Manuchar Privacy Statement

1. Manuchar Privacy Statement: Business Relations

At Manuchar, we attach great importance to protecting the privacy of everyone from whom we collect data. We treat and protect this data with the utmost care, in accordance with Brazil's new Data Protection Legislation, better known as LGPD - Law 13.709/2018.

This Privacy Policy contains information about the way we handle, in whole or in part, automated or not, the personal data of internal and external users.

Its purpose is to clarify for interested parties the types of data that are collected, the reasons for collection, and how the user can update, manage, or delete this information.

 We do everything possible to protect data transmitted to us from loss, destruction, disclosure, unauthorized access, or misuse.

In this privacy statement we explain who we are, when or why we need your personal data, what personal data we collect, how and for how long we process it, to whom we may transfer it, what your rights are and how you can exercise them thereby ensuring transparency in the use of your personal data.

This statement is directed to you if:

  • You are the contact person for one of our potential clients, suppliers or professional service providers;
  • You are the contact person in an instance (company, authority, professional federation of employers or workers, school, university, partner, ...) with whom we wish to initiate or maintain a form of contact or collaboration.
  • If you choose to provide us with information voluntarily, we will use that information in accordance with this privacy statement.
  • If you are one of our employees or freelance contractors.

1.1. What are personal data and sensitive personal data?

According to Personal Data Protection Law - 13.709/18, personal data: is information related to an identified or identifiable natural person.

Sensitive personal data includes: data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical, or political organization, data concerning health or sex life, genetic or biometric data when linked to a natural person.

1.2. Who are we?

The Companies that are part of the Manuchar Brasil Group (Manuchar Comércio Exterior Ltda., Manuchar Logística Ltda., Manuchar Agro Ltda.) with headquarters and jurisdiction in the City and State of Rio de Janeiro, at Rua Lauro Muller, nº 116, salas 4301, 4304, 4305 e 4306, Botafogo, CEP 22290-160.

​​​​​​​​​​​​​​1.3. When Do We Collect Personal Data?

We collect your data from the moment you provide it. This can happen by e-mail, WhatsApp, contracts, resumes, verbally (by phone, during a visit to your company, during an event, training, ...), by giving your business card or any other way.

It can also occur when your company or organization nominates you as a contact person.

We may also collect your data if it is publicly accessible or if you have posted it on social media (e.g. LinkedIn, Instagram, Facebook) and your posting suggests that you are the appropriate contact person to initiate a dialog within Our activities.

By accepting the terms of this Privacy Statement, you expressly agree to provide only true, current and accurate personal data and not to alter your identity or your personal data in any way in accessing and using our products or services. You will be solely responsible for any false, outdated or inaccurate information you provide directly to Manuchar.

These are your personal data processed by Manuchar, divided into categories:

  • Personal data informed by the holder
  • Registration data, such as: name, identification documents, nationality, address, date of birth, filiation, gender, among others.
  • Bank Details
  • Contact details, such as phone and e-mail
  • Education/Professional Experience
  • Biometric data, such as your ID card photo and your face

Public data

  • We may collect information about you that is publicly available or has been made public by you:
  • Information on mentions or interactions with Manuchar
  • Testimonials regarding Manuchar posted on social network profiles and pages, along with his name and image (including profile pictures)

1.4.​​​​​​​ Why Do We Need Your Personal Data

We collect your personal data for the following purposes and will not use it for other purposes without notifying you in advance and, if necessary, seeking your consent to do so.

We use your data in connection with the presentation and execution of our business activities for you or your company or organization, for the presentation and execution of joint projects, associations, for the defense of Manuchar's interests or in connection with the provision of services as a supplier or consultant on your part.

 We will use your personal data to, if applicable:

  1. to be able to provide you with information about Manuchar's activities and better adjust them to your needs and interests and those of your company or organization;
  2. start a business relationship with you and/or your company or organization, close business deals with your company or organization, close business deals, and maintain business relationships; 
  3. to be able to exchange information with you about the products and services we offer, including billing and the corresponding accounting treatment;
  4. Contact you with Manuchar's commercial offers, newsletters, events, workshops and other marketing and promotional activities that may be of interest to you;
  5. To be able to contact you for your role in a public institution (authority, university, professional federation, ...) to defend Manuchar's interests;
  6. Ensuring the security of companies;
  7. Fulfilling management objectives, including generating management information, performing internal controls for fraud prevention, and performing (internal / external) audits and accounting controls;
  8. Allow you to exercise your rights and subsequently demonstrate that we have complied with your request to exercise those rights;
  9. Our (pre) contractual relationship and all corresponding legal obligations of Manuchar: when we negotiate or conclude an agreement with you, your company or organization, we need a certain amount of data about you or the people involved in your company or organization in order to present and comment on a suitable proposal, to be able to prepare this contract, draft and execute it correctly afterwards. If you do not wish your personal data to be processed in this regard, it will be impossible for us to initiate or execute the provision of services;
  10.  The legitimate interest of Manuchar or third parties: if necessary, we use your data to satisfy the legitimate interests of Manuchar or third parties. This may be done, for example, for the presentation and promotion of any services and/or informational messages that are in line with what you reasonably expect to receive from us in the context of our existing or potential relationship. This may also occur in access controls or audits and internal controls to ensure the security and continuity of our systems and business. This legitimate interest is also present when we have to retain data in the context of initiating, exercising or supporting legal action;
  11. For hiring purposes, such as: admission process, provision of benefits, preparation of exams;
  12. For training and development purposes (Hiring consultants).

1.5. What personal data do we process?

First, we process your personal data necessary for the proper performance of our business activities: your first and last name, your function (job title), your business address and your professional contact information (telephone and/or e-mail). Some additional information (e.g. preferred language, department, ...) is not always required, but may be relevant in the development of our business relationship or to adjust our services and business activities to your interests, wishes and needs.

There are also data that are completely optional and whose sole purpose is to maintain a good personal relationship with you (for example, your date of birth, hobbies, ...). If you decide to share this kind of personal data with us, we may include it in our databases.

We ask that you always notify us as soon as possible of any changes to your personal data.

​​​​​​​​​​​​​​1.6. With whom do we share your personal data?

Only if it is necessary for the fulfillment of the purposes stated in section 1.3, the execution of the agreement between us, the fulfillment of a legal obligation (by Manuchar of or a third party) or the defense of a legitimate interest (of Manuchar or a third party).

The sharing of your data may also be done with companies in Manuchar's economic group, with third-party partners and with authorities and regulatory bodies for different purposes, when necessary. Whenever effected, the sharing of data will be carried out within the limits and purposes of our business and in accordance with what the applicable legislation authorizes.

Manuchar may transfer some of your personal data:

  1. to all other companies of the Manuchar group in Brazil, to, among other things
    • The fulfillment of our goals for our business relationships;
    • Internal services (administrative affairs, service checks, billing, customer and vendor accounting, credit management, ...);
    • Promotions and marketing activities within the scope of our services;
    • Management related information;
    • Internal Audits;
    • Internal Services;
    • Investigation of individuals under the relevant financial sanctions legislation;
  2. for Manuchar's subcontractors and suppliers, to, among other things:
    • providing services or performing tasks and commissions in the name and on behalf of Manuchar (e.g. IT providers, cloud service providers, investigation agencies, access security, consultancies...);
  3. to our internal auditors, auditing and certification companies, to, among other things
    • The review of the annual accounts;
    • Obtain and retain certain Certificates;
    • Auditing the granted files;
  4. to various government authorities as part of inspections and investigations, such as:
    • federal and regional inspection and certification services;
    • welfare entities
    • tax authorities;
  5. to all other third parties when required by law, court order, or judgment.

Manuchar does not sell, rent or make available your personal data to third parties for commercial purposes.

In the course of its business, Manuchar may sell activities or assets. In the event of a sale, merger, reorganization, dissolution or similar transaction, your personal data and other information may become part of the transferred assets.

When our providers process your personal data on behalf of Manuchar, they act as data processor as set out in the LGPD. We do everything possible to ensure that your personal data is sufficiently protected.

In certain exceptional cases, your personal data may be transferred outside the national territory. In this case, Manuchar takes all contractual and technical security measures necessary to ensure that all personal data transferred enjoys adequate protection against loss or unlawful processing.

For additional questions you can contact our Privacy Committee at privacidade@manuchar.com.br.

​​​​​​​1.7. How long do we store your personal data?

Your personal data will be stored for the period necessary to fulfill the objectives described in point 1.3 and to comply with legal obligations, and will be kept in a secure and controlled environment.

When applicable, and even after termination of the business or working relationship with Manuchar, we may store your personal data for an additional period of time for auditing purposes, compliance with legal or regulatory obligations, for the regular exercise of Manuchar's rights or also for the necessary period of time according to the legal basis that justifies the retention of data. For example, we may store your data to comply with obligations imposed by the Central Bank of Brazil and also to preserve our rights in legal actions.

​​​​​​​​​​​​​​1.8. Security Measures

Manuchar does its best to protect your personal data against unlawful use by applying physical, administrative and technological measures.

For example: only authorized persons will have access to our office and systems, and this access is limited to the systems they need for professional reasons. These persons must be aware of and correctly apply our internal privacy and data protection policy. To the extent that data is transferred to third parties, Manuchar agrees with these third parties that they will also ensure maximum data security.

If any personal data is processed unnecessarily, in excess of the purpose for which it is intended, or in non-compliance with the LGPD, you can request that Manuchar anonymize, block, or delete this data, provided that the excess, lack of need, or non-compliance with the law is effectively verified.

If you have given your consent to the processing of your personal data for specific purposes (and not necessary for the provision of our services or delivery of our products), you may request the deletion of such personal data, such as personal data obtained from your geolocation to indicate where your purchases were made. If you have given your consent to the processing of your personal data, you may request the revocation of this consent. The revocation of consent may result in the impossibility of using some features of the application, or even in the termination of the services provided, but does not prevent the use of (i) anonymized data; and (ii) data whose processing is based on another legal hypothesis provided for in the LGPD.

​​​​​​​1.9. What are your rights?

Manuchar handles your personal data in accordance with this privacy statement. As a concerned party, you have a number of rights that you can exercise at any time.

You can exercise the following rights:

  • Right to object

You can object to the processing of your personal data. You can only object to Data Processing carried out on the basis of the legitimate interests of Manuchar or a third party (see above at point 1.3). When exercising this right, you must indicate to which specific processing you object and for which specific reasons. This is necessary to determine the balance of interests. It is very easy to object to the use of your e-mail address for sending newsletters, promotions and marketing activities by Manuchar. Every email we send about this always includes a link that allows you to unsubscribe

  •  Right of Access

You can request confirmation whether your personal data are being processed or not.

If so, you may have access to such personal data and may request the following information: the purposes of the processing, the categories of your personal data that we keep, the categories of recipients of such data, (third countries or international organizations), the retention periods or the criteria for determining them, your other rights, other sources of origin of your data and the existence of an automated decision-making process. In providing you with this information, we must always take into account the rights and freedoms of others.

  • Right to Rectification (correction and completion)

You may request that any information that you believe is incorrect or incomplete be corrected or completed. In exercising this right, you must indicate which specific data you wish to correct or complete.

  • Right to Data Portability

You have the right to request that Manuchar electronically transfer the personal data that you have provided to Manuchar (via an e-mail address indicated by you) or to another data controller designated by you (via your e-mail address indicated by you).

  •  Right to Erasure (right to be forgotten)

In the cases foreseen by the LGPD, the user may request the deletion of his/her personal data. We will endeavor to answer you in the shortest time possible, respecting the storage periods established by the legislation.

  • Right to Restriction of Processing

You have the right to request the limitation of the processing of your personal data when:

    • or you question the veracity of your personal data (during the time it takes Manuchar to verify it).
    • or the processing of your personal data by Manuchar would be unlawful, but you still do not wish to invoke your right to erase the data.
    • if or you have objected to the processing of certain personal data of yours (during the time when the balance of interests is checked).

You can exercise your rights free of charge. You can do this by notifying us at privacidade@manuchar.com.br.

No later than one month after receiving your correspondence, we will inform you in writing about the follow-up we have given to your request. Depending on the complexity of your request or the number of requests we receive from others, this period may be extended by two months. In this case we will inform you of this extension in any case within one month of receiving your correspondence. In some cases (e.g. legal obligations, rights of other persons, expiration dates, ...) you will not be able to exercise your rights or will not be able to do so comprehensively. You will receive a notice with the reasons why we cannot attend or do not fully respond to your request.

In principle, you can exercise your rights free of charge. You can do this by notifying us at the e-mail address: privacidade@manuchar.com.br.

1.10. Cookies

On our websites, we use cookies and statistical Internet browsing data to see how our visitors use our site. This information helps us to improve the site. A cookie is a file stored on your computer. When you visit us next time, our site will recognize these cookies. If you want to learn more, you can consult our Cookies Policy on our website.

​​​​​​​​​​​​​​1.11. Questions, remarks, complaints, and data leaks

If you have questions, comments or complaints about Manuchar's protection of your personal data or about this privacy statement, you can contact Manuchar's Legal Department at privacidade@manuchar.com.br.

You also have the right to file a complaint to the ANPD - Agência Nacional de Proteção de Dados, through the government service channels: https://www.gov.br/anpd/pt-br

If you know or suspect a data leak, we ask that you inform us immediately at privacidade@manuchar.com.br.

​​​​​​​​​​​​​​1.12. Modifications

For various reasons, Manuchar may amend, supplement and modify this privacy statement. You can always refer to the most current version on our website. This version was produced in October 2020.

2. Law and Jurisdiction

This Privacy Statement shall be governed, interpreted and executed in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13.709/2018, regardless of the Laws of other states or Countries, being competent the jurisdiction of the domicile of the User to settle any doubt arising from this document.