Data Privacy Policy

of Confederação Nacional da Indústria - CNI

This is the Data Privacy Policy of Confederação Nacional da Indústria (hereinafter referred to as “CNI”), available via the electronic address https://www.portaldaindustria.com.br/cni/ and any other applications available for download in the App Store and Play Store through which information on CNI services can be accessed. In this Data Privacy Policy, we explain how we treat personal data provided by users on CNI websites and applications.

Each capitalized term is a defined term and has the meaning ascribed to it in this Policy.

This Policy regulates the processing of personal data or other information provided by users when browsing, accessing and/or using our Platforms, as applicable.

1. Definitions:

For the purposes of this Data Privacy Policy, the following definitions shall apply:

(I) “CNI”, “we”, “our”: Confederação Nacional da Indústria, a legal entity under private law, registered under corporate taxpayer’s ID (CNPJ) No.33.665.126/0001-34, with registered office at SBN Quadra 1 - Bloco C Ed. Roberto Simonsen - Asa Norte, DF, 70.040-903;

(II) “National Entities and Bodies of the Industry System”: the national network of a private nature responsible for initiatives in support of the Brazilian industrial sector, which includes the Brazilian National Confederation of Industry (Confederação Nacional da Indústria - CNI); the National Department of the Social Service of Industry (Departamento Nacional do Serviço Social da Indústria - SESI/DN); the National Department of the National Service for Industrial Training (Departamento Nacional do Serviço Nacional de Aprendizagem Industrial - SENAI/DN) - and the Central Hub of Euvaldo Lodi Institute (Núcleo Central do Instituto Euvaldo Lodi - IEL/NC);

(III) “Platforms”: include CNI websites, applications and social media profiles(such as Facebook, Instagram, LinkedIn, Twitter, TikTok, YouTube);

(IV) “You”, “your”: shall mean anyone who uses the Platforms;

(V) Personal Data”: any information relating to an identified or identifiable natural person;

(VI) Sensitive Personal Data: any personal data concerning racial or ethnic origin, religious beliefs, political opinions, affiliation to a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, whenever linked to a natural person.

(VII) “Processing”: any operation carried out with Personal Data, such as those that refer to the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, information evaluation or control, modification, communication, transfer, diffusion or extraction;

(VIII) “Data Subject”: the natural person to whom the Personal Data under Processing refer;

(IX) “IP”: the abbreviation for Internet Protocol. It is a series of numbers (and in some cases letters) that identify the user's computer on the World Wide Web; “Logs”: records of your activities on CNI websites and applications;

(X) “Logs”: records of your activities carried out on CNI websites and applications;

(XI) “Cookies”: small text files sent to your computer by the website server and valid for a certain period of time. Cookies identify the user's computer and obtain Data on the pages visited (browser session) or the links clicked, which allow us to: store browsing history and user preferences, collect statistical data, customize the use of the platforms and direct personalized marketing according to the user profile. In addition, some of our cookies are part of the technical solution and are essential to the operation of our platforms and applications, and therefore the decision to use or not to use them is not optional. Cookies are safe, anonymous, private and are used only for your benefit to provide you with personalized content;

(XII) “Session ID”: the identification of your session in the registration process or when using the Platforms in any way; and

(XIII) “LGPD”: Brazilian Federal Law no. 13,709/18, the General Data Protection Law.

2. Commitment to the security of your Data

2.1 CNI is committed to ensuring the security of your Data throughout the process of browsing the Platforms, using the Services and submitting requests through the communication channels available on the Platforms. For this reason, your Data will be treated with the utmost confidentiality and will not be sold, exchanged or transferred to third parties, unless permitted by applicable law.

3. Data we collect

3.1. By accepting the terms of this Data Privacy Policy, you expressly agree to provide only true, current and accurate Data and not to misrepresent your identity in any way when accessing and using the Platforms and/or Services. You are solely responsible for any false and inaccurate information you provide through the Platforms, as well as for any direct or indirect damage caused to CNI and the national bodies and entities of the Industry System or to third parties.

3.2. Data is collected when it is voluntarily entered or transmitted by you: when you register on our Platforms to use the Services, when you sign up to receive our newsletters, when you register for our events, and when you use the Services through alternative channels also available on the Platforms (and other interactions), such as: Facebook, Twitter, YouTube, TikTok, LinkedIn, Instagram, Customer Service and Ombudsman channels, email, or telephone available on the Platforms.

3.3. We also collect Data when you access our website and browse the items available there through cookies.

3.4. When you use our Platforms, CNI only receives or collects the following types of information about you:

(i) Prior to Registration: (a) Browsing data; and

(ii) During and after registration: (a) Browsing data; (b) Registration data; (c) Billing data.

3.4.1. Browsing data: The CNI website may use Cookies. You can configure your Internet browser so that you can block them. If you block Cookies, some features of the website may be impaired. We may collect the following data during your access to the Platforms, even if you are not registered and/or logged in:

(i) Your IP address;

(ii) Actions you take on the website;

(iii) Pages you have accessed;

(iv) Date and time of each action and each access to each website functionality;

(v) Data about your location; and

(vi) Your Session ID, where applicable.

3.4.2. Registration data: We may collect data to enable you to start and complete your registration, use our Platforms and access our services. The Data collected for registration purposes may include, but is not limited to, name, username, password, date of birth, CPF, email address, and/or phone number.

3.4.3. Billing data: We may collect additional Data to enable you to purchase courses, events, consulting and other services on our Platforms. When paying by credit card, the credit card and cardholder details are collected to process the payment.

3.4.4. Event participation data: we may collect Data when you participate in an event sponsored by CNI, SESI/DN, SENAI/DN or IEL/NC. The Data collected at events includes, but is not limited to, name, e-mail, position, image and voice.

4. Purposes of Using the Data and Information:

4.1. The Data and information collected from users may be used for the following purposes:

4.1.1. Browsing data:

(i) To improve the use and experience of our Services;

(ii) To carry out statistics, studies, research and surveys relating to the activities and behavior of users when using the services, also with the aim of developing campaigns of CNI and the national entities and bodies of the Industry System;

(iii) To protect our rights and obligations in connection with the use of the Services, including in the case of judicial and administrative proceedings;

(iv) To comply and/or cooperate with a court order or request from an administrative authority;

(v) To recommend Services or features of the Platforms, including third party services, that may be of interest to you; and

(vi) To redirect you to our profile on other websites.

4.1.2. Registration data:

(i) To complete your registration on our Platforms;

(ii) To respond to your requests or queries;

(iii) To allow you access to the restricted area of the website by identifying yourself beforehand and using a personal, non-transferable password;

(iv) To ensure your security;

(v) To keep your registration up to date and, if necessary, to allow telephone contact to confirm the registration data and avoid any damage or loss to our customers; and

(vi) To recommend courses and campaigns to you, as well as to send you magazines, newsletters or other services that may be of interest to you.

4.1.3. Billing data:

(i) CNI uses billing Data only during the billing process and takes all necessary measures to ensure that this Data is protected against any interception, misuse or manipulation.

4.2. Data of minors

4.2.1. We do not intentionally process data of minors, as our services are not intended for people under eighteen years of age. In the event that we need to process the data of minors, we ensure that the processing of Personal Data has legitimate purposes and is in accordance with the LGPD.

5. Activity Log

5.1. We may record your activities on the Services by creating, where possible and applicable, logs that include: the IP address of the device used, the access and actions you perform on the Service provided, the date and time of each action performed, and information about the device used, such as the version of the operating system, browser and geolocation.

5.2. We may use certain technologies to monitor the activities performed on the Platforms, such as:

(i) Cookies: Cookies may be used for various purposes, including to remember you and your preferences and to track your visits and activities related to the Platforms. The Platforms may also use locally stored objects to deliver certain content.

(ii) Web beacon: Web beacon is a technology that allows us to map who visits a particular web page and identify their behavior across different websites or web servers.

(iii) Analytics tools: These tools may collect information about how you visit the Platforms, including which pages you visit and when you visit those pages, as well as other websites you have previously visited, to name a few.

(iv) Redirecting tools: Our Platforms use redirecting technologies. This allows us to interact with you through our social networks. Redirecting technologies analyze the information we collect about your interactions with the Platforms.

All technologies we use will always comply with the terms of this Policy.

6. Sharing and disclosure of Data

6.1. The database is our property and our responsibility and it will be used, accessed and disclosed as necessary within the limits and purposes of our business and in accordance with applicable laws.

6.2. We may share your Data in the following situations:

(i) With other national entities and bodies of the Industry System (including SESI/DN, SENAI/DN and IEL/NC and other partner bodies) to provide you with the best possible experience when using our Services;

(ii) With judicial, police or governmental authorities or other third parties to whom we are obligated by law, governmental regulation or court order;

(iii) If you choose to conduct payment-related transactions, we will share your data with the relevant payment provider to facilitate that transaction;

(iv) We share information with service providers that support our business, such as cloud service providers; and

(v) With state federations of industry, regional departments of SESI and SENAI, regional centers of IEL, and partners involved in the implementation of the individual initiatives.

7. Storage, retention and deletion of Data:

7.1. The Data is stored in a secure and controlled environment and can only be accessed by qualified persons previously authorized by CNI, the national institutions and bodies of the Industry System and partner entities, for a minimum period of six (6) months, in accordance with the Brazilian Civil Framework of the Internet, observing the technical level available.

7.2. The Data may be stored on our own servers or on servers of third parties contracted for this purpose, whether located in Brazil or abroad, in accordance with applicable legislation, and may also be stored using cloud computing technologies and/or other technologies that may be developed in the future, always with the aim of improving and expanding our services. In cases where personal data is transferred internationally, we apply the appropriate transfer mechanisms where applicable.

7.3. The data will be stored for as long as necessary to provide the Services. If we no longer need your data to provide the Services, we will only store it for as long as we have a valid legal basis. In some cases, we may retain your data for longer, in particular if this is necessary for the establishment, exercise or defense of legal rights.

8. 8. Your rights, options and controls

8.1. You have rights and safeguards in relation to your Data under the LGPD, which may not apply or may be limited in certain circumstances. The following conditions apply:

(i) Confirm and access your Data: You can request details and/or a copy of your Data retained by us.

(ii) Change or correct your Data: If you wish to modify your Data or if you have reason to believe or suspect that any Data we have about you is incorrect or incomplete;

(iii) Where appropriate, you can withdraw your consent, delete, block, anonymize and request the portability of your Data: You can, depending on the circumstances, (i) withdraw your consent when the processing of Data is based on consent in accordance with the provisions of the LGPD, or (ii) request the deletion of your Data in the cases provided for in the LGPD or deactivate your account at any time in accordance with the law. The withdrawal of consent will result in you no longer being able to use the Platforms and Services and the interruption of the use of your Data, with the exception of (i) anonymized Data; and (ii) Data required by CNI, the national institutions and bodies of the Industry System and/or third parties involved in the provision of the Services for the purposes of judicial, arbitration or administrative defense, as well as to comply with legal and regulatory obligations; and

(iv) We keep your history: You may contact us and we are authorized to contact you so that you may access certain features of our Services, ask questions about the Platforms and make complaints or suggestions, by email, telephone, chat on the Platforms or on social networks. The conversations will be stored by us and we may use their content as evidence in court, for the provision of our Services or in other cases provided for by law.

8.2. In order to verify your request and, where appropriate, enforce your rights, we may request proof of your identity as a security and fraud prevention measure. In this case, all data and documents received will be used only for this purpose.

8.3. In certain situations, we may have legitimate reasons not to comply with some of your requests. For example, we may choose not to disclose certain information to you when disclosure could harm our business, such as when there is a risk of violating our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for deletion when it is not applicable due to the lack of the requirements provided for in the LGPD, when retaining your personal data is necessary to comply with legal or regulatory obligations, or when such retention is necessary to protect our rights and interests in the event of a legal dispute. If this is the case and we are unable to comply with a request you have made, we will inform you of the reasons why we cannot comply with your request.

8.4. To exercise your rights or ask any questions, please contact encarregadolgpd@cni.com.br.

9. Security on the Internet

9.1. For your security, we recommend that you do not disclose your access data (e.g. e-mails for website access, passwords (personal and non-transferable), CPF and other personal documents) to third parties. Any problems arising from the disclosure of access data will be properly investigated and held accountable.

9.2. We use state-of-the-art tools to prevent alteration, fraud, disclosure or destruction of the information we store, such as SSL (Secure Socket Layers) encryption and firewalls. However, we cannot guarantee complete data security. Unauthorized access or use, hardware or software errors, and other factors may jeopardize the security of the Data.

9.3. Please note that Data transmission over the Internet is not completely secure due to a variety of factors, including network and operational factors, and CNI cannot guarantee the complete security of transmitted data. Although we will do our best to protect your Data, we cannot guarantee the security of data transmitted to our Platform. You are solely responsible for any transmission and, by agreeing to this Policy, you expressly acknowledge and accept this responsibility.

9.4. As soon as Data is received by the Platforms, we undertake to ensure the security of this Data. In order to prevent unauthorized access to or disclosure of your Data, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Data we process.

10. Changes to this Policy

10.1. CNI may change the terms of this Policy at its sole discretion and at any time. In the event of material changes to the Policy, such changes shall be valid, effective and binding upon: (1) being posted on the Platforms; (2) being emailed to you; and/or (3) otherwise being communicated to you.

10.2. Whenever the Policy is changed, these changes will be posted on the Platforms and may be sent by email. You should check the most current version of this Policy each time you visit the Platforms.

11. General Provisions:

11.1. If you no longer wish to receive emails from CNI, simply click on the link at the bottom of each email sent indicating the option to unsubscribe.

11.2. By providing Data via the Platforms, you confirm that you are aware of the usage, protection and security rules set out in this Data Privacy Policy.

11.3. The Platforms may contain links to partner websites. The mere availability of such links by CNI does not imply consent or knowledge of the respective content, which is the sole responsibility of the partner.

12. Contact Us

12.1. According to the LGPD, CNI is considered the “Controller” of your Data. If, after reading this Policy, you have any further questions or need to communicate with us regarding your Data, please contact us by email: encarregadolgpd@cni.com.br

 

Last update: November 2023.

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