This Privacy Policy is based on Brazilian legislation, especially the General Data Protection Law, Law 13,709/2018, when in force. According to this Law, personal data is information about a natural person that identifies him or makes him identifiable. Soon, information such as CPF, RG, location, address, IP address, age, etc. are considered personal data.

In short, this Policy aims to demonstrate our Organization's commitment to:

  • (I) Protect the rights of employees, customers and partners;
  • (II) Adopt processes and rules that ensure compliance, in a comprehensive manner, with rules and good practices related to the protection of personal data;
  • (III) Promote transparency about the way in which the Organization handles personal data, and
  • (IV) Adopt protective measures in relation to the risk of a security incident involving personal data.

In order to provide the Services offered by Progás Indústria Metalúrgica and Braesi Food Equipment, some personal data may be collected, accessed, stored and eventually shared with partners.

Thus, fulfilling our commitment to maintain a transparent relationship with you, in this space we provide the rules that guide our data processing.

When you register with the Progás Indústria Metalúrgica and Braesi Food Equipment, we understand that you agree with the conditions indicated below. Therefore, it is important that you read, understand and if you have any questions, please contact us. This will make your experience with our product much more productive and smooth.

1. Scope

This Policy applies to all services offered by Progás Indústria Metalúrgica and Braesi Food Equipment, hereinafter called “services” or “applications” and apply to everyone who somehow has contact with the services, whether they are customers, suppliers, users of websites, apps or other service delivery resources of the Progás Indústria Metalúrgica and Braesi Food Equipment. All these individuals will be referred to below as “users”.

2. What data do we process?

Whether to present the benefits that our service can provide to your business, or to perform its features, we need to handle some information, which will be detailed below.

2.1. Users Data:

  • (V) General company data, such as the name of the legal representatives, e-mail, telephone, address, official identification documents of the representatives and the company, bank details.
  • (VI) Users may send information and personal data to register suggestions, complaints and solve doubts with the Customer Service Channels of Progás Indústria Metalúrgica and Braesi Food Equipment, before, during or after using the Services;
  • (VII) A Progás Indústria Metalúrgica and Braesi Food Equipment may request images from customer holders or linked to customers for promotional purposes, collection of testimonials, campaigns and opinion surveys.

2.2. Third Party Data provided by the Customer or User

Considering the nature of the Services offered by Progás Indústria Metalúrgica and Braesi Food Equipment, Users may provide data from third parties for the execution of the Services, in which case the User is responsible for the information provided and the respective legal authorization, being the responsibility of the Progás Indústria Metalúrgica and Braesi Food Equipment the role of operator of such data.

  • (I) Third party data that may be provided by Users are general data of supplier companies and customers, such as name of legal representatives, e-mail, telephone, address, official identification documents of representatives and the company, bank details; general data of the Service providers, such as name, email, telephone, official identification documents; general employee data, such as name, address, telephone, official identification documents, CTPS data, CNH, voter registration, employee registration data, such as reservist certificate, employee registration, e-mail, capacity, function, union , labor regime, social security system, working hours, nature of activity, category, relationship with another company, date of admission, type of employment contract, type of admission, remuneration, date of birth, sex, marital status, race/color , education level, mother's name, father's name, spouse data, dependent data, company representatives data, among others.

2.3. Data collected automatically Cookies and similar technologies

When using the services of Progás Indústria Metalúrgica and Braesi Food Equipment we may collect personal information about the services you use and how you use them. This information is necessary for the proper execution of the services, as well as to proceed with continuous improvements in the application's functionalities.

  • (I) Geolocation Information: When using the Services of Progás Indústria Metalúrgica and Braesi Food Equipment we may collect information about your location, identified from data such as your IP address or your mobile device's GPS, to provide you with an optimized user experience. Most mobile devices allow you to control or disable the use of Application Location Services in the device's settings menu.
  • (II) Usage: We may collect information about the way you use the Services. Progás Indústria Metalúrgica and Braesi Food Equipment, such as the most used features, changes made, time of use, etc.
  • (III) Log Data: We may collect log data and device information automatically when you access and use the Services. Progás Indústria Metalúrgica and Braesi Food Equipment, even if you are not a customer.

We may also use technologies to store temporary browsing information in order to enhance and improve your experience using our product. The main technological tools that do this are “cookies”, and similar technologies are also used.

With this we will be able to know, for example, which sites you have visited, your Internet Protocol (IP), the version of your browser, etc.

However, you can configure your device to manage the use of cookies or to alert you when they are active. Some cookies may be necessary for browsing and their deactivation may impair some functionality of our Service.

3. How do we use the collected data?

The User will always be informed about the purpose of collecting their personal data, being at their sole discretion whether to provide them or not, and, in this case, they will be warned of the consequences of not providing them.

In general, the data collected will be used for the following purposes:

  • (I) Grant access to the features of the Services of Progás Indústria Metalúrgica and Braesi Food Equipment, which include:
  • For businesses;
  • For Individuals;
  • Financial management;
  • Issuance of invoices;
  • Financial services, integration, payments and receipts;
  • ERP system;
  • Service management;
  • Product Management;
  • Reports;
  • Financial management of the company itself;
  • Payroll management;
  • Tax routines integrated with customers;
  • Accounting closing.
  • For more information about each functionality, the User may contact us through the service channels of Progás Indústria Metalúrgica and Braesi Food Equipment.
  • (II) To offer educational material, such as courses, guides, infographics, spreadsheets, handouts, webinars, e-books and others;
  • (III) For holding events;
  • (IV) Contact us to send you communications, such as security alerts, updates, to present our Services, carry out marketing operations;
  • (V) Contacting us for support and support and troubleshooting;
  • (VI) Operate, protect, perform functionality tests, maintenance and continuous improvements in the services, improving the User experience;
  • (VII) Maintain the security and integrity of our Services and Users, perform identity confirmations, fraud prevention, internal investigations, investigate and prevent legal, regulatory and contractual violations;
  • (VIII) Conduct development research;
  • (IX) Consult and edit records, access the User's account to carry out the changes requested by him and provide assistance in the use of the functionalities;
  • (X) Consult and manage the User's financial situation with the Progás Indústria Metalúrgica and Braesi Food Equipment, make chargebacks or charges; issue invoices.

4. Other possible uses of the data

To make your experience even better, from time to time we may also process personal data for other purposes, listed below, but you will be informed.

4.1 Statistical analysis, improvements to the Services and products

The data (including that collected by cookies) may also be used for statistical purposes, so that we can better understand the profile of our customers, continuously improve our product and for the purpose of targeting specific content. In this case, you will not be identified, and your data will only compose statistics on the use of our product, such as how many percent of our customers are in a certain region, User preferences, how many customers are companies, how many are individuals. physics, etc.

The data itself and the statistical results may also be used to direct administrative, commercial and financial matters of the Progás Indústria Metalúrgica and Braesi Food Equipment, including by targeting marketing campaigns.

4.2. Disclosure of campaigns, promotions and similar

The data may be used by Progás Indústria Metalúrgica and Braesi Food Equipment or third parties hired by it to send information, advertising campaigns, questionnaires, invitations to events, satisfaction surveys, etc.

You can opt out of receiving this information at any time by sending a request to INSERT communication channel of Progás Indústria Metalúrgica and Braesi Equipamentos para Alimentação.

4.3. For legal and mandatory purposes

THE Progás Indústria Metalúrgica and Braesi Food Equipment may process User data and data from third parties, entered by Users, to comply with legal or regulatory obligations, sharing personal data with public authorities. Some non-exhaustive examples of this type of treatment are

  • (I) Issuance of Invoices, sharing with the Federal Revenue: Name, CPF, CNPJ, address, telephone, e-mail, corporate name, municipal/state registration, sales data;
  • (II) Completion of the Services taken book, Services provided book, tax integration, filling out the DAS – sharing with the Federal Revenue: CPF informed in the Invoice;
  • (III) Accreditation with the Federal Revenue - name and CPF of the partner;
  • (IV) Issuance of DRE, balance sheet, ledger, daily book or fixed assets report – sharing with the Federal Revenue – name;
  • (V) Completion of SEFIP, GRRF, CAGED, DIRF, RAIS and other labor obligations – sharing with the Ministry of Labor and Employment.

In addition, personal data may eventually be processed:

  • (I) For internal and external audits, for validation of information security issues, seeking, as far as possible, the confidentiality and anonymization of this data;
  • (II) To meet legal requests from public authorities;

5. sharing

THE Progás Indústria Metalúrgica and Braesi Food Equipment has the practice of not transmitting data to external organizations and/or individuals, except with the User's free, informed and unequivocal consent, or when consent is dispensable in the scope of legitimate hypotheses for the processing of personal data, provided for in current legislation.

There are possibilities for sharing:

• (I) Where permitted under applicable law, we may process certain personal data, such as email address, to share it with social media platforms such as Facebook and Google, to generate leads, drive traffic to our website or otherwise promote our Services. These processing activities are based on our legitimate interest in carrying out marketing activities to offer Services that may be of interest to you.

• (II) Any questions about how your application providers, such as Facebook and Google, process your personal information should be directed to these providers.

• (iii) A Progás Indústria Metalúrgica and Braesi Food Equipment may share User data with public authorities, such as tax, treasury, judicial and police authorities, or authorized third parties, if and to the extent necessary or permitted to comply with the law, in situations such as:

• To comply with legal obligations;

• To comply with a valid legal request and respond to allegations made against the Progás Indústria Metalúrgica and Braesi Food Equipment;

• To promote or defend in lawsuits;

• To respond to a valid legal request related to criminal investigations, suspected illegal activity, or any other activity that may expose Progás Indústria Metalúrgica and Braesi Food Equipment and the Users the legal responsibility;

• To enforce and administer our General Terms and Conditions;

• To carry out the physical and cyber security of the Progás Indústria Metalúrgica and Braesi Food Equipment, in all its assets, and of its Users.

• To perform the Services to Progás Indústria Metalúrgica and Braesi Food Equipment may share User data with outsourced service providers, who work in various processes, such as:

• Storage of information in the cloud;

• Verification of Users' identity, for fraud prevention and credit risk assessment;

• Verification of information against public databases;

• Research, development and maintenance of applications;

• Provision of the Services of Progás Indústria Metalúrgica and Braesi Food Equipment through third-party platforms and software tools (e.g. through integration with APIs)

• User Service;

• Marketing promotion, including social media advertising services, lead prospecting and data analysis;

• Provision of consulting, legal, accounting and other professional service providers;

• Processing and guaranteeing payment security.

Service providers have limited access to Users' data to perform specific tasks and are contractually obliged to protect the information, using it only for the contracted purposes and under the supervision of the Progás Indústria Metalúrgica and Braesi Food Equipment.

• (V) In the selection processes of candidates for job vacancies, we may share data with third-party companies for the processing of data under instructions and on behalf of Progás Indústria Metalúrgica and Braesi Food Equipment. In this case, we ensure that the third parties offer sufficient guarantees, based on adequate technical measures, so that the treatment meets the legal requirements, in full compliance with the rights of data subjects;

6. Security of your information

THE Progás Indústria Metalúrgica and Braesi Food Equipment adopts technical and administrative measures to protect the privacy of customer data, using all efforts to maintain strict confidentiality, integrity and availability restricted to authorized persons.

Both our website, through which you access the product Progás Indústria Metalúrgica and Braesi Food Equipment, as well as backing up our data, are at Amazon Web Services, the world's largest and most trusted datacenter.

In addition, we use the best security practices on the market, in addition to physical and digital access controls, encryption, measures against destruction or illegal use, vulnerability management, handling of incidents and unauthorized access or in violation of this Policy or Product Terms of Use.

7. User Responsibility

Without prejudice to the other obligations provided for in this Policy or in the Terms of Use, for the proper use of the product Progás Indústria Metalúrgica and Braesi Food Equipment, when using our product, you must commit to:

  • (I) To be solely responsible for the protection and confidentiality of the login and password, not being able to provide them to third parties;
  • (II) Provide credit card information, passwords of any nature using existing features in our application.
  • (III) Communicate any and all suspicions or findings of violation of the Terms of Use or the Privacy Policy, including unauthorized access to your account, suspicious transactions, slips that you are unaware of, etc.
  • (IV) Consult us, via the website or contact channels, whenever you receive information or communications about promotions, campaigns and surveys received by email, to verify their veracity;
  • (V) Provide truthful, honest and complete information, being responsible for any and all incorrect or false information;
  • (VI) Be responsible for all third party data (eg personal data of its customers);
  • (VII) Communicate any and all changes to your data, so that for all legal purposes the latest data provided will be considered correct, authentic and sufficient to comply with this Policy and the Terms of Use and General Conditions;

For security reasons, we reserve the right to suspend or cancel the User's account in case of suspicion or non-compliance with the General Terms and Conditions or the Privacy Policy, without prejudice to other judicial and administrative measures.

8. Data maintenance

Considering the situations, we will keep the User data for the necessary retention period, considering the situation that justifies the treatment:

  • (I) if to comply with a legal or regulatory obligation, for the period indicated in the rule in question;
  • (II) if for the fulfillment of the contract, until the scope of the objectives of the contractual relationship;
  • (III) if based on legitimate interest, which will always be preceded by a privacy impact analysis and carried out within the limits of the purpose that justifies it, until it ceases.
  • We may also keep your personal data, regardless of your request for deletion and consent, pursuant to article 16 of the General Data Protection Law, in the following situations and respecting the following purposes:
  • Compliance with legal or regulatory obligations;
  • Study by research body, guaranteeing, whenever possible, anonymization; Transfer to a third party, respecting the rights of the holder and provision in the data protection and privacy laws;
  • Our exclusive use, provided that access by a third party is prohibited, and provided that the data is anonymized.

9. Users' Rights

if to comply with a legal or regulatory obligation, for the period indicated in the rule in question;

if for the fulfillment of the contract, until the achievement of the objectives of the contractual relationship; and

if based on legitimate interest, which will always be preceded by a privacy impact analysis and carried out within the limits of the purpose that justifies it, until it ceases. Users will be able to manage the use of their data, being able to:

  • (I) Request the deletion of your data, unless there is a legal impediment;
  • (II) Request the change or correction of your data
  • (III) Request information about the sharing of your data;
  • (IV) Restrict, as far as possible, the use of your data, including with regard to the receipt of advertising campaigns and the use of Cookies;
  • (V) Request a copy of your data in a legal and adequate format;
  • (VI) Revoke consent for the processing of your data, being advised in this case of the consequences;
  • (VII) Request that the Progás Indústria Metalúrgica and Braesi Food Equipment cease processing your data for marketing purposes by sending an email to INSERT email marketing@progas.com.br.

THE Progás Indústria Metalúrgica and Braesi Food Equipment will meet the requests of Users, but informs that these rights will not be absolute, so that some situations may result in partial fulfillment of the request or even negative. In these situations, it will provide the necessary clarifications and justifications.

10. Contact and incident reports

For the exercise of your Rights or any necessary communication with the Progás Indústria Metalúrgica and Braesi Food Equipment due to the use of the product or on account of this Privacy Policy, you may use the following Communication Channels:

Fill in the communication channels.

11. Responsible for the privacy program

The person responsible for the Privacy Program of Progás Indústria Metalúrgica and Braesi Food Equipment is the Data Protection Officer (DPO or Data Protection Officer), identified below:

Name: Outsourced or In-house defined by XXXXXX

Email: To fill in

The main duties of the Person in Charge involve, without prejudice to other activities established in specific policies and procedures that make up the Privacy Program:

  • Privacy Program Management;
  • Development, maintenance, and proposal to review the Organization's privacy policies and procedures, including this Policy;
  • Supervision of compliance with the Privacy Program's procedures and policies;
  • Monitoring the Organization's level of compliance, through recurring diagnostic analyses, with the definition of action plans to improve training and the clarity of documents that make up the Privacy Program;
  • Acting as a point of contact for the ANPD and the Holders;
  • Receipt of requests from Holders, and
  • Preparation of Impact Reports for the Protection of Personal Data, with calculation and review of the risks of the activities.

Finally, the Person in Charge must assist the employees of the Progás Indústria Metalúrgica and Braesi Food Equipment and clarify any doubts about the Privacy Program and the correct way of Processing Personal Data to be adopted during the performance of their activities.

12. POLICY REVIEW

This Policy may change, and customers will be notified in advance. The current version was published in 20th of January of XXXXXX.

The documents that make up the Privacy Program of Progás Indústria Metalúrgica and Braesi Food Equipment they can only be changed with the approval of the person responsible for the privacy program.

13. JURISDICTION

Our Privacy Policy complies with the legislation of the Federative Republic of Brazil. Any issue arising from the relationship between the customer and the Progás Indústria Metalúrgica and Braesi Food Equipment will be dealt with in the Forum of XXXXXX.