Last updated on June 27, 2022

 

VRI Industria Eletrônica LTDA has as its mission to perpetuate the organization through businesses, processes, and people aimed at the constant profitability of the operation, combined with respect for the environment and integrated with the community and its culture. Communication and digital services on the world's leading messaging channels.

VRI cares about the privacy and protection of the personal data of its clients, employees, partners, suppliers, and all other personal data subjects, and is committed to ensuring that these rights are respected, complying with applicable laws, especially Law No. 13.709/2018 ("General Personal Data Protection Law" or "LGPD").

This Privacy Policy ("Policy") aims to inform users of the VRI website and other data subjects about how their personal data will be processed when they access and use the website and interact with VRI through other means.

If you have any questions about the content of this Policy, please contact our Data Protection Officer directly at the e-mail: ti@vri.com.br

1. How do we collect your personal data?

When you access and use our website or when you interact with VRI through other means, we may collect your personal data in different ways, such as those indicated below:

Through the provision of information when you contact VRI directly through our website or by other communication channels, such as telephone, e-mail, or messages on our social networks.

Through the automatic collection of data, such as information about your device type, your device's unique identifier number, browser type, approximate geographic location, by means of your browser's tools and other technologies, such as cookies (see section 7 of this Policy).

Through the receipt of your personal data from recruitment companies, referrals, or other people who share your data with us in order to allow your participation in selection processes conducted by VRI.

Through the receipt of your personal data from our partners, group companies, service providers, suppliers, or third parties, such as in cases where we have business relationships with your employer, when we may receive your personal data to ensure our communication and confirm your identity as an employee of that company.

 

2. For what reasons do we collect your personal data?

VRI processes your personal data for various purposes, according to your relationship with us and the way you interact with us.

Among the main purposes for which we collect, process, or otherwise handle your personal data are the following:

For user registration. We will process the personal data that is necessary to complete your registration as a user on the VRI platform, in order to allow the creation and management of your account, whether it is linked to your employer or directly to you.

To respond to your questions, compliments, complaints, suggestions, and to communicate with you. When you contact us, whether through our website, by telephone, by e-mail, through the Help Center, relationship and customer/consumer service sites, or by any other means of communication, we will process your personal data so that we can communicate with you, responding to your questions, compliments, complaints, or suggestions, as well as to any message you have sent us.

To promote our activities. We will process your personal data to send you our newsletter, invitations to events held by VRI and/or with partner companies, as well as newsletters about our services, surveys, studies, news, videos, promotions, new solutions, or any other content or material we produce, in order to promote our activities.

For marketing, sending information about our products or services. If you already have a commercial relationship or have interacted with VRI previously, or have registered to receive materials and newsletters, through the website, content downloads, or access to sponsored media, we may process your personal data for marketing and/or to send information about the products or services provided by VRI.

To contact potential clients, leads, and prospects. If you have filled out the form on our website, provided your information via landing pages, or if we identify that you or your organization may be interested in our products or services, we will process your personal data to promote our activities and to contact you and share information about the solutions offered by VRI.

To conduct satisfaction surveys. We may process your personal data to carry out satisfaction surveys, to identify whether the products or services we offer are being received positively and what can be changed so that usability and operability are improved.

To recruit new employees. When you send us your résumé by e-mail, social networks, instant messaging applications, among others, when we receive your résumé from third parties, or when we have an open selection process and seek professionals in the market, we will process your personal data for the purpose of recruiting new employees, contacting them and allowing them to participate in all stages of the respective selection processes, such as interviews, group dynamics, practical or theoretical tests, among other activities inherent to the recruitment process, to assess the compatibility of your professional profile with the characteristics of the open position.

When you access and browse our website, we will process your personal data to understand aspects related to the use of the website, such as the pages that were visited and the duration of visits, the form of interaction, the most used tools, among other aspects related to the use of the platform, in order to improve the content provided to visitors, clients, and data subjects, as well as process your personal data to identify the engagement rate of the e-mails we send and of the interaction with the content we publish, so that we understand which materials we produce are being best received by our users.

To ensure the security of our platforms. We will process your personal data to ensure the security of the website, evaluating unusual patterns in relation to its use, high volumes of unexpected access requests, access attempts with invalid logins and passwords, among other actions that may indicate a cyberattack or an attack against the confidentiality, integrity, or availability of our systems.

To comply with legal or regulatory obligations or court orders. When we need to comply with legal or regulatory obligations or court orders, we will process your personal data that is necessary for such purposes, including by sharing this data with public bodies and with the Judiciary.

To defend ourselves in judicial, administrative, or arbitration proceedings. When necessary, we will process your personal data to defend our interests in judicial, administrative, or arbitration proceedings brought by you or by third parties against us, or brought by us against you or against third parties.

To ensure the security of our facilities and employees. If you visit our physical facilities, we will process your personal data to ensure the security of our employees and our facilities, including the security of the information we store, whether it is personal data, trade secrets, or other corporate information.

To ensure the protection of your health, the health of our employees, and of third parties. If you visit our physical facilities in person, we will process your personal data to ensure that you, our employees, or third parties do not show any symptoms of an infectious contagious disease (especially COVID-19) that could compromise everyone's health.

To evaluate new acquisitions. We will process your personal data when necessary in the process of evaluating new acquisitions of products, services, or equity interests in other organizations, especially during the legal or tax due diligence process, during which we may have access to information about employees of the organizations we are evaluating as commercial partners or as potential acquisitions of equity interests.

To investigate any reports. When you initiate or are involved in a report made through our Whistleblowing Channel, about conduct inconsistent with our corporate values or that violates current legislation, we may process your personal data to investigate the reports made and, if you were the whistleblower and choose to reveal your identity, report to you the developments of the process relating to the reports.

For credit analysis. In cases where VRI sells products or services to you, we will process your personal data to assess your ability to meet your financial obligations and to protect our credit.

Holding meetings, videoconferences, or telephone conferences. We will process your personal data to hold meetings, videoconferences, or telephone conferences, including, depending on the means used, your image and voice, as well as identification and electronic correspondence data, to send invitations and links to access the meetings.

To receive referrals from third parties. We will process your personal data when we receive referrals from third parties about your potential interest, or the potential interest of your organization, in contracting our products or services, allowing our subsequent contact with you to present our solutions.

To carry out internal audits. We will process your personal data when necessary to carry out internal audits of our platforms and systems, including in relation to financial, tax, and accounting audits, audits of compliance with the laws and regulations to which we are subject, audits of financial and risk controls, audits for the reorganization, sale, assignment, or transfer of part or all of our assets, audits required by Government Authorities, or any other audits that are necessary or relevant to the proper development of our business.

 

3. What data do we collect?

To achieve the purposes indicated above, we may process one or more of the following personal data, to the extent that they are necessary for the respective purposes:

User registration data. When you are a user of the website, we will process data such as your full name, e-mail, and telephone number to create your account and to receive our newsletter and marketing e-mails. For the Sales team to contact you, we will process the data filled in the form, such as your full name, e-mail, telephone number, and your position at your company.

Usage and device data. We will process data related to your use of the site, such as clicks, page scrolling, cursor scrolling and pages visited, geolocation, date and time of access, your device's IP, browser used, device type, language preference, features used, registrations made, among others.

Other information. We will process additional data that may be voluntarily entered by users in their resumes or in the communications sent to VRI, by email, correspondence, or any other means.

 

4. With whom is your personal data shared?

We may share your personal data with:

Companies of our Economic Group. We may share your personal data with the other companies of our economic group, in order to improve our products or services and to gain efficiency in our business, such as in the case of the use of single or integrated systems among companies of the same group.

Our partners, service providers and suppliers. To carry out our commercial activities, we maintain relationships with and engage various partners, service providers and suppliers that are essential to our business. Some of these partners and suppliers may need to have access to the personal data we collect in order to perform their functions as cloud data hosting service providers or solution providers for sending email communications, external recruiters, auditors, banks and affiliated companies, in which cases we will share your personal data with them. We carry out an assessment of all our partners and suppliers, requiring that personal data be processed in compliance with all applicable laws and ensuring information security, so as to minimize any risks in the sharing of data.

External Advisors. We may share your personal data with external advisors who provide services to us, including financial, accounting, legal or technical advisors, who need to have access to the data in order to perform the activities for which they were engaged.

Government Authorities. We may share your personal data with any and all Government Authorities that request it, including with agencies that oversee labor activities or financial activities, in order to comply with our legal or regulatory obligations.

Judiciary. We may share your personal data with Judiciary bodies, whenever necessary to comply with a court order, with our legal or regulatory obligations, or for the regular exercise of our rights.

Police Authorities. We may share your personal data with police authorities or bodies with police powers, such as the Public Prosecutor's Office, whenever we believe there is suspicion or confirmation of any unlawful and criminal act, when necessary to protect our employees, our rights and our property, even when there is no legal or regulatory obligation requiring the sharing.

With third parties interested in the combination or acquisition of our business. We may share your personal data with third parties interested in the combination or acquisition of our business, with whom we are dealing regarding potential merger, acquisition or incorporation operations of VRI, of its business units or of its specific assets, both during the due diligence phase carried out by the third parties on VRI's business or at a later time, with its definitive transfer to the acquiring company or person, when applicable. In the event of any insolvency or reorganization process of VRI, your personal data may also be shared with third parties that acquire our business or assets.

With third parties indicated by you. We may share your personal data with third parties that have been indicated by you, upon your request and based on your consent.

 

5. What are the legal bases that authorize the processing of your personal data?

All our personal data processing operations are always carried out with the support of a legal basis provided for in the applicable legislation, in accordance with the particularities of each data processing activity.

Among the legal grounds that authorize the processing of your personal data and that are used by us to enable our processing activities are the following:

Compliance with a legal or regulatory obligation. In certain situations, we process your personal data with the support of the need to comply with a legal or regulatory obligation, such as, for example, when we keep the records of your access to our site or to our applications, in compliance with article 15 of Law No. 12,965/2014 ("Brazilian Internet Civil Framework").

Regular exercise of rights. We may process your personal data when necessary to enable the regular exercise of our rights in contracts, or in administrative, judicial or arbitration proceedings, such as, for example, the indication of your registration data in a lawsuit filed by you against VRI.

Protection of life or physical safety. We will process your personal data when necessary for the protection of life or physical safety, yours or of third parties, such as, for example, when measuring your temperature before allowing your entry into one of our physical facilities, to ensure that you do not show signs of infection by infectious-contagious diseases that could contaminate our employees or third parties.

Credit protection. We will process your personal data when necessary for the protection of our credit, such as, for example, in cases where it is necessary to verify your ability to bear the payment for the products or services offered by VRI.

Legitimate interest. We will process your personal data when we have a legitimate interest in the processing, except in the case where your fundamental rights and freedoms prevail, such as, for example, when we promote our activities through the sending of emails to our customers.

Guarantee of fraud prevention and the security of the data subject. We will process your personal data when necessary to guarantee fraud prevention and the security of the data subject, in registration identification and authentication processes in electronic systems.

Consent. When we do not have another legal basis that allows the processing of your personal data, we may process your personal data based on your free, unequivocal and informed consent, which may be revoked at any time, free of charge and easily.

For further details about the legal basis used in a specific personal data processing carried out by us, please contact our Data Protection Officer, by email: ti@vri.com.br

6. For how long is your data processed

 VRI is committed to processing your personal data only for the period necessary to achieve the specific purposes of each processing, retaining the data for the shortest possible period, taking into account all existing legal and regulatory obligations and the need to defend VRI's interests in judicial, administrative or arbitration proceedings.

In this regard, the retention periods are defined by VRI according to the specific characteristics of each processing, including the purposes of the processing, the existing legal or regulatory obligations, among other criteria relevant to this definition.

To obtain more information about specific retention periods, please contact our Data Protection Officer by email: ti@vri.com.br

7. Cookies

Cookies are files, of text or image, made available on our site and stored on the devices used by the Users who access it, for the functioning, performance and optimization of navigation.

These cookies may also be used to assess performance metrics, allow the correct functioning of the site and make it more secure, provide a better user experience, understand how the site works and where it needs to be improved, and collect information about user behavior. There are several types of cookies. On our site, we use the following cookies:

Strictly necessary cookies. They are essential for the functioning of our site, to ensure its security and adequate performance, without which it would not function correctly.

Preference cookies. They store information about your preferences, such as, for example, your language and your region, allowing a better browsing experience on the site.

Analytics cookies. They collect information about your behavior during navigation on our site, such as the pages that are accessed, the visit time, the pages that are rarely accessed, so as to allow us to improve the quality of the site.

An example of the cookies we use are those provided by Google Analytics, which helps us understand the interaction of users with our platform, in order to then find opportunities to evolve our services.

If you wish to manage your cookie preferences, it is possible to configure your browser or device to remove them. However, by performing this action, you are aware that some features may not function properly and that your experience with VRI may not be as personalized, compromising the usability of the platform.

Each browser provides its own means to configure cookies. When accessing the respective sites, you will be subject to the privacy policies of other companies, which may not be consistent with or similar to the terms of this Policy. To learn more about how to manage and delete cookies from your browser, visit:

How to remove cookies in Google Chrome

How to remove cookies in Mozilla Firefox

How to remove cookies in Internet Explorer

How to remove cookies in Safari

8. What are your rights as a personal data subject?

You have a series of rights in relation to your personal data and VRI is committed to fully respecting them, in its capacity as Processing Agent. Among the rights available to you are the following:

Confirmation of the existence of processing. To question whether we process your personal data, confirming the existence or not of such processing.

Access to data. To request a copy of your personal data that is processed by us, by electronic, secure and reliable means or in printed form, according to your preference.

Rectification. To request the correction of your personal data that is incomplete, inaccurate or outdated.

Anonymization, blocking or deletion. To request the anonymization, blocking or deletion of your personal data, in cases where unnecessary or excessive data is processed or data is processed in noncompliance with the legislation.

Portability. To request the portability of your personal data to other content platforms, in accordance with the regulation issued by the National Data Protection Authority, respecting VRI's commercial and industrial secrets, if any.

Information about sharing. To request information about the public and private entities with which we share your personal data.

Information about the possibility of denying your consent. To receive information about the possibility of not providing your consent, when consent is the applicable legal basis for the processing of personal data, with the indication of the consequences of such refusal.

Revocation of consent. To revoke your consent easily and free of charge, simply by communicating your decision to VRI's Data Protection Officer or through other possible formats made available exclusively for this purpose. It is important that you know that the revocation of consent does not invalidate or render illegitimate the personal data processing activities that were carried out before the date of revocation.

Objection to processing. To object to the processing, indicating your reasons for doing so, in cases where consent is not the applicable legal basis for the processing of your personal data and when there is any noncompliance with the LGPD. VRI will assess whether your objection is justified or not, adopting the necessary measures to suspend the processing or to inform the grounds on which it understands that the processing is lawful and permitted.

Complaint. To file a complaint regarding the processing of your personal data carried out by VRI before the National Data Protection Authority. However, we hope that, before doing so, you will give us the opportunity to respond to any questions or complaints you may have directly. Our Data Protection Officer is available to clarify any questions and help you in the processing of any complaints.

Deletion of data processed with consent. To request the deletion of your data, in cases where your consent is the legal basis for a certain processing activity, except for the possibilities of us continuing to store the data when necessary for the compliance with a legal or regulatory obligation, or for the defense of our interests in judicial, administrative or arbitration proceedings.

9. Request for Access to or Deletion of Data and the manner of exercising the rights of personal data subjects

All these rights may be exercised by you at any time, free of charge, unless the charging of a fee is permitted in accordance with the current legislation or regulation, and VRI undertakes to use its best efforts to meet your requests in a transparent and prompt manner.

If you wish to request the deletion of personal data, or to exercise any other right as a personal data subject, simply contact us through the following channel: ti@vri.com.br

To ensure that the rights are being exercised by you or by your duly constituted legal representative, VRI may request the necessary information or proof regarding your identity, in order to prevent fraud and ensure your privacy, so that your personal data is not shared with anyone who does not have authorization to do so.

In certain cases, such as when your request is particularly complex or when we receive a high volume of requests at the same time, our response may not be as prompt as we would like it to be. On these occasions, we will always keep you informed and updated about the progress of your request.

In situations where we act as a Personal Data Processor, engaged by companies with which you have a relationship, it is the duty of the respective companies to respond to your requests to exercise the rights provided for above. In the event that you send the request to VRI, we will indicate who the Controller of your Personal Data is in that processing activity and we will forward your request to that organization. Considering that in these cases we only carry out processing activities at the direction of the respective Controllers, we will be prevented from meeting your requests without the express authorization of the respective Controllers.

10. Information Security

VRI adopts technical and organizational measures, based on good market practices, to protect your personal data against unauthorized access or unlawful or accidental situations of destruction, loss, alteration, communication or any other form of inappropriate processing. Your data is stored in a secure operational environment, which is not accessible to the public.

Among the measures we adopt to protect your personal data are: access controls, monitoring of access to local networks and of remote connections via VPN, user authentication, antivirus, firewall, maintenance of backup copies, periodic performance of tests and scans on the systems, encryption of data in transit and at rest, among others.

We maintain administrative, technical and physical safeguards to support the protection of the personal information that you share with us. These actions are associated with the effort to prevent security incidents, such as loss, misuse and unauthorized access, disclosure, alteration, destruction or any counter-attacks perpetrated by malicious persons, which may be highly sophisticated and innovative, with techniques and methods unknown until then, even to the best information security tools.

We know that no transmission over the internet is 100% secure, therefore, the security of your data also depends on the adoption of reasonable measures by you in the use of your devices and software.  It is important that you protect data, and in this way, we prevent other people from being able to access your services.

The security of your data also depends on the adoption of reasonable measures by you in the use of your devices and software. Should you identify or become aware of something that may compromise the security of your personal data, or of any possible vulnerability in our site or systems, please contact us.

11. Third-Party Websites

Our website may make available links to third-party websites. These websites, in turn, have their own privacy policies, which may not be compatible with this Policy. We recommend that you consult the respective privacy policies of these third parties to inform yourself about the personal data protection practices they adopt.

VRI is not responsible for the regularity of the data protection practices of third-party websites, nor for their content, which is in no way validated, ratified or endorsed by VRI.

12. How to contact us

Should you have any questions about this Policy or about the way your personal data is processed by VRI, or, further, wish to contribute with complaints, suggestions or comments about our personal data processing practices, do not hesitate to contact us by email: ti@vri.com.br

We have a duly appointed Data Protection Officer, who is ready to respond to all your questions or complaints, being the point of contact for your communication with VRI regarding the processing of your personal data.

Our Data Protection Officer can be contacted directly through the following channel:

Anderson Augusto Berni – ti@vri.com.br

13. Data of the Agent Responsible for the Processing of Personal Data

VRI, corporate name VRI Industria Eletrônica LTDA, CNPJ: 67.037325/0001-10, established at rua ROD BR-158, Nº1625, in Campo Mourão, PR, CEP: 87308-555, is responsible for the processing of the Personal Data defined herein, in the form of the definition provided for in the Brazilian General Data Protection Law.

14. Updates

As our goal is always to improve our services, this Privacy Policy may undergo changes and updates over time, to better reflect our personal data processing practices and to provide greater security and transparency to our operations.

When relevant changes are made, we will place a notice on the main page of our sites so that you can quickly identify the existence of an updated version of this Policy.

For the personal data processing activities that we carry out and that are eventually based on your consent, should the changes to this Privacy Policy result in effective changes in our personal data processing practices, we will request your consent again, based on the updated terms of this Policy.

We recommend that you periodically check this Policy to familiarize yourself with any changes.