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Privacy Policy and Personal Data

PURPOSE

To inform all clients of GLOBAL SP TECHNOLOGIES & SERVICES LTDA about the application of the General Data Protection Law (LGPD).

SCOPE

This policy applies to all clients of GLOBAL SP TECHNOLOGIES & SERVICES LTDA.

PROCESS DESCRIPTION

GLOBAL SP TECHNOLOGIES & SERVICES LTDA collects and processes personal data to support the development of its business platform, which focuses on optimizing the entire logistics process (Supply Chain) for companies. As part of a group of consulting, technology, and service companies, our expertise lies in identifying performance improvement opportunities and recommending the most effective process strategies and business solutions for our clients.

This Privacy Policy and Personal Data Policy (hereinafter referred to as the "Privacy Policy") aims to help our clients understand:

What personal data we collect
How and why we use it
Who we share it with
How we protect your privacy when you use our services

WHY?

GLOBAL SP TECHNOLOGIES & SERVICES LTDA is committed to protecting the security and privacy of its clients. In this regard, we have developed this Privacy Policy to reaffirm our commitment and respect for data privacy and protection regulations.

We want our clients to be fully informed about our general privacy rules and the terms of data processing, in strict compliance with applicable legislation, particularly Law No. 13.709, dated August 14, 2018 ("General Data Protection Law - LGPD").

GLOBAL SP TECHNOLOGIES & SERVICES LTDA strives to follow best practices in data security and protection, promoting awareness and improving systems to safeguard the personal data provided by our clients while ensuring full compliance with legal obligations.

By providing and processing personal data, GLOBAL SP TECHNOLOGIES & SERVICES LTDA assumes that clients acknowledge and accept the conditions outlined in this Privacy Policy, along with any additional terms, policies, and conditions related to the services offered.

WHAT ARE PERSONAL DATA?

Personal data refers to any information related to an identified or identifiable natural person (data subject), regardless of its format or nature. A person is considered identifiable if they can be directly or indirectly identified, particularly through reference to an identification number or other specific elements of their physical, physiological, psychological, economic, cultural, or social identity.

In certain cases, personal data may have a special nature and are classified by the LGPD as "sensitive data." These include information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric identifiers, sexual life, sexual orientation, or health status.

Key Definitions:

Data Subject's Consent: A free, specific, informed, and explicit expression of will by which the data subject agrees, through a declaration or a clear affirmative action, to the processing of their personal data.
Controller: A natural or legal person, public or private, who is responsible for decisions regarding the processing of personal data.
Profiling: Any automated processing of personal data that involves using personal data to classify an individual based on professional performance, economic situation, health, personal preferences, interests, behavior, location, or movements.
Data Protection Officer (DPO): The designated person or entity responsible for ensuring compliance with LGPD within an organization, facilitating communication with data subjects and regulatory authorities, and coordinating data protection efforts across different business areas. The DPO operates independently, reporting directly to the organization's leadership.
Processor: A natural or legal person, public or private, that processes personal data on behalf of the Controller.
Third Party: Any individual, legal entity, service, or entity other than the Data Subject, Controller, or Processor, and those authorized by them to process personal data.
Data Subject: The identified or identifiable individual to whom the personal data refer.
Processing: Any operation or set of operations carried out on personal data, whether automated or not, including collection, recording, organization, structuring, storage, modification, retrieval, consultation, use, transmission, dissemination, comparison, restriction, deletion, or destruction.
Personal Data Breach: A security breach that results in accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data that are transmitted, stored, or otherwise processed.
Pseudonymization: The processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and protected by technical and organizational measures to ensure that the data cannot be linked to an identifiable person.
Anonymization: A process by which personal data are permanently altered so that they can no longer be linked to a specific individual, even when using all reasonably available means.
National Data Protection Authority (ANPD): The public administration body responsible for overseeing, implementing, and ensuring compliance with the LGPD.

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

This Privacy Policy aims to inform our clients about the terms of personal data processing within GLOBAL SP TECHNOLOGIES & SERVICES LTDA, defining the purposes and means of data processing in the context of service provision. GLOBAL SP TECHNOLOGIES & SERVICES LTDA acts as a Processor (Operator) under the LGPD.

The Controller (CLIENT) is responsible for making decisions regarding personal data processing. The Processor (GLOBAL SP TECHNOLOGIES & SERVICES LTDA) carries out data processing according to the instructions provided by the Controller, acting on their behalf.

Under this Policy, GLOBAL SP TECHNOLOGIES & SERVICES LTDA is accountable for the personal data stored in its database and may also be held liable in the event of a data breach involving information shared with its partners, employees, service providers, or any third parties who fail to comply with the LGPD.

WHAT PERSONAL DATA DO WE COLLECT AND THROUGH WHAT MEANS?

GLOBAL SP TECHNOLOGIES & SERVICES LTDA (Processor) receives personal data when contracted by the Client (Controller), who provides its database with the personal data to be processed by GLOBAL SP TECHNOLOGIES & SERVICES LTDA, in accordance with the LGPD.

Personal data are typically transferred to GLOBAL SP TECHNOLOGIES & SERVICES LTDA through system integration, but in some cases, clients send data via spreadsheets through email.

Data Sharing

GLOBAL SP TECHNOLOGIES & SERVICES LTDA shares the personal data received from clients with its employees and internal and external service providers, who carry out specific processing tasks.

How We Collect Your Personal Information

We collect your personal information when you use our platforms or contact us through various sources, including when you:

Visit or browse our websites;
Fill out forms on our websites;
Participate in events and complete event-related forms;
Place or attempt to place an order;
Register an account or sign up as a customer;
Send us an email;
Take part in surveys;
Interact with our customer service representatives.

Types of Data Collected

To ensure efficient service delivery, the Client (Controller) provides certain information about its own customers (such as CNPJ, company address, corporate phone, corporate email, and names of business partners) and third-party employees (such as name, CPF, CTPS, address, etc.).

All collected data are securely stored in a cloud service contracted by GLOBAL SP TECHNOLOGIES & SERVICES LTDA.

CATEGORIES OF DATA PROCESSED, MEANS, AND METHODS OF COLLECTION

GLOBAL SP TECHNOLOGIES & SERVICES LTDA receives personal data when contracted by a Client (Controller) and processes them in accordance with the contractual agreement.

The company operates through nine (9) departments, each responsible for receiving and processing data provided by the Client. These data pertain to the Client's customers and outsourced employees and are categorized as follows:

(i) Data Received from the Client (Operational Structure Data)

These include:

Personal and employment data: Full name, CPF, CTPS, PIS, address, phone number, mobile number, email
Employment-related information: Medical and dental assistance, life insurance, IP address, labor records, job title, employee registration forms, payroll details, and attendance tracking of third-party service providers hired by the Client.

Note: All these data are provided by the Client when they transfer their database to GLOBAL SP TECHNOLOGIES & SERVICES LTDA.

(ii) Client Data

These include:

Business information: CNPJ, company address, bank details, phone number, email, names of business partners and representatives.

GLOBAL SP TECHNOLOGIES & SERVICES LTDA does not collect sensitive data.

PURPOSES OF COLLECTING YOUR PERSONAL DATA

The personal data received from the Controller (Client) may only be used for the contractually agreed purpose. If GLOBAL SP TECHNOLOGIES & SERVICES LTDA intends to process data beyond the originally authorized purpose under the client's contractual agreement, it must obtain new consent from the data subject.

The legal basis for processing personal data is the execution of the contract, meaning that GLOBAL SP TECHNOLOGIES & SERVICES LTDA does not need to obtain consent from the data subject-this responsibility lies with the Client (Controller). The processing purpose must be specific, except in cases where legitimate interest applies to the Controller.

We May Use the Collected Personal Data for One or More of the Following Business Purposes:

To process your request for information (e.g., about products/services or Independent Consultant opportunities).
To complete product and service transactions and send notifications regarding your transactions.
To provide sales support and customer service, ensuring quality assurance.
To fulfill or serve the purpose for which the information was provided. For instance, if you provide your bank details for commission payments, we will use them for that purpose.
To deliver targeted marketing and advertising, provide service update notifications, and offer promotional deals based on your communication preferences.
To enable "email-a-friend" functionality. We may allow you to send messages about website content to a friend. If you use this feature, you may provide your friend's email address so we can facilitate the message delivery.
To verify your identity, including account-related matters.
To send administrative communications, such as service-related announcements, that are necessary to serve you, address your concerns, and ensure the high level of service GLOBAL SP TECHNOLOGIES & SERVICES LTDA provides. Because these communications are important for your use of our services, you cannot opt out of receiving them unless you explicitly withdraw your consent for us to use your personal information as outlined in this Privacy Policy.
To review/manage site usage and operations, ensuring compliance with our Terms of Use and applicable laws.
To resolve issues related to the website, business operations, or services.
To contact you via phone calls, SMS, or email, as permitted by our Terms and Conditions.
To detect, prevent, or investigate security breaches, fraud, or other suspicious, prohibited, or illegal activities, as well as violations of this Privacy Policy.
To maintain appropriate internal administrative records.
To provide important product safety information.

Use of IP Addresses and Website Tracking

We use your IP address and the IP addresses of all users to:

Calculate site usage levels
Diagnose server issues
Administer the website
Analyze trends and statistics, including fraud detection and prevention
Track traffic patterns
Collect demographic information for aggregated use

Website Improvement and Data Analysis

We may collect information through cookies and other technologies for purposes such as:

Analyzing site usage
Personalizing your experience
Enhancing our content and services
Conducting research, testing, and product development
As described to you at the time of data collection
Your browser may offer tools to block or delete cookies. However, if you reject or manually delete cookies, you may experience issues accessing and using certain features and pages on our website, including those that may be introduced in the future.

ON WHAT BASIS DO WE PROCESS YOUR PERSONAL DATA?

GLOBAL SP TECHNOLOGIES & SERVICES LTDA is a business platform focused on optimizing the entire logistics process for companies. To provide these services, the processing of certain personal data is required.

Under the LGPD, the processing of personal data is only lawful if there is a valid legal basis for each specific processing activity.

Legal Basis for Data Processing

GLOBAL SP TECHNOLOGIES & SERVICES LTDA operates a third-party monitoring system, providing consulting and BPO (Business Process Outsourcing) services. We analyze operational structures of client companies, identifying performance improvement opportunities and recommending optimized process implementation strategies, supported by specialized software solutions and outsourcing activities.

For data processing related to service improvement, administrative objectives, and quality assurance, the appropriate legal basis includes:

Legitimate interest of the Controller and Processor
Contractual performance (when applicable)
Client consent

Under the LGPD, data subjects have the right to object to the processing of their personal data for the above purposes if they present valid reasons related to their particular situation. In such cases, the Controller may provide legitimate reasons justifying continued processing, particularly when necessary for legal claims, defense in legal proceedings, or the exercise of rights.

For data processing required for compliance with legal obligations, particularly data communications with external entities, the legal basis will be:

Necessity for compliance with legal obligations of the Controller
Contractual performance
Legitimate interest

WHICH PROFESSIONALS AT GLOBAL SP TECHNOLOGIES & SERVICES LTDA HAVE ACCESS TO YOUR DATA?

As part of our personal data processing practices, GLOBAL SP TECHNOLOGIES & SERVICES LTDA strictly adheres to the principles of data protection by design (privacy by design).

This commitment ensures that:

Access to your personal data is strictly limited to employees and professionals who need to process it as part of their job functions.
Data is only accessed to the extent necessary to fulfill the specific processing purposes outlined in this Privacy Policy.

This controlled access policy reinforces security and compliance with data protection regulations, ensuring that your personal data is handled responsibly and lawfully.

WHAT ARE THE RIGHTS OF DATA SUBJECTS?

Under applicable law, data subjects have the right to request, at any time, access to their personal data, as well as rectification, portability, and deletion of their information. These requests can be made by contacting GLOBAL SP TECHNOLOGIES & SERVICES LTDA via email at dpo@sejaglobal.co or through in-person contact with the company.

Data Subject Rights:

Request details about the categories of personal information collected about you and, if feasible, obtain a copy of such information (data portability).
Request the deletion of any personal information we have collected from you, subject to certain exceptions. If your request is verified, we will proceed with the deletion unless an exception applies. We may deny a deletion request if data retention is necessary for us or our service providers to: Complete the transaction for which the personal data was collected, Provide a requested product or service, Perform actions reasonably expected within the context of our ongoing business relationship with you, Fulfill our contractual obligations with you.
Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities, as well as prosecute those responsible for such activities.
Debug products to identify and fix issues affecting their intended functionality.
Exercise freedom of expression or protect another consumer's right to exercise their freedom of expression.
Comply with the LGPD and other applicable laws.
Engage in public or scientific research, historical studies, or statistical analyses, provided that such research complies with applicable ethics and privacy laws. Data deletion may be restricted if its removal would make research impossible or severely impair its purpose, given the data subject's prior consent.
Allow internal uses that align with consumer expectations, based on their relationship with us.
Fulfill a legal obligation.
Make other lawful internal uses of the data that are compatible with the purpose for which it was originally provided.

Filing Complaints with Authorities

Without prejudice to other administrative or judicial remedies, data subjects have the right to file a complaint with the National Data Protection Authority (ANPD) or another competent regulatory authority if they believe that GLOBAL SP TECHNOLOGIES & SERVICES LTDA is not lawfully processing their data in accordance with the applicable legislation and this Privacy Policy.

WHAT SECURITY MEASURES ARE ADOPTED BY GLOBAL SP TECHNOLOGIES & SERVICES LTDA?

GLOBAL SP TECHNOLOGIES & SERVICES LTDA is committed to ensuring the confidentiality, protection, and security of its clients' personal data. To achieve this, we implement appropriate technical and organizational measures to safeguard data against unauthorized processing, accidental loss, or destruction.

We have systems and dedicated teams responsible for data security, continuously developing and updating procedures to prevent unauthorized access, accidental data loss, or destruction. Our commitment includes:

Strict compliance with data protection laws
Processing data only for the purposes for which it was collected
Ensuring adequate levels of security and confidentiality

Data Sharing and Third-Party Processing

In some cases, GLOBAL SP TECHNOLOGIES & SERVICES LTDA may share personal data with its employees, internal service providers, and third-party contractors. We have clear contractual rules regarding personal data processing and require all partners to implement appropriate technical and organizational security measures.

However, in certain situations, we may be legally required to disclose personal data to third parties (such as regulatory authorities), over whom we have limited control regarding data protection compliance.

Legal and Governmental Data Disclosure

It may be necessary for GLOBAL SP TECHNOLOGIES & SERVICES LTDA to disclose personal data in cases involving:

Legal requirements, judicial proceedings, or litigation
Requests from public and government authorities (both domestic and international)
National security, law enforcement, or other matters of public importance
Enforcement of our terms and conditions, business operations, or user protection

Data Transfers in Business Transactions

In the event of a reorganization, merger, or sale, we may transfer any and all personal information collected to the relevant third parties involved in the transaction.

UNDER WHAT CIRCUMSTANCES ARE DATA SHARED WITH OTHER ENTITIES?

GLOBAL SP TECHNOLOGIES & SERVICES LTDA relies on third-party entities for the provision of specific services. In some cases, these services may require access to client personal data by these entities.

Sub-Processors and Third-Party Service Providers

Any entity acting as a sub-processor will process personal data strictly according to the instructions of the Controller (Client). GLOBAL SP TECHNOLOGIES & SERVICES LTDA ensures that all sub-processors provide adequate guarantees regarding the implementation of technical and organizational security measures to comply with applicable laws and safeguard the rights of data subjects, as established in contractual agreements with the Controller.

Legal and Governmental Data Sharing

GLOBAL SP TECHNOLOGIES & SERVICES LTDA may also share client personal data with third parties when such data sharing is deemed necessary or appropriate, specifically:

To comply with applicable laws
To fulfill legal obligations or court orders
To respond to requests from public or governmental authorities

Accordingly, GLOBAL SP TECHNOLOGIES & SERVICES LTDA may transfer personal data to contracting public entities, courts, legal representatives, law enforcement agencies, or the Public Prosecutor's Office, when legally required to do so.

Commitment to Data Protection

In all the scenarios mentioned above, GLOBAL SP TECHNOLOGIES & SERVICES LTDA is committed to taking all reasonable measures to ensure effective protection of the personal data it processes.

CONTACT US

For more information regarding the processing of your personal data or any inquiries related to your data protection rights, as outlined in this Privacy Policy and applicable legislation, you may contact the Data Protection Officer (DPO) at GLOBAL SP TECHNOLOGIES & SERVICES LTDA using the following contact details:

E-mail: dpo@sejaglobal.co

RIGHT TO NON-DISCRIMINATION FOR EXERCISING YOUR PRIVACY RIGHTS

We will not discriminate against you for exercising any of the privacy rights described in this policy. This means that we will not:

Deny you goods or services
Charge different prices or fees for goods or services, including through discounts, benefits, or penalties
Provide a different level or quality of goods or services
Suggest that you may receive a different price, fee, level, or quality of goods or services

Your privacy rights will always be respected and protected without any adverse consequences for exercising them.

HOW WILL I BE NOTIFIED ABOUT CHANGES TO THE PRIVACY POLICY?

GLOBAL SP TECHNOLOGIES & SERVICES LTDA reserves the right to modify or update this Privacy Policy at any time. Any changes will be duly updated on our platforms.

We recommend that you review this policy regularly to stay informed about any updates or modifications.