Privacy Policy

Please read carefully, your privacy is of great importance to us!

By clicking on the “ACCEPT”, the USER declares himself aware and agrees that his data will be treated in accordance with this Privacy Policy, which integrates the Terms of Use of our Organization's website. If the user does not agree with the terms and conditions set forth herein, he/she must immediately stop using our website.

GLOSSARY
Senior Management	Highest decision-making body of a given organization. For the purposes of this policy, it may also refer to lower bodies immediately subordinate to it to which the highest deliberative body has delegated the powers to make certain decisions.
Threat	Potential cause of an unwanted incident, which could result in damage to the Organization.
Active	It is anything that is of value to the Organization and needs to be adequately protected.
Committee on Information Security and Data Protection (CSIPD)	Body responsible for implementing, directing and improving the Integrated Management System in Information Security and Data Protection (SIGSIPD).
Controller	Entity responsible for making essential decisions, especially regarding the purpose and means of treatment.
Coordination	Administrative subdivision within the Organization in accordance with a given area of activity.
Personal data	Any and all data or information that can be directly or indirectly associated with a physical (human) person.
In charge of Data Protection /Data Protection Officer (DPO)	Responsible for directing the Data Protection Committee in its activities and for serving as an intermediary between the interested parties and the Organization.
regulatory entities	Legal entities and bodies whose primary function is the supervision of a given economic activity.
Operator	Subject who processes personal data in the name and on behalf of the controllers.
Information	Set of data that, whether processed or not, can be used for the production, transmission and sharing of knowledge, contained in any medium, support or format.
Economic Partners/Partners	Subject, natural or legal person, with whom a given organization has or plans to do business, including, but not limited to, suppliers, operators and contracted representatives;
Websites/Websites	Common name for internet pages.
International Transfer of Personal Data	Operation in which personal data is transferred outside the national territory, regardless of the medium in which it occurs.
Treatment	Any operation made with personal data.
Holder	Natural person to whom the personal data refer.
User	Individual or legal entity that makes use of the Web site, whether as a mere visitor or accessing its features.
Promotion User	Individuals who sign up for promotions carried out by the Organization and/or partners.

Introduction to the Privacy Policy

The Privacy Policy is a formal document that seeks to clarify for the general public, as well as for employees, partners, customers and regulatory entities, the personal data treatment and privacy practices adopted by the Organization.

The Privacy Policy serves to convey to the data subject the conditions under which their personal data will be processed by the Organization's team.

This Privacy Policy applies to the processing of data by Users of the Web site of the Organization, and must be respected by all those who represent, integrate or maintain relations with any of these organizations.

The Privacy Policy does not derogate (revoke) other internal rules, as long as they are compatible with it.

What do we do with your data?

We, at Fluxo Soluções Integradas, value your privacy and wish that any treatment of your data that we may do be carried out in a transparent way, so that we can maintain a relationship of mutual trust and partnership. To this end, we seek to list the usual ways in which we can process your personal data:

What personal data do we process? As controllers, we can handle:

1. Your name, informed when filling out the contact form;
2. Your e-mail, informed when filling out the contact form;
3. Your browsing history, through navigation cookies, under the terms set out in our Privacy Policy. Cookies;
4. Other data necessary to comply with legal obligations or voluntarily offered by you.

What do we do with your data?

1. We may use your name and e-mail address to receive, categorize, manage and return the contact, as well as for possible adoption of measures regarding the reason for your contact, respecting your legitimate interest.
2. We use your browsing history, collected through Cookies navigation in terms of our Privacy Policy Cookies, to optimize your experience on our website, within the limits of your legitimate interest.
3. We may process your personal data to comply with other legal obligations or in response to requests made by you or judicial and administrative authorities.
4. We may process some of your personal data for the purposes of accountability and auditing, seeking to guarantee our honesty, the adequate provision of our services and our compliance with the legal norms in force.

What legitimate bases do we use to process your data?

1. The data of users who contact the Organization through the contact form will be treated, as a rule, on the basis of legitimate interest (item IX, article 7 of the General Data Protection Law), the Organization and/or the Owners.
2. User data will be treated based on legitimate interest.
3. The processing of data referring to the fulfillment of their Rights as Holders operates on the basis of Compliance with Legal Obligation.
4. We may process your personal data, when required by law or by a judicial and/or administrative authority, in which case we will be based on compliance with a legal obligation.

Sharing Personal Data with third parties and international data transfer:

We may share your data with third parties located outside Brazilian territory, when so commanded by legal obligation, court order or request from a regulatory authority.

How long do we store your data?

Except when required by law, we do not store the personal data of the user who only access the website to access the content.
The data of the User who makes contact through the website form is processed for the time necessary to properly process the requests that may be forwarded.

Your rights and how to exercise them

We, at Fluxo Soluções Integradas, respect the rights granted to holders as necessary for the proper functioning of democracy in a digital world and we always seek to inform them about these rights, as well as to facilitate their safe exercise.

What Rights do the Holders have? The General Data Protection Law (Law No. 13.709/2018) reaffirmed a series of rights to the Data Subject, which may be exercised under the terms of this policy, namely:
1. Right to Information: is the right of the data subject to obtain clear, accurate information in simple and intelligible language regarding the processing of information about him. It includes the right to confirm the existence of a treatment, to access the data that the organization contains about you, to be informed about the transfer of this data to third parties and the consequences of refusing to grant your consent.
2. Right of rectification: is the right of the holder to correct any data that is wrong or out of date about him.
3. Right to be forgotten: grants the holder the right to anonymize, block or delete data that have become unnecessary or are being treated in violation of the General Data Protection Law.
4. Right of Portability: is the right of the data subject to receive a copy of all personal data concerning his person that are in the possession of the organization, or to request that said copy be sent directly to a data controller.
5. Right to Withdraw Consent: guarantees to the Data Subject that, if the data processing is based on their consent, they may, at any time and in a no more complex way than the one with which their consent was collected, withdraw the aforementioned consent and demand the elimination, blocking or anonymization of your personal data processed on the basis of them.

How can the holder exercise his rights?

The holders can exercise their Rights by contacting the Data Protection Committee, through the email address “dpo@fluxo.si”. Our DPO, Ms. Christina Tiscenko, will serve you.

We request that the request, and the information on which it is based, be presented in a clear and precise manner, in order to enable a speedy and effective service.
In order to avoid fraud, the holder-applicant may be asked to attach, along with the request, a copy of a document proving his identity.
Said copy of the document will be discarded once the holder's request has been met, however data contained therein may be kept on record for purposes of demonstrating compliance.

Contact

In case of further queries regardingthe use and security of your data, you can contact our Committee, through our DPO, Ms. Christina Tiscenko, via the email address “dpo@fluxo.si”.

Policy Review

Our Organization is in a process of continuous improvement, which is why we reserve the right to review and update this policy whenever necessary. In addition, we undertake to visit and review it at least annually.