Company
Privacy Policy
PRIVACY NOTIFICATION TO ALL PROFIGEN COMMERCIAL PARTNERS
We take privacy seriously.
We have a commercial relationship with you or with your employer, for example, because you or your employer commercialize, promote or consume ProfiGen products. This notification provides more details about information we could eventually collect about you by virtue of our commercial relationship, as well about the way we process this information.
Click on the “saiba mais” (know more) button to get more information.
Please, also read occasional terms of use related to services offered by ProfiGen and used by you, as well as any complementary notes provided by us, relative to the collection and use of your information, including our warning about cookies.
Who are we?
We are Profigen do Brasil Ltda. (“ProfiGen”), a company devoted to research, production and commercialization of tobacco seed, based at Estrada do Couto, Km 03, Santa Cruz do Sul/ RS, Brazil, and registered under CNPJ/MF 01.085.458/0001-53.
Whenever the words “we” or “our” are used from here to the end of the document, we refer to ProfiGen.
How do we collect your information?
We can collect your information in many ways.
• You can provide information directly (for example, filling in a form or contact us by phone).
• We can collect information automatically (for example, when you use a ProfiGen application or site).
• We can acquire information from third parties (for example, information publicly available in social media platforms, like LinkedIn, Facebook and Twitter).
In this notification, we refer to all methods through which you can contact us, like “ProfiGen points of contact”. The points of contact provided by ProfiGen include both physical means (for example, ProfiGen offices, sales outlets and events) or electronic means (for example, e-mail messages, applications and sites).
Know more…
We can collect information provided directly by you:
• register on our databases (this can be done, for example, personally, via application or online);
• negotiate, commercialize or acquire products or services from ProfiGen, for example, in a sales outlet;
• celebrate an agreement with us to sell, promote, distribute or acquire ProfiGen products (or lend support to these activities);
• download or utilize a point of contact (for example, an app or a website);
• contact us through a point of contact, or by e-mail, social media or telephone;
• register in order to receive press communications, warnings by e-mail or ProfiGen marketing communications
• take part in studies promoted by ProfiGen or (to the extent permitted by law) in contests or promotions run by ProfiGen; or
• visit our offices or attend an event organized by ProfiGen.
We can collect your information automatically. Normally, this happens when you:
• visit our offices (for example, through video recordings, surveillance video recorders
• and access control records);
• work at or visit a sales point of ProfiGen products (for example, collecting their data at the cashier or through sensors at the sales point, connected to mobile technology);
• attend an event organized by ProfiGen (for example, through purchases or sales at the event) or through sensors at the event connected to mobile technology;
• communicate with us (for example, through a point of contact or social media platforms);
• utilize points of contact for ProfiGen (for example, through traceability mechanisms in an application or in a website); or
• enter public postings on social media followed by us (for example, so that we can understand public opinion or reply to claims regarding ProfiGen products).
We can also collect information automatically by means of cookies and similar traceability technologies in electronic points of contact at ProfiGen. The cookies and specific technologies will depend on ProfiGen’s point of contact in question. To know more about the cookies (including Google Analytics cookies) and similar technologies utilized in a point of contact, seeing that you can accept or refuse cookies, you should consult the cookie notification available through the respective point of contact.
To the extent permitted by law, we can acquire your information from third parties. This could include information shared by ProfiGen affiliates, information of a publicly available profile in sites of third party social media sites (like Facebook and Twitter) and marketing lists acquired from third party marketing agencies.
We can equally collect information in other contexts made known to you at the time of collection.
Which information do we collect?
We can collect several types of your information:
• information needed to manage and administrate our relationship with you, your employer or representative;
• information needed to negotiate, or provide consultancy for ProfiGen products or services (for example, to fulfill purchase orders);
• information needed to lend support to ProfiGen products or services or for warranty services;
• information on what you do in your business relative to our consumers, ProfiGen products and relative to us (for example, register a consumer on a database, carry out warranty services, exhibit products and materials in ProfiGen sales outlets, etc.);
• information you provide to us in contracts, forms, studies, in interactions in electronic points of contact;
• information on your visits to our offices, points of sale and events;
• information you provide to us in phone calls, by e-mail or other similar means;
• information on your preferences and interests; and
• information needed to check your age, identity and authority to act on behalf of your employer, if applicable.
Know more…
All information we collect directly from you will be evident in the context in which you supply information. For example:
• if you order a product through a point of contact, you will supply your name, contact, invoicing data and products chosen by you, so that we can fulfill your order;
• if you commercialize ProfiGen products, you will provide your name, contact and invoicing details so that we can manage our relationship with you or your employer and comply with our contract with you or with your employer;
• you may supply information about your preferences and interests in products so that we can offer products and services that are of interest to you;
• we can collect information to check your age, for example, from a copy of an identity document or your facial image;
• you can send us a photo of the manner you display the products or the materials at the ProfiGen sales point;
• you can reply to text messages;
• you can register on our databases, for example, so that we can carry out warranty services.
All information we collect automatically usually is about:
• details about your visit or phone call (like time and duration);
• in our offices, sales point or event (including its premises), how often do you visit, which areas do you visit and for how long, and what kind of purchases do you prefer?
• your use of ProfiGen’s electronic points of contact (like the pages visited, from which page you came and to which you went when you exited, inserted seeking terms or links clicked at the point of contact); and
• your device (like your IP address or exclusive device identifier, location data, data of eventual cookies we store in your device).
Information we collect from third parties is usually information of a publicly available profile (like your preferences and interests), for example, postings in public social medias
.
What do we use your information for and on what legal grounds?
In this section, we describe for which purposes we use personal information. In accordance with the laws of a specific country that may restrict or ban certain activities herein described, we will not use your information for such purposes in the respective country.
Subject to the above, we use your information for the following purposes:
• To comply with regulatory obligations, like checking your age, identity and retailer status, conduct verifications relative to the policy that sets forth “Know your Supplier” and administrate our contractual relationship with you or your employer;
• Legal compliance, like storing and utilizing your records with regard to any foreseen controversies, in order to get advice from our lawyers and other consultants;
• To sell our products to you, including the fulfillment of your orders, and the processing of your payments;
• Supply sales-related services to you, including the clarification of your doubts and solicitations and supply warranty servicers;
• To keep you informed about updates, promotions, events and administrate aspects related to our relationship, including the management of loyalty programs, product improvement, market research, development of marketing strategies and to personalize your experiences in the sales points of ProfiGen products and in events;
• Registering consumers on our databases, for example, to commercialize our products;
• To lend support to all items above, including the administration of your accounts or your employer’s accounts, allowing you to use ProfiGen points of contact and (as applicable) sell, promote and distribute ProfiGen products (or lend support to these activities), keeping in contact with you, personalizing your experiences relative to ProfiGen points of contact, administration and solution to problems, general maintenance of records and management of your access to any systems to which we have granted access to you;
• For business analyses and improvements, including the improvement of ProfiGen products, offices, processes, points of sale of ProfiGen products, events and information provided by us (or by our affiliates) to our clients and suppliers;
• In order to make it possible for us and our business partners to inform you about possible opportunities to participate in the marketing or in the promotion of ProfiGen products; and
• For other purposes we will let you know or will remain clear within their context, at the moment your information is collected for the first time;
The legal basis for us to utilize your information are some of the following options (which we will explain in more detail in section “know more”):
• Compliance with a legal obligation to which we are subject to;
• Execution of a contract of which you are a part;
• A legitimate commercial interest that does not violate your data protection interests; and
• In case none of the above items are applicable, your consent (which will be required before processing any information).
Know more…
The purposes for which we utilize your information, the corresponding collection methods and legal basis for using it, are as follows:
| Objective | Collection method and legal basis for processing |
|---|---|
| Compliance with regulatory obligations • check your age, identity and retailer status • tax accounting and entrepreneurial obligations • commercial sanctions • background checks • healthcare management and safety • disclosure solicitations by virtue of Law or regulation • conflicts of interest • store contracts and documents related to the ones to which you may be linked • inquiries about denouncements and offenses |
This information is generally provided to us directly by you. We use it because it is necessary for us to comply with an obligation to negotiate only with adult people and to conduct our businesses in compliance with the law (even with regard to entrepreneurial rights and compliance with tax obligations, keep financial and tax records, observe commercial sanctions, comply with healthcare and safety laws (which could include incident records), produce reports, provide for information required by competent authorities and manage conflicts of interest, and, equally, because we have a legitimate commercial interest in negotiating only with adults and conduct our businesses in accordance with best practices. |
| Sell our products • meet your orders (including sending receipts) • process your payments • provide warranty services |
This information is generally supplied to us directly by you or by your employer, as applicable (normally, name, position, address, e-mail address, payment data, correspondence). In order to comply with our contractual obligations we treat you as a purchaser of our products. |
|
Provide for sales-related services • answer your questions and solicitations |
This information is generally provided by you or by your employer We use it because we have a legitimate commercial interest in providing services related to sales to you or to your employer |
| Promotional activities and relationship management (as permitted by law) • inform about updates, promotions and relevant events • manage our relationship • help you help your adult consumers with their financial controls • understand your preference (like which products or events could interest you or could be more appropriate to your needs) • manage loyalty programs • invite you to take part and manage studies or market research campaigns • for market research • develop marketing strategies • administrate marketing campaigns • personalize your experience in points of contact of ProfiGen (for example, personalize your visit with greetings or suggestions that might interest you) |
This will normally be a combination of information that you provide (for example, your name, contact and social media data); information we collect automatically (for example, using technology to monitor the utilization of ProfiGen points of contact and (as permitted by law) information that we acquire from third parties (like public social media postings). We utilize this information because we have a legitimate commercial interest in managing our relationship and communicate about our businesses, products and events, operate all ProfiGen points of contact and personalize your experiences. |
| Commercial promotion and relationship management (as permitted by law) • provide information about ProfiGen affiliates and manage their promotions, products, services, points of sale, events and about the regulation of our products; whilst developing and improving tools for these purposes |
This will normally be a combination of information that you provide to us (for example, your name and contact data); we inform that we collect it automatically (for example, using cookies and similar technologies) and as permitted by law, we inform that we acquire information from third parties (like public postings by social media). We use it based on the fact that we have a legitimate commercial interest that is not subjugated to your interests, rights and liberty to protect your data. |
| Corporate Governance • general organizational management and maintenance of commercial records • management of visitors and maintenance of records • manage and carry out events, training and compliance programs • correspondences relative to our relationship with you or your employer, including answers to your doubts and solicitations • development, implementation, operation and maintenance of TI systems • maintenance of the security of systems, devices and buildings • database operations regarding contacts and collaboration tools • operation of safe work environment • preservation of safety of workers, clients, suppliers, visitors and the premises of ProfiGen affiliates |
This information is generally provided to us directly by you or by your employer. |
| Security and systems monitoring • authentication of access and record controls, as applicable • monitoring of ProfiGen systems, devices, internet and e-mail to which you have access • monitoring access to the premises of ProfiGen, deliveries to ProfiGen affiliates and processes related to the security of our facilities |
This information is collected automatically through various means, like automated systems and monitoring of devices, recordings from surveillance cameras, voice from telephone calls in our facilities. We use this information because we have a legitimate commercial interest in ensuring confidentiality, integrity and safety of our physical and digital infrastructure and facilities. |
| Support to all items above • managing your accounts • allowing you to use ProfiGen points of contact (for example, allowing you to continue connected to sections of a point of contact which are reserved for only authorized users, managing your language of preference, associating your shopping cart to you) • communicating with you • improving your experiences, how to suggest orders of products that could be appropriate for you (for example, based on previous orders) • managing and solving problems |
This will generally be a combination of information you provide to us, generally, name and password (or equivalent); information collected automatically (for example, information on the device, cookies and similar traceability technologies). We use it based on the reasons that correspond to the purpose of using information that is the target of the respective support. For example, when we administrate your account to lend support to a purchase and to provide you with post-sale service, we utilize the information to comply with our contractual obligations with you as a purchaser of our products; when we administrate your account to inform you about novelties about our products or we suggest orders that might be appropriate to you, we are lending support to the development of businesses and, therefore, we use it based on the fact that we have a legitimate commercial interest in our products which do not jeopardize or violate your interests, rights and liberties to protect your data, and so on. |
| Analysis and business improvements • allowing our business partners to inform you about possible opportunities of participating in the marketing or promotion of ProfiGen products • for analyses and business improvements (including products, systems, processes, ProfiGen offices, training, events, electronic points of contacts at ProfiGen and the information that we (or our affiliates) provide to us, your employer or clients. |
This will normally be a combination of information that you provide to us; information that we collect automatically; and (as permitted by law) information we get from third parties. We use this information base on the fact that we have a legitimate commercial interest in analyzing and improving our commercial performance, our products, systems, processes, offices, points of sales, training, events, points of contact at ProfiGen and information we supply and in the invitation of other people to take part in promoting ProfiGen products. |
In case we do not base our use of your information on one of the above legal bases, we will ask for your consent before processing this information (these cases will become evident within their respective context).
In some cases, we could use your information in manners different from the ones described above. If this is the case, we will send a complementary privacy notification explaining the respective use. You shall have any complementary notification along with this notification.
With whom do we share your information and with what objectives?
We can share your information with:
• ProfiGen affiliates;
• Third parties that supply products or services to you or to the ProfiGen affiliates (like consultants, providers of payment services, delivery services, auditors and information service providers;
• Commercial partners and advertisers carefully selected by ProfiGen affiliates (in areas related to our products, or consistent with their style and image) so that they can contact you with offers they deem to be of your interest, in accordance with their preferences; and
• Other third parties, in accordance with what is required or permitted by law (like regulatory authorities, government departments and professional consultancies).
Where can my information be sent to?
ProfiGen and its current global affiliates have commercial partners in several countries. Consequently, your information can be transferred globally, provided it remains in the format and within the purposes indicated in the present privacy policy.
Know more…
Upon using your information in the manner described in this notification, ProfiGen can transfer it internally or to a foreign country or territory where it has been collected, even to a country or territory that might not have equivalent data protection standards.
In any case, appropriate security measures will be taken to protect all personal data in these countries or territories, according to the applicable data protection laws.
How do we protect your information?
We implement technical and organizational standards appropriate to protect the personal information against disclosure, use, alteration or non-authorized destruction. As appropriate, we use cryptography and other technologies able to protect any information provided to us by you. We also require our service providers to comply with strict privacy requisites and data safety.
For how long will your information be stored?
We will store your information for the period that is needed to materialize the purposes for which the information was collected and for the legal period required to defend the interests of ProfiGen and its affiliates. After this, we exclude the information. The period could vary depending on the purpose for which the information was collected. Please note that, in some circumstances, you have the right to require the exclusion of the information. Furthermore, sometimes we are legally forced to store the information, for example, for tax and accounting purposes or to defend ourselves in case of litigation stemming from the contract that gave rise to the processing of such information.
Know more…
Normally, we store data based on the criteria described in the table below:
| Type | Explanation / typical storing criteria |
|---|---|
| • Information relative to the management of commercial relations with retailers (active in digital platforms) | Most information in your retailer profile is stored during the period of our commercial relationship with you. However, some elements of your profile, like your history of tasks concluded, your award winning history or your purchasing history, of course, expire after a period of time, therefore, we exclude it automatically after certain periods, as appropriate for the purpose for which we collected it. |
| • Information relative to the administration of the commercial relationship with the retailer (inactive in digital platforms) | This scenario is similar to the above one, however, if we do not have any contact with you for a long period of time (normally two years), we will cancel your access to the digital platform and we will exclude the records we still have related to your use (except if they fit into another processing purpose like the record of your orders). The reason is that, in such circumstances, we presume that you would prefer to refrain from using the digital platform. |
| • retailer (uncontactable) | If you are registered with us as a retailer, but the data you provided us with to contact you do not work, we will store your data for a period of just six months, in general, so as to give you time to return to us and correct the data. |
| • retailer (incomplete registrations) | If you start to register as a retailer, but fail to conclude the process, we will not store your data. |
| • Business and payment registers | We store registers of invoices, sales, purchases carried out and received and vouchers (like contracts and according to the company’s tax requirements, normally 11 years. We also store scan logs of suppliers for the time needed by us to comply with our legal and regulatory obligations. |
| • visitors registers | Should you visit our facilities, the visitors registers will normally be stored for a period of three years. |
| • surveillance cameras | Should you visit our facilities, the registers of the surveillance cameras will normally be stored for just some days, or some weeks, depending on the specific purpose of the recording. |
| • market research | If you are not registered with our database, and if we use your publicly available information to understand the market or its preferences, we will store your information for a short period for the conclusion of the specific market research item. |
| • purchases and warranty | If you purchase goods, we will store the relative data for a time needed to conclude the sale and for complying with any legal obligation (for example, for the purpose of keeping tax and accounting registers). If you also register for the sake of a warranty for a ProfiGen product, we will store all related data for the time pertinent to the warranty. |
| • costumer service | If you contact the costumer service department, we will do a register of the matter (including details of your solicitation and our reply) and we will store it for the time it is deemed relevant to our relationship, for example, if you need help for using a point of contact or if your recent solicitations are relevant. Other relevant consumer service registers (for example, an automated recording of a phone call in which you ask us to redirect a sales point) could be relevant until more permanent registers are carried out, and they will be stored only temporarily |
| • system audit registers | The system audit registers are stored normally for a period of just some months. |
| • business analysis | All business analysis data are generally collected automatically when you utilize ProfiGen points of contact and are anonymized /aggregated shortly after. |
What are your rights and options?
You may have some or all of the following rights with regard to your personal information we have:
• require access to information;
• ask for a correction, update or exclusion of the information;
• ask us to restrict the use of the information, in certain circumstances;
• oppose to our utilization, in certain circumstances;
• withdraw your consent for its use;
• data portability, in certain circumstances;
• ask for an exclusion of it from direct marketing; and
• file a complaint with the inspecting authority of your country (should there be such an authority).
We offer easy manners for you to exercise these rights, like links for “cancellation of registration”, or offering an option of contact in the messages received or through the contacts contained in paragraph “who should you contact in case of doubts?”, at the end of this notification.
Some mobile applications we offer can also send push notifications, for example, about new products or services. You could disable the receipt of these notifications in the configurations of your telephone or application.
Know more …
Your rights depend on the legislation of your country. If you are in Brazil or in the European Economic Environment, you will have the rights listed on the table below. If you are somewhere else, you can contact us (see paragraph “who do you have to contact in case of doubts?”, at the end of this notification) to know more about it.
| Rights regarding your information we have | More details (please note: certain legal limits could be applicable to all these rights) |
|---|---|
| • require access to information | This confirms: • if we process or not your information; • our name and contact data; • the processing objective; • the information categories in question; • the categories of people with whom we share the information • (if we have it) the source of information, if we did not collect it from you; • (as long as there is, you will be informed) the existence of automated decision taking, including the creation of the profile, which gives rise to legal effects about it, or affects significantly you in a similar manner and information about the logic involved, as well as the meaning and the anticipated consequences of such a processing for you; and • the criteria to determine the period during which store the information. At your request, we will provide to you a copy of your information used by us (provided it does not affect the rights and liberties of other people). |
| • ask for correction, update or exclusion of information | This is applicable in case information we store is imprecise or incomplete. |
| • Ask for the exclusion of information | This is applicable if: • information we store is no longer necessary regarding the purposes for which we use it; • we use information through your consent and you withdraw your consent (in this case, we will remind ourselves not to contact you again, unless you let us know that you want us to exclude all your information, a case in which we will respect your decision); • we utilize the information on the grounds of legitimate interest and we will discover, after your objection, that we do not have a prevalent interest to continue using your information; • information was illegally obtained or utilized; or • for compliance with a legal obligation. |
| • require restriction of our utilization or processing | This right is applicable temporarily while we analyze your case, if you: • challenge the accuracy of the information we utilize; or • oppose to our utilization of the information based on legitimate interest (if you use your rights in these cases, we will inform you before we use the information again). This right is also applicable if: • our use is illegal and you oppose the exclusion of the data; or • we no longer need the data, but you need them for the basis of a legal interpretation. |
| • You oppose to our processing | Here, you have two rights: (i) if we use your information for direct marketing: you can “require your exclusion” (with no need to justify) and we will fulfill your requirement; and ii) If we utilize your information on the grounds of legitimate interests for purposes other than direct marketing, you can oppose to the use for these purposes, providing us with an explanation about your specific situation, and we will consider your objection. |
| • Withdraw your consent to the use of your information by us | This applies if the legal basis for our utilization of your information is consentment. These cases will be evident within their respective context. |
| • data portability |
If: |
| • file a complaint with the authorities |
Whom should you contact about your doubts?
Should you have any doubt or wish to exercise one of your rights, you can find all contact data of the ProfiGen affiliate through the website www.profigen.com.br. Contract data will also be provided in any communication sent to ProfiGen.
If ProfiGen is unable to solve your doubts or concerns, you are also entitled to seek legal action with the national judicial branch. If your country possesses a data protection authority, you have the right to contact this authority to clear your doubts or share your concerns.
Alterations in this notification
We can update this notification (and any complementary privacy notification) on a periodical basis. We will inform you about the alterations as required by law.
Latest alteration: 30th June 2019.
Veja também
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Empresa
- Home
- Empresa
- Certificado ISO 9001:2015
- Política de Qualidade
- Termos e Condições Gerais
- Política de Privacidade
- Política de Candidatos
