To demonstrate Machado Meyer's commitment to the security and privacy of data/information collected from suppliers who have maintained or maintain a commercial relationship with Machado Meyer.
2. DATE OF EFFECTIVENESS
This Policy is effective as of February 9, 2021, for an indefinite period of time, and may be revised and updated whenever necessary, according to the responsibility matrix provided in item 8 of this document.
3. TO WHOM IT APPLIES
The Policy applies to all individuals linked to suppliers who have maintained or maintain a commercial relationship with Machado Meyer.
4. GENERAL GUIDELINES
4.1 The Policy will be published and disclosed internally on its intranet, externally on the Website www.machadomeyer.com.br and attached as an integral part of the contract signed with its suppliers and will be available for reading, according to the following wording, directed to the specific public - “SUPPLIER".
4.2 We explain in the Policy, clearly and transparently, to people who have worked or work for or on behalf of suppliers, or their partners or shareholders, what is done with the Personal Data we process.
4.3 The topics below clarify for what purposes personal Data of the persons indicated above is used, for how long, how you can access it, update it, and obtain additional information.
5. SPECIFIC GUIDELINES
5.1 We process Data of individuals who have worked or work for or on behalf of Suppliers, or their partners or shareholders, in the following categories:
- Registration data (name, RG, CPF, CNH, PIS, INSS registration number, e-mail, business address, home address, landline, mobile phone, department, position, company, profession, date of birth, nationality, marital status, professional registration (e.g. OAB, CRC), signature, photos, videos, CCTV image)
- Financial data (bank details, salary)
- Sensitive data (racial origin, biometrics only in units of São Paulo and the Federal District).
5.2 Machado Meyer, as the controlling agent, will make decisions regarding the personal data processed within the scope of the relationship established with you.
5.3 We process personal Data for the following purposes:
- Hire professionals for specialized services in legal and extrajudicial processes and outsourced services (reception, cleaning, maintenance);
- Supplier management: assessment, homologation, registration, contract drafting e payments;
- Maintaining custody of documents to support legal, tax, and business requirements;
- Security and physical access control to the office premises;
- Information security and business continuity plan;
- Control of internal and external mail (Dispatch);
- Internal and external publicization (social networks) of training/events sponsored internally by Machado Meyer; and
- Compliance with a legal or regulatory requirement.
5.4 We may share the Personal Data referred to in the Policy to render our services in the following instances:
- Client companies when requested;
- Competent public authorities (judicial and extrajudicial), government entities, regulatory or tax agencies for which Machado Meyer is subject to comply with a legal or regulatory obligation or under applicable local law.
- Operating Agents who handle your personal Data in accordance with Machado Meyer's instructions:
- Authorized service providers to support supplier management and for the execution of Machado Meyer’s professional activity;
- Technology service providers;
- Event organizing agencies to offer the services you have requested or that may be of interest to you;
- Document safekeeping services companies; and
- Providers related to physical security whenever you access our office premises.
5.5 Machado Meyer uses cloud systems, for this reason it is possible that Personal Data may be transferred outside Brazil (currently, to Chile and the USA), since they are the backup countries for the data storage of our service provider. To ensure that your Personal Data is processed solely for the stated purposes, we will adopt safeguards and guarantees such as specific clauses, standard clauses, and global corporate standards.
5.6 The Personal Data collected and processed by Machado Meyer shall be stored until the purpose of the Processing is exhausted or when there is no longer a legitimate purpose or a legal and regulatory reason that allows Machado Meyer to retain it.
5.7 We adopt safety standards set forth in applicable laws and regulations, such as:
- Training, governance, internal security policies;
- Control of storage on internal or outside servers
- Software to encrypt data collected;
- Protection against unauthorized access;
- Authorized access only to specific persons to the place where your personal information is stored, provided that such access is essential for the performance of the intended activity;
- Confidentiality of the professionals who access the information/data;
- Application of administrative, disciplinary, and legal sanctions against Staff Members and persons who unduly use your information, in violation of this Privacy and Information Security Policy;
- Absolute commitment to the principles laid down by the applicable laws and regulations, as well as the storage and deletion of data, the latter when requested;
- Access by Data Subjects to all of their information stored.
5.8 While our best efforts are put into preserving your privacy and protecting your personal Data, it is important for you to know that no transmission of information is ever completely secure. For this reason, Machado Meyer cannot fully guarantee that all the information it receives and/or sends will not be subject to unauthorized access and performed through methods designed to obtain information improperly, such as viruses or database intrusions.
5.9 In the event of a breach of Personal Data in our custody, we guarantee we will make every effort to remedy the consequences of the event.
5.10 In order to ensure your privacy and the protection of your data, Machado Meyer will facilitate the exercise of the rights described in article 18 of Law 13,709/2018, General Personal Data Protection Law, as applicable, which are:
- confirm the existence of Processing;
- access the data;
- correct incomplete, inaccurate, or outdated data;
- request anonymization, blocking, or elimination of unnecessary or excessive data or data processed in violation of the provisions of the General Personal Data Protection Law;
- request portability of data to another provider of a service or product, upon express request, in accordance with the regulations of the national authority, subject to commercial and industrial secrets;
- request erasure of personal data processed with the consent of the Data Subject, except in the cases provided for in article 16 of the General Personal Data Protection Law;
- obtain information on public and private entities with which the Controller has shared the use of data;
- obtain information about the possibility of not providing consent and the consequences of refusal; and
- request revocation of consent, pursuant to paragraph 5 of article 8 of the General Data Protection Law.
5.11 To meet the above requests, we will undertake all reasonable efforts within the shortest time possible, but you should be aware that the following may occur:
- Possible delay in service due to justifiable factors, such as the complexity of the request.
- Rejection of your request for formal (e.g., if you are unable to prove your identity) or legal reasons (e.g., request for deletion of data that may be kept by force of law or regulation; request for copy of a document that will only be provided if there is explicit consent; request for portability due to lack of specific regulation for the activity performed by Machado Meyer).
5.12 For any case of impossibility of meeting your request, Machado Meyer will provide due reasons.
5.14 In the Policy, all the relevant and necessary information regarding the Processing of your Personal Data may be found and, therefore, we strongly recommend reading this entire document.
6. TERMS AND DEFINITIONS
Individual or legal entity, public or private, Brazilian or foreign, as well as depersonalized entities that carry out activities of production, assembly, creation, construction, transformation, import, export, distribution, or marketing and sale of products or rendering of services.
Any information relating to a directly or indirectly identified or identifiable individual.
Sensitive personal data
Special category of personal data concerning racial or ethnic origin, religious belief, political opinion, membership in a trade union or a religious, philosophical, or political organization, concerning health or sex life, genetic or biometric data concerning individuals.
Individual to whom the Personal Data refers, such as, for example, the persons to whom this policy applies: persons who worked or work for or on behalf of clients, suppliers, or who are its shareholders and who maintained or maintain a business relationship with Machado Meyer.
Data Protection Officer
Person appointed by the Controller and Operator to act as a communication channel between the controller, the data Holders, and the National Data Protection Authority (ANPD)
Designates the electronic address www.machadomeyer.com.br and its subdomains
Any operation performed with personal Data, such as those relating to the: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, discarding, assessment, or control of the information, modification, dissemination, transfer, diffusion, or extraction.
- Code of Conduct
- Information Security Policy
- Physical Security Policy
- Document Management Policy
- Data Protection Standard
- Procedure for the enforcement of Data Holders' Rights
- ISO 27701
- Federal Law No. 13,709/2018 (General Personal Data Protection Law)
- Federal Law No. 12,965/2014 (Brazilian Civil Rights Framework for the Internet)
- Federal Law No. 8,078/1990 (Consumer Protection Code) and other applicable laws for the activity provided by Machado Meyer.
8. RESPONSIBILITY MATRIX
|Executive Board|| |
|Information Security and Privacy Committee (CSI&P)|| |
|Information Security|| |
|Responsible Person for personal data Processing (Data Protection Officer - DPO)|| |