Introduction
The policy defined below must always be publicly available on the sites of units belonging to Group DB1.
We at DB1 Group and/or our affiliates, subsidiaries and associates understand and respect your privacy, and are committed to taking consistent measures and appropriate safeguards to protect the personal data processed on our websites, applications and other digital channels.
DB1 Group has an Information Security and Privacy Management System (SGSIP), with practices based on the international standards ISO/IEC 27001 and ISO/IEC 27701, which ensures technical and organizational controls to protect personal data against unauthorized access, undue loss, alteration or disclosure.
This Policy aims to inform, in a clear and accessible way, how we collect, use, store, share and protect your personal data, in accordance with the General Law on Personal Data Protection (Law no 13.709/2018 in Brazil), and other applicable rules.
1. PERSONAL INFORMATION DEFINITION
In accordance with the applicable Personal Data Protection legislation, in the countries where DB1 Group provides its services and for the purposes of this Privacy Policy or Personal Data Processing, we will consider the information provided by the user to be personal, provided that they, alone or in conjunction with other data delivered or generated, cause a natural person to be identified or identifiable (Data Subject). An identifiable natural person is a person who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social characteristics of this natural person.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
As permitted by applicable legislation, the personal data we collect directly from you may cover various categories and types, always observing the principles of purpose, adequacy, necessity, free access, quality of data, transparency, security, prevention, non-discrimination and accountability. We may have access to:
(i) your contact information, such as but not limited to that used to communicate with you, such as name, job title, company name, email address, telephone or postal address;
(ii) account information, such as username, user ID, data about your registration or participation in trainings, webinars, or other events;
(iii) professional or employment-related information, such as curriculum vitae, cover letter, work history;
(iv) automatically collected information such as IP address, location, date and time, browsing history, geolocation, reference source, browser type, duration of visit and pages visited;
(v) inferences, that information taken from the personal data collected in the previous item, such as the topics you may be interested in based on the areas of the website you visit or which products you may be interested in based on the purchase records.
It is possible to disable, through the settings of your internet browser, the automatic collection of information by means of some technologies such as cookies and caches, as well as on our own website, specifically regarding cookies. However, the User should be
aware that if these technologies are disabled, some features offered by the site, which depend on the processing of said data, may not function correctly.
3. ROLES IN DATA PROCESSING
DB1 Group may act as controller or operator of personal data, as provided by current legislation, especially under the terms of art. 5o, paragraphs VI and VII of the LGPD, depending on the nature of the relationship established with customers, employees, suppliers and other third parties, as well as the obligations arising from the contracts signed.
We undertake to inform you about our role in the processing of your data, whether by means of contractual instruments, terms of use, privacy policies or other related documents, ensuring the transparency provided for in art. 6o, item VI da LGPD.
4. HOW WE OBTAIN YOUR PERSONAL DATA
DB1 Group obtains personal data directly through interactions with you, as well as through the use of our products and services. This includes, but is not limited to situations in which you: request support; register for or participate in a training, webinar or other event; request information or materials, such as e-books or the like; participate in surveys or evaluations, promotionsif to a job; send questions or comments;
Personal data collected through online means may also be combined with information provided by offline channels, such as during job interviews or at events held or sponsored by DB1 Group in which you participate.
We may also automatically collect information related to your use of our websites and response to our emails through the use of various technologies. Collecting information in
this way allows us to analyze the effectiveness of our websites and our marketing efforts, allowing us to personalize your experience and improve our interactions with you.
5. ABOUT THE USE OF YOUR PERSONAL INFORMATION
DB1 Group may use the personal data we collect for some purposes, among them: to identify and authenticate you, verifying your identity when you access and use our services and to ensure the security of your personal data. We process your personal information in order to fulfill our contractual obligations with you.
The purposes of the processing are linked to the legal bases provided for in art. 7 of the LGPD, such as:
(i) execution of contract or preliminary procedures related to the contract to which the holder is a party (Art. 7, V);
(ii) compliance with legal or regulatory obligation by the controller (Art. 7, II);
(iii) Regular exercise of rights in judicial, administrative or arbitration proceedings (art. 7, VI);
(iv) Credit protection (art. 7, X);
(v) Legitimate interest of the controller or third party (art. 7, IX), with due impact assessment and guarantee of rights;
(vi) Consent of the holder, when necessary (art. 7, I).
In other cases, it is our legitimate business interest to be able to contact you, for example if you request something from DB1 Group, such as a product or service, a callback, a newsletter subscription or specific marketing, or other materials, we will use the personal data provided by you to respond to your request. We or our representatives may also contact you as part of customer satisfaction surveys or for market research purposes.
Where required by applicable law, we will obtain your consent before sending you marketing messages. DB1 Group may also use your personal data to notify you about offers of products and services, as well as events that we believe may be of interest to you, or to respond directly to your requests for information, including registrations for newsletters or other specific requests.
When you apply for a position at DB1 Group, we use the personal data you provide for the purpose of evaluating your application, considering you for future positions and performing human resources functions in accordance with applicable law. DB1 Group will share the personal data provided during the application process with internal human resources professionals, as well as with professionals in our business functions who are participating in the application and interview process.
When you use our websites and/or respond to our emails, we use the personal data that you provide for the purpose of improving and personalizing your experience on our websites and to provide content and offers of products and services relevant to your interests, including targeted offers through our website, third party websites or email (with your consent where required by applicable law), we may also use this information to help us improve and further develop our websites, products and services.
We will not use your personal data in an inconsistent manner with the purpose of its original collection, unless we have provided additional notice and you have consented. DB1 Group will retain your personal data for as long as it is necessary to fulfill the purposes for which the information is processed or for other valid reasons to retain your personal information (For example, to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements and to establish, exercise or defend legal claims).
6. HOW WE SHARE YOUR DATA
DB1 Group may disclose personal data to business partners and service providers to support our operations. Such business partners and service providers are contractually
required to keep the information received on behalf of DB1 Group confidential and secure and not use it for any purpose other than that for which it was provided to them.
The information collected may be shared by DB1 Group with:
(i) other group companies for marketing actions or when they are necessary for the proper provision of services, object of their activities;
(ii) to protect the interests of DB1 Group in any type of conflict;
(iii) with business partners, for purposes such as performance of the service contract or sale of products, security, fraud prevention and credit analysis;
(iv) by court order or request of competent authority.
DB1 Group may also disclose personal data as required by law or legal process, as well as respond to requests from police authority or public authority, to enforce or protect the rights of DB1 Group, when such disclosure is necessary or appropriate to prevent physical harm or financial loss as permitted by applicable law, or in connection with an investigation of suspected or actual illegal activity.
DB1 Group may carry out the international transfer of personal data, especially due to cloud storage (cloud computing) on servers located abroad. In these cases, all legal measures are adopted to ensure the protection of the transferred data, including, where necessary, obtaining the specific and highlighted consent of the holder, pursuant to art. 33, item VIII, of the LGPD, and art. 9o, II, c, of the RESOLUTION CD/ANPD No 19, OF AUGUST 23, 2024 (in Brazil).
7. RIGHT TO ACCESS, CONTROL AND DELETE YOUR PERSONAL DATA
DB1 Group guarantees you, the Data Subject, various options for what to do with your personal data collected, processed and stored, including their deletion and/or correction. You may: (i) request the deletion of your personal data; (ii) amend or correct data by requesting updates, changes or corrections to your data in certain cases, especially if they are incorrect; (iii) object, limit or restrict the use of data, requesting termination of the use of all or some of your personal data; (iv) accessing your data.
Personal data will be stored for the time necessary to fulfill the purposes for which it was collected, as well as to comply with legal and regulatory obligations. After the end of processing, the data will be safely discarded or anonymized in compliance with art. 15 of the LGPD.
DB1 Group has a structured process for registration, tracking and response of requests from holders, according to deadlines and requirements of the LGPD. Each request is recorded, analyzed and answered in a reasoned manner, and may be met or justified on the basis of legal obligation, legitimate interest or other applicable legal grounds.
You may make the requests listed above by contacting our Data Protection Officer via email at privacy@db1Group.com and these requests will be considered in accordance with applicable laws.
8. DATA PROTECTION OFFICER - DPO (DATA PROTECTION OFFICER)
DB1 Group has appointed Alexandre de Souza Dona as its Data Protection Officer ("DPO"). You, the Data Holder, can contact the DPO at the following physical address: Avenida Carneiro Leão, 563, Centro Empresarial Le Monde, 2nd floor, City of Maringá, State of Paraná, CEP 87.014-010, or by e-mail privacy@db1group.com.
9. CHANGES TO THE PRIVACY POLICY
This Privacy Policy may undergo updates. Therefore, we recommend that you visit this page periodically so that you are aware of these changes. Before using your information for purposes other than those set out in this Privacy Policy, we will seek your consent.
10. JURISDICTION AND APPLICABLE LAW
This document is governed and shall be interpreted in accordance with the laws of the Federative Republic of Brazil. The Tribunal of the Comarca of Maringá, State of Paraná is elected as competent to settle any questions arising from this document, with express waiver of any other, however privileged it may be.
