Data Privacy Policy

1 PURPOSE

Narwal Sistemas, as a company of the BECOMEX GROUP, prioritizes the proper, accurate, and secure processing of data in its business model. The purpose of this document, therefore, is to explain how Narwal Sistemas carries out the processing, collection, use, storage, and/or handling of personal data collected on our websites — in a transparent, responsible, and ethical manner, always observing the provisions of Law No. 13,709/2018 (the General Data Protection Law — “LGPD”) and other applicable legislation on the subject.

We recommend that you read this Privacy Policy, and if you have any questions, suggestions, or requests, please contact us at privacidade@narwalsistemas.com.br.

2 SCOPE

This policy applies to all personal data collected on our corporate website.

3 DEFINITIONS

For the purposes of these Terms, the following definitions apply:

National Data Protection Authority (ANPD): A regulatory agency, linked to the Ministry of Justice and Public Security, whose mission is to safeguard the protection of personal data as guided by the General Data Protection Law (LGPD). Its responsibilities include, without limitation, safeguarding the protection of personal data and overseeing and applying sanctions in cases of data processing carried out in breach of the legislation, under the terms of the LGPD;
Cookies: small units of data stored by your browser on your computer’s hard drive. Cookies are necessary for the use of the Platform.
Controller: the natural or legal person, governed by public or private law, responsible for decisions regarding the processing of personal data;
Personal data: any information relating to an identified or identifiable natural person;
Sensitive personal data: personal data concerning racial or ethnic origin, religious belief, political opinion, membership in a trade union or in a religious, philosophical, or political organization, data concerning health or sex life, and genetic or biometric data when linked to a natural person;
Economic group: companies that, while each retaining its own autonomy, are part of an economic or financial group;
General Data Protection Law (LGPD): the law governing the processing of personal data, including in digital media, by a natural person or by a legal entity governed by public or private law, regardless of the medium, the country where the entity is headquartered, or the country where the data is located, provided that (i) the processing operation is carried out within the national territory; (ii) the purpose of the processing activity is to offer or supply goods or services, or to process data of individuals located within the national territory; or (iii) the personal data being processed was collected within the national territory;
Processor: the natural or legal person, governed by public or private law, that processes personal data on behalf of the controller;
Intellectual property: comprises the rights relating to industrial property and copyright, the latter understood to include authors’ rights and related rights;
Processing: any operation carried out with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction;
Data Subject: the natural person who merely accesses the Platform, as well as the person who completes the registration form and agrees to the Privacy Terms.

4 GUIDELINES

Privacy principles guide our business processes, where our information and that of our clients must be handled with care, in compliance with the information security principles established in the company’s strategic objectives.

4.1 What Information Do We Collect?

We collect personally identifiable information, such as your name and email address, directly from you when you complete the “I’d like more information — Leave your details and we’ll get in touch,” “Request Our Contact,” and “Work With Us” forms on our website. We use this information to respond to the request you submit to us through the contact form.

4.2 How Do We Collect Your Personal Data?

Our website uses cookies, which are small text files stored on the user’s computer. Cookies store non-personally-identifiable information related to your browsing on our website. We only collect the products and pages you may have browsed.

Our cookies are placed for the purposes of:

Personalizing your browsing: These cookies allow us to recognize you and remember any information you provided during your browsing on our website, such as: language preference, which country you are visiting us from, browser type, etc. This makes your visit to our website easier, since we don’t ask for the same information multiple times during your browsing.
Website analytics: We use Google Analytics cookies to collect information related to web traffic and the number of visitors. These are tools that allow us to measure browsing performance on our website and to deliver personalized marketing messages.
Social: We use communication tools to share links with social networks. If you click on these features, the company responsible for the social network may collect your IP address, which page you are visiting on our website, and may place cookies when you are logged in to its services. Your interaction with these features is governed by the privacy policy of the company responsible for the social network. For more information about the cookies used by these sites, you can read their specific privacy statements listed below: Facebook: http://www.facebook.com/about/privacy/
Google+: https://www.google.com/intl/en/policies/privacy/
LinkedIn: http://www.linkedin.com/static?key=privacy_policy&trk=hb_ft_priv
Twitter: https://twitter.com/privacy

We will not process any of this information, directly or indirectly, with the help of a third party or otherwise, to determine your identity.

Search Engine Marketing: We use the Google AdWords service to advertise on Google’s search results page. Google uses cookies to display ads based on your activity. To learn more and how to join the opt-out list, see Google’s specific page on its privacy policy and settings for Google ads.

Your Autonomy: You hold the power to turn off your cookies in your browser options, or by making changes to the tools of antivirus programs. However, this may change the way you interact with our website. It may also affect permission to log in to exclusive areas of our website or to our company’s social media content.

4.3 How We Use Your Information

We use the information collected on our website for marketing purposes, such as sending newsletters or other promotional emails. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these communications.

4.4 Data Sharing

We do not share your information with third parties for promotional purposes. We may share your information solely for storage purposes, such as with an email service provider or with data centers. We reserve the right to disclose your personally identifiable information as required by law, as part of a merger, acquisition, or sale of assets, and when we believe that disclosure is necessary to protect our rights and/or comply with judicial proceedings, a court order, or legal process.

4.5 Responsibility for and Protection of Your Personal Data

Narwal Sistemas, in its capacity as controller of your data under the terms of the law, is responsible for the processing and the processing guidelines for the data when shared with suppliers and partners, under the terms of this policy.

4.6 Storage Period of Your Information

Your personal data will be stored in our systems for a period no longer than necessary to fulfill the purposes of the processing, taking into account, in particular, the legal obligations of Narwal or the group’s companies.

The data retention period is defined according to the following criteria:

The length of use based on the service chosen by the user on the website and/or the term of the contract established with the organization;
The data will be retained by the organization, after the end of the chosen service or contract, in the following cases: to comply with a legal or regulatory obligation of the controller;
for study by a research body, ensuring, whenever possible, the anonymization of personal data;
for transfer to a third party, provided that the data processing requirements set out in the legislation are observed;
for the exclusive use of the controller, with access by third parties prohibited, and provided that the data is anonymized.

4.7 Your Rights as a Data Subject

You may contact us at any time to obtain information about which personal data or which information we hold about you, as well as to exercise any of your rights, such as:

Confirmation of and access to data: the right to obtain confirmation as to whether or not personal data concerning you is being processed by the organization and, if so, the right to access your personal data;
Rectification of data: the right to request the correction or updating of personal data concerning you that is inaccurate or out of date;
Deletion of data: the right to have your personal data deleted from the website, subject to Narwal’s legal rights and obligations;
Anonymization of data: the right to have your data anonymized — that is, dissociated from any and all forms of connection with its Data Subject, making identification impossible;
Blocking of data: the right to temporarily suspend the processing of your personal data when it is inaccurate, used unlawfully, or used without observing the stated purposes or for unnecessary purposes;
Objection: the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you, subject to Narwal’s rights;
Data portability: the right to request the transfer of your personal data to another service or product provider;
Obtaining information about data sharing: the right to obtain information about the public and private entities with which the controller has carried out shared use of your data;
Obtaining information about consent: the right to obtain information about the possibility of withholding consent and the consequences of doing so;
Right to obtain review of automated decisions: the right not to be subject to any decision made solely on the basis of automated processing (if any);
Right of revocation: the right to request the revocation of your consent for the processing of your data by Narwal.

The information above may be requested at any time by the data subject via email: privacidade@narwalsistemas.com.br.

We emphasize that your request will always be addressed within a reasonable time frame, as determined by law. However, there are situations in which your data cannot be deleted or destroyed, for example:

Conflict with any other applicable law or regulation that requires Narwal to retain the data.
The existence of a contractual relationship established between the Data Subject and Narwal, in which only the termination of the contract would allow the deletion of the data, subject to legal and regulatory obligations.
The existence of judicial, administrative, or arbitration proceedings, in which the data may be required to be provided for the progress of the proceedings.

4.8 Data Protection Officer

All information related to the processing of Personal Data, as well as the guarantee of the Data Subject’s rights set out in this policy, will be handled through the Data Protection Officer appointed by Narwal Sistemas, in this case represented by:

Data Officer: Rogério Borili Pereira.
Position: Data Protection Officer (DPO).
Email: privacidade@narwalsistemas.com.br.

5 FINAL PROVISIONS

This Privacy Policy may be amended at any time, with immediate effect, in accordance with our internal needs or with legislative changes that lead us to update this policy.

The version of the policy can always be confirmed at the bottom of the pages by reviewing the document with the date of the last amendment.