPD (Article 18, IV);
d. Deletion of personal data processed with the data subject's consent, except in the circumstances provided for in Article 16 of the LGPD (Article 18, VI);
e. Withdrawal of consent; and
f. Other requests not listed above.

As CMV CONSTRUÇÕES MECÂNICAS LTDA. processes personal data in connection with its activities and its relationships with customers, employees, suppliers and the community, it acts as a controller or as an entity responsible for processing personal data. In that capacity, it has established this Policy to address the requests that the law guarantees to data subjects.

For CMV CONSTRUÇÕES MECÂNICAS LTDA. to fulfill a request, the data subject must clearly state what they are requesting.

CMV CONSTRUÇÕES MECÂNICAS LTDA. must provide a response as soon as possible, including in a simplified format, through a clear and complete statement delivered within the statutory time limit and indicating the source of the data, the absence of any record, the criteria used and the purpose of processing, while respecting trade and industrial secrets.

Data subjects may choose to receive the response through secure and appropriate electronic means or in printed form. The contact methods are explained in the next section.

If it is not possible to fulfill a data subject's request immediately, CMV CONSTRUÇÕES MECÂNICAS LTDA. may state that it is not a processing agent for the data and, whenever possible, identify the relevant agent; or explain the factual or legal reasons preventing the immediate adoption of the requested measure.

2.Contact methods

CMV CONSTRUÇÕES MECÂNICAS LTDA. provides a direct contact email address: dpo@cmv.com.br.

In addition to email, applicants who wish to submit their request in physical form may send it by post with acknowledgment of receipt (AR - Aviso de Recebimento) to the following address:

CMV CONSTRUÇÕES MECÂNICAS LTDA.
Av. das Indústrias, No. 940
Distrito Industrial
Cachoeirinha, Rio Grande do Sul, Brazil
Postal code: 94930-230

CMV CONSTRUÇÕES MECÂNICAS LTDA. will make every effort to respond as quickly as possible, observing the time limits indicated for each type of request.

3.Scope of this Policy

This Policy covers all individuals protected by Brazil's General Personal Data Protection Law (LGPD), whether or not their data is processed by CMV CONSTRUÇÕES MECÂNICAS LTDA.

In other words, this Policy applies both when CMV CONSTRUÇÕES MECÂNICAS LTDA. acts as a personal data controller and when it does not. If it is not the controller, it will inform the applicant accordingly as part of its response, enabling the applicant to direct their request to another controller they consider appropriate.

4.Calculation of time limits

For the purpose of calculating any time limit expressed in days in this Policy, only business days observed in the city of Cachoeirinha, Rio Grande do Sul, will be counted, excluding the starting day and including the due date.

5.Records of requests

Every request you submit to CMV CONSTRUÇÕES MECÂNICAS LTDA. will be recorded in our files, together with details of what was or was not fulfilled. This request record will be stored for five years after the request has been addressed.

If we do not process your personal data, the request record will contain only the date and time of the request and the response.

6. Authentication of the applicant

In some cases, CMV CONSTRUÇÕES MECÂNICAS LTDA. may request proof that the applicant is the data subject or their authorized representative. This is intended to prevent one individual's personal data from being sent to another, either accidentally or as a result of fraud.

7. Types of requests and response time limits

Any of the requests mentioned above will be addressed within 15 (fifteen) days of receipt.

8. Updates

This Policy does not replace, modify or extend any other policy that may also govern your relationship with our company.

This Policy was prepared in February 2023, and to date we have not considered any update necessary. If changes are made, they will be recorded here.

Accordingly, this is version No. 1.

9. Jurisdiction for disputes concerning personal data protection

Any disputes concerning this POLICY FOR RESPONDING TO DATA SUBJECT REQUESTS OF CMV CONSTRUÇÕES MECÂNICAS LTDA. must be brought before the courts of the judicial district of the city of Cachoeirinha, State of Rio Grande do Sul, with waiver of any other jurisdiction, however privileged it may be or become.

Public Notice on LGPD Compliance

CMV CONSTRUÇÕES MECÂNICAS LTDA. announces that it is implementing a project to comply with Brazil's General Personal Data Protection Law (Law No. 13,709/2018 - LGPD).

This law governs the processing of personal data in physical or digital form by public or private entities.

As we process individuals' personal data, we are making the adjustments required by law to our documents, contracts, consent forms and notices. We are also improving our security systems and receiving training to align our personal data processing culture with the law.

We expect to complete the compliance schedule within six months and are receiving guidance from AGORA LGPD Cursos e Treinamentos Ltda.

CMV CONSTRUÇÕES MECÂNICAS LTDA. affirms its commitment to protecting personal data in a manner that safeguards the fundamental rights to freedom and privacy and the free development of the personality of natural persons, contributing to the improvement of our society.