Tabacos Marasca Ltda. is constantly committed to a policy of social responsibility towards its customers, employees, suppliers, partners and communities in which the company operates, which means that it diligently complies the General Data Protection – Law Nº 13.709/2018.

Considering the company’s performance in the global market, the export activity requires strict compliance with the quality standards of the products and services provided, including an essential boost to the laws that strengthen these business relationships.

The purpose of this Privacy and Cookies Policy is to establish rules processing of personal data that may eventually be collected when accessing the website of Tabacos Marasca Ltda., depending on how the user uses it.

What do I need to know to understand this Privacy and Cookie Policy?

In order to facilitate your understanding, based on the LGPD, we present some useful definitions:

LGPD: Refers to the General Personal Data Protection  – Law Nº 13,709/18;

Legal Bases: These are legal hypotheses, provided for in Articles 7 of the LGPD, which authorize us to processing personal data, of adults and of children and adolescents: it could be your consent (or that of their legal guardians), the need to fulfill a contract we have with you, or complying with a legal obligation (such as issuing a invoice), just as an example;

Consent: According to art. 7º, item I, art. 11, I and art. 14, first paragraph, of the GDPL, consent is the hypothesis that authorizes, based on the free, informed and unequivocally of the Data Subject, the processing of personal data for a specific purpose, informed by us;

Cookies: These are small files that, once transferred to your browser or mobile device (cell phone or tablet), can identify them, in addition to making it possible to know how was your navigation on our page, how long and how many people access it. Can serve to, for example, make the website page fit your screen and generate analytics statistics (aggregated and anonymous);

Personal Data: Corresponds to information from a natural person, which allows identify it or make its identification possible, pursuant to art. 5º, item I, of the GDPL. Examples of personal data are: name, telephone, e-mail, etc.;

Sensitive Data: According to art. 5º, item II, of the GDPL, is information about racial origin or ethnicity, religious belief, political opinion, trade union membership or the organization of a religious, philosophical or political nature, or concerning health or sexual life, or genetic or biometric, when linked to a natural person;

Person in charge of Personal Data: Is the person who acts as a communication channel between Data Holders and the National Data Protection Authority (ANPD) when the subject is the protection of your personal data, in compliance with art. 5º, item VIII, of GDPL;

Tabacos Marasca Ltda: For the purposes of this Policy, the terms “Company” and “We” are refer to Tabacos Marasca Ltda, a limited liability company headquartered at RSC 287, Km 79, Nº 5001, Linha Estrela in Venâncio Aires/RS, CEP: 95800-000, registered with CNPJ under nº 01.497.282/0001-47.

Policy: This is the Privacy and Cookie Policy;

Data Holder: A natural person, is the holder of your personal data, according to article 5º, item V, of the GDPL. Whether as a customer, employee, third party, business partner or user;

Processing of personal data: It is what we do with the data, based on art. 5th, item X of the GDPL, for example: collection, storage, access, use, processing, sharing, transmitting, evaluating, controlling information and elimination;

Controller: Is the person who makes the essential decisions regarding the processing of data personal. See art. 5th, inc. VI of the GDPL; Joint

Controllership: When two or more controllers determine jointly the purposes and means of such treatment, both are responsible sets;

Operator: Is the person who processes personal data on behalf of the controller. To see art. 5th, inc. VII of the GDPL;

User: All people who access and interact on the site;

Lawyer, Representative or User’s Legal Representative: Person who provides representation or assistance to the user who does not have civil capacity.

1. WHO IS TABACOS MARASCA LTDA.

Tabacos Marasca Ltda, is a company that operates in the production, processing and commercialization of Virginia and Burley tobacco varieties, based on the cultivation integrated, that is, the company provides seeds, agrochemicals, fertilizers and specialized assistance to farmers, so they can produce tobacco according to the required quality standards.

2. COLLECTION OF PERSONAL DATA AND PURPOSE

The collection of personal data depends on how and why the user interacts with Tabacos Marasca Ltda’s website and service channel In the event that the user is not 18 years old, it will be necessary to express consent of the legal guardian before starting to use the services made available.

Without the express consent of the legal guardian, the user must not continue browsing and using the services. Possible identification of inconsistency or fraud in the statement of authorization by the legal guardian may lead to cancellation and elimination of the contact made.

Personal data will be processed for an adequate period, considering factors of need and purpose of processing, and only for legitimate activities related to provision of services, the contractual relationship and the fulfillment of the request of the user of the site. The data processing will be adequate to the General Data Protection Law, and may, including, be used to meet the purposes authorized by the rest of the base.

2.1. INTERACTION THROUGH THE WEBSITE

The processing of personal data will take place with the purpose of meeting the contact requests made by the user in the fields designated for “Contact” and “Contact us”. In the “Contact” field, this collection of personal data will occur from the filling in the full name, e-mail and any message written by the user, be forwarded to the applicant’s sector of interest.

By clicking on the “Contact Us” field, the e-mail manager for the holder of the account will be opened. data and, consequently, the e-mail and any message written for the company.

The processing of data collected in this activity consists of collecting, receiving, access, use, processing, evaluation or control of information, storage, communication and disposal. Completing the form for “Contact” has the purpose of processing the fulfillment of website user requests. Considering the active and voluntary conduct in make contact in a free, unequivocal and informed manner, having as legal basis for data processing consent (art. 7, I, LGPD). Which is based on the user expresses his consent for the request to be answered through the acceptance check and acknowledgment of this Privacy and Cookies Policy.

2.2. INTERACTION THROUGH THE COMMUNICATION CHANNEL

The communication channel, intended for the interaction of the general public with the Tabacos Marasca Ltda, uses the WhatsApp instant messaging tool.

The processing of data collected in this activity consists of collecting, receiving, access, use, processing, evaluation or control of information, storage, communication and disposal.

The information and data collected will always be in accordance with legal requirements of protection. With regard to this treatment, we identified as the main foundations legal the contractual relationship between the parties (art. 7, V, GDPL), the legitimate interest (art. 7, IX, GDPL) upon receipt of resumes or consent from the holder (art.7, I, GDPL) when the interaction begins on the initiative of the holder without prior relationship with the company.

In the event of initiative by the holder without a prior relationship with the company, it is the holder is guaranteed access, reading and acceptance of this Policy, a document that expresses all rights of the data subject and other rules for the processing of personal data.

In order to ensure transparency, the company will make this document available to knowledge of every person when accessing the channel.

3. SHARING OF PERSONAL DATA BY TABACOS MARASCA LTDA.

Tabacos Marasca Ltda. values the protection of the personal data of its customers, collaborators, suppliers, partners and users of the site, in view of the transparency of company activities and with the intention of keeping the Data Subject informed, the data collected on this page may be shared with third parties, when necessary, in the following cases:

• PROVISION OF SERVICES

Website user personal data may be shared with partners and suppliers of Tabacos Marasca Ltda. with the aim of enable, in the best way, the provision of services such as, for example, data hosting and storage of the company’s database, hosting on the site and e-mails, companies that offer means of billing and payment of services rendered by Tabacos Marasca Ltda.

• ACCESS AND INTERACTION ON THE TABACOS MARASCA LTDA.

Website user personal data may be shared with Google Analytics partners and service providers through cookies, which are small files created to customize and facilitate the user access to the website and improve the performance and experience of the user. As pointed out by good practices, Tabacos Marasca Ltda. Inform that uses only the cookies necessary for the regular development of the page, with a duration of 01 (one) year. For adults clarification, please refer to the respective Google Privacy Policy Analytics: https://policies.google.com/privacy.

• PROTECTION OF LAW

The user’s personal data may be shared in the event of need to safeguard the rights of Tabacos Marasca Ltda. compliance with a legal obligation or compliance with a court order, or competent authority.

In response to requests from government authorities, law enforcement, When in connection with investigations of illegal or fraudulent activities, even when there is only suspicion, personal data may be shared.

In all cases, your personal data will only be shared with the purpose of serving the purposes, and within the limits expressed herein. Whenever possible, we apply the technical protection measures possible and require third parties to maintaining the confidentiality and security of shared data.

4. COOKIES USED ON THIS SITE?

Cookies are small files that contain information that allow identify who is visiting the page, control the access traffic of the site and monitor the behavior of the public, demonstrating which information was most relevant to customers and page visitors.

However, our website only uses the pll language cookie whose function is to remember the last language visited and which is maintained for one year.

5. RIGHTS OF THE DATA SUBJECT

Tabacos Marasca Ltda. provides services aimed at social responsibility and personal data protection. It is essential to inform users of the site about their respective rights as a Data Subject, which are provided for in articles 9, 18 to 20 of the General Data Protection Law, which focus on the following:

• Confirmation of the existence of treatment involving your personal data and easy access to information on the processing of personal data, made available in a clear, adequate and conspicuous way;

• The correction of your personal data that is incomplete, inaccurate or outdated data, as well as the possibility of anonymizing, blocking or deletion of personal data that is unnecessary, excessive or treated in non-compliance with the GDPL;

• The portability of your personal data to another service provider or product;

• The deletion of personal data processed with your consent, the information about the possibility of not giving consent and about the consequences of the refusal, and option to revoke your consent;

• The review of automated decisions and treatments;

• Information about the entities with which Tabacos Marasca Ltda. share your personal data. Compliance with the Data Subject’s rights will be exercised in accordance with the principle of proportionality, considering the nature of the process and the legal basis used, reason for which it will be subject to analysis regarding the feasibility and suitability of the request. The are cases in which it will not be possible, nor allowed by the law itself, to meet all the rights, situation that will be duly substantiated.

6. THIRD PARTY WEBSITES

This document deals only with respect to the Tabacos domain website Marasca Ltd. and does not have its applicability extended to the constant links on the page that link to third-party websites.

The user must be aware that third-party sites are governed by their respective Privacy Policies and Terms of Use, it being up to the user to accept or reject the documents that apply to the access and use of third-party pages. Although the Tabacos Marasca Ltda. have links that point to websites from third parties, it is important that the user is aware that it does not have no control over these sites, and they have no responsibility for the processing of personal data outside the scope of the company’s domain.

7. PERIOD OF STORAGE OF PERSONAL DATA

The personal data collected on the Tabacos Marasca Ltda. will be stored for an indefinite period, considering the factors of necessity, nature and according to request for the exercise of the Data Subject’s rights, in accordance with the General Law of Personal Data Protection – GDPL.

8. WHAT ARE THE RESPONSIBILITIES OF TABACOS MARASCA LTDA?

Our responsibility is to take care of personal data in accordance with the strict necessary to meet the legal bases and purposes described in this Policy. For this reason, we adopt appropriate security practices for our market, including the use of encryption techniques and other information security systems.

We have internal policies and procedures in line with the principles of good faith, prevention and safety, aiming to control and mitigate treatment risks.

We also promote training and educational actions with our collaborators. In addition, we choose business partners who are aligned with the our care and enter into contractual obligations with a view to security and privacy.

9. CONTACT INFORMATION INVOLVING PERSONAL DATA

If there are doubts about the processing of personal data on our website, comments or suggestions, you may contact Tabacos Marasca Ltda. By Data
Officer, available below:

● Data Manager: Angela Marleti da Costa

● Address: RSC 287, Km 79, n° 5001, Linha Estrela, Venâncio Aires, RS, Brazil, CEP: 95800-000

● Telephone: 55 (51) 3793-1200

● E-mail: lgpd@tabacosmarasca.com.br

10. CHANGES TO THE PRIVACY AND COOKIE POLICY

Aiming to give constantly more attention to privacy and effectiveness in the protection of personal data, this Privacy and Cookie Policy may undergo updates to reflect the improvements made. Therefore, we recommend that the Data Subject access the site periodically so that you are aware of any changes performed.

The dated version of each Policy and future updates will always be in last page of each document.