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Privacy Policy

1. OBJECTIVE OF THIS POLICY

The Grupo Aço Cearense adopts this Privacy Policy as a means of protecting the Personal Data of all those Holders who interact with their companies, guaranteeing a uniform security standard and in full compliance with current legal rules, in particular with the General Protection Law of Personal Data (Law No. 13,709 / 2018).

This Policy aims to establish the parameters for the collection and treatment of your Personal Data by the Grupo Aço Cearense, and covers all environments of your interaction, whether online or offline, as well as the means by which you will be able to exercise your rights. rights over your Personal Data.

2. DEFINITIONS

a. For the purposes of this Policy and its better understanding and understanding, the following definitions and descriptions must be considered:

(i) Anonymization: use of reasonable and available technical means at the time of the Treatment, whereby a data loses the possibility of association, directly or indirectly, with an individual;

(ii) Log files: these are files (logs) that detail the activities of the website and collect statistics on the user’s browsing habits;

(iii) Cookies: small files sent by Our Environments, saved on your devices, which store preferences and little other information, in order to personalize your browsing according to your profile;

(iv) Data: any information inserted, processed or transmitted through Our Environments;

(v) Personal Data: data related to the identified or identifiable natural person;

(vi) IP addresses: it is a number used on the internet or on a network to identify your computer;

(vii) Grupo Aço Cearense, or Group: economic group composed of the following companies Aço Cearense Comercial Ltda, Aço Cearense Industrial Ltda, Siderúrgica Norte Brasil S.A. – SINOBRAS, Sinobras Florestal Ltda., WMA Participações S.A and Instituto Aço Cearense;

(viii) Our Environments: are all platforms, websites and means by which you can interact with Grupo Aço Cearense, such as: (a) websites and pages of the Group’s companies on the internet; (b) pages of the Group’s companies on social networks, such as Linkedin, Facebook, Instagram, Twitter, among others; (c) electronic mail and instant messaging systems, such as WhatsApp, Telegram, SMS (short message service) and the like; (d) the Group’s mobile applications, whether provided directly by the Group or by third parties, such as Google or Apple; (e) customer service channels and sales center; (f) advertisements, advertisements and online forms; (g) offline records and registrations and physical documents delivered or sent to the Aço Cearense Group;

(ix) Web beacons: also known as web bugs or web beacons, they are small sequences of code that allow the delivery of a graphic image on a web page with the purpose of transferring data back to the owner of the page;

(x) Personal data holder: natural person to whom the personal data being processed refer (hereinafter also referred to as you);

(xi) Treatment: any operation performed with Personal Data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, disposal, evaluation or control of information, modification, communication, transfer, diffusion or extraction.

3. WHAT PERSONAL DATA WE COLLECT AND HOW IT IS COLLECTED

3.1. During your interaction with the Aço Cearense Group through one of Our Environments, some of your Personal Data may be collected, as detailed below:

(i) Contact Information: physical mailing address, telephone numbers, e-mail addresses, websites and profiles on social networks;

(ii) Login information: registration name (login), password in unrecoverable (encrypted) format and security questions, when used to access Our Environments;

(iii) Technical information about your computer equipment or mobile devices: record of the IP address used to connect your computer or device to the internet, including its geographic location, the type and version of the operating system and the type and version of the web browser ;

(iv) Information about how you use our sites and services: details such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as response times to content, errors download and duration of visits to certain pages;

(v) Market research and consumer feedback: information that you voluntarily share with Grupo Aço Cearense about your experience of using our products and services.

(vi) Content generated by you: any content that you create and share with Grupo Aço Cearense on third party social networks, including your profile, and that you allow the third party social network to share with us, or by uploading to a our websites, applications and other online and offline services, such as Facebook, Instagram, Linkedin and the like;

(vii) Financial and payment information: any data that the Grupo Aço Cearense needs to fulfill an order, or that you use to make a purchase, such as your debit or credit card details, bank details, or other forms of payment. payment used;

(viii) Contacts with our Customer Service and Sales Center: your interactions with our Service Center and sales channels can be recorded, in accordance with applicable laws, for the operational needs of the Grupo Aço Cearense.

3.2. We use Cookies to improve the use and functionality of the websites and other compatible web services of Grupo Aço Cearense and to better understand how you use our websites and online services, as well as the tools and services offered by them, in order to adapt the Grupo Aço Cearense websites to your personal needs, facilitating their use whenever possible.

3.2.1. You do not need to have Cookies enabled to use or browse most of the websites and online services of Grupo Aço Cearense, and you can freely ensure that the settings on your computer or portable device reflect whether you consent to accept Cookies or not. However, in the event of non-consent, we cannot guarantee that you will be able to access all the resources available on our online channels.

3.2.2. To learn more about the use of Cookies on our online channels, please visit our Cookie Policy.

3.3. Grupo Aço Cearense‘s websites and compatible services may also use other tracking technologies similar to Cookies, which may collect information such as IP Addresses, Registration Files and Web Beacons (web beacons), among others. This data is also used to help us adapt the websites and other compatible services of Grupo Aço Cearense to your personal needs.

3.3.1. As our web beacons can be part of a web page, it is not possible to opt out of this type of feature, but you can make it completely non-functional by activating the opt out feature. ”For Cookies placed by that flag.

3.3.2. More information and details about these tracking technologies, you can also get through our Cookie Policy.

3.4. Grupo Aço Cearense does not knowingly request, collect, process, store or share personal data of minors and children, except in cases where there is a legal provision, or explicit consent from one of their parents or legal guardians, according to current legislation.

3.4.1. If we discover the occurrence of any type of treatment of this type of personal data, unintentionally, we will remove the personal data of that child or adolescent from our records quickly, safely and with a record of this treatment.

4. REASONS FOR COLLECTING YOUR PERSONAL DATA

4.1. Grupo Aço Cearense collects your Personal Data according to the legal precepts, based on the fulfillment of legal, contractual obligations or legitimate interest and, when necessary, upon your consent. The main situations of collection and treatment are due to:

(i) Enable commercial relations and the supply of our products;
(ii) Realization of promotions and marketing actions;
(iii) Interactions on social networks and third party websites;
(iv) Meeting your demands;
(v) Other legal purposes and situations in general.

5. ABOUT SHARING YOUR PERSONAL DATA

5.1. In addition to the entities that are part of the Grupo Aço Cearense, your Personal Data may be shared with:

(i) Service providers;
(ii) Credit analysis agencies, debt collection and financial services;
(iii) Third party companies that use Personal Data for their own marketing purposes:
(iv) With competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, requisition or court order; and
(v) In the case of corporate transactions such as mergers, acquisitions and mergers.

6. ABOUT TERM OF RETENTION OF YOUR PERSONAL DATA

6.1. Grupo Aço Cearense uses your Personal Data for as long as necessary to satisfy the purposes for which it was collected, as described in this Policy.

6.2. You can obtain more details about the retention of your Personal Data through the communication channels detailed in this Policy.

6.3. When the processing of your Personal Data is finished, it will be eliminated within the scope and technical limits of the activities, conservation is authorized for the purposes of auditing, security, fraud control, credit protection and preservation of rights, under the terms of the current legislation.

7. ABOUT PROTECTION OF YOUR PERSONAL DATA

7.1. Grupo Aço Cearense takes appropriate measures to ensure that your Personal Data is kept confidential and secure, with regard to access, storage and transfer:

(i) People who can access your Personal Data: your Personal Data will be processed by our employees or authorized agents, as long as they need to have access to such information, depending on the specific purposes for which your Personal Data has been collected;

(ii) Measures taken in operational environments: your Personal Data is stored in operating environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data;

(iii) Transfer of your Personal Data: given the nature of our business, we may have to transfer your Personal Data stored within the Grupo Aço Cearense to third parties, in accordance with the purposes set out in this Privacy Policy. For this reason, we may transfer your Personal Data to other countries, as long as they have laws and regulations compatible with those in force in Brazil.

7.2. The protections applied by the Grupo Aço Cearense do not apply to information that you have chosen to share in public areas, such as third party social networks.

7.3. It is important that you also take steps to keep your Personal Data safe, such as:

(i) When creating an online account, be sure to choose a password that is strong to prevent unauthorized parties from guessing it. Never reveal or share your password with others. You are solely responsible for keeping your password confidential and for any action taken through your account on the Grupo Aço Cearense websites and compatible services;

(ii) If you use a shared or public computer, never choose the option to remember your login name, email address or password, and make sure that you log out of your account (logged out) whenever you leave the computer.

(iii) You must also use any privacy settings or controls that Grupo Aço Cearense provides on our website, services or applications, including those considered optional.

7.4. It is your sole responsibility for the veracity and accuracy of the Data you provide to the Grupo Aço Cearense, assuming the consequences in the event of inaccuracy of the data provided.

8. ABOUT RIGHTS REGARDING YOUR PERSONAL DATA AND HOW TO EXERCISE THEM

8.1. Through the communication channels provided for in this Policy, you will be able to exercise the Rights related to the information, access and modification of your Personal Data, among which:

(i) Ask questions or comments about this Policy, about the Cookies Policy, and about our privacy and personal data protection practices;
(ii) Make a complaint regarding the Treatment of your Personal Data;
(iii) Request confirmation of the existence of Treatment of your Personal Data;
(iv) Obtain information on how to access your Personal Data;
(v) Carry out the correction of incomplete, inaccurate or outdated personal data;
(vi) Obtain information on the Anonymization, blocking or elimination of unnecessary, excessive or treated data in non-compliance with the provisions of the current legislation;
(vii) Obtain information about the portability of your personal data to another service or product provider, upon express request, in accordance with current legislation;
(viii) Request details of the public and private entities with whom we share your Personal Data;
(ix) Obtain information on the possibility of not providing consent and on the consequences of such denial;
(x) Request details about the origin of your Personal Data or the sharing of this data with third parties;
(xi) Limit the use and disclosure of your Personal Data;
(xii) Revoke consent and / or oppose any of our Personal Data Processing activities;
(xiii) Request the deletion of your Personal Data.

8.1.1. There are situations in which, if you request the deletion of your Personal Data, or request the limitation of use in Our Environments, there may be an impossibility of continuity in the relationship with the Grupo Aço Cearense.

8.1.2. Some situations require the retention of your Personal Data after you request its deletion, in order to satisfy contractual obligations and / or under the terms of the current legislation.

8.2. You can exercise your rights through the communication channels detailed in item 9 of this Policy, upon proof of identity by providing a copy of your RG or equivalent means of identification, in accordance with the legislation in force.

9. COMMUNICATION CHANNELS

9.1. Grupo Aço Cearense provides you with the following communication channels for any and all dealings related to this Policy and / or your Personal Data collected by us:

(i) In charge of the Processing of Personal Data:

Name: Marcelo Rangel
privacidade@acocearense.com.br

(ii) Privacy Portal:

https://www.grupoacocearense.com.br/privacidade

(iii) By phone:

55 85 40111333 (Extension: 1614)

(iv) In person or by conventional mail:

Rua Antônio Pompeu, nº 1900, Centro, CEP: 60.040-000, Fortaleza / CE – Privacy Sector – Data Protection Officer

9.2. Grupo Aço Cearense will receive, investigate and / or respond, within a reasonable time, to any request or complaint about the way we treat your Personal Data, including complaints about breaches of your rights under the laws of privacy and protection of Personal Data in force.

9.3. In the event of communication without proper proof of the identity of the Data Subject, under the terms of item 8.2, above, the communication will be automatically rejected. Any and all identifying information provided to the Grupo Aço Cearense will only be processed in accordance with, and to the extent permitted by, the applicable laws.

10. ABOUT THIS PRIVACY POLICY

10.1. Grupo Aço Cearense reserves the right to make changes to the privacy, data protection and information security practices, including this Privacy Policy and the Cookies Policy, at any time and without prior notification to you, according to the purpose or need of the Group, or for the adequacy and legal compliance of a provision of law or rule that has equivalent legal force.

10.2. We recommend that you access this Policy frequently, or whenever you access Our Environments or use our services, in order to check for any updates or changes. The date of the last updated version will always appear at the end of this Policy.

10.3. In the event of updates to this Policy that imply new collection of consent, you will be notified through the contact channels you have informed us about.

(Português do Brasil)