PRIVACY POLICY

Updated on March 4, 2022.

1. Privacy Notice

VALGROUP is aware of how important is to know and to practice the safe use of personal data until its disposal. For this reason, we want to clarify and explain our Privacy Policy.

We recognize the need to protect and manage the personal data collected in our website appropriately. The current Privacy Policy will help you in understanding the type of information we can collect, how this information can be used, which information can be shared and what are the rights concerning the person’s personal data protection.

2. What personal information do we collect?

The personal data we obtain can be collected as follows:

Service Channels: The user can contact VALGROUP through the link: www.valgroupco.com/sac

The personal data are collected with the aim to identify the user, as well as to help with his request. This can be included, among others, name, e-mail, and telephone contacts. Besides these ones, we also collect any personal information that is entered by the user.

Cookies: personal data can be collected by cookies. For more information, see VALGROUP Cookies Policy.

Contract: The personal data collected by VALGROUP is used to protect the signed agreements, delivery or products acquired and the issuance of Electronic Invoices. This data includes, among others, the Name/Trade Name, Individual Taxpayer Number/Legal Entities Taxpayer Number, User’s Full Name, Telephone number, Address including the Zip Code, District, City and State and the State Registration Number when applicable, as well as the e-mail for eventual contact and Electronic Invoice delivery.

Social Projects: Personal data from children and youngers can be collected regarding to the participation in VALGROUP’s social projects. The collected data are their names and their pictures.

Client’s Page: Personal data are collected at the moment that VALGROUP ’s Client interacts with the website for registration, by completing his name, company, and e-mail. The Client may access the website by inserting his personal login and password that is previously registered as well as the acceptance of the Terms and Conditions of the Website Use of VALGROUP: www.valgroupco.com in order to consult about the information, issuance of reports and invoices, regarding to the contract or existent commercial relationship between VALGROUP and the client.

Candidates for Job Application: Candidates Personal Data and Job Applications are collected by forms available in VALGROUP‘s website. This data refers to: e-mail, telephone number, city, interest field and other professional information included in the document and sent to the candidate.

Employees: Regarding to VALGROUP’s employees personal data, this is necessary for the respective registration according to the Labor Law and execution of Work Contract.

3. Social Media

VALGROUP uses the Social Media to communicate and interact with their Clients and Consumers through third parties websites, i.e., LinkedIn, Instagram, and YouTube. These websites use third party cookies that are not operated or controlled by VALGROUP. When interacting, sharing, or pressing “Like” on VALGROUP ’s pages in LinkedIn, Instagram and YouTube, or another social media, you will release certain personal data to VALGROUP or to third parties.

We use “social buttons” to allow our users to share or bookmark the web pages. These are buttons from third parties social media that can record information about your activities on Internet, including this website. Please, review the respective terms of use and privacy policy of the platforms to understand exactly how they use your information, how to proceed and opt not to convey or exclude such information.

The amount of visible personal data will depend on your own configurations of privacy in Facebook, Twitter, and other social media.

4. Purposes and Legal Basis

Here you will find the purposes and legal basis of VALGROUP’s concern about their data:

We are only based on our legitimate interests for specific purposes. The treatment of this personal data does not infringe upon any interests, rights, and freedom of the user’s personal data.

5. About sharing and cease of information

It is not VALGROUP’s practice to disclose information that may identify the user and we never share information or sell or rent personal data to third parties. This information is exclusive for internal use of the companies to attain the purposes expressed in the previous item.

The data may be shared with third parties only under the following conditions:

• By court order or any request from the government fiscalization entities;
• Data transferred to public entities to meet the current legislation, i.e., personal data included in the electronic invoices and respective XMLs, or data of our employees for INSS or FGTS payments;
• Transferred data for services providers of Accountability or Human Resources, for complying fiscal and labor duties;
• Transferred data to financial institutions to make feasible the payment to our clients, or to pay the salaries to our employees and services providers;
• Shared data with our partners, operators and services providers that participate directly or indirectly in VALGROUP’s activities, such as the transport of the products, storage and data processing, verification of records, collection and credit attribution, processing and commitment of orders and transactions, services provided to our clients, e-mails delivery, customer satisfaction index, advertisement and marketing, safety and monitoring of development and audit;
• Transferred data for the execution of the contract, as well as the protection of VALGROUP ‘s interests in any kind of conflicts, including judicial lawsuits.

Some of the services providers mentioned above, can be located abroad and, in this case, VALGROUP adopts additional backups to guarantee an appropriate level of discretion regarding personal data, according to the corresponding and current Brazilian Law.

The personal data collected may be shared among the manufacturing plants in VALGROUP, including the plant in the United States and the ones in Mexico and Spain, reinforcing the commitment to use the information for the same purposes and with the same guarantees indicated in this Policy.

6. Information Security

To guarantee that your personal data is safe, we communicate our privacy and safety guidelines to our employees and VALGROUP’S commercial partners, and we strictly follow the safeguard measures regarding its integrity inside the company.

Our commitment is to protect your personal data, and that conferred to us by our Clients through physical, technical, and organizational measures with the aim to reduce risks of loss, misuse, non-authorized access, disclosure, and any improper alteration.

7. Holder’s Rights

The holders can voice their concerns about their rights by contacting us via: dpo@valgroupco.com

Holder’s rights:

• Confirm the existence of personal data treatment;
• Access to the personal data, according to applicable regulations;
• Correct incomplete, inaccurate, and outdated personal data;
• Portability of personal data;
• Exclusion of personal data, when the treatment is based on the holder’s consent or when data is unnecessary, excessive, or treated not according to the applicable regulations.
• Data request about sharing its use with other people;
• Consent revocation, when applicable.

VALGROUP will always evaluate the best way to fulfill the holders’ request regarding the exercise of their rights. However, we may not approve their request, totally or partially, in specific situations protected by the law, i.e., the fulfillment of a legal duty or because of a signed agreement.

We reinforce the importance to keep your personal data accurate and updated. So, please inform VALGROUP about any alteration or incorrect data.

For safety reasons, any request sent via e-mail to dpo@valgroupco.com, will be assisted once the user is identified. So, we can request additional data or further information to confirm the holder’s identity. These data will be protected during the storage term and deleted as soon as the confirmation of the user is concluded.

8. Term of Treatment

This Privacy Policy applies to the circumstances above mentioned during the whole period VALGROUP stores the personal data. We store and keep your information: (a) during the time required by law; (b) until the end of the personal data treatment as was mentioned below; or (c) for the necessary time to protect VALGROUP’s rights. This way, we will treat your data during the terms prescribed or whatever necessary to fulfill the legal or regulatory duties.

The end of the treatment for the personal data occurs in the following events: (a) When the personal data is collected or reached the end of its useful life, and/or the personal data is not necessary anymore; (b) when the user requests his data exclusion; and (c) whenever a legal determination requests.

For the cases of the end of treatment, except the hypothesis established by the applicable regulation under this Privacy Policy, the personal data can be deleted.

9. Officer Responsible for the Personal Data (DPO)

VALGROUP provides below the contact of the Officer Responsible for the Personal Data (DPO), who will assist all and any requests made by the users or National Authorities, related to the personal data.

For any doubt, request or claim related to the personal data, please contact our official in charge via:

DPO EXPERT® (www.dpoexpert.com.br) – contact: dpo@valgroupco.com

If, after our commitment and efforts to protect your data, you still think that your personal data was misused, please contact our DPO. You also have the right, at any moment, to register a complaint directly with the National Authority of Data Protection in case you think that your personal data was violated.

10. Changes in the Privacy Policy

VALGROUP reserves the right to update or modify this Policy, at any time and without prior notice. However, we will always be publishing the revised version on our website. In case of any alterations on the way we treat the personal data, you will be informed to verify if you want to continue using our products.