1. Introduction
The Pormade Economic Group is committed to the transparency, privacy, and security of its customers' data, working to protect the personal data processed and controlled within the scope of its responsibilities.
Pormade Online is an integral brand of the Pormade Economic Group, composed of the companies listed below:
Pormade Portas de Madeiras Decorativas Ltda - 81.639.023/0018-90 / 81.639.023/0001-42DRZ Portas Ecológicas Ltda - 10.652.922/0001-37 / 10.652.922/0002-18Transportes Rodoviários SBA Ltda – 82.574.245/0001-97Pormade Franchising Ltda – 30.358.654/0001-52Decore Tech Ltda - 49.933.965/0001-26Pormade Aberturas Ltda - 75.743.096/0001-87Showroom - Pormade Portas Ltda - 26.947.930/0001-40CA Zini Industrial Florestal Jacutinga Ltda - 11.337.806/0001-96The detailed Privacy Policy below demonstrates how personal data is processed, what information we collect, and how we use and store it, both physically and digitally, in accordance with the provisions of the Brazilian General Data Protection Law (Law 13.709/18).
For the Privacy Policy to be well understood, it is essential to clarify some important concepts:
2. Concepts
National Data Protection Authority (ANPD) - It is the body that will oversee and guide the application of the LGPD (Brazilian General Data Protection Law), as well as being responsible for applying administrative sanctions in case of violation of the law.Consent – clear and objective authorization that the data subject gives for the processing of their personal data for a previously stipulated purpose. After giving consent, the data subject can revoke it at any time. The revocation does not cancel processings carried out previously.Customer – any individual or legal entity that purchases products or services on the website or in any way uses our platform.Personal Data – any information related to an identified or identifiable individual. Also, any information through which it is possible to identify a person or contact them.Sensitive Personal Data – Personal data revealing racial or ethnic origin, religious conviction, political opinion, trade union membership, data concerning health or sexual life, genetic or biometric data.Purpose – what we want to achieve with the processing of personal data.Legitimate interest - Processing of data carried out by the Controller, due to an interest of its own, other companies, or society, without the processing affecting the individual rights and freedoms of the Data Subject.Free access - Right of the Data Subject to access all information regarding the processing of their Personal Data.Necessity – the processing of personal data must be limited to the minimum necessary for the intended purpose. That is, it must be relevant, proportional, and not excessive.Opposition – It is the right of the Data Subject to not want their data to be processed. This right can be exercised in certain specific situations.Security – Means the use of technical and administrative measures capable of protecting Personal Data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication, or dissemination.Processing - considers all operations with personal data: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, communication, transfer, dissemination, or extraction of data from individuals.Transparency - It is the guarantee, to the Data Subjects, of clear, precise, and easily accessible information about the processing and the respective processing agents, observing commercial and industrial secrets.Data subject – any individual whose personal data is processed by Pormade Online.
3. Application
Applies to all customers, employees, and service providers of the Pormade Economic Group, as well as those who in any way have their personal data processed by us. Using our online platform implies acceptance of this Privacy Policy.
4. Personal Data Collection
In general, the personal data processed by the Pormade Economic Group is collected directly from the data subjects themselves, who have a contractual relationship or have shown interest in developing a relationship with us. Except for information required by law or applicable internal policies, the Data Subject's decision to provide us with their personal data is voluntary. However, it is important to note that if the Data Subject chooses not to provide certain information, we may eventually be unable to perform some of the actions that require the use of this data to be executed, given the nature of the related activities.In some other situations, personal data may be sought from other sources, such as publicly available data or provided by public authorities, suppliers, contractors, other business partners, and related sources, always paying attention to the legal basis required for processing this data and its respective applicable legislation.Data collection can occur directly and indirectly. Directly, when registering to receive information, commercial contacts, filling out forms, sending job resumes, participating in recruitment and selection processes, preparing and signing contracts, among other actions related to the execution of our activities. Indirectly, when collected through the technology existing on our website and applications, to provide a more positive user experience. On the online platform, data is collected automatically whenever Cookies are essential for the page's operation.If you provide personal data of third parties to the Pormade Economic Group according to the existing relationship between the parties, but also in other cases such as job referrals and resume submissions, you are responsible for ensuring that the Data Subject is aware of the information contained in this Data Privacy Policy and must have the respective person's consent to share the information with us.
4.1 Children and teenagers
The collection of data from children and teenagers, i.e., individuals under the age of 18, will only be carried out upon the explicit authorization of the parent(s) and/or legal guardian(s) through a specific instrument, in person, and informing the legitimate purposes for doing so. We do not deliberately collect personal data from children and teenagers in any other way.
For children and teenagers in the age group of 12 to under 18 years, who participate in Pormade's teaching projects, the registration on the platform must be filled out exclusively by at least one parent or the legal guardian.
If the User is under 18 years old, they should not register on our relationship platforms nor provide us with any personal data in this situation. If we become aware that we have collected personal data from a child or teenager, we will take reasonable measures to delete the personal data in question.
5. Processing
Regarding the personal data processed within the scope of our activities, we highlight:Registration data: Registrations may include name, email address, address, CPF (Brazilian ID), phone number, image, photo, audio, among other data related to the purpose of the registration in question and any linked legal or contractual obligations (Employee File, Supplier Registration, Customer Portfolio, Participants in Selection Processes, Visitor Registration, among others).Contact data: information obtained through inquiries, requests, and interactions made through our contact forms and communication means, commercial and relationship activities, among others.Financial transaction data: related to transactions carried out through our Services, including for the acquisition of products and/or services. Transaction Data may include your address, CPF, financial, banking, and credit card number, among others.Data regarding the use of our websites, products, cloud services and applications and through their use (“Computing Data”):Pormade Online collects Customer information in various ways: when you create an account and provide data in “My Account”; make a purchase of any of the products offered on our platform; when you interact with the Consumer Service or team of specialists to assist you with your purchase; when you participate in surveys or marketing promotions, etc. Among the information that may be requested are: full name, email, CPF, date of birth, address, phone numbers, and credit card number. We collect and store certain information whenever the Customer interacts with us. For example, we use cookies and obtain information when your browser accesses our website; when you click on advertisements, emails from partners, and other content provided by us on other websites.Information collected by the mobile device: when the customer accesses our e-commerce through the mobile version, we may receive data about your location and your mobile device. We may use this information to offer personalized content such as advertisements, search results, and others. Most mobile devices allow the customer to turn off location services. Search for your mobile device's model and operating system version for more details on how to exercise the right to turn off GPS.The collection of sensitive data occurs for clear purposes and with a legal basis, such as compliance with legal obligations, among which we highlight the Employee File, and legitimate interest for the operation of our activities, among which we highlight biometric timekeeping records and periodic exams. Other purposes may be applied, provided a specific term is used for your knowledge and/or acceptance of the processing in question.It is important that you are aware of what we do with your data and the legal bases for this use. We generally highlight the following processing purposes:
No.PURPOSESLEGAL BASIS
1Opening Salary Account in BanksContract performance
2CAT (Work Accident Communication) MonitoringLegal obligation
3Access to the website by data subjectsConsent
4Employee AdmissionLegal obligation
5Customer RegistrationContract performance
6Registration for sale formalization and invoice issuanceContract performance
7Campaign Registration (data collection – Leads)Consent
8ADVI Partner RegistrationLegitimate interest
9ADVA Partner RegistrationLegitimate interest
10Contractual clausesContract performance
11Agreement for employeesConsent
12Contacting potential customers and partnersLegitimate interest
13Keeping the registration updatedLegitimate Interest
14Exams (scheduling appointments, performance, vaccines)Consent
15Storage of Documents from approved registrationsContract performance
16Storage of Documents after Employee TerminationLegal obligation
17Sales AnalysisLegitimate interest
18ProspectingLegitimate interest
19Order identificationContract performance
20Personal identification to make a paymentConsent
21Registration of Employees in external trainingsConsent
22Health and dental planConsent
23Use of Company Contract TemplatesContract performance
24Invoice IssuanceContract performance
Personal data is processed for the purposes and according to the bases mentioned above, not limited to these, provided a specific term is applied for the knowledge and/or acceptance of the processing in question by the Data Subject.
When electronically or physically accepting privacy terms, we will consider that permission has been given by the Data Subject for the proper processing of their personal data, in compliance with legal and internal requirements related to data privacy.
Personal data under the control of the Pormade Economic Group will not be used for purposes incompatible with those informed to its subjects, except those required or authorized by law, as well as those of vital interest to the Data Subject. If other personal data come to be collected and processed, this document will be updated and disclosed according to any legal requirements.
6. Data transfer to third parties
We may disclose your personal data to any member of our group of companies (this means our factories, subsidiaries, our ultimate holding company and all its subsidiaries), to the extent reasonably necessary for the purposes informed and in accordance with applicable legislation, as well as observing the legal bases for processing informed in this policy.We may disclose your personal data to our insurers and/or professional consultants, to the extent reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of administrative, arbitral, or legal claims. Furthermore, we may disclose your data to our suppliers and service providers to the extent reasonably necessary to provide you with our products and/or services and ensure security in their use and in the use of your personal data, such as suppliers, software companies, marketing and customer service providers, network and cloud service providers. Such third parties may be located in other countries or have their servers in different regions.Financial transactions related to our services and the acquisition of our products and/or services are handled by our financial service providers, and we share transaction data with our payment service providers only to the extent necessary for the purposes of processing payments, refunding amounts, and dealing with complaints and queries related to these matters.In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal and/or regulatory obligation to which the Pormade Economic Group is subject, or to protect your vital interests or the vital interests of another Data Subject. Before sharing, we will take the necessary precautions to ensure that the related personal data will have adequate protection as required by applicable legislation.The Pormade Economic Group has representatives, stores, showrooms, Pormade Móvel (Mobile Unit) and Promoters throughout the national territory, and also has suppliers in other countries (website hosting, cloud services, payment gateways, technical support, development, modeling, customization, among others). Thus, we may transfer your data outside of Brazil for the purposes indicated above. The Pormade Economic Group adopts all appropriate measures and enters into necessary contracts with its suppliers and offices to ensure that the processing of personal data outside Brazil is carried out in accordance with the LGPD and in observance of the Pormade Economic Group's policies.You acknowledge that the personal data you provide to the Pormade Economic Group through the existing relationship, services provided, or our products and/or services may be transferred or accessible by operators internationally.
7. Storage and deletion of personal data
7.1 We keep personal data only for as long as necessary, according to specific retention and record management procedures based on the existing legal basis, among which we highlight:
During the relationship with the Data Subject;During the period necessary to comply with our legal, contractual obligations and regular exercise of rights, among other applicable legal bases.As long as the Data Subject's consent lasts, for cases where this is the legal basis.7.2 We will retain your personal data according to the available legal bases, given that by the nature of the business in some cases it is not possible to specify in advance the periods for which your personal data will be retained based on the existing relationship between the parties. In these cases, we will determine the retention period based on the following criteria, without prejudice to others:
Existence of a specific law or regulation requiring a determined period for data retention;Internal policies of the Pormade Economic Group;Existence of judicial, administrative, or arbitral proceedings; andRequests for information made by government authorities.8. Your Rights
The Pormade Economic Group respects the rights of data subjects set forth in the LGPD. Among these, we highlight:
Confirm the existence of processing of my personal data.Access my personal data held by the Pormade Economic Group.Correct my personal data.Request the anonymization, blocking, or elimination of unnecessary data.Request the portability of my personal data.Request the deletion of personal data processed with the data subject's consent.Know with whom my personal data has been shared.Information about the possibility of not providing consent and about the consequences of denial.Revoke consentRight not to be subject to automated decisions and profiling;You have the right to confirm whether or not we process your personal data and where we do so, as well as the right to access such personal data. If the rights and freedoms of others are not affected, we will provide you with a copy of your personal data.
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:
The personal data are no longer necessary in relation to the purposes for which they were collected or processed;You withdraw consent to consent-based processing;The processing is for direct marketing purposes; andThe personal data have been unlawfully processed.However, there are exceptions to your right to object to processing, such as when it is necessary for the exercise of the right to freedom of expression and information, for compliance with legal and/or regulatory obligations, for the exercise of rights in proceedings, or even for the legitimate interest of the Pormade Economic Group.
If you make such an objection, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of administrative, legal, or arbitral claims.
If you consider that the processing of your personal information violates data protection legislation, you have the right to lodge a complaint with the competent authority and request that the Pormade Economic Group immediately stop the processing in question.
To the extent that the legal basis for the processing of your personal data is consent, you have the right to withdraw that consent at any time. The withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notification to the address of the Pormade Economic Group, addressed to the Data Protection Officer (“DPO”) or through the electronic procedure available at dpo@pormade.com.br.
9. Cookies, Identifiers, Trackers and Third-party information
We use cookies on our website. To the extent that these cookies are not strictly necessary for browsing our website and/or providing our Services, we will ask for your consent to the use of cookies when you first visit our website.
Cookies do not typically contain any information that personally identifies a user, but the personal information we store about you may be linked to the information stored in and obtained from cookies. We use cookies for the following purposes:
Authentication - identify you when you use our portals and electronic applications;Status - help us determine if you are logged into our portals and electronic applications;Personalization - store information about your preferences and personalize services for you;Security - as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials and to protect our portals, electronic applications, and services in general;Advertising - help us display advertisements that will be relevant to you;Analysis - help us analyze the use and performance of our website and services; andCookie consent - store your preferences regarding the use of cookies more generally.Our service providers use cookies and these cookies may be stored on your computer when you use our portals and electronic applications. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing this vary from browser to browser and their versions. Blocking all cookies will have a negative impact on the usability of many websites. If you block cookies, some features available on our portals and electronic applications may not function properly.
In addition to identifiers, we also use Web Beacons that help us better manage the content of our Sites, informing us which content is effective. Web Beacons are embedded in or associated with certain emails or other communications you receive from us or our offices. Web Beacons help us track your responses and interests and provide relevant content and services to you. For example, they can let us know when you take actions based on the emails we send.
We may use third-party services, such as open search tools and social networks, to obtain information about you (such as your name or company) and enrich your personal data, obtaining publicly available information about you, such as your position, employment history, and contact information.
10. Incidents
The Pormade Economic Group assesses and promptly responds to the occurrence of incidents that may compromise your Personal Data. If the Pormade Economic Group becomes aware of any incident involving the Personal Data of data subjects for which it acts as controller, the Pormade Economic Group will notify you and the competent authorities.
11. Data security and good practices
The Pormade Economic Group uses the best information and asset security protocols to preserve the privacy of customer data, but also recommends individual protection measures.
We take organizational security precautions, whether physical or technical, to promote good governance of the personal data controlled by the organization.
Protocols, related controls and policies have been developed, as well as procedures and guidelines to maintain these measures based on a risk mapping conducted.
Trainings, capacity-building actions, and specific awareness campaigns on Data Privacy topics have been included in our preventive actions, aiming to disseminate good practices and train our employees.
The Information Security and Personal Data Privacy Committee constantly works by proposing improvements, changes, and adjustments related to data privacy policy, information security, and other regulations related to the good practices applied by the organization.
12. Data Protection Officer (“DPO”)
The Pormade Economic Group has a Data Processing Officer (“DPO – Data Protection Officer”), Ms. Miriam Götz Mayer, duly appointed to act as a communication channel between the controller, the data subjects, and the National Data Protection Authority (ANPD). The identity and contact information are available on our website at www.pormade.com.br or through direct access on the LGPD Portal at https://lgpd.pormade.com.br.
If necessary, for questions or clarifications about this Privacy Policy, contact us by email at dpo@pormade.com.br.
13. Changes to the Data Privacy Policy
The Pormade Economic Group may change this policy at any time, and such updates are published on our website and other related platforms, and can be checked at any time. We recommend that you periodically check our communication tools to consult any changes to this Data Privacy Policy.
In case of significant changes to this privacy policy, we may notify you by email about such changes or through specific messages on our communication platforms.
14. Governing Law and Jurisdiction
This policy will be governed, interpreted, and enforced 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, with the jurisdiction of União da Vitória - PR being competent to formalize any doubts arising from this document.
15. Our Details
The Pormade Economic Group is headquartered in the City of União da Vitória, State of Paraná, Brazil, at the address Rua Prudente de Morais, Nº940, Centro, ZIP Code 84600-905.