1. GENERAL PROVISIONS
1.2. MWM provides users in general with the website www.geradoresmwm.com.br
1.3. Users are not required to provide identification to navigate and use the website in general. However, some website services such as “Contact Us” require User data for MWM.
1.4. All the information collected will be stored in the MWM database, which has security systems compatible with Brazilian and international market standards.
1.5. For the purposes of this Privacy Statement, the words, capitalized terms that are not determined herein will have the definitions established in the General Personal Data Protection Law (LGPD) - Law 13.79/2018.
2. HOW DO WE PROCESS YOUR PERSONAL DATA AND WHAT IS THE PURPOSE OF THE PROCESSING
2.1. As provided for in clause 1.3. herein, using the website does not require user registration; however, some features require processing of some personal data. Therefore, to ensure transparency in the processing of data on our website, please see below the data used in each case:
Contact Us: MWM Contact Us is provided through web form (https://www.geradoresmwm.com.br/contato/), email and telephone. To use this service, users must provide personal data (name, email, telephone number, full address and company). These information have the purpose of identifying them, as well as allow the company to contact you and meet your request. In addition, it also allows to find the MWM near you. Such data are stored for 5 years. Data provided by customers are also processed for sending information, offers and invitations for events.
3. LEGAL BASES USED
3.1 The legal bases for processing personal data applied by MWM are as follows:
|Hypothesis of processing||Legal basis|
|Processing described in clause 2.1, item “b” in the call center|
a) By providing the data subject’s consent, according to the provision of item I of article 7 of the LGPD;
b) Whenever there is no legal prohibition, the Legitimate Interest of the Controller or third parties may justify the processing of personal data, as provided for in article 7, item IX, of the LGPD.
4. PROCESSING AGENTS AND SHARING OF PERSONAL DATA
4.1. Personal data collected, stored or processed in any way due to the use of the website are controlled by MWM. Thus, MWM must be consulted by the Personal Data Subject for the possible exercise of the rights provided for in the General Personal Data Protection Law - LGPD.
4.2. Personal data will be stored in security systems compatible with the Brazilian and international market standards, both in MWM security system and/or its advertising agency. Personal data will not be marketed, assigned or shared with third-party companies, with the exception of the advertising agency approved by MWM, and will be used, when not to comply with MWM’s legal and regulatory obligations, in the same ways as described in item 2 of this Declaration.
a) With a public or delegated entity, to fulfill a legal or regulatory obligation;
b) With operators, for the execution of contracting and meeting an operational need for a service or product, such as MWM employees, independent contractors, subsidiaries, affiliates, consultants, service providers and suppliers, if the disclosure enables the entity to perform a business, professional or technical support function for MWM;
c) With Operators, to offer products or services from third parties, related to MWM main activities;
5. INFORMATION ACCURACY
5.1. User ensures the veracity and accuracy of the information and data that he/she provides to MWM, assuming the corresponding responsibility in the event of its inaccuracy, as well as undertakes to keep them up to date. MWM does not assume any responsibility in case of inaccuracy of the data informed.
5.2. MWM may, at its sole criteria, suspend and/or cancel the User’s registration at any time, if it detects any inaccuracy in the information provided by the User, until the inaccuracy is remedied. This procedure aims to protect the User and optimize the purchase process.
6. IP ADDRESS AND GEOLOCATION
6.1. MWM identifies the IP (Internet Protocol) address of its users to increase their security, since, in case of fraud, it may provide the IP address to the police and the court, in accordance with the provisions of the Internet Civil Framework. Approximate geolocation data will be collected from users so that MWM may prepare specific commercial actions for certain regions, communicate with the public regionally to offer promotions, measure the capillarity of the digital platform for more adequate territorial coverage with its audience, among other related actions.
7. CONSUMPTION INFORMATION
7.1. Consumption information, thus considered information related to purchases made by an individual, associated or not with personal data, will serve for MWM to offer its customers benefits more suited to their consumption habits, such as, but not limited to, products of interest, offer new products, brands and characteristics, grant optimized discounts, encourage conscientious consumption, etc.
8. COOKIES AND OTHER TECHNOLOGIES
8.1. The website, the online services, the email messages and the advertising material may use “cookies” and other technologies as pixel tags and web beacons. These technologies help us to better understand User behavior, tell us which parts of our website people have visited, and facilitate and measure the effectiveness of advertising and web searches. We treat information obtained through cookies and other technologies as non-personal information. However, to the extent that IP (Internet Protocol) address or similar identifiers are considered personal information by local law, we will also treat these identifiers as personal information. Likewise, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Statement. If you wish to block cookies, please refer to your browser guidelines/settings.
8.3. As with most websites, we obtain some information automatically and store it in log files. This information includes IP addresses, browser type and language, Internet service provider (ISP), query and exit pages, operating system, date and time information, and clickstream data. We use this information to understand and analyze trends, manage the website, learn about User behaviors on the website and obtain demographic information about our user base in general. MWM may use this information in our marketing and advertising services.
8.4 In some of our email messages, we use a “click-through URL” linked to the website content. When users click on one of these URLs, they are sent to a different web server before reaching the landing page on our website. We monitor this click-through data to understand the interest in certain topics and assess the effectiveness of communications with our customers. If you rather not to be tracked in this way, please do not click the text or image links in email messages.
8.5 “Pixel-tags” allow us to submit email messages using formats the customers are able to read and tell us if the email was opened or not. We may use this information to reduce or eliminate messages sent to users.
8.6 At any time, if you no longer wish to receive future contact via email, simply access the unsubscribe link in the message or reply to the email stating that you no longer wish to receive messages.
9. EXTERNAL LINKS
10. RIGHTS OF USERS REGARDING THEIR PERSONAL DATA
10.1. Users are entitled to, upon request to the Data Protection Officer:
I. Confirmation of the processing;
II. Access to personal data;
III. Correction of incomplete, inaccurate or outdated data;
IV. Anonymization, blocking or deletion of unnecessary, excessive or processed data in breach of the provisions of this Law;
V. Data portability to another service or product provider, upon express request, in accordance with ANPD regulations;
VI. Revocation of consent and consequent elimination of personal data processed, except in the cases provided for in art. 16 of the LGPD;
VII. Information on public and private entities with which the controller shared data;
VIII. Information about the possibility of not providing consent and about the consequences of refusal;
10.2. MWM reserves the right to maintain data processing if it has a legal basis for processing applicable to the specific case, such as, but not limited to, compliance with legal obligation, contract performance, legitimate interest, etc.
11. DATA OF THE PERSONAL DATA PROCESSING OFFICER
11.1. For matters related to the processing of personal data, the interested party should contact the Officer below:
Richard Alexander Lekitsch
T: +55 11 3882-3355
12. CLAIM BEFORE THE NATIONAL PERSONAL DATA PROTECTION AUTHORITY - ANPD
12.1. The User can make complaints to ANPD through the website https://www.gov.br/anpd/pt-br.
13.1. Since there are no infallible or inviolable security systems, MWM is not responsible for any damage, injury or loss of user information caused by third-party conduct, as well as in cases of fortuitous or force majeure event beyond its control.
14.1. Seeking continuous improvement, MWM may change this Declaration at any time, and the changes will be posted on the website for consultation at any time.
14.2. When using the website services, the User is aware of the terms of this Statement in force on the date of use, and the User is responsible for checking it in advance each time he/she visits the website.