PRIVACY POLICY
I. INTRODUCTION
This website (www.greenway.eco.br) is maintained by CYA RUBBER DISTRIBUIDORA LTDA (“CYA”), a private legal entity, headquartered in Porto Alegre, RS, at Av. Severo Dullius nº 1.395, sala 604, neighborhood São João, CEP 90.200-310, registered with the CNPJ/MF under No. 04.435.399/0001-94.
CYA uses some personal data that belongs to those who use the website (www.greenway.eco.br).
In doing so, CYA acts as controller of this data and is subject to the provisions of Federal Law n. 13.709/2018 (General Law on Personal Data Protection - LGPD).
CYA takes care of the protection of users' personal data, and, therefore, makes available the terms of this Privacy Policy, which contains important information, notably about:
(i) who should use the site (www.greenway.eco.br);
(ii) what data is collected and what is done with it;
(iii) not collecting and not processing sensitive data and data not provided for in this privacy policy;
(iv) not sharing data with third parties;
(v) personal data storage time;
(saw) legal bases for the processing of personal data;
(vii) the rights of users in relation to their personal data;
(viii) security measures in the processing of personal data;
(ix) where visitors' personal information is stored, used and shared;
(x) how the site uses cookies and other tracking technologies;
(xi) complaint to a control authority;
(xii) changes to this privacy policy; and
(xiii) how to contact the CYA.
II. WHO SHOULD USE THE SITE (WWW.GREENWAY.ECO.BR)
The website (www.greenway.eco.br) should only be used by people aged eighteen or over. Therefore, children and teenagers should not use it.
III. DATA THAT CYA COLLECTS AND REASONS FOR COLLECTION
The website (www.greenway.eco.br) collects and uses some personal data of users, in accordance with the provisions of this section.
Personal data are provided spontaneously and expressly by the user.
CYA collects the following personal data that users provide when using the website (www.greenway.eco.br): full name, company they represent, email, telephone, contact message, as well as the IP address used to connect your computer to the internet.
CYA may use tools to measure and collect browsing information, including page response times, total time spent on certain pages, page interaction information, and the methods used to leave the page.
The collection of this data occurs when the user accesses the website and when using the "contact" tab on the website (www.greenway.eco.br).
The data provided by users of the website (www.greenway.eco.br) is collected for the following purposes: for users to express their intention to do business with CYA, either as suppliers or as buyers of the products distributed by CYA, for provide users with ongoing technical assistance and support, in order to be able to contact visitors and users with general or personalized service-related notices and promotional messages, to create aggregated statistical data and other aggregated and/or inferred non-personal information that may be used to provide and improve the respective services, to comply with any applicable laws and regulations.
IV. SENSITIVE DATA
Sensitive data from users will not be collected, thus understood as those defined in arts. 11 et seq. of the General Law for the Protection of Personal Data (LGPD).
Thus, there will be no collection of data on racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person.
V. DATA COLLECTION NOT EXPRESSLY PROVIDED
Occasionally, other types of data not expressly provided for in this Privacy Policy may be collected, provided they are provided with the express, unambiguous and clear consent of the user, or even if the collection is allowed based on another legal basis provided for by law .
In any case, the data collection and the processing activities resulting from it will be informed to the website users (www.greenway.eco.br).
SAW. SHARING PERSONAL DATA WITH THIRD PARTIES
CYA does not share users' personal data with third parties. Despite this, it is possible that the CYA does so in order to comply with a legal or regulatory requirement, or even to comply with an order issued by a public authority.
VII. PERSONAL DATA STORAGE TIME
The personal data collected by the website (www.greenway.eco.br) are stored and used for a period of time that corresponds to what is necessary to achieve the purposes listed in this document and that considers the rights of its holders, the rights of the website controller ( www.greenway.eco.br) and the applicable legal or regulatory provisions.
Once the periods of storage of personal data have expired, they are removed from the CYA database or anonymized, except in cases where there is a possibility or need for storage due to legal or regulatory provision.
VIII. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
A legal basis for the processing of personal data is nothing more than a legal basis, provided for by law, that justifies it. Thus, each operation for processing personal data must have a corresponding legal basis.
CYA handles users' personal data only when necessary to serve their legitimate interests, as a controlling shareholder, or the legitimate interests of third parties.
To find out more about which cases, specifically, the CYA relies on this legal basis, or to find out more about the tests it does to make sure you can use them, please contact the Personal Data Protection Officer at CYA, through any of the channels informed in this Privacy Policy, in the section "how to contact us", contained in Chapter XV below.
IX. USER RIGHTS
The user of the website (www.greenway.eco.br) has the following rights, granted by the General Law for the Protection of Personal Data:
(i) confirmation of the existence of treatment;
(ii) access to data;
(iii) correction of incomplete, inaccurate or outdated data;
(iv) anonymization, blocking or deletion of unnecessary, excessive or processed data in breach of the provisions of the General Data Protection Law;
(v) portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;
(saw) deletion of personal data processed with the consent of the holder, except in the cases provided for in article 16 of the General Data Protection Law (compliance with a legal or regulatory obligation by the controller, study by a research body, whenever possible, anonymization of personal data, transfer to a third party, provided that the data processing requirements provided for in the General Data Protection Law are respected, or exclusive use of the controller, its access by a third party being prohibited, and provided that the data is anonymized), as applicable;
(vii) information on public and private entities with which the parent company (CYA) shared data;
(viii) information about the possibility of not providing consent and about the consequences of denial;
(ix) revocation of consent, at any time upon express manifestation of the user, data holder, by free and facilitated procedure, with ratification of the treatments carried out under the protection of the consent previously expressed while there is no request for deletion.
It is important to note that, under the General Data Protection Law, there is no right to delete data processed on the basis of legal bases other than consent, unless the data is unnecessary, excessive or processed in disagreement with the provisions of the Law.
To ensure that the user who intends to exercise his rights is, in fact, the owner of the personal data object of the request, CYA may request documents or other information that may help in their correct identification, in order to safeguard the rights of CYA and the rights of third parties. This will only be done, however, if absolutely necessary, and the applicant will receive all related information.
X. SECURITY MEASURES IN THE PROCESSING OF PERSONAL DATA
CYA employs technical and organizational measures capable of protecting personal data from unauthorized access and from situations of destruction, loss, misplacement or alteration of such data.
The measures that CYA uses take into account the nature of the data, the context and purpose of the processing, the risks that a possible violation would generate for the rights and freedoms of users, and the standards currently used in the market by similar companies.
Among the security measures adopted by CYA, the following stand out:
(i) user data is stored in a secure environment;
(ii) limited access to user data so that unauthorized third parties cannot access it;
(iii) records are kept of all those who have, in any way, contact with said data.
In the event of any type of security incident that could generate relevant risk or damage to any of the users, CYA will notify the affected users and the National Data Protection Authority about the event, in accordance with the provisions of the General Protection Law of Data.
XI. WHERE THE PERSONAL INFORMATION OF SITE VISITORS IS STORED, USED AND SHARED (www.greenway.eco.br)
The website ( www.greenway.eco.br ) is hosted on the Wix.com platform. Wix.com provides CYA with an online platform that allows it to sell products and services to CYA customers. Your information may be stored in the Wix.com database. Wix.com stores your information on secure servers behind a firewall.
Wix.com complies with PCI DSS (Payment Card Industry Data Security Standards) and is recognized as a Tier 1 vendor. PCI DSS is an information security standard for organizations or businesses that accept credit card payments . This standard helps create a secure environment, improving the quality of cardholder data and reducing credit card fraud.
XII. HOW CYA USES COOKIES AND OTHER TRACKING TECHNOLOGIES
The website (www.greenway.eco.br) uses essential cookies. These cookies activate functionality such as security, network management and provide access to features such as your profile and purchases, member-only features and other areas of the site. You can disable them by changing your browser settings, but this can affect how the website works.
XIII CLAIM TO A CONTROLLING AUTHORITY
Without prejudice to any other means of administrative or judicial recourse, holders of personal data who feel, in any way, have been harmed, may file a complaint with the National Data Protection Authority through the following access link: https://www. gov.br/anpd/pt-br.
XIV. CHANGES TO THIS POLICY
This version of this Privacy Policy was last updated on: March 1, 2021.
CYA reserves the right to modify, at any time, these rules, especially to adapt them to any changes made to the website (www.greenway.eco.br), either by making new features available, whether by deletion or modification of those already existing, or even to comply with the law or regulations, if so determined by the competent public authority.
Whenever there is a modification, users will be notified about the change, through the contact channels provided by users, who undertake to keep them updated.
XV. HOW TO CONTACT CYA
To clarify any doubts about this Privacy Policy or about the personal data that are processed by CYA, please contact CYA's Personal Data Protection Officer, through one of the channels mentioned below:
E-mail: alonso.silva@cya.com.br
Phone: (51) 3452-3500
Address: Av. Severo Dullius, 1395 - Porto Alegre - RS - 90200-310