PRIVACY AND DATA PROTECTION POLICY OF ASLL AIRSEA LAND ASSESSORIA E LOGISTICA LTDA.
GEOBOX, aware of the importance and need of adjusting its personal data processing operations to the Law No. 13.709/18 – Brazilian General Data Protection Act – LGPD and other rules related to the subject, makes the disclosure of this policy demonstrating its obligation to the privacy of personal data of those who interact on its platforms, applications, websites or any other digital or physical means of communication.
The purpose of the Privacy and Data Protection Policy is establishing rules and procedures for the collection, processing, and safekeeping of information and/or personal data obtained in the course of its business activities, specifically those collected from the website, applications, and other interactive systems available on the Internet and used by the company.
The following terms and provisions set forth in this Policy are aligned with the provision of the LGPD and other national and international personal data protection regulations.
This policy is applied to (a) employees; (b) all third parties, either they are individuals or legal entities that act for or on behalf of the company in operations that involve the processing of personal data; (c) agents of personal data processing external to the company that somehow are related to the company; and (d) the data subjects whose data is processed by the company.
The objectives of this GEOBOX’S Privacy and Data Protection Policy are:
- Establishing company’s guidelines and responsibilities that ensure and reinforce the commitment to the compliance with applicable personal data protection legislations;
- Describing the rules to be followed in the conduction of the activities and operations of personal data processing carried out by the company and by the Recipients of this Policy, within the scope of the activities of the company, which ensures its compliance with the LGPD and applicable legislation regarding the subject;
The Policy should always be analyzed with the obligations provided in the following documents:
- Employment agreements of the company’s employees and other related documents;
- All internal rules regarding the personal data protection that may be prepared or updated;
- All agreements related to the company, which involve personal data or related sensitive information.
IV. PRIVACY AND PERSONAL DATA PROTECTION PRINCIPLES
GEOBOX shall comply with the following privacy and personal data protection principles regarding the processing thereof:
Purpose: process the personal data only for the legitimate and specific purposes informed to the data subject, without any possibility of further processing other than for the purpose specified;
Adequacy: process the personal data in a compatible form with the purposes informed to data subjects and according to the processing context;
Necessity: ensure that data processing is kept to the minimum necessary to fulfill its purposes, with coverage of the relevant, proportional and non-excessive data in relation to its purpose;
Free Access: ensure data subjects with the easy and free consultation regarding the use and processing, as well as regarding the integrity of the informed data;
Data quality: ensure data subjects with the accuracy, clarity and updating of data, according to the need and fulfillment of the purpose;
Transparency: ensure data subjects with clear and easily accessible information regarding the performance of the processing and the respective agents of data processing, according to the industrial and trade secrets;
Security: use technical and administrative measures to enable the protection of personal data from unauthorized access and from accidental or unlawful destruction, loss, change, communication or publication;
Prevention: adopt measures to prevent the occurrence of damages by virtue of the processing of personal data;
Non-discrimination: ensure the impossibility of data processing for unlawful or abusive discriminatory purposes;
Accountability: commitment to demonstrate the adoption of effective measures capable of proving the compliance with and respect for the personal data protection regulations.
V. LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA
The personal data processing operations by GEOBOX comply with the legal bases that legitimize their execution, with the respective purposes and designation of those responsible for the processing.
GEOBOX is committed to periodically evaluate the purposes of its processing operations, considering the context in which they occur, the risks and benefits they may cause to the data subjects and the legitimate interest of the company.
The performance of the processing operation of personal data by the company can be made in the following events:
- Upon provision of consent by the personal data subject;
- For the compliance with legal or regulatory obligation;
- For the conduct of studies by official research agencies;
- When necessary in the draft of agreements or related procedures to which the data subject is a party;
- For the regular exercise of rights in legal, administrative or arbitration proceedings;
- For the protection of the personal data subjects’ life;
- For the credit protection.
GEOBOX shall perform the records of its data processing operations indicating in each of its purpose, so that it can compose the periodic evaluation in the procedure of compliance with the LGPD and other related standards.
The data processing operations records can be consulted by the personal data subjects, as well as by competent public authorities, safeguarding the personal data subjects’ right.
The sensitive personal data processing that presents greater risks to its subjects shall be processed by the company with special care, according to Article 5, item II of LGPD.
The sensitive personal data processing operations can be made in the following events:
- When the personal data subject or its legal responsible consents in a specific form, clearly pointing out its purpose;
- Without the personal data subject’s consent, when it is indispensable in the cases of compliance with legal or regulatory obligations; the performance of internal researches; in the regular exercise of rights in the agreements and legal, administrative and arbitration proceedings; in the protection of the personal data subject’s life; in the guarantee of fraud prevention and the security of the personal data subject; and in the identification and authentication processes of registrations in electronic systems.
VI. RELATIONSHIP WITH THIRD PARTIES
LGPD establishes that the responsibility, in the cases of moral patrimonial damages, individual or collective, resulted from the violation of the legislation, is joint and several for all the agents of the chain that involves the processing of personal data, and they can be held responsible for the eventual caused damages.
In this sense, in face of the possibility of the company being held responsible for the acts of third parties, GEOBOX shall endeavor its best efforts to ensure that third parties comply with the data protection legislations, always reviewing and submitting the agreements to the adequacy of what the legislation provides.
VII. INTERNATIONAL TRANSFER OF DATA
In the events that GEOBOX is authorized to process personal data regardless of the data subject’s consent, it may transfer personal data to other countries, provided that, alternatively:
i. The country is classified at the appropriate level assigned by the ANPD (National Data Protection Agency) or the data transfer is authorized by it;
ii. While there is no list of adequate level countries disclosed by the ANPD, the country is classified by the European Commission, through an adequacy decision, as an adequate level country to the international LGPD criteria;
iii. Obtain explicit and distinguished consent from data subjects, duly informed on the purpose in a clear and explicit form.
GEOBOX undertakes to inform the data subjects on the occurrence of international transfer operations of personal data, indicating the set of informed data, the purpose of the sending and its destination.
VIII. GENERAL PROVISIONS:
GEOBOX safeguards its right to amend the content of this Policy at any time, according to the purpose or necessity, such as for adequacy and legal compliance with the provision of law or rule that has equivalent legal force, being applicable the disclosure by the contact channels that the parties have informed at the time of the negotiation or procurement of the services.
 Hereinafter referred to as Geobox or company.