Privacy notice

IVS Global Data Privacy Notice

This Privacy Notice is effective January 1   January 1, 2018.

This Privacy Notice explains how IVS and its affiliated companies  (“IVS”, “we”, “us”, “our”) use personal data about you on our websites, mobile applications or other websites that display this Privacy Notice. This Privacy Notice will also apply to information collected from your visits to our facilities.

Specific provisions

In specific situations, other provisions apply or supplement this Privacy Notice:

• when applying for employment with IVS, only the Privacy Notice for  Recruitment  applies;

• When using our websites, the  Cookies  Policy supplements the Privacy Notice.

Protecting your personal data

With offices and operations around the world, personal data will be transferred or accessible internationally across IVS's global business. All such transfers within IVS's global business are in accordance with applicable local data privacy laws and regulations ​​e, for the European Union, in accordance with the Rules Binding Corporate Letters (“BCR”) approved by the authority.

Our BCRs reflect the standards contained in European data privacy laws and regulations (including the General Data Protection Regulation). Having our BCR means that all entities in the IVS group that have signed up for our BCR must comply with the same internal rules. It also means that your rights remain the same no matter where your data is used ​​by IVS.

Types of personal data we use, purpose and legal basis

consumers;

IVS rarely uses personal data about consumers; however, we may use personal data about you to provide logistical services to you or our customers, for example, customs clearance services, document and parcel shipping, etc., where we use:

1. Contact information (e.g. name, address, email and phone number)

2. Delivery and packaging information

In accordance with applicable laws ​​ of certain jurisdictions, IVS is required to document personal data in financial transactions when fulfilling our contract, for example, when paying or receiving payment for the delivery of goods and services, etc.

IVS customers (excluding consumers)

If you are an IVS customer, we use personal data about you to fulfill the agreement between the parties, for example contract administration, payment, delivery of goods and services, etc., where we use:

1. Business contact information (e.g. name, address, email and phone number)

2. Office

IVS is also legally obliged to document personal data in financial transactions when fulfilling our contract, for example when paying or receiving payment for the delivery of goods and services, etc.

Suppliers, Suppliers or other Third Parties of IVS

If you are a supplier, vendor or other third party involved with IVS, we use personal data about you to fulfill the agreement between the parties, for example contract administration, payment, delivery of goods and services, etc., where we use:

1. Business contact information (e.g. name, address, email and phone number)

2. Office

3. bank information

4. Third-party compliance screening

IVS is also, in accordance with relevant laws, obliged to document personal data in financial transactions when fulfilling our contract, for example, when paying or receiving payment for the delivery of goods and services, etc.

IVS consultants

If you are an IVS consultant, we use personal data about you to fulfill the agreement between the parties, for example contract administration, payment and services etc., where we use:

1. Business contact information (e.g. name, address, email and phone number)

2. Professional CV and position

3. Date of birth and other relevant personal information

4. bank information

5. Information relating to consultancy tasks

IVS is also, in accordance with relevant laws, obliged to document personal data in financial transactions when fulfilling our contract, for example, when paying for the provision of consultancy services, etc.

Guests at our facilities

If you visit our facilities and websites, we use personal data about you to identify you and inform you of the rules applicable ​​to visitors, where:

• our legitimate interest in correctly identifying you and providing you with visitor instructions overrides your interest that the information not be used, or

• your freely given consent when you choose to disclose your personal data to us, or

• personal data are collected for the fulfillment of any contractual obligations,

are the legal bases for our use, where we use:

1. Contact information (e.g. name, address, email and phone number)

2. Work-related information (e.g. job title, place of work)

3. Personal information (for example, registration number, if you have already used one of our car parks)

Business Administration

If you contact us, we will use personal data about you to document quality and compliance (for example, in relation to statutes of limitations, security, litigation or regulatory investigations) where:

• our legitimate interest in improving our legal position overrides your interest that the information not be used, or

• your freely given consent when you choose to disclose your personal data to us,

• or personal data is being collected for the fulfillment of any contractual obligations,

are the legal bases for our use, where we use:

1. Contact information (e.g. name, address, email and phone number)

2. Other applicable information

When you're marketed to

By subscribing to one of our newsletters, you are consenting to us sending you our newsletters, where we use:

1. Contact information (e.g. name, address, email and phone number)

2. Content and your choices regarding newsletters – contact forms and content etc.

Marketing in newsletters and on our websites, including social media, is tailored to your personal preferences based on our knowledge of you through profiling, where we use:

1. Content of subscribed newsletters

2. Declared areas of interest

3. Cookies as set out in our  Cookies Policy

4. Information from your social media profiles

5. Information from our customer databases

Any:

• our legitimate interest in making an automatic assessment of your personal data to personalize the marketing presented to you prevails over your interests and fundamental rights, or

• your freely given consent when you choose to disclose your personal data to us, or

• personal data collected to fulfill any contractual obligations.

We do not use automated decisions that have legal effect or that significantly affect you.

Understanding our customers, consumers and suppliers

We also do analytics to optimize our products, marketing, website, sales and better understand our customers' preferences regarding IVS products and maintain a CRM database. We do this by analyzing our databases with information about, for example, website usage, customer preferences, purchase history, sales and by sending questionnaires where:

• our legitimate interest in using the personal data overrides your interest that the data not be used, or

• your freely given consent when you choose to disclose your personal data to us, or

• personal data collected for the fulfillment of any contractual obligations.,

We collect:

1. Information from our customer databases

2. Cookies as set out in our  Cookies Policy

3. User behavior and logs from our websites and databases

4. The answers you provide about suggestions and preferences in the survey

Compliance and security operations for all data subjects

We monitor user behavior and implement security solutions on our website, as well as our solutions and our facilities, where:

• our legitimate interest in anti-corruption, anti-fraud, anti-bribery, technical and physical security overrides your interest in information not being used or

• your freely given consent when you choose to disclose your personal data to us, or

• personal data collected to fulfill contractual obligations.  

We collect:

1. Contact information (e.g. name, address, email and phone number)

2. Cookies as set out in our  Cookies Policy

3. User behavior and logs

4. Images captured by video surveillance in marked areas on IVS premises

Sharing of Personal Data

In addition to sharing your Personal Data with IVS Group Entities, we may, in some situations, also share your Personal Data with third parties, such as business partners, suppliers, vendors, consultants, agencies, customers, consumers, government bodies, courts and IT providers. of hosting, provisioning and services that we use for our group's (Third Party) IT environment. We only share Personal Data where it is relevant and necessary for us to carry out the activities described in this Privacy Notice, for example fulfilling your order, processing your payment details or providing support services.

Transfer and protection of your personal data

As a global organization with offices and operations around the world, we will transfer Personal Data collected by us on an aggregate or individual level to various divisions, subsidiaries, joint ventures and affiliated companies of IVS around the world for the purposes stated above and in in accordance with applicable laws and regulations, as well as to IVS contractors and subcontractors (data processors and subprocessors) for storage and service purposes. Your Personal Data will not be disclosed to anyone outside IVS, unless permitted or required by applicable laws and regulations ​​and, where necessary, subject to appropriate written safeguards third parties who have access to your personal data,

Unless otherwise notified to you, any transfers of your Personal Data will be based on applicable local data privacy laws, which, inter alia, include appropriate international data transfer mechanisms and safeguards, such as an adequacy decision, Clauses Standard Contracts and/or Binding Corporate Rules.

You can always request a copy of the transfer mechanisms, which include the transfer of personal data, through the email contato@ivscommercial.com.br 

Automated decisions

IVS uses automated decision-making regarding some of your personal data for some services and products. One example is our efforts to prevent and detect fraud on our online platforms.

You can ask IVS to provide information about the decision-making methodology and request that we verify that the automated decision was made correctly.

We may reject the request as permitted by applicable law, including where providing the information would result in the disclosure of a trade secret or interfere with the prevention or detection of fraud or other crime. However, generally under these circumstances, we will verify that the algorithm and source data are working as intended, with no errors or biases.

Security measures

We choose to use vendors who implement security in accordance with industry practices for good IT security and use only encrypted data communications when transferring sensitive and confidential personal data. We also maintain organizational, physical and technical security arrangements for all personal data we hold. We have relevant protocols, controls and policies, procedures and guidelines in place to maintain these agreements taking into account the risks associated with the categories of personal data and the use we carry out. We store personal data on servers with limited access located in secure facilities and our security measures are continually evaluated. Servers are protected by antivirus software and firewalls, among other measures.

Personal data retention

IVS stores your personal data for as long as necessary to fulfill the purpose of use, unless IVS is required by applicable laws and regulations ​​or has the right to store personal data for a longer period, more specifically:

• We retain your personal data for as long as we maintain an ongoing relationship with you (in particular if you have an account with us or have not withdrawn your marketing consent).

• We will only keep personal data for as long as your account is active or for as long as necessary to provide services to you.

• We retain your personal data for as long as necessary to comply with our global legal and contractual obligations.

We will also retain your Personal Data when it is advisable to protect or improve our legal position (for example, in relation to statutes of limitations, security, litigation or regulatory investigations).

Rights of Data Subjects

You are entitled, under the circumstances and conditions, and subject to the exceptions set forth in applicable law, to:

• Request access to the personal data we use about you: You have the right to request information or access to your personal data from us. There are some exemptions, which means you may not always receive all of the data we use. 

• Request rectification of your personal data: this right gives you the right to rectify your personal data if they are inaccurate or incomplete.

• Object to the use of your personal data: this right gives you the right to request that we no longer use your personal data. However, it only applies under certain circumstances and we may not need to discontinue use if we can provide you with legitimate reasons to continue using your personal data.

• Request the erasure of your personal data: this right allows you to request the erasure of your personal data under certain circumstances.

• Request restriction of use of your personal data: This right gives you the right to request that we use your personal data only under limited circumstances, including with your consent.

• Request portability of your personal data: this right gives you the right to receive a copy (in a structured, commonly used and machine-readable format) of the personal data you have provided to us or to request that we transmit that personal data to another data controller .

• Withdrawing Your Consent: You can withdraw your consent at any time by opting out via email or by contacting us. However, this will not affect our right to use personal data obtained prior to the withdrawal of your consent, or our right to continue parts of the use based on other legal bases than your consent.

• File a complaint: You can always file a complaint with a data protection authority, for example the Brazilian Data Protection Agency.

Please note that certain personal data may be exempt from the aforementioned rights under applicable data privacy laws ​​ or other laws and regulations.

Contact information

Please contact our Data Privacy Compliance Officer at contato@ivscommercial.com.br, Att.: Data Privacy if you have a general question about how IVS uses and/or protects your personal data, if you wish to exercise your rights or if you wish to make a complaint about how IVS uses your personal data.

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