Privacy policy

 

Version: February, 2022

Sitrad’s Privacy Policy (“Policy”) was created to show the commitment of Full Gauge Eletro-Controles Ltd., company registered with CNPJ/ME nº 90.446.048/0001-10, (herein referred together as “Full Gauge”, “we” or “our”), with the safety and privacy of information collected from users, being these the owners of their personal data (“Owner”, “User” or simply ”you”), as well as helping the title holders to take decisions based on your privacy.

The policy clarifies the general conditions for data collection, use, storage, and other handling and personal data protection forms on our website www.fullgauge.com.br (“Website”) in accordance with Brazilian Law currently in force in relation to personal data privacy and protection, including, but not limited to Law nº 12.965, from April 23rd 2014 and Decree nº 8.771, from May 11th 2016 (“Internet Civil Frame”), Law nº 13.709, from August 14th 2018 (“General Data Protection Law” or “LGDP” in Portuguese).

To maintain a direct contact with you, a Responsible for Personal Data Handling was designated by Full Gauge to administer a communication channel:

Responsible person: Gabriela Coelho

Contact: privacidade@fullgauge.com.br

This Privacy Policy may be updated or modified at any moment, with the modifications being informed in an emphatic manner on our Website.

By using our Website, you agree with this Policy on your own free will, in an unquestionable, expressly and integral manner. We recommend you read carefully.

1. TARGET AUDIENCE
2. WHAT IS PERSONAL DATA HANDLING
3. WHO CONTROLS YOUR PERSONAL DATA
4. INFORMATION WE CAN COLLECT
5. LEGAL BASE FOR PERSONAL DATA HANDLING
6. PERSONAL DATA SHARING
7. PERSONAL DATA OWNER RIGHTS
8. HOW WE STORE AND HANDLE PERSONAL DATA
9. INTERNATIONAL TRANSFER OF PERSONAL DATA
10. INFORMATION RETENTION TIME
11. COMMUNICATIONS POLICY
12. LINKS TO OTHER WEBSITES

1. TARGET AUDIENCE

 This Privacy Policy is applied to people who:

Access our website

Register with our website

Contact us

2. WHAT IS PERSONAL DATA HANDLING

Personal data handling (or data handling), means any operation performed with that data:

For example:

Personal data gathering

Use

Access

Processing

Storage

Deleting

Communication

Transference

Personal data is an information related to an identified or identifiable natural person.  The data related to you, a Full Gauge client, is a personal data.

3. WHO CONTROLS YOUR DATA

When you access our site, Full Gauge takes on the role of controller for the treatment of your personal data, acting in accordance with the applicable law and as described within this Policy.

4. INFORMATION WE CAN COLLECT

 

Important: You are not obligated to allow us to collect your information, however, by not allowing us to collect information when it is requested, the access to some functions will be restricted. Apart from the data you enter, whenever you interact with our Website, information will be collected automatically. Such information is usually anonymous, however, whenever combined with other data that can be associated to you, it will be handled by Full Gauge as personal data.

Within the limitations allowed by applicable law, Full Gauge may handle the following personal data entered by you:

Origin	Data collected	Treatment goal
Website navigation	Navigation information:	Access registration: we have the legal duty to store your information to give it to the authorities, upon request.
Forms filles out on the website	Information for contact/talk with us: name, company, industry, telephone, e-mail, country, Sitrad version and message.	Answer your questions, information requests about Sitrad and talk with us;
	Newsletter sign-up and news information: Name and e-mail.	Send our new products, information about the company, addressed products and sales.

Please note that the personal data listed above will be collected by Full Gauge and later handled only as needed to comply with the purpose described herein.

We do not collect, store, or handle in any other intentional way excessive or unnecessary personal data to the purpose that initiated the data collection, as well as data considered sensitive (those related to your ethnic or racial origin, religious beliefs, political opinion, membership to syndicates or religious, philosophical, or political organizations, health status or sexual orientation, as well as genetic data) and data from children and teenagers. Regarding this topic, please refrain from sharing such data with us. If we become aware that such data was collected unintentionally, they will be erased from our registries.

5. LEGAL BASE FOR PERSONAL DATA HANDLING

The legal base classification for stored and processed data by Full Gauge listed in section 2 happens through an analysis of the specific context in which we collect them.

The data handled by Full Gauge tend to be collected only:

Art. 7º, I Law Nº 13.709/18	With your consent.
Art. 7º, II Law Nº 13.709/18	To comply with legal or regulation obligations.
Art. 7º, V Law Nº 13.709/18	When necessary for the contract execution or preliminary procedures related to the contract.
Art. 7º, IX Law Nº 13.709/18	When the personal data processing is in accordance with the legitimate interests of Full Gauge, always considering your own interests related to data protection or liberties and fundamental rights. A need for processing your data will also arise to protect your interests or third parties interests.

 

6. PERSONAL DATA SHARING

 

Whenever needed to achieve the purposes described in Section 2, Full Gauge may share your personal data with the third parties listed below, assuring the correct provision of the offered services, the personal data storage safety and a better experience with Full Gauge. Whenever performed, the data sharing will be done within the limits and purposes of our business, in accordance with the purpose of the personal data handling and in fulfilment with the applicable law. Thus, your data may be shared with:

E-mailing company	Sending e-mails automatically for the people registered with our newsletter.
Hosting company	Company that offers the hosting for our website.
Security Service providers	Warranty of the security of the information handled by Full Gauge.
Cloud Servers	Information storage on the cloud.
Public Authorities	Answer to reports, investigations, judicial orders and judicial processes, requested case, as well as complying with other legal, regulation and fiscal obligations.

 

7. PERSONAL DATA OWNER RIGHTS

 

In the forms and within the limits of the applicable law, you, as owner of the personal data, may contact us to exercise your rights to request:

Confirmation and access	It allows you to confirm the existence of personal data handling and, if affirmative, request the access to a copy of these data.
Correction	It allows you to request the data correction that are incomplete, mistaken or outdated.
Anonymity, blocking or deleting	It allows you to request the anonymity of your data (so they cannot be related to you), data blocking (suspending temporarily our use of them), or data deleting (so we delete them, without any reversal).
Portability	It allows that, through a written request, we deliver your personal data to another supplier for services or products, in a structured and interoperable format.
Information about sharing	It allows you to know which public and private entities we share your personal data.
Information about the possibility of not giving consent	It allows you to have a clear and complete information about the consequences of not offering your consent, meaning, you are free to deny your consent, even if that limits our services to you.
Consent revoking	It allows you to revoke your given consent, at any moment, without it affecting the legal base of the treatment performed previously.
Objection	It allows you to object the personal data handling, in case you don’t agree with the handling.

Your requirement may be done free of charge though the e-mail privacidade@fullgauge.com.br. We will analyze your request and will answer as soon as possible, considering the time periods and terms foreseen in the applicable law. In case it is not possible to answer your request immediately, we will indicate the legal and other reasons that prevent us from doing so.

Full Gauge is not responsible for the correction, accuracy, authenticity, completeness, and update of the data entered by the Owner. It is an exclusive responsibility of the Owner to enter only correct, accurate, authentic, complete and updated data.

8. HOW WE STORE AND HANDLE PERSONAL DATA

 

Full Gauge adopts safety, technical and administrative measures to keep the stored data secured, through internal training, confidentiality clauses and with strict access control, with our collaborators only accessing the strictly necessary data to comply with specific purposes, as stated in Section 2. Specifically in relation to relation to the data collected through our Website, it is stored, handled and protected through the best practices in hosting and processing.

Nevertheless, the Owner must be aware that no Internet safety systems is completely protected from unwanted hacking, the commitment of Full Gauge is limited to adopting the recommended protection measures in accordance with the current state of the art.

 

9. INTERNATIONAL TRANSFER OF PERSONAL DATA

 

Full Gauge will perform the international transfer of your data to other countries or international organization only when strictly necessary to achieve the purposes that originated the handling of your personal data, prioritizing whenever possible the storage in serves located in the Federative Republic of Brazil. When your personal data is transferred out of Brazil by Full Gauge, we will adopt appropriate measures to warrant an adequate protection of your personal data in accordance with the applicable data protection law requirements, including through the celebration of appropriate data transference contracts with third parties, when necessary.

10. INFORMATION RETENTION TIME

We store and retain your information: (i) for the time required by law; (ii) until the end of the personal data handling, as stated below; (iii) for the necessary time to preserve the legitimate interests of Full Gauge, on a case-by-case basis; (iv) For the necessary time to safeguard the regular exercise of Full Gauge rights in judicial, administrative or arbitral processes. Thus, we will handle your data, as an example, during the applicable expiry deadlines or as necessary to comply with legal or regulatory obligations.  

The end of the personal data handling will occur in the following cases:

1. When the purpose for which the personal data of the Owner were collected has been reached and/or the collected personal data stop being necessary or relevant to the scope of such purpose;
2. When the Owner withdraws their consent or exercises the right to request the termination od the handling and the erasing of their personal data; and
3. When there is a legal order that determines to do so.

Observing the principle of necessity, some data collected through the Website may be erased from our registries through the routine registries maintenance. We do not have the obligation to store the personal data for an indefinite time and we disclaim any and all responsibilities resulting from or related to the destruction of this personal data.

Upon the termination of your personal data handling, safeguarding the hypothesis established by applicable law or by this Privacy Policy, they will be erased from the Full Gauge database. Whenever erasing is not possible at first, the data will be stored safely and isolated from any further processing, until the erasing is possible.

 

11. COMMUNICATIONS POLICY

 

We avoid sending non-requested e-mails, restricting communications with you to topic relevant to your specific interests.

If you prefer not receiving more information from us, you may request to unsubscribe through the unsubscribe button within the e-mail or in the received message (opt out) or request it through the e-mail privacidade@fullgauge.com.br.

You must be aware that several scammers try to use recognizable brands to obtain personal information such as passwords and financial data. Full Gauge WILL NEVER REQUEST YOUR FINANCIAL DATA THORUGH E-MAIL OR PHONE CONTACT. IN CASE OF ANY SUSPICIOUS ACTIVITIES, PLEASE SEND US YOUR DOUBTS OR ALERT THROUGH E-MAIL TO privacidade@fullgauge.com.

12. LINKS TO OTHER WEBSITES

 

Our Website may contain links of frames from other websites. These links or frames aim to provide additional benefits to the contents and services offered to the User.

We clarify that the addition of these links in our Website does not mean that Full Gauge is in acknowledgement, agrees with or is responsible in any way for the content of said links and frames. It is important to highlight that our objective is only to post links or frames from reputable and trustworthy companies, but Full Gauge is not responsible for the information, services and products obtained by the User in said websites, nor it is responsible for the commercial practices and privacy policies adopted by said companies, and Full Gauge may not be liable for eventual losses and damages or lost profits suffered by using those resources.

Insofar as the linked websites are not a part of out Website, we do not control, recommend or endorse these websites and their content, products, services, policies and their privacy practices; we do not have access to your personal data collected and handled by them and their advertising policies, cookies and terms of use. Thus, we recommend a careful reading of these documents on third party websites.

Upon entering our Website and interacting with us, you agree and accept the terms herein expressed.

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