Global Data Protection Policy

Your privacy is very important to us. We have developed this Global Data Protection Policy so that you understand how we collect, use, store, share, transmit, transfer, delete or process your personal data. This Global Data Protection Policy describes the measures we take to ensure the protection of your personal data. In this document we also tell you how you can contact us so that we can answer any questions you may have about data protection.

SCOPE

The Global Data Protection Policy applies to TRIE CONSULTORIA E TREINAMENTO EM PROCESSOS INDUSTRIAIS LTDA (“Trie”) for all aspects and activities, in all regions where we operate.

This policy applies to the processing of personal data directly or indirectly collected by Trie, from all individuals, including, but not limited to: current, future or potential job candidates, employees, customers, suppliers, contractors/subcontractors, shareholders, or any third parties, with “Personal Data” defined as any data relating to an identified or identifiable individual or a person who can be identified by means reasonably likely to be used.

In this Policy, “you” and “your(s)” refer to any individual covered in the Policy. “We”, “our(s)” and “Trie” refer to TRIE CONSULTORIA E TREINAMENTO EM PROCESSOS INDUSTRIAIS LTDA.

COLLECTION AND PROCESSING OF USE OF YOUR PERSONAL DATA

COMPLIANCE WITH THE GENERAL DATA PROTECTION LAW AND ANY OTHER LOCAL APPLICABLE DATA PROTECTION LEGISLATION

We are fully committed to complying with all applicable legislation in relation to personal data and will ensure that personal data is collected and processed in accordance with the provisions of Law 13709/2018, or the Brazilian General Data Protection Law - LGPD, as well as any other applicable local laws, should they exist.

LOYALTY, FAIRNESS, AND TRANSPARENCY

We do not collect or process personal data without legal basis. We may have to collect and process your personal data when necessary for the performance of a contract in which you are a party, or when required for the fulfillment of a legal obligation to which we are subject or required, with your prior consent. We may also collect and process your personal data for the legitimate interests of Trie, except when such interests are/have been nullified per your fundamental interests or rights and freedoms.

When collecting and processing your personal data, we will provide you with a fair and comprehensive notification or a privacy statement about who is responsible for processing your personal data, for what purposes your personal data is being processed, who the data recipients are, what their rights are and how to exercise them etc., unless such disclosure is impossible, or requires disproportionate efforts.

When required by applicable law, we will seek your prior consent (for example, before collecting any sensitive personal data).

LEGITIMATE OBJECTIVE, DATA LIMITATION AND MINIMIZATION

Your personal data is collected for specific, explicit, and legitimate purposes and is not processed in a manner incompatible with those purposes.

When Trie performs its business purposes, your personal data is processed primarily for, but not limited to, the following purposes: recruitment and human resource management, provision of IT tools or internal websites and any other digital solutions or collaborative platforms, IT support management, health and safety management, information security management, customer relationship management, sales and marketing management, internal and external communication, compliance with anti-money laundering obligations or compliance with any other legal requirements, data analysis, legal corporate management, and implementation of compliance processes.

DATA ACCURACY AND STORAGE LIMITATIONS

Trie will keep personal data processed accurately and, when necessary, it will also keep it updated. In addition, we only keep personal data for as long as necessary for the purposes for which they are processed. Trie shall act in accordance with its customers’ instructions in order to assist them in fulfilling this obligation.

PERSONAL DATA SECURITY

At Trie, we have implemented appropriate technical and organizational measures to protect Personal Data from accidental or illegal alterations or losses, or from unauthorized use, disclosure or access, in accordance with our Security Policy.

Where appropriate, we take all reasonable standard measures to implement the necessary safeguards and protect the processing of personal data. We also provide additional security protections for confidential/classified data.

DISCLOSURE OF YOUR PERSONAL DATA

We may, in the normal course of our business and for processing purposes, share your personal data with relevant personnel within Trie, or with our duly authorized employees, contracted/subcontracted personnel. To ensure consistency in our contracting activities, we maximize the quality and efficiency of our services and our commercial operations.

We may also be required to disclose your personal data to regulatory authorities, courts, and government agencies when required by law, regulation or legal process, or to defend the interests, rights or property of Trie or related third parties.

We will otherwise not share your personal data with other parties, unless you request it or have given us prior consent for such sharing.

YOUR RIGHTS

Trie is committed to ensuring the protection of your rights under applicable laws. Below you will find a table summarizing your rights:

Right to access	You shall have the right to request access to your personal data. You shall also have the right to request that inaccurate personal data be corrected or have incomplete personal data amended. You shall also have the right to request any information available about the source of the personal data, and you may also request a copy of your personal data as processed by Trie.
Right to erasure (‘right to be forgotten’)	Your right erasure (or ‘right to be forgotten’) gives you the right to request the deletion of your personal data in cases where: i. your data is no longer needed; ii. you have chosen to withdraw your consent; iii. you object your personal data being processed by automated means, using technical specifications; iv. your personal data has been processed illegally; v. there is a legal obligation to delete your personal data; vi. removal is necessary to ensure compliance with applicable laws.
Right to restriction of processing	You shall have the right to request that the processing of your personal data be restricted in cases where: i. you challenge the accuracy of personal data; ii. Trie no longer requires personal data for processing purposes; iii. you have opposed processing for legitimate reasons.
Right to data portability	When applicable, you may request the portability of the Personal Data you have provided to Trie, in a structured, commonly used, and machine readable format. You shall have the right to transmit those data to another Controller without any hindrance from Trie, where: (a) the processing of your Personal Data is based on consent or a contract; (b) processing is carried out by automated means. You may also request that your personal data be transmitted to third parties of your choice (when technically feasible).
Right to object to processing for direct marketing purposes	You shall have the right to object (that is, exercise your right to “opt out”) to the processing of your personal data, particularly in relation to profiling or marketing communications. When we process your personal data as per your consent, you can withdraw consent at any time.
Right not to be subject to decisions based on automated processing	You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you or significantly affects you.

UPDATES

We may update this Global Data Protection Policy from time to time following changes in our business or in data-related legal requirements/legislation. If significant changes are made to this policy, a notification will be posted on our website when such changes take effect and, where appropriate, we will inform you directly about the change.

CONTACT

If you have any questions about the collection and processing of your personal data by Trie, please send your questions or complaints following the procedure set out in the privacy statements communicated to you at the time of collecting your personal data, or by sending your questions to the following email address: trie@trieengenireeing.com