Privacy Notice

PRIVACY NOTICE OBJECTIVE

This Privacy Notice (“Notice” or “Privacy Notice”) aims to clarify the rules and guidelines regarding the use and protection of personal data processed by Columbia Trading S/A (“Columbia”), in order to strengthen the relationship of trust with our Users, as defined below.

Columbia is a company dedicated to all activities in the foreign trade segment, including indirect imports and exports, BPO, diversified customized solutions, structured import and export financing operations and projects with tax and logistics intelligence applications.

If you do not agree with any of the provisions of this Privacy Notice, please contact us via [=] so that we can find out where you disagree and clarify what is necessary. If you still disagree, unfortunately it will not be possible to establish any relationship through our services.


TERMS AND DEFINITIONS

In order to understand this Notice, we must consider the following definitions and terminology:

Processing agents: the controller and the operator.

Anonymization: the use of reasonable technical means, available at the time of processing, by which a piece of data loses the possibility of direct or indirect association with an individual.

National Data Protection Authority (ANPD): public administration body responsible for ensuring, implementing and monitoring compliance with the LGPD throughout the country.

Database: structured set of data, established in one or several locations, in electronic or physical form.

Blocking: temporary suspension of any processing operation, through the safekeeping of personal data or the database.

Employees: people hired to work for Columbia.

Consent: free, informed and unequivocal expression by which the data subject agrees to the processing of their personal data for a specific purpose.

Controller: an individual or legal entity, whether governed by public or private law, which is responsible for decisions regarding the processing of personal data.

Cookies: files containing small pieces of data that are shared between a technological device and a website and/or application in order to make browsing more user-friendly and improve the user experience.

Anonymized Data: data relating to the data subject that cannot be identified, considering the use of anonymization at the time of its processing.

Personal Data: information relating to an identified or identifiable individual.

Sensitive Personal Data: personal data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data relating to health or sex life, genetic or biometric data, when linked to an individual.

Deletion: deletion of data or a set of data stored in a database, regardless of the procedure used. 

Data Protection Officer (DPO): a person appointed by the controller and operator to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).

Purpose: the reason for which the personal data of the data subject is processed.

General Personal Data Protection Law (LGPD): Law No. 13.709/2018 or LGPD, which provides for the processing of personal data of individuals, regardless of the medium, by an individual or legal entity governed by public or private law, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the personality of the individual.

Operator: individual or legal entity, governed by public or private law, which processes personal data on behalf of the controller.

Opt-In: the manifestation of the data subject in expressing, previously and explicitly, their consent to receive specific communication or authorization to process personal data.

Opt-Out: the opposite of opt-in, i.e., the revocation of a previously given consent.

Site/Website: virtual address of the individual or legal entity, consisting of a set of electronic pages.

Data Subject: individual to whom the personal data being processed refers.

International Data Transfer: transfer of personal data to a foreign country or international body of which the country is a member.

Processing: all operations carried out with personal data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

Shared Use Of Data: communication, dissemination, international transfer, interconnection of personal data or shared processing of personal databases by public bodies and entities in compliance with their legal competencies, or between private entities, reciprocally, with specific authorization, for one or more processing modalities permitted by these public entities, or between private entities.

User: individual who uses the site and/or services of Columbia.


DATA COLLECTED

In order for Columbia to carry out its activities, it is essential to collect certain information about the data subject. Therefore, personal data provided directly by the data subject, by third parties or collected automatically, depending on the service contracted or the type of relationship between the data subject and Columbia, may be collected by telephone, e-mail or on our website. Below are the ways in which personal data is collected:

Personal data provided directly by the data subject: All personal data voluntarily entered or submitted by the data subject when accessing and registering on the website, and/or using the services offered by Columbia, will be collected.

Personal data provided by third parties: Columbia may receive personal data through third parties (such as fairs and events) that have some relationship with the data subject. Note that, in these cases, the applicable regulations and privacy policies will be those elaborated by these third parties. If you do not wish for third parties to share your data with Columbia, you should contact them directly.

Personal data collected automatically: Columbia may also collect a range of information automatically and, to do so, makes use of some market technologies (cookies, for example), with the purpose of improving the browsing experience of its Users, according to their habits and preferences.


The following essential rules will always be followed when collecting personal data:

  • Only information essential for the intended purpose of processing will be collected;
  • If necessary, we will request authorization or notify the data subject of the collection of new data, accompanied by the appropriate justification; and
  • The personal data collected will only be used to fulfill the purposes informed to the data subject.

Any and all processing of personal data of children and adolescents will be carried out based on the legal hypotheses provided for in the LGPD and observing the best interests of the minor.

PURPOSES OF PROCESSING PERSONAL DATA

The personal data processed by Columbia is intended to serve various purposes, depending on the relationship of the data subject with us. Below, we present, in a non-exhaustive manner, the main hypotheses in which we may process the personal information of the data subject:

(i) To comply with contractual obligations assumed or preliminary steps in import, nationalization, distribution and marketing of products, inventory maintenance and other services and activities related to the foreign trade segment.

(ii) To resolve doubts and provide support for various requests regarding Columbia's services.

(iii) To comply with any legal, regulatory or administrative obligation.

(iv) For the regular exercise of rights in judicial, administrative or arbitration proceedings, including proceedings before Procons and other public bodies.

(v) In the pursuit of the legitimate interest of Columbia, always at the limit of the expectation of the data subject, such as:


  • When you apply for one of our job vacancies.
  • In the construction and evaluation of the profile of Users, as well as to consolidate statistical data about them, in order to offer personalized services compatible with their needs;
  • To operate, evaluate and improve the businesses of Columbia, including the analysis and review of the User base, data analysis, market research and the execution of accounting, auditing and other internal functions;
  • In establishing statistics, tests and evaluations for research and development, aimed at managing and evaluating business risks, improving and/or creating new products and services;
  • Promoting, offering and marketing services and products provided by Columbia. In such cases, if you wish to stop receiving communications from us, you can request this at any time by clicking on the opt-out link in the communications you receive, to be directed to the cancellation process, or you can use one of the means of communication mentioned in this Notice.
  • To provide Users with a good and easy browsing experience on Columbia's platforms; and
  • In cases of complaints related to the company on social networks or specific platforms, in order to resolve the points complained of, as well as to adopt the necessary measures to resolve the situation in the best possible way.


(vi) Through authorization granted by the data subject, if applicable, such as for making and publishing testimonials, photos and videos of professionals on the company's website and social media, or

(vii) For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law.


Any databases formed through the collection and storage of the personal data of the data subject are the property and responsibility of Columbia, and their use, access and sharing, when necessary, will be carried out within the limits and purposes of its business, and may, in this sense, be made available for consultation, shared and transferred to suppliers, authorities and service providers, provided that the provisions of this Notice and the applicable regulations are complied with.

Internally, User data is accessed only by duly authorized employees, respecting the principles of purpose, adequacy, necessity and other principles inherent to the processing of personal data, always for Columbia's objectives, in addition to the commitment to confidentiality and preservation of privacy under the terms of this Notice.

SHARING DATA WITH THIRD PARTIES

The personal data processed by Columbia may be shared with companies in its economic group and third parties, as defined below:


To grow and strengthen relationships with companies in the economic group

Columbia may share personal data with the companies of its economic group for the purposes of consolidating the customer base, better serving Users, advertising facilities and/or maintaining business with said group.

For the performance of services

Columbia may share data with service providers and partners who assist us in carrying out our activities. When we share data with third-party service providers, we require them to use your data in compliance with our instructions, contracts and applicable law. Columbia requires all of its service providers to process data only in compliance with this Notice and applicable regulations.

For strategic reasons

Columbia may share data with other entities that provide us with services or assist us in operating, executing, enhancing, customizing and advertising our internal facilities and functions, such as data analysis, maintaining the security of internal systems or to ensure compliance with legal provisions. As an example, Columbia may share information with auditing firms, law firms for legal assistance, or other professionals. Other entities that may receive personal data for such purposes include information security service providers, data analytics companies, quality assurance assessors, among others. 

For legal and regulatory reasons

Columbia may share personal data with service providers and other entities when necessary to comply with legal or regulatory obligations, including compliance with any applicable law, judicial or administrative process. Columbia may also share information to protect and defend its own rights, and to cooperate with law enforcement agencies. 

In relation to corporate transactions

If Columbia enters, directly or indirectly, into the process of a business transaction, such as a merger, acquisition or sale of all or part of its assets to another company, we may share data with the successor or potential successor company, its respective employees and with audit firms and law firms assisting during the transaction.


When the holder consents to disclosure

In other cases not specified above, if we intend to share your personal data and information, we will send you a notification with information about such sharing in order to request your consent for that specific purpose.


TRANSFER OF DATA OUTSIDE BRAZIL

Columbia may transfer some of your personal data to service providers located abroad, including cloud service providers and technology and software tools. When your personal data is transferred outside Brazil, we will take appropriate measures to ensure adequate protection of the information in compliance with the requirements of applicable data protection legislation.


RIGHTS AND REQUESTS OF THE DATA SUBJECTS

In compliance with the applicable regulations, Columbia ensures the following rights to data subjects:

  • Confirmation of the existence of processing;
  • Access to your data;
  • The correction of incomplete, inaccurate or outdated data;
  • The anonymization, blocking or deletion of unnecessary data, excessive data or data processed in noncompliance with the applicable regulations;
  • The portability of data to another service or product provider, upon express request, in compliance with the regulations of the National Authority;
  • The deletion of personal data processed with the consent of the data subject, with the exceptions provided for in the applicable regulations;
  • Information on the public and private entities with which we share data;
  • Information about the possibility of not giving consent and the consequences of not doing so;
  • Revocation of consent, in accordance with applicable regulations; and
  • Review of automated decisions.


The rights of the data subjects provided for in the applicable regulations and in this Notice may be exercised upon express request by the data subject or their legal representative, which may be made through the relationship channel available at [=].

The User is aware, by reading this document, that any request to delete essential information for the management of their registration with Columbia, when applicable, will result in the termination of their contractual relationship, with the consequent cancellation of the services then provided.

Columbia will make every reasonable effort to respond to requests made by the data subject in the shortest possible time. However, justifiable factors may delay or prevent it from being dealt with promptly, and in the event of a delay, the data subject will be given the reasons.

The data subject must be aware that their request may be legally rejected, either for formal reasons (such as their inability to prove their identity) or for legal reasons (such as the request to delete data whose maintenance is a free exercise of rights by Columbia), and it is certain that, in the event that it is impossible to comply with these requests, the data subject will be provided with reasonable justifications within a reasonable period of time.

Finally, it is the duty of the data subject to provide correct and up-to-date information. Columbia is not responsible for the accuracy, veracity or lack thereof of the information provided and may, at its discretion, suspend and/or cancel the User's registration at any time if any inaccuracy is identified.


TERMINATION OF PROCESSING

The personal data processed by Columbia will be stored for as long as necessary to fulfill the purposes for which they were collected, for as long as necessary to preserve the legitimate interests of Columbia or to comply with legal and regulatory requirements. At the end of the data retention period or when requested by the data subject, Columbia will securely delete the data.


INFORMATION SECURITY

Any personal data held by Columbia will be stored in accordance with the strictest security standards adopted by the market, which includes the adoption of measures such as:

  • Protection against unauthorized access;
  • Carrying out frequent vulnerability tests, whether on the company's servers or on its own systems, ensuring total security in the traffic of data subjects' information;
  • Restricted access by people to the location where personal information is stored; and
  • Adoption of procedures so that employees, service providers and suppliers who process personal data commit to maintaining absolute confidentiality of the information, adopting best practices for handling this data, as determined in corporate policies and procedures.


In addition to technical efforts, Columbia also adopts institutional measures aimed at protecting personal data, so that it maintains a governance and privacy program applied to its activities and governance structure, which is constantly updated.

In any case, in the unlikely event of security incidents involving personal data, Columbia guarantees its full efforts to remedy the consequences of the event, always ensuring due transparency to the data subject.

TYPES OF COOKIES WHAT DO THEY DO?
REQUIRED Cookies that are essential for the platform visited to function correctly. This type of cookie does not store personally identifiable information and is usually set in response to a request for services from the user, such as setting their privacy preferences, logging in or filling out forms. This type of cookie cannot be disabled on Columbia's platforms, and the user can configure their browser to block them. However, it should be noted that this action will affect some of the functionalities of the platforms. 
PERFORMANCE Cookies that enable the counting of visits and traffic sources in order to measure and improve the performance of our platforms. All information collected by this type of cookie is anonymous. The user can prohibit the execution of these cookies, but Columbia will be unable to understand how the user interacts with its platforms, without providing information on the areas visited, the time of visit and any problems encountered, such as error messages, for example.
FUNCTIONALITY Cookies that allow platforms to remember user choices, providing a personalized experience. They may be set by Columbia or by suppliers whose services we add to our platforms. The user may prohibit the execution of these cookies, but some or all of these functionalities may not work as intended.
ADVERTISING Cookies that may be set on Columbia platforms through our marketing partners. They will be used by these partners to build a profile and display content more relevant to the interests of the user, as well as to measure the effectiveness of advertising campaigns. They do not directly store personal information, but are based on the unique identification of your browser and device used for access. The user may prohibit the execution of these cookies, but will receive less targeted advertising.
SOCIAL MEDIA Cookies set by third parties and added to the Columbia platforms to track users of social media who visit our services, allow them to share our content with their list of friends and acquaintances. They are also able to track your browsing on other websites and create a profile of your interests. This may affect the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or view these sharing tools.

Users can revoke their consent to the use of cookies at any time by accessing their preferred browser settings. However, we would like to point out that, depending on the settings made, certain functionalities of our services may not work optimally, as well as aspects of information security.

For more information on how to manage cookies directly in your preferred browser, please consult the links below:


Microsoft Edge:

https://support.microsoft.com/pt-br/microsoft-edge/excluir-cookies-no-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09


Mozilla Firefox:

https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-que-os-sites-usam


Google Chrome:

https://support.google.com/accounts/answer/61416?co=GENIE.Platform=Desktop&hl=pt-BR


Safari:

https://support.apple.com/pt-br/guide/safari/sfri11471/mac


Note: The above instructions are provided by the official websites of the manufacturers themselves. Columbia cannot be held responsible for any damage or loss of information caused by the use of these procedures

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