PRIVACY POLICY
CBC Indústrias Pesadas S.A.
CBC has been designing and producing high-quality, reliable equipment for over 65 years, following our vision of being the best capital goods company and contributing to a better future for the organization and society.
We at CBC value the privacy of all our external audiences and take the responsibilities related to the protection of their personal data seriously.
All our activities are based on our values: health and safety, customer satisfaction, quality, compliance, environmental protection, partnership, innovation, corporate identity and personal data protection. These same values, present in our Conduct Code and combined with transparency, are followed to the letter to protect your personal data. We work to maintain a culture of privacy and personal data protection that involves all our activities, always valuing security in the processing of your personal data.
Our activities are based on the principles of good faith, purpose, necessity, transparency, security, prevention, non-discrimination, adequacy, free access, accountability and data quality, in accordance with the General Personal Data Protection Regulation (LGPD) and the guidelines of the National Data Protection Authority (ANPD).
We have therefore made this Privacy Policy available to representatives of our clients, representatives of potential clients and the general public (such as job applicants and dependents of our employees), so that they understand how we use their personal information and how they can exercise their rights in relation to their personal data.
It is important that you read this policy carefully. If you still have any questions about how we handle your personal data, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.
In order to keep this Policy up to date, we may change it at any time, at which point the updated version will be made available on our institutional website.
Definitions relevant to understanding this policy
This policy uses some expressions with which you may not be familiar. For this reason, we have included below a brief explanation of some of the terms used:
* What does "LGPD" mean? LGPD stands for General Personal Data Protection Regulation (Law 13.709/2018), federal legislation that has been in force in Brazil since September 2018.
* Who is the "data subject"? The data subject is the natural person to whom the personal data being processed relates. In other words, when you interact with us and share your personal data in the course of providing our services, you are the data subject.
* What is "personal data"? Personal data is any information relating to an individual that identifies them or makes them identifiable (even if this identification is indirect). For example, a person's full name, email address, parents' names, consumption habits and many other data that can identify them. When we mention "personal data" in this Policy, we are also referring to sensitive personal data.
* What is "sensitive personal data"? Sensitive personal data is personal data about racial or ethnic origin, religious conviction, political opinion, trade union membership, religious, philosophical or political organization, data concerning health or sexual orientation, genetic or biometric data.
* What does "processing" mean? The processing of personal data is a definition provided by the LGPD which includes any and all activities carried out with personal data. This includes the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction. Therefore, whenever we use the term "processing" we are referring to any of these activities.
* Who is a "data Controller"? The Controller is the party responsible for decisions regarding the processing of personal data.
* Who is a "data processor/Operator"? The Operator is the party that processes personal data in accordance with the instructions and on behalf of the Controller.
* What does "ANPD" mean? ANPD is the National Data Protection Authority, the public administration body responsible for ensuring, implementing and monitoring compliance with the LGPD throughout the country.
Who is this Policy aimed at?
This Policy is intended to inform you how we process the personal data of our clients' representatives, potential clients' representatives, job applicants and our employees' dependents.
This policy does not refer to the processing of employees' personal data, which is described in the Privacy Policy for Employees
In order to bring more transparency to personal data subjects, we have divided the information on how we process personal data according to specific categories of data subjects, as follows.
Customer representatives
Below is complete information on how we process the personal data of our clients' representatives.
How is personal data collected?
The personal data of customer representatives is collected in the following ways:
* Provided directly by employees or representatives of our clients, at the time of negotiations for the preparation of the technical proposal or technical-commercial proposal, by e-mail or via the form on our website;
* Through the sales team, which collects data directly from customer representatives;
* Through trade bodies, regulatory agencies or judicial court; or
* Through the government website.
What personal data does CBC use and for what purposes?
In short, we process personal data to enable commercial relations with our clients, during and after the provision of a service or supply of a product. Below is a detailed list of our processing activities, as well as a list of the personal data used.
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WHY WE TREAT PERSONAL DATA? |
WHAT PERSONAL DATA IS USED? |
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Carrying out all activities related to the sale of our products, such as:
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Full name Identification generated by official bodies (CPF and RG) Occupation or position Address, telephone number and business or home e-mail address Content of e-mails exchanged with CBC Personal cell phone Credit score and other information taken from the reports generated by the credit bureaus |
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Carry out activities related to participation in fairs and events |
Full name Identification generated by official bodies (CPF and RG) Occupation or position Address, telephone and business e-mail |
| Carrying out access control at CBC units |
Full name Business phone and/or cell phone Email address Copy of official identity document (confirm identity) Closed-circuit video footage, as permitted by law (to protect our facilities) |
| Manage the "Alô Etica" complaints channel |
Full name Identification generated by official bodies (such as CPF, RG, CNH, passport, CTPS, PIS/PASEP) Other information that is relevant to the investigation of the complaint and is provided by the complainant, for example, business address and telephone number, position or occupation, among others relevant to the situation. |
| Attend to any judicial or administrative demands |
Full name Identification generated by official bodies (CPF, RG, CNH, CTPS, passport, visa to enter other countries and PIS/PASEP) Other personal information relevant to the demand such as address and telephone number, occupation or position, history of the relationship with us, among other relevant information that has been mentioned in the legal proceedings. |
| Information shared as a job applicant |
Name and information (identification) Telephone and/or cell phone l Email address (enable communication) Curriculum vitae, application form, supporting documents (to assess job applicants) Letters of offer and acceptance, email content (making and answering requests, exchanging information) Age, disability, nationality, religion, race/ethnicity, sexual orientation (full reports required by law, collected only when necessary and mandatory) |
It is important to note that consent is not the only legal basis for processing the personal data of our clients' representatives. We may process personal data for compliance with legal obligations, for the regular exercise of our rights, for the performance of a contract entered into, or to fulfill our legitimate interests as a result of our business relationship. In all cases, the legal basis has been carefully defined in good faith by CBC.
Whenever we intend to use consent to process personal data, this consent will be requested from the data subject in an express and transparent manner, enabling the free expression of consent.
How long will CBC process your personal data?
We will continue to actively process the personal data of our clients' representatives for the duration of the business relationship.
After the termination of this relationship, personal data may still be kept for the fulfillment of legal obligations to which we are subject as a result of our professional activity or to exercise our rights in judicial, administrative, arbitration or contractual proceedings.
If there is any information that we cannot, for technical reasons, completely delete from our systems, we will implement appropriate measures to prevent any further processing or use of the data.
Is personal data shared with third parties?
We may share the personal data of our clients' representatives with our partners and suppliers in Brazil or with public authorities. We do not share personal data outside of Brazil. Below are more details about the sharing we do.
* Sharing with public authorities in Brazil
We share the personal data of our clients' representatives with public and administrative authorities, such as Health Surveillance, the Internal Revenue Service and CEREST, in order to comply with legal or regulatory obligations that we must fulfill as a result of the activities we carry out, or in compliance with court orders.
Personal data may also be shared with the Judiciary, Public Prosecutor's Office, Municipalities or Police Authorities, when related to any matter concerning such authorities, or in compliance with court orders.
* Sharing with partners and suppliers
This sharing will always be carried out to fulfill the purpose for which the personal data is processed, such as to meet legal demands and manage the complaints channel, among other activities related to the contract signed with our clients.
CBC encourages its partners to adopt personal data protection measures in line with best market practices and compatible with the LGPD, and to adopt appropriate privacy and data protection rules.
Representatives of potential clients
Job pplicants
Employees' dependents
Security measures adopted by CBC
CBC adopts security, technical and administrative measures based on the best market practices aimed at protecting personal data from unauthorized access and situations of undue or unauthorized destruction, loss, amendments, communication or dissemination.
Our information security team is dedicated to protecting your information through the continuous improvement of processes, with the following guidelines, among others: (i) protecting personal data from external threats; (ii) preserving the confidentiality of passwords;
(iii) preventing access to e-mails or websites with suspicious or dubious content; and (iv) prohibiting physical or electronic access to personal data by unauthorized persons.
Selling and sharing personal data
CBC has not engaged in any activity that constitutes data selling in recent years.
Children's privacy
We do not knowingly collect any information from children under the age of 18, except for the provision of benefits to our employees' dependents. If we know that a child under the age of
18 has improperly provided us with personal information, we will delete it in compliance with the relevant legislation. If you are a parent or guardian and believe that we have inadvertently collected information from your child in a manner not permitted by law, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.
International transfer
CBC may transfer the personal data of employees outside the national territory, specifically to Japan, when it is necessary to share the information with group companies, given that CBC is a subsidiary company of the Mitsubishi Heavy Industries group, headquartered in Japan.
If necessary, CBC, in addition to Japan, may also transfer personal data to other countries, considering the following premises:
- Purpose: the processing is carried out for legitimate, specific, explicit and informed purposes, without the possibility of processing in a manner incompatible with those purposes. CBC uses this premise in cases of travel to meetings, training, visits to suppliers, clients, among other related activities.
- Lifetime: data will be kept with CBC only for as long as it is necessary to achieve a specific purpose, to comply with legal or regulatory requirements, and during the legal limitation period of possible contractual or legal responsibilities.
- Data subjects' rights: according to art. 18 and 20 of Law 13.709/2018, data subjects have the right to request from the controller, in relation to the data of the data subject processed by it, as detailed in the topic below.
What rights do Data Subjects have and how can they exercise them?
Under Brazilian law, the data subject has the following rights:
- Confirmation of treatment
- Data access
- Correction of incomplete, inaccurate or outdated data
- Anonymization, blocking or deletion of personal data processed excessively or in breach of the law
- Data portability to another supplier
- Deletion of personal data processed with the data subject's consent
- Information about third parties with whom we share your personal data
- Implications of not providing consent in situations where it is requested
- Revocation of consent
It is important to clarify that there may be exceptions to the above requests. For example, when you ask us to delete personal data, we may be prevented from complying with your request due to a legal or contractual requirement. If this happens, you will be informed of the situation.
When this Privacy Policy was last updated
This Privacy Policy was last updated on October 16, 2024
To exercise your rights, or ask any questions regarding how CBC handles your personal data, you can contact us through the following channels:
* Via e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it.
* By conventional mail or in person at Rodovia Dom Gabriel Paulino Bueno Couto S/N
- KM 68, Medeiros - Jundiaí/SP, CEP 13212-240.
We know that malicious people can use this type of request to impersonate other people and obtain your data. In order to prevent fraud of this kind and guarantee the security of the holders of the personal data we process, we may ask for more information to confirm the identity of the requesters.
The data provided for this verification will be used exclusively for this purpose and, once the identity has been confirmed, the application will follow the regular procedures.
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CBC Indústrias Pesadas S.A.