Our Privacy Policy – LGPD

This Policy and its respective updates shall prevail over all policies, proposals, contracts, prior understandings, and agreements, oral or written, that may exist between the parties dealing, directly or indirectly, on the subject of privacy.

The solutions contained on the gavealog.com website (or simply “Platform”) are made available by Gavea Logística (Invented name), a private legal entity, registered with the CNPJ/MF under No. 12.064.608/0001-69, headquartered at Av Rio Branco, n° 01, room 1307 Centro – Rio de Janeiro | RJ CEP 20090 907.

A. Introduction

1. The privacy of our website visitors is very important to us, and we are committed to protecting it. This policy explains what we will do with your personal information.
2. Consenting to the use of cookies following the terms of this policy, when you first access our website allows us to use cookies every time you access our website.

B. Collection of personal information

The following types of personal information can be collected, stored, and used:

1. information about your computer, including your IP address, geographic location, browser type, and version, and operating system;
2. information about your visits to and use of this website, including the referral source, length of visit, page views, and navigation paths on the website;
3. information, such as your email address, that you enter when you register on our site;
4. information, such as your name and email address, that you enter to set up subscriptions to our emails and/or newsletters;
5. information you enter while using the services on our website;
6. the information generated when using our website, including when, how often, and under what circumstances you use it;
7. information contained in any communications you send us by email or through our website, including the content and metadata of the communication;
8. any other personal information you submit to us.

Before disclosing another person’s personal information to us, you must obtain that person’s consent to the disclosure and processing of that personal information in accordance with this policy.

C. Use of your personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

1. administer our website and our business;
2. customize our website for you;
3. customize our website for you;
4. send products purchased through our website;
5. provide services purchased through our website;
6. send statements, invoices, and payment reminders, as well as collect your payments;
7. send commercial marketing communications;
8. send email notifications specifically requested by you;
9. send our newsletter by email if you have requested it (you can let us know at any time if you no longer want to receive the newsletter);
10. send marketing communications relating to our business or the businesses of carefully-selected third parties that we believe may be of interest to you, by mail or, where you specifically agreed to do so, by email or similar technology (you can let us know at any time if you don’t more want more to receive marketing communications);
11. provide third parties with statistical information about our users (but such third parties will not be able to identify any individual users from this information);
12. handle questions and complaints made by or about you concerning our website;
13. keep our website secure and prevent fraud;
14. verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent via our website’s private messaging service);
15. other uses.

If you submit personal information for posting on our website, we will post and use that information following the license you have granted us.

Your privacy settings may be used to limit the publication of your information on our website and adjusted through the use of privacy controls on the website. Without your express consent, we will not provide your personal information to third parties for direct marketing purposes by them or third parties.

D. Disclosure of personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisors, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our holding company, and all of its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

1. to the extent that we are required to do so by law;
2. in relation to any ongoing or potential legal proceedings;
3. to establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and credit risk reduction);
4. to the buyer (or potential buyer) of any business or asset we are selling (or contemplating selling); and
5. to anyone we reasonably believe may request a court or other competent authority to disclose such personal information when, in our reasonable opinion, such court or authority is likely to order the disclosure of such personal information.

Except as set out in this policy, we will not provide your personal information to third parties.

E. International data transfers

1. The information we collect may be stored, processed, and transferred between any of the countries in which we operate to allow us to use the information following this policy.
2. The information we collect may be transferred to the following countries that do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China, and India.
3. Personal information that you post on our website or submit for posting on our website may be available, over the internet, throughout the world. We cannot prevent the use or misuse of such information by third parties.
4. You expressly consent to the transfers of personal information described in this Section E.

F. Retention of personal information

1. This Section F sets out our data retention policies and procedures, designed to help ensure compliance with our legal obligations regarding the retention and deletion of personal information.
2. Personal information that we process for any purpose or purposes must not be kept longer than necessary for that purpose or purposes.
3. Without prejudice to article F-2, we will generally delete personal data belonging to the categories defined below at the date/time defined below:
   
   1. type of personal data will be deleted;
   2. Notwithstanding the other provisions of this Section F, we will retain documents (including electronic documents) that contain personal data:
   3. to the extent that we are required to do so by law;
   4. if we believe the documents may be relevant to any ongoing or potential legal proceedings; and
   5. to establish, exercise, or defend our legal rights (including providing information to third parties for fraud prevention and credit risk reduction).

G. Security of your personal information

1. We will take appropriate technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
2. We will store all of the personal information you provide on our secure servers (protected by password and firewall).
3. All electronic financial transactions carried out through our website will be protected by encryption technology.
4. You acknowledge that the transmission of information over the internet is inherently insecure and that we cannot guarantee the security of data sent over the internet.
5. You are responsible for keeping the password used to access our website confidential; we will not ask for your password (except when you log in to our website).

H. Changes

We may update this policy from time to time by posting a new version on our website. You should check this page from time to time to ensure that you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

I. Your right

You can instruct us to provide any personal information we hold about you; the provision of this information will be subject to the following:

1. providing the proper evidence of your identity (for this purpose; we will generally accept a certified copy of your passport plus an original copy of a utility bill showing your current address).
2. We may retain requested personal information to the extent permitted by law.
3. You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will generally expressly agree in advance to the use of your personal information for marketing purposes, or we will offer you the opportunity to not allow the use of your personal information for marketing purposes.

J. Third party websites

Our website includes links to details of third-party websites. We have no control over and are not responsible for the privacy policies and practices of third parties.

K. Update of information

Please let us know if the personal information we hold about you needs to be corrected or updated.

L. Cookies

Our website uses cookies. A cookie is a file that contains an identifier (a string of letters and numbers) that is sent by a web server to a browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can be “persistent” cookies or “session” cookies: a persistent cookie will be stored by a browser and will remain valid until the defined expiration date unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user’s session when the browser is closed. Cookies normally do not contain any information that personally identifies a user, but the personal information we store about you may be linked to the information stored and obtained from cookies. We use session cookies / persistent cookies / persistent and session cookies on our website.

1. The names of the cookies we use on our website and the purposes for which they are used are described below:
   
   1. we use Google Tag Manager on our website to include recognizing a computer when a user accesses the website, tracking users as they browse the website, improving website usability, analyzing website usage, administering the website, preventing fraud and improving security of the site, customize the site for each user and target ads that may be of particular interest to specific users;
2. Most browsers allow you to refuse to accept cookies – for example:
   
   1. in Internet Explorer (version 10), you can block cookies using the available cookie handling cancellation settings by clicking on “Tools”, “Internet Options”, “Privacy” and “Advanced”;
   2. in Firefox (version 24), you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu and unchecking “Accept cookies from websites”; and
   3. in Chrome (version 29), you can block all cookies by going to the “Custom and Control” menu and clicking “Settings”, “Advanced” and “Site Settings” and then selecting “Block Third-Party Cookies” in the section “Cookies and website data”.

Blocking all cookies will negatively impact the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

1. You can delete cookies that are already stored on your computer – for example:
   
   1. in Internet Explorer (version 10), you must delete the cookie files manually (see http://support.microsoft.com/kb/278835 for instructions to do so);
   2. in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history”, clicking “Show Cookies” and then “Remove all cookies”; and
   3. in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history”, clicking “Show Cookies” and then “Remove all cookies”; and
      in Chrome (version 29), you can delete all cookies by going to the “Custom and Control” menu and clicking on “Settings”, “Advanced”, “Clear browsing data” and then selecting “Delete cookies and other data of websites and plugins” before clicking on “Clear browsing data”.
2. Deleting cookies will negatively impact the usability of many websites.

M. Data of people under 18 years

Treatment of personal data from minors: We do not collect or knowingly request personal data from minors under 18 years of age. If we become aware that we collect personal data from a person under the age of 18, we will cancel the account created and delete the personal data, only being able to keep personal data that are intended to prevent a new attempt to register.

N. Rights regarding your personal data

Rights and Guarantees: The User has rights and guarantees in relation to his/her personal data. We provide mechanisms, detailed below so that Users have clarity and transparency in the exercise of their rights. Whenever necessary, our team will be ready to evaluate any requests.

Rights Provided in the LGPD: Under the General Data Protection Law (Law 13.709/2018 -) (“LGPD”), you have the right to:

1. confirm that we carry out the processing of your personal data;
2. access your personal data;
3. require the correction of personal data that is incomplete, inaccurate, or out of date;
4. request the anonymization, blocking, or deletion of unnecessary, excessive, or processed personal data in violation of the provisions of the LGPD;
5. require the portability of your personal data to another service or product provider, subject to our commercial and industrial secrets, after regulation by the National Data Protection Authority;
6. request the deletion of personal data processed based on your consent, except in the cases of conservation of personal data provided for in the LGPD;
7. request information about whom we share your personal data with;
8. request information about the possibility of not providing your consent and the consequences;
9. revoke your consent to the processing of your personal data, when processing is carried out based on your consent;
10. express opposition to treatment that violates the LGPD.

Additional Information: Before we respond to a request to exercise the above rights, we may ask you to provide us with certain information to confirm your identity.

O. SPAM practice

Positioning: We are against any practices that promote SPAM of any kind and we are committed to ensuring that messages sent by the Platform are always of interest or importance to the respective recipients. In addition, at any time, you can choose to stop receiving emails by adjusting your preferences for receiving emails or canceling your account.

Particular guidelines: Likewise, we charge our Users who do not practice SPAM, to make sure that the messages sent are always in the interest of the recipient, being aware that failure to comply with good Internet usage practices may lead to cancellation of the infringing User’s account, as defined in the Terms of Use, as well as the disclosure of personal Registration data, according to this Privacy Policy.

P. Information and questions

14.1. Questions about the Policy or Your Personal Data: If after reading this Policy you have any questions or want to submit any request regarding your data, you can contact our privacy team or our Supervisor through these contacts: [email protected] or +55 21 99669 6184.