PRIVACY POLICY

At SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES, “Company” or simply “we”), we believe that together we are bigger, stronger and wiser to be pioneers in the new world of communication. Therefore, we always seek to conduct our business respecting the rights and legitimate expectations of all people who participate and share our mission, guaranteeing the Privacy Policy and the Protection of Personal Data.

In the information age, valuing the protection of Personal Data and Privacy Policy is essential. It is not an easy task, but remember: together we can break today to transform tomorrow.

To ensure this transparency, we provide this Privacy, Personal Data Protection and Cookies Policy (“Policy”), which describes how we process your Personal Data.

The word “you” is used in this Privacy Policy as a reference to any natural person whose Personal Data is processed by SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES, for example, customers, prospects, users of our website, candidates in selection processes, among others.

We ask that you read this Privacy Policy carefully and, if you have any questions or requests regarding your Personal Data, you may contact us directly through the channels provided herein.

1. DEFINITIONS

1.1. Before informing you how we process your Personal Data, we have defined some terms used in this Policy below so that, in case of doubt, you can consult their meaning:

a) “LGPD”: Law No. 13,709/2018 – General Data Protection Law, as well as the rules and guidelines of the ANPD;
b) “Personal Data”, “Personal Data” or “Data”: all information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified, directly or indirectly, mainly, but not limited to, by reference to a unique identifier such as a name, identification document number, location data, electronic identifier or one or more specific physical, psychological, genetic, mental, economic, ideological, cultural or social identity;
c) “Processing”: any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information. , modification, communication, transfer, dissemination or extraction;
d) “Holder” or “Holders”: natural person to whom the Personal Data that are subject to Processing refer.
e) “ANPD”: National Data Protection Authority, special authority in charge of ensuring, implementing and monitoring compliance with the LGPD throughout the national territory;
2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSE?

2.1. USE OF THE SITE

During your experience on our website (splack.com.br/), we may collect information that characterizes Personal Data. This may occur, for example, when you voluntarily fill out a form or contact us through the available channels, such as:

a) Contact us: When you click on the “Contact” item on our website, we will ask you to fill out a form with the following Personal Data: name, email and phone number. This Data is necessary so that we can identify who sent us the message in order to address the matter as efficiently as possible.
b) Email: You can also contact us for various matters via email at splack@splack.com.br. Initially, we will only have access to the email address through which you contacted us, but, depending on the subject, we will need other Personal Data in order to serve you. In SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES email contacts for prospecting purposes, you will have the option to unsubscribe from our mailing lists whenever you deem it necessary.
c) Telephone: We provide a telephone number on our website. If you contact us, we will only have access to the phone number you use, but we will need other Personal Data, such as your name, the company you work for, among others that are necessary for us to assist you.
d) Social networks: if you choose to access us or we access you through social networks, initially, we will only have access to the public information available in your profile, but, depending on the subject, we will need other Personal Data, always within your legitimate needs and expectations.

2.1.2. COOKIES

We collect information (some of which may constitute Personal Data) automatically through “Cookies”, which are small pieces of text or code whose main purposes are to control traffic, identify users and their usage sessions, as well as monitor and record their activities carried out on the website.

These technologies help you connect to services, remember settings and preferences, and keep information secure. Below we discuss the types of Cookies used on our website and the third parties involved.

2.1.2.1. NECESSARY COOKIES

“Necessary Cookies” are those that are essential for the operation of the services and resources. Below are some examples of Necessary Cookies used on our website and their purpose:

2.1.2.2. PERFORMANCE COOKIES

A Tracking Cookie is designed to collect information about website navigation, such as: environments accessed, time spent, error detection, among others. Below are some examples of performance cookies used on our website and their purpose:

Tag Name Cookie Name Expiration Source
Adopt AdoptGD17012629 56165 1 second

Used to verify domain and subdomain consent.
Adopt VisitorId 60 days

Third-party cookie responsible for storing the visitor’s consent.
AdOpt AdoptVisitorId 60 days

AdOpt’s own cookie (first-party) responsible for storing the anonymous visitor identifier and the value used to ensure the operation of the AdOpt Tag in browsers that do not support third-party cookies.
AdOpt AdoptConsent 60 days

Third-party cookie responsible for storing the visitor’s consent.
TIKO VOLPE.com.br pys_session_limit 1 hour

TIKO VOLPE.com.br pys_start_session session

Google CONSENT 1 second

Google cookie consent tracker.

2.1.2.3. ADVERTISING COOKIES

Advertising cookies are those that target advertisements based on your interests. Below are some examples of Advertising Cookies used on our website and their purpose:

Tag Name Cookie Name Expiration Source
Google Analytics _ga_SRD1X8HWN6 730 days

ID used to identify users.
Google Analytics _ga 730 days

Records and counts visits to the Google website.
Google Analytics _gat_UA- 33273850-1 1 second

Cookie used by Google to track certain actions of website visitors on a specific page.

2.1.2.4. LIST OF THIRD PARTIES (COOKIES)

Tag Name Cookie Name Expiry Source
Youtube YSC Session

YouTube cookie to detect the user’s screen size.
Google Ads VISITOR_INFO1_LI VE 180 days

Google cookie to validate user information.
Facebook _fbp 7 days

Cookie used by Facebook to deliver advertising product stories, such as real-time bidding from third-party advertisers.

2.1.2.5. THIRD PARTY DOMAINS

SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES has no influence on the security of information and the Processing of Personal Data carried out by third parties on other websites, including through links on our website.

2.1.2.6. COOKIE MANAGEMENT

Although most browsers and devices accept cookies and other collection technologies by default, their settings generally allow the user to delete or reject cookies. If Necessary Cookies are disabled, some of the features of our Services may not be available or may not function properly.

2.1.2.7. APPLICATIONS

To access the full list of Cookies used and/or more detailed information about the processing of your personal data through this tool, you can contact us by email at splack@splack.com.br.

WHAT LEGAL BASIS DO WE BASE OUR PROCESSING OF YOUR PERSONAL DATA ON?

3.2. USE OF THE SITE

3.2.1. For the Processing of Personal Data processed in connection with access to our website, we rely on the assumption contained in Article 7, IX, of the LGPD, namely, to satisfy the legitimate interests of the controller (us), so that we can carry out our activities as closely as possible to our customers and other third parties.

3.3. PARTICIPATION IN THE SELECTION PROCESS

3.3.1. For the Processing of your Personal Data for recruitment and selection purposes, we rely on the hypothesis contained in article 7, IX, of the LGPD, that is, on our Legitimate Interest in finding a person compatible with the vacant position. As the process progresses, we may also rely on art. 7, V, of the LGPD, considering that the analysis of the Data present in the CV and other documents is a prior procedure related to the employment contract of which you, as a candidate, are interested in being a part.

3.4. PROJECTS, PARTNERSHIPS AND SERVICE PROVISION

3.4.1. For the development of projects, the celebration of alliances and/or the provision of our specialized services, we base the Data Processing on art. 7º, V, of the LGPD, that is, for the execution of the contracts signed by SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES.

3.5. CAMPAIGNS

3.5.1. For the processing of data for the purposes of carrying out campaigns, we rely on art. 7, IX, of the LGPD, that is, on our legitimate interest in promoting our activities, respecting your rights and legitimate expectations.

HOW LONG WILL PERSONAL DATA BE STORED?

4.1. Your Personal Data will be stored for as long as necessary for us to achieve the purposes set out for the Processing. For example: for business relationships, provision of services and similar, we will retain your Data for as long as necessary to execute the contract or comply with the legal obligations arising from it.

4.2.1. If it is necessary to retain your Data after the Processing has been completed, SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES will do so in accordance with the provisions of art. 16 of the LGPD.

4.3. HOW DO WE STORE YOUR INFORMATION?

4.3.1. Personal Data collected by SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES may be stored on servers located outside Brazil. We use Google and other cloud service providers that comply with applicable data protection legislation, including with regard to arts. 33 to 36 of the LGPD (International Data Transfer). In this case, the Privacy Policy of the service provider applies.

WHEN DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES AND WHY?

5.2. The sharing of Personal Data will only occur in the circumstances defined below.

a) Employees and service providers: Our employees and service providers may access your Data only to the extent strictly necessary to fulfil a stated purpose. For example: to enable internal and external communication or to send you material during a campaign.
b) Business partners: We may share your Data with partners we assist for project development, communication and/or prospecting purposes, and will only use it for purposes within their legitimate expectations.
c) Legal obligations/judicial or extrajudicial proceedings: We may share your Data to comply with a legal obligation or to regularly exercise rights in judicial or extrajudicial proceedings.

5.3. In operations involving Data Processing, SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES formally establishes with the third parties involved, whether they are Controllers or Operators, the obligation to process their Data to the strictest extent necessary for the established purposes, in addition to the adoption of technical and administrative measures capable of protecting them.

TERMINATION OF TREATMENT

6.1. Personal Data will be processed by SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES for the time necessary to achieve the purpose proposed and reported to the Data Subjects, as well as during the retention periods required by applicable legislation (when retention exists).

6.2. If the Data is processed with your consent, you may, by means of an express declaration that you must send through the communication channel established in point 8 of this Privacy Policy, revoke the consent given, which will entail the interruption of the Processing. This measure will be taken within 15 (fifteen) days following receipt of the request by SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES in this regard.

WHAT ARE YOUR RIGHTS AS THE OWNER OF PERSONAL DATA?

7.1. Through the communication channel established in point 8 below, you may make requests regarding:

a) confirmation of the existence of Personal Data Processing;
b) access to information related to the Personal Data we have;
c) correction of incomplete, inaccurate or outdated Data;
d) anonymization, blocking or elimination of unnecessary or excessive Data;
e) Data portability, within the legal limits and prior pronouncement of the ANPD on the portability of Personal Data to third parties;
f) elimination of Personal Data;
g) information of public and private entities with which we share your Personal Data;
h) information on the possibility of not giving consent to the

Processing of your Data and the consequences of this choice;

i) revocation of consent, in accordance with point 6.2. above.
IN CHARGE (DPO)

8.1. SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES has formally appointed https://goadopt.io/ to act as its DPO, whose contact details are as follows:
Name of the responsible lawyer: Aston Pereira Nadruz
Email: aston@depaulaenadruz.com.br

SECURITY

9.1. We adopt technical and organizational measures capable of protecting your Personal Data.

9.2. The development, implementation and updating of the technical measures mentioned in the previous point will take into account the current state of technology, the scale and volume of operations to be carried out, as well as security and risk mitigation mechanisms compatible with good compliance practices.

RESPONSIBILITIES

10.1. SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES adopts the best digital compliance practices to provide the appropriate level of privacy and security for your Personal Data. However, we emphasize that, despite all our efforts, we are not able to guarantee the absolute and total inviolability of the Treatment, so we cannot be held responsible for possible damages caused by third parties due to non-compliance with this Policy and/or the contractual obligations agreed with SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES, especially when they appear as Data Controllers.

10.2. SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES shall not be liable for any criminal acts by hackers, crackers or similar, or for any actions or omissions that may be attributed exclusively to you or to third parties, except in the case of proven negligence on the part of SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES in keeping its systems up to date and adopting the good practices necessary to ensure the security of your Data.

UPDATE OF PRIVACY POLICY

11.1. This Privacy Policy may be modified or replaced at any time, at the sole discretion of SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES, without prior notice, and the Company undertakes to keep all content of this document always updated and available for access on our website.

11.2. We recommend that you periodically review this Privacy Policy, as the rules and information on the Processing of your Personal Data will always be linked to the most recent version of the document.

GENERAL PROVISIONS

12.1. If one or more provisions contained in this Privacy Policy are deemed invalid, illegal or unenforceable in any respect, the validity, legality or enforceability of the other provisions contained in this Policy shall not be affected and/or impaired in any way by this fact. In this case, SPLACK EMBALAGENS E SOLUÇÕES DESSECANTES will replace the invalid, illegal or unenforceable provisions with valid provisions.

LEGISLATION AND JURISDICTION

13.1. This Privacy Policy shall be governed by the laws of the Federative Republic of Brazil.

13.2. To resolve any issue or conflict arising from this Privacy Policy, the Court of the District of Campinas, State of São Paulo, is chosen, waiving any other, however privileged it may be.