PRIVACY NOTICE

The protection of users’ privacy and data reflects the values of PROCOB and reaffirms its commitment to continuously improve the effectiveness of the data protection process.

Please read this Privacy Notice and Personal Data Protection carefully to understand our notices and practices regarding your Personal Data and how the processing of this data is carried out.

This Notice applies to individuals (natural persons) who interact with PROCOB services as consumers (“You”). This Notice explains how your Personal Data is collected, used, and disclosed by PROCOB (referred to in this Notice as “PROCOB,” “We,” “Us”). It also informs how You can access and update your Personal Data and make certain decisions about how your Personal Data is used.

This Notice covers our data collection activities both online and offline, encompassing Personal Data that We collect through our various channels, including – but not limited to – websites, applications, third-party social networks, customer service, points of sale, surveys, and events. Please note that We may aggregate combined Personal Data from different sources (e.g., our website and offline events). As part of this, We combine Personal Data that was originally collected by different entities of PROCOB or PROCOB partners. You can refer to the section “About Your Rights Regarding Personal Data” for more information on how to object to this.

In some specific cases, if You choose not to provide us with your Personal Data indicated as necessary (We will indicate when this is the case, for example, by explicitly stating this information in our registration forms), We may not be able to provide You with our products and/or services.

Sources of Personal Data

We collect your Personal Data from the following sources:

– PROCOB Websites: All our websites can be used for the collection of personal data. This includes both sites that we operate directly through our domains and IP addresses, as well as sites or pages that we establish on third-party services such as Facebook, Linkedin, and other similar services.

– Email and Instant Messaging Systems: Services used to maintain electronic communications between you and PROCOB, including those provided directly by us or third-party services such as WhatsApp, SMS (short message service), and similar platforms.

– PROCOB Mobile Applications: Mobile applications provided directly by PROCOB or through third-party services such as Google or Apple.

– Sales Center Communication: Communications conducted with You through our sales and service call centers.

– Advertisements, Promotions, and Online Forms: Interactions with any type of PROCOB advertisements, promotions, and online forms.

– Offline Records: Records filled out offline, distributed during events, and other interactions with PROCOB.

– Data Received from Third Parties: Including but not limited to social media platforms and third-party websites such as Facebook, Instagram, Linkedin, and similar services, data aggregator services, PROCOB partners, publicly available sources, and data received during the acquisition of other companies.

What Personal Data Do We Collect and How Is It Collected

During your interaction with PROCOB using one of the previously mentioned data sources, we may collect various types of personal data about you, as outlined below:

– Contact Information: This includes any information that facilitates our contact with you, including your physical mailing address, phone numbers, email addresses, websites, and profiles on social media platforms.

– Login Information: This encompasses information used to identify and authenticate you in services provided by PROCOB, including your username (login), irrecoverable password (encrypted), and security questions.

– Demographic Information and Your Interests: Any information that describes your demographic data, habits, or behavioral characteristics, including items such as your birthday, date of birth, age or age range, gender, geographic location, favorite products, hobbies and pastimes, other interests, and family or lifestyle information.

– Technical Information about Your Computing Equipment or Mobile Devices: Details about your computer or other portable device that was used to access one of our websites, services, or applications. This includes the record of the IP address used to connect your computer or device to the internet, including your geographic location, the type and version of operating system, and the type and version of the web browser. If you access a PROCOB website or application using a mobile device such as a cell phone or tablet, the collected information will also include, whenever permitted, the unique device ID of your phone, geographic location, and other similar mobile device data.

– Information about how you use our websites and services: During your interaction with our websites and services, we use automated data collection technologies to capture information about the actions you’ve taken. This may include details such as which links you click, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as response times to content, download errors, and duration of visits to specific pages. This information is captured through automated technologies such as Cookies (browser Cookies, Flash Cookies, and similar), web beacons, and third-party tracking. You have the complete freedom to oppose the use of such technologies; for details, refer to the section “About Your Rights Regarding Personal Data”.

– Market research and consumer feedback: These are pieces of information that you voluntarily share with PROCOB about your experience using our products and services.

– Consumer-generated content: This includes any content you create and share with PROCOB on third-party social networks or through uploading to our websites, applications, and other online and offline services, including the use of third-party social network applications such as Facebook, Instagram, Linkedin, and similar. This data includes texts, comments, articles, photos, videos, personal stories, or other similar content and media. Whenever allowed, we collect and publish consumer-generated content in connection with various activities, including promoting PROCOB’s products and services, contests, awards, and other promotions, website community features, consumer engagement, and third-party social networks.

– Third-party social network information: This refers to any data that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as Facebook, Instagram, Linkedin, and similar) and that you allow the third-party social network to share with us. This data can include details such as your basic account information (name, email address, gender, date of birth, current city, profile picture, user ID, friend list, and similar information) and any other additional information or activities that you allow the third-party social network to share with us. We receive your third-party social network profile information (or parts of it) whenever you download an item or interact with a PROCOB web application or service on a third-party social network, whenever you use a social network feature integrated into a PROCOB website, or whenever you interact with us through a third-party social network. To learn more about how your third-party social network information is obtained by PROCOB or to choose not to share this social network information, visit the specific third-party social network’s website.

– Financial and payment information: Any data that PROCOB needs to fulfill an order or that you use to make a purchase, such as your debit or credit card details (cardholder’s name, card number, expiration date, etc.) or other forms of payment used. PROCOB or our payment processing service providers handle your financial and payment information in accordance with applicable laws, regulations, and security standards.

– Contacts with our Customer Service and Sales Center: Your interactions with our Customer Service and Sales Center may be recorded or listened to, in accordance with applicable laws, for PROCOB’s operational needs. Details of financial and payment information are not recorded. When required by law, you will be informed about such recording at the beginning of your call.

– Sensitive Personal Data: PROCOB does not normally deal with Personal Data considered sensitive according to current legislation, and therefore we do not intend to collect or process sensitive personal data in the normal course of your interactions with our products or services. When there is a legitimate interest or a need to process your sensitive personal data for any reason, we will obtain your prior, explicit, and formal consent for any voluntary processing (for example, for marketing purposes). If we process your sensitive personal data for other purposes, we rely on the following legal bases: (i) detection and prevention of crime; and (ii) compliance with applicable law.

About Personal Data of Children and Adolescents

PROCOB does not knowingly request, collect, process, store, or share personal data from children and adolescents under the age of majority. If we discover any handling of such data, it will be unintentional, and we will promptly remove the personal data of that child or adolescent from our records. However, PROCOB may collect personal data of children and adolescents directly from their parents or legal guardians with explicit consent and in accordance with the rules of current legislation.

Regarding the Use of Cookies, Log Files, and Similar Technologies

Cookies are small text files that can be placed on your computer or portable device by websites or online services you use. They are used to ensure the proper functioning of websites and other online services, as well as to provide information to the owners of the website or online service.

Cookies are used to improve the use and functionality of PROCOB’s compatible websites and online services, and to better understand how our visitors use our websites and online services, as well as the tools and services they offer. Cookies make it easier for us to tailor PROCOB’s websites to your personal needs, facilitating their use whenever possible and gathering feedback on consumer satisfaction.

PROCOB uses the following types of Cookies on its compatible websites and services:

– Session Cookies: These are temporary use Cookies that are deleted as soon as you close your browser. When you restart your browser and return to the website that created the cookie, that site treats you as a new visitor.

– Persistent Cookies: These are Cookies that remain on your browser until you manually delete them or until your browser deletes them according to the duration period set by the cookie. These Cookies recognize your return as a visitor to a PROCOB website or service.

– Necessary Cookies: These are strictly necessary Cookies for the operation of a PROCOB compatible website or service. They allow you to navigate the site and use our features.

– Cookies that send us information about You: We place this type of Cookies on a PROCOB compatible website or service, and this type of Cookie can only be read by our compatible websites and services.

– Cookies in PROCOB advertisements: We place Cookies in advertisements displayed on third-party compatible websites and services. We obtain information through these Cookies when you click or interact with the advertisement. In this case, PROCOB is placing a “third-party” cookie. We may use the data obtained from third-party Cookies to send you other advertisements that we believe are relevant or of interest to you based on your previous behavior.

– Cookies that share your information with third parties: These are Cookies placed on a PROCOB website by our partner companies, such as online advertising services. They may use the data collected by these Cookies to anonymously send you targeted advertisements from other websites, based on your visits to PROCOB compatible websites or services.

PROCOB’s compatible websites and services may also use other tracking technologies similar to Cookies, which may collect information such as IP addresses, log files, and web beacons, among others. This data is also used to help us tailor PROCOB’s compatible websites and services to your personal needs.

See more details below:

– IP Addresses: An IP address is a number used on the internet or a network to identify your computer. Every time you connect to the internet, your computer is assigned an IP by your internet service provider. We may record IP addresses for the following purposes:

– Addressing technical issues;

– Maintaining the protection and security of our websites and other online services;

– Gaining a better understanding of how our websites and other online services are used;

– Tailoring our content to your needs based on your geographic location.

– Log Files: PROCOB or a third party working on our behalf may collect information in the form of log files that detail website activities and gather statistics about user browsing habits. Typically, these logs are generated anonymously and help us understand details such as:

– The type of browser and system used by users of our websites or online services;

– User session details, including the source URL, date, time, and which pages the user visited on our compatible websites and services, and how long the user used them;

– Other navigation or click-through details, including website traffic reports, unique visitor counts, and similar data.

– Web Beacons: We may use web beacons (also known as web bugs or transparent GIFs) on PROCOB websites. Web beacons are small code sequences that allow the delivery of a graphic image on a web page with the purpose of transferring data back to us. We use web beacon information for various purposes, including:

– Understanding how a user responds to email campaigns;

– Reporting website and compatible services traffic;

– Counting unique visitors, auditing, advertising and email reporting, and personalization on our websites and compatible services.

It’s important to remember that it’s up to you to ensure that your computer’s or portable device’s settings reflect whether you consent to accepting cookies or not.

Most browsers allow you to set rules to be notified before accepting cookies or simply to refuse them. You don’t need to have cookies enabled to use or browse most PROCOB websites and online services, however, in this case, we cannot ensure that you will be able to access all of their features. We recommend that you check the “help” button in your browser to learn how to perform this type of configuration. Remember that if you use different browsers or even different computers and/or portable devices in different locations, you need to ensure that each device and browser is set to your personal cookie preferences.

Since our web beacons can be part of a web page, it’s not possible to “opt-out” of this feature, but you can render it completely non-functional by activating the “opt-out” feature for cookies placed by this beacon.

About the use of your Personal Data

The following items describe the purposes for which PROCOB collects your Personal Data, and the different types of Personal Data we collect for each purpose. Please note that not all of the uses below will be relevant to all individuals and may only apply to specific situations.

– Consumer Services: Your Personal Data is used for the purpose of providing consumer services, including responding to your inquiries, questions, and suggestions. Typically, this requires certain personal contact information and information about the reason for your inquiry, question, or suggestion. For example, if you have made an order, experienced a technical issue, have a general question, or a complaint about a product.

Reason for using your personal data in this situation:

– Fulfill contractual obligations;

– Fulfill legal obligations;

– Our legitimate interests.

Our legitimate interests in this situation:

– Continuously improve PROCOB products and services;

– Continuously enhance the effectiveness of our consumer support.

– Conducting promotions and other marketing activities: With your consent (when required by applicable laws), PROCOB uses your Personal Data to provide information about products or services, such as marketing communications, advertising campaigns, or promotions. This can be done through various communication channels, including email, advertisements, SMS messages, phone calls, and postal mailings (as allowed by applicable laws), as well as on our own websites and/or third-party websites and social media. In this situation, the use of your Personal Data is entirely voluntary, meaning you can object to or withdraw your consent to the processing of your Personal Data for these purposes at any time. For more details on changing your preferences regarding marketing communications, refer to the “About Your Personal Data Rights” section in this notice. For more information about our Promotions, please refer to the regulations or details posted for each promotion.

– Reason for using your personal data in this situation:

– Fulfill contractual obligations;

– Our legitimate interests;

– We have obtained your consent (when necessary).

Our legitimate interests in this situation:

– Understand which of our products and services may interest you and provide information about them;

– Identify consumers for new products or services.

– Social media and third-party websites: We use your Personal Data when you interact with social media features and third-party websites, such as “liking” content, to provide advertisements and interact with you on third-party social media. How these interactions work, the profile data PROCOB obtains about you, and how to opt-out can be understood by reviewing the privacy notices directly on the respective social media and third-party websites.

– Reason for using your personal data in this situation:

– Our legitimate interests;

– We have obtained your consent (when necessary).

Our legitimate interests in this situation:

– Understand which of our products and services may interest you and provide information about them;

– Identify consumers for new products or services.

– Personalization (offline and online): With your consent (when required by applicable laws), PROCOB uses your Personal Data: (i) to understand your preferences and habits, (ii) to anticipate your needs based on our understanding of your profile, (iii) to enhance and personalize your experience on our websites and applications, (iv) to ensure that the content of our websites and applications is optimized for you and your computer or device, (v) to send you targeted advertising and content, and (vi) to enable you to participate in interactive features whenever you choose to do so. In this situation, the use of your Personal Data is entirely voluntary, meaning you can object to or withdraw your consent to the processing of your Personal Data for these purposes at any time. For more details, see the “About Your Personal Data Rights” section in this notice.

– Reason for using your personal data in this situation:

– Our legitimate interests;

– We have obtained your consent (when necessary).

Our legitimate interests in this situation:

– Understand which of our products and services may interest you and provide information about them;

– Identify consumers for new products or services.

– Fulfilling your requests: We use your Personal Data to process and fulfill your orders, as well as to inform you about the status of your orders, correct addresses, and conduct identity verification and other fraud prevention activities. This involves the use of certain Personal Data and, in certain situations, payment information.

– Reason for using your personal data in this situation:

– Fulfill contractual obligations;

– Legal obligations;

– Our legitimate interests;

– We have obtained your consent (when necessary).

Our legitimate interests in this situation:

– Improve and develop new products and services;

– Be more efficient in fulfilling your orders;

– Protect our systems, networks, and employees;

– Fully comply with legal obligations.

– Legal reasons or merger/acquisition: In the event that PROCOB or its assets are acquired by, or merged with, another company, including in the event of bankruptcy, we will share your Personal Data with our legal successors, in accordance with the requirements of applicable laws. We will also disclose your Personal Data to third parties:

(i) when required by applicable law;

(ii) in response to legal proceedings;

(iii) in response to a request from a competent legal authority;

(iv) to protect our rights, privacy, security, or property;

or (v) to enforce the terms of any agreement or the terms of our website, products, and services, as required by applicable law.

– Reason for using your personal data in this situation:

– Legal obligations;

– Our legitimate interests.

Our legitimate interests in this situation:

– Fully comply with legal obligations;

– Protect our systems, assets, and employees.

– Other purposes and general situations: In accordance with applicable laws, PROCOB uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research, and measuring the effectiveness of our advertising campaigns. We reserve the right, if you have PROCOB accounts, to integrate these accounts into a single account. We also use your Personal Data for the management and operation of our communications, IT, and data security systems.

– Reason for using your personal data in this situation:

– Fulfill contractual obligations;

– Legal obligations;

– Our legitimate interests;

– We have obtained your consent (when necessary).

Our legitimate interests in this situation:

– Improve and develop new products and services;

– Be more efficient in fulfilling your orders;

– Protect our systems, networks, and employees;

– Fully comply with legal obligations.

– On the disclosure of your Personal Data

– In addition to entities that are part of PROCOB, we may share your Personal Data with the following types of third-party organizations:

– Franchises: These include franchises that PROCOB uses to assist in operating our business. Franchises and their employees are only authorized to access your Personal Data on behalf of PROCOB for specific tasks that are requested of them based on our direct instructions. Our service providers are contractually obligated to keep your Personal Data confidential and secure, and in cases of violation, they are jointly responsible in accordance with applicable laws.

– Credit analysis agencies, debt collection, and financial services: As permitted by applicable law, credit analysis agencies and/or debt collection companies are external entities that PROCOB may use to assist us in verifying your credit status or collecting overdue payments.

– Third-party companies that use Personal Data for their own marketing purposes: Except in cases where you have provided specific consent, PROCOB does not license or sell your Personal Data to third-party companies for their own marketing purposes. In cases where such sharing occurs, the identity of these third-party companies will be disclosed before obtaining your consent.

– Third parties that use your Personal Data for legal reasons or due to merger/acquisition: We will disclose your Personal Data to third parties for legal reasons or in the context of a merger or acquisition involving PROCOB.

About the retention and termination of the processing of your Personal Data

In accordance with applicable law, PROCOB uses your Personal Data for as long as necessary to fulfill the purposes for which your Personal Data was collected, as described in this notice, or to comply with applicable legal requirements.

Personal Data used to provide a personalized experience to you will be retained only for the time allowed by applicable law.

You can obtain further details about the retention of your Personal Data through the communication channels detailed in this notice.

When the processing of your Personal Data is terminated, it will be deleted within the scope and technical limits of the activities, with conservation authorized in situations provided for by applicable law.

About disclosure, storage, or transfer of your Personal Data

PROCOB adopts appropriate measures to ensure that your Personal Data is kept confidential and secure. However, these protections do not apply to information you have chosen to share in public areas, such as third-party social networks.

Individuals who may access your Personal Data: Your Personal Data will be processed by our employees or authorized agents as needed to access such information, depending on the specific purposes for which your Personal Data was collected.

Measures taken in operational environments: We store your Personal Data in operational environments that use reasonable technical and administrative security measures to prevent any unauthorized access. We follow reasonable protocols to protect Personal Data.

Measures PROCOB expects you to take: It is important for you to also play a role in keeping your Personal Data secure. When creating an online account, please ensure you choose a strong password to prevent unauthorized parties from discovering it. We recommend that you never disclose or share your password with others. You are solely responsible for keeping this password confidential and for any actions performed through your account on PROCOB’s compatible websites and services.

If you use a shared or public computer, never choose the option to remember your login name, email address, or password, and make sure you log out of your account whenever you leave the computer. You should also use any privacy settings or controls that PROCOB provides on our website, services, or applications, including those that are considered optional.

Transfer of your Personal Data: Due to the nature of our business, we may need to transfer your Personal Data stored within PROCOB to third parties, in accordance with the purposes set out in this Privacy Notice.

About your rights regarding Personal Data

You have the right to confirm the existence, access, review, modify, and/or request an electronic copy of the information about your Personal Data processed by PROCOB.

You also have the right to request details about the origin of your Personal Data or the sharing of this data with third parties.

At any time, you can also limit the use and disclosure, or revoke consent to any of our processing activities of your Personal Data, except in situations provided by applicable law.

These rights can be exercised through the communication channels detailed in this notice, requiring the validation of your identity by providing a copy of your ID card or equivalent identification means, in accordance with applicable law.

Whenever a request is submitted without providing the necessary evidence to prove the legitimacy of the data subject, the request will be automatically rejected. We emphasize that any identification information provided to PROCOB will only be processed in accordance with, and to the extent permitted by, the applicable laws. We also highlight that in certain cases, we may not be able to delete your Personal Data without also deleting your user account. Additionally, some situations require the retention of your Personal Data after you request its deletion, to fulfill legal or contractual obligations.

Where available, our websites, applications, and online services may have a dedicated function that allows you to review and edit your Personal Data.

We emphasize that PROCOB requires validation of your identity using, for example, a login system with an access password or a similar feature, before allowing access or modification of your Personal Data, thereby ensuring that there is no unauthorized access to your account and associated personal data.

PROCOB strives to address any questions you may have about how we process your Personal Data. However, if you have unresolved concerns, you have the right to complain to the relevant data protection authorities.

Your choices about how we use and disclose your Personal Data

PROCOB enables you to have as much freedom as possible in choosing how your Personal Data is used. The following mechanisms give you control over the processing of your Personal Data:

Cookies/Similar Technologies: You can manage your consent by using:

– Our consent management solutions;

– Your browser settings to refuse some or all Cookies and similar technologies or to alert you when they are being used.

Advertising, marketing, and promotions: You can consent to have your Personal Data used by PROCOB to promote our products or services through checkboxes located on registration forms or by responding to questions posed by our representatives.

If You decide that You no longer want to receive such communications, You can unsubscribe from receiving marketing-related communications at any time by following the instructions provided in such communications.

To unsubscribe from marketing communications sent through any means, including third-party social networks, you can opt-out at any time by unsubscribing through the links provided in our communications, logging into our websites, applications, compatible online services, or third-party social networks, adjusting your user preferences, or by directly contacting our customer service.

It’s important to remember that even if you unsubscribe from our marketing communications, you will continue to receive administrative communications from PROCOB, such as orders, transaction confirmations, notifications about your account activities on our websites and compatible services, and other important non-marketing announcements.

Personalization (offline and online): Whenever allowed by law, if you want your Personal Data to be used by PROCOB to provide you with a personalized experience or targeted advertising and content, you can indicate this through the relevant checkboxes located in the registration form or by responding to questions posed by our representatives.

If You decide that you no longer want to benefit from this personalization, you can opt-out at any time by logging into our websites, applications, and compatible services and selecting user preferences in your account profile or by directly contacting our customer service.

Targeted advertising: PROCOB may partner with ad networks and other service or ad providers that present advertisements on our behalf or on behalf of non-affiliated companies. Some of these ads may be tailored to your interests based on the information collected on PROCOB’s websites and compatible services or on websites of non-affiliated organizations.

You can contact us using the communication channels detailed in this notice to obtain more information about how to manage or opt-out of targeted advertising.

Data Protection Officer (DPO): The Data Protection Officer is the professional responsible for informing, advising, and monitoring the data controller, as well as workers processing data, regarding PROCOB’s obligations under the General Data Protection Law (LGPD) and other data provisions in national and international legislation, in cooperation with the competent supervisory authority.

Data Protection Officer (DPO) of PROCOB:

ABREU, NABBOUH & ASSOCIADOS S/C – LEGAL OFFICE

Contact Email:

[email protected]

Changes to Our Privacy Notice

Whenever PROCOB decides to change the way we process your Personal Data, this notice will be updated. We reserve the right to make changes to our practices and to this Notice at any time, as long as we remain compliant with current legislation.

We recommend that you regularly access this notice, or whenever you have questions, to check for any updates or changes to our Privacy Notice.

How to Contact Us

You can contact us to:

– Ask questions or provide comments about this Notice and our privacy and Personal Data protection practices;

– File a complaint;

– Confirm the existence of the processing of your Personal Data;

– Obtain information on how to access your Personal Data;

– Correct incomplete, inaccurate, or outdated Personal Data;

– Obtain information on anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully treated data in accordance with current legislation;

– Obtain information on portability of your Personal Data to another service or product provider, upon express request, in accordance with current legislation;

– Request the deletion of Personal Data processed with your consent, except for cases provided by current legislation;

– Request details of public and private entities with which we share your Personal Data;

– Obtain information about the possibility of not providing consent and the consequences of such refusal;

– Revoke consent for the processing of your Personal Data, except for cases provided by current legislation;

– Other rights of the data subject, as per current legislation.

To do so, we ask that you contact us using the following channels:

Phone: +55 11 4000.1000
Email: [email protected]

PROCOB will receive, investigate, and respond within a reasonable time frame to any request or complaint about how we handle your Personal Data, including complaints about breaches of your rights under current privacy and Personal Data protection laws.

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