PERSONAL DATA HOLDER RIGHTS POLICY

We at CAVALETTI S/A – Professional Seating, a legal entity governed by private law, registered with CNPJ No. 88.709.621/0001-90 are committed to ensuring transparency in the information (“Personal Data”) we handle and, for this reason, we make available to the user (“You”) this Personal Data Holder Rights Policy (“Rights Policy”), which must be read in conjunction with our Privacy and Personal Data Protection Policy.

The Brazilian laws of privacy and protection of personal data assure You, holder of Personal Data, a series of guarantees (“Rights of Holders” or “Rights”) that put You in control of the information You provide to us. As a way of informing you about your Rights and how to exercise them, we present below everything that applies to you:

1. HOW TO EXERCISE YOUR RIGHTS?

Cavaletti S/A Profesional Seating, has trained professionals to answer your questions and requests. In order to exercise your Rights, you must complete our Request of Rights Form (“Form”) available online at www.cavaletti.com.br.
It is important to emphasize that fathers, mothers or legal guardians may exercise their rights on behalf of children or adolescents, under the terms of the applicable legislation.

2. WHAT ARE YOUR RIGHTS?

    • Confirmation of the existence of treatment: This Right allows you to request and receive confirmation about the existence of collection, storage, sharing or any type of Treatment based on your Personal Data.
    • Access to personal data: This Right allows you to request and receive a free and accessible copy of the Personal Data processed by us.
    • Correction of incomplete, inaccurate or outdated data: If you identify any inaccuracy or inaccuracy in your Personal Data that we process, you may request that we rectify them.
    • Anonymization, blocking or elimination of Personal Data that is unnecessary, excessive or treated in violation of the legislation: This Right allows the anonymization, blocking or elimination of Personal Data from our database to be requested. All Data collected will be anonymized, blocked or deleted from our servers when possible and requested by you.
    • Portability: Cavaletti S/A Profesional Seating, allows You or a named third party to gain access to Personal Data that is processed by us in a structured and interoperable format.
    • Revoking or not providing consent: You have the right to withdraw your consent or, where appropriate, not to provide it to us and to be informed of the consequences of the refusal. In some cases, it is possible that the refusal results in the impossibility of providing you with certain products or services.
    • Review of automated decisions: You have the right to request a review of decisions made solely on the basis of Automated Processing of Personal Data and to receive clear and adequate information regarding the criteria used in the decision, provided that this information does not violate any commercial secret of the group companies.
    • Opposition to treatment: You also have the right to object to certain purposes of processing Personal Data, such as, for example, sending advertising, newsletters or new offers.
    • Deletion of Personal Data processed with consent: If you have given us your consent for a Processing purpose, you can request the deletion of the Personal Data that we have stored until then.

 

3. HOW WILL YOUR REQUEST BE ANALYZED?

When we receive your request, our privacy and data protection team will analyze it and may respond in two ways, determining that: (i) your request is lawful and legitimate, and therefore must be complied with; or (ii) your request has been denied and, for certain reasons, cannot be honored. Don’t worry, because even in case of denial, we will inform you of the reasons why your order was not approved. All our responses will always be sent by the same means by which you contacted us, either email or mail.

It may be necessary to ask you for specific information to confirm your identity and ensure that you can exercise your Rights. This is a security measure to ensure that the Data is not disclosed to anyone who does not have the legitimacy to receive it. This measure is necessary considering, above all, our concern with the information we deal with children and adolescents.

If your request is accepted, we will do our best to contact our suppliers and business partners who may have access to your Personal Data so that they can also rectify, eliminate or exercise any other Right you have requested. However, unfortunately, we cannot guarantee the actual exercise of these Rights by these third parties, who use, disclose and protect Personal Data in accordance with their respective policies.

We may store and maintain, in the form of a record, a history of requests for Rights that You have made so that we can, if necessary, present it to the competent authorities as proof that we have responded to requests in a timely manner and in an appropriate manner, in accordance with the law lays down.

 

4. HOW LONG WILL IT TAKE TO RESPOND TO YOUR REQUEST?

Upon receipt of your request, our team will respond to you within the following deadlines:

HOLDER’S RIGHT DEADLINE
Confirmation of the existence of treatment Within 15 calendar days from receipt of the request
Access Within 15 calendar days from receipt of the request
Anonymization, blocking or deletion Within 15 calendar days from receipt of the request
Portability Within 15 calendar days from receipt of the request
Revocation or non-provision of consent Within 15 calendar days from receipt of the request
Automated decision review Within 15 calendar days from receipt of the request
Deletion of Data processed with consent Within 15 calendar days from receipt of the request

If clarification or more information about your request is needed, we may send you some questions so that we can respond to your request in a satisfactory manner, so that the deadlines will be suspended from sending our questions to receiving your response.

5. IN WHAT SITUATIONS CAN WE DENY YOUR RIGHT?

Your Rights are not unlimited and, therefore, we present below some situations that may lead to their total or partial denial:

  • Preservation of business secrets and intellectual property of the group’s companies;
  • Violation of the rights and freedoms of others;
  • The information is anonymized and therefore is not Personal Data;
  • Obstruction of law and justice;
  • The legitimate interests of the group companies override those of the data subject;
  • The holder has made repetitive or excessive requests.
  • In any case, we will respond to requests in time and will inform you clearly about the reasons that led us to the eventual denial of your request.

6. HOW CAN I CONTACT CAVALETTI S/A PROFESIONAL SEATING?
Caso tenha dúvidas, comentários ou sugestões relacionados a esta Política, você pode entrar em contato com o time de privacidade da Cavaletti pelo seguinte meio:

If you have questions, comments or suggestions related to this Policy, you can contact Cavaletti’s privacy team by the following means:

Supervisor: Esfera Compliance
E-mail for contactencarregado@cavaletti.com.br

Changes in the Rights Policy

How Cavaletti S/A Profesional Seating is always looking to improve its services, this Rights Policy may undergo updates. Therefore, we recommend that you periodically visit this page to learn about the changes. If material changes are made that require a new consent, we will post that update and ask You for a new consent.

DATA DA ÚLTIMA ATUALIZAÇÃO: 29 de December de 2023