Privacy Policy and Protection of Personal Data

1.1. Data subject: is any natural person to whom the personal data being processed refers.  

1.2. Personal Data: This is any information that allows the identification of a natural person or that can make them identifiable. For example, their name, CPF (Brazilian tax identification number), email, telephone number, among others.  

1.3. Sensitive Personal Data: This includes personal data relating to racial or ethnic origin, religious beliefs, political opinions, membership in a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data.  

1.4. Processing of Personal Data: This includes any operation performed on personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.  

2.1. The user's and visitor's personal data is collected by the platform as follows:

• When a user or visitor accesses pages on the FAXE.COM.BR website: Information about interaction and access is collected by the company to ensure a better user and visitor experience. This data may include keywords used in a search, the sharing of a specific document, comments, page views, profiles, the URL from which the user or visitor comes, the browser they use, and their access IPs, among other data that may be stored and retained;

• When a user or visitor fills out forms on the FAXE.COM.BR website: Contact information provided by the user is collected by the company to enable a company representative to contact the visitor. This data may also be stored and retained;

• Through third parties: The FAXE.COM.BR platform receives data from third parties, such as Facebook and Google, when a user interacts with an advertisement from the company. The use of this data is previously authorized by the users with the third party in question.

2.2. The personal data obtained by FAXE ASSESSORIA ADUANEIRA SS LTDA are:  

• Data for signaling interest in a company solution, whether as an end consumer or a new integrator, such as: Email, Name, City and State of Residence, Phone Number, and Type of Project of Interest;

• Cookie Data: For optimizing browsing experience, such as page access, keywords used in searches, recommendations, comments, interaction with other profiles and users, followed profiles, and IP address;

• Newsletter: The email address provided by visitors who choose to subscribe to the Newsletter will be collected and stored until the user requests to unsubscribe;

• Sensitive data: Average monthly electricity consumption.

The Controller (FAXE ASSESSORIA ADUANEIRA SS LTDA) will process Personal Data to achieve specific purposes and only in the presence of a legal basis (or requirement for processing) provided for in applicable legislation on privacy and protection of personal data.  

When necessary, consent will be requested clearly and specifically for each type of data processing, with an easy option to revoke it at any time.

When employees, clients, partners, and other interested parties register and/or fill out the form provided by FAXE ASSESSORIA ADUANEIRA SS LTDA, the data will be kept confidential and will only be used for the purpose that motivated the registration.  

The processing of Personal Data for purposes not foreseen in this Privacy Policy will only occur after prior notification to the user, so that the rights and obligations provided herein remain applicable.

The following list indicates the purposes of all data collected and processed by FAXE ASSESSORIA ADUANEIRA SS LTDA. See below:  

3.1. Legal Basis: Legitimate Interest

• User and visitor well-being: improving the product and/or service offered, facilitating, streamlining and fulfilling the commitments established between the user and the company, improving the user experience and providing specific functionalities depending on the user's basic characteristics;

• Platform improvements: understanding how users utilize the platform's services, to aid in business and technical development;

• Advertisements: Present personalized ads to the user based on the data provided;

• Commercial: the data is used to personalize the content offered and generate revenue for the platform to improve the quality of service operation;

• User profile prediction: automated processing of personal data to evaluate platform usage;

• Registration data: to allow the user access to certain platform content, exclusive to registered users;

3.2. Legal Basis: Contract Execution

• Contract details: to provide legal security to the parties and facilitate the conclusion of the transaction;

Other: The processing of personal data for purposes not foreseen in this Privacy Policy will only occur after prior notification to the user, so that the rights and obligations provided herein remain applicable.

Personal data may be shared with third parties, such as:  

• Google (GOOGLE BRASIL INTERNET LTDA. 06.990.590/0001-23)
• Facebook (FACEBOOK SERVIÇOS ONLINE DO BRASIL LTDA. 13.347.016/0001-17)
• RD Station (RESULTADOS DIGITAIS SA 13.021.784/0001-86)

Sharing may be done to comply with legal, regulatory, or tax requirements, as well as to fulfill the purposes mentioned above, and within the limits required and authorized by law.  

• With employees and collaborators of FAXE ASSESSORIA ADUANEIRA SS LTDA who are directly authorized for processing, or by group companies acting as independent Controllers or Processing Agents;
• With its clients and partners when necessary and/or appropriate for the provision of related services;
• With companies and individuals contracted to perform certain activities and services on behalf of FAXE ASSESSORIA ADUANEIRA SS LTDA;
• With suppliers and partners for the execution of services contracted with FAXE ASSESSORIA ADUANEIRA SS LTDA;
• For administrative purposes such as: research, planning, service development, security and risk management;
• When necessary due to legal obligation, determination by a competent authority, or court order.

In cases where your Data is shared with third parties, all parties mentioned above must use the shared Data in a consistent manner and in accordance with the purposes for which it was collected (or to which the User previously consented), as determined in this Privacy Policy, as well as observing other website or country privacy statements, and all applicable privacy and data protection laws.

If data is shared, the third party will only receive the data necessary to provide the contracted services. It is important to note that our contracts are drawn up in accordance with Brazilian data protection regulations. However, our partners have their own Privacy Policies, which may differ from this one.

When you are redirected to a third-party application or website, you will no longer be governed by this Privacy Policy or our platform's Terms of Service. We are not responsible for the privacy practices of other websites and encourage you to read their privacy statements.

No documents and/or personal information will be disclosed and/or shared, except if expressly authorized by its owner, by court order, or by legal determination.

No documents and/or personal information will be sold. Furthermore, the personal information of Users (referred to as Data Subjects) will not be individually disclosed to third parties, except as established in this instrument or as required by law and by court order.

Some of the third parties with whom we share your data may be located in or have facilities located in foreign countries; however, your personal data will be subject to the General Data Protection Law and other Brazilian data protection laws.

In this regard, to guarantee and comply with legislative requirements, FAXE ASSESSORIA ADUANEIRA SS LTDA undertakes to adopt efficient cybersecurity and data protection standards.  

The Personal Data of employees, clients, partners, and all other individuals who have any connection with FAXE ASSESSORIA ADUANEIRA SS LTDA are stored digitally and/or physically for the period necessary to provide the service or fulfill the purposes set forth in this document, in accordance with the provisions of item I of article 15 of the LGPD (Brazilian General Data Protection Law).  

The data will be deleted when it is no longer useful for the purposes for which it was collected, or when the user requests its deletion, except in cases where it is necessary to comply with a legal or regulatory obligation, in accordance with the General Data Protection Law.

Furthermore, the personal data of data subjects will only be retained after the end of its processing in the cases provided for in article 16 of the General Data Protection Law – LGPD (Law No. 13.709/18), namely:  

• For compliance with a legal or regulatory obligation by the controller;
• For study by a research body, ensuring, whenever possible, the anonymization of personal data;
• For transfer to a third party, provided that the data processing requirements set forth in this Law are respected;
• For the exclusive use of the controller, access by third parties being prohibited, and provided that the data is anonymized.

All data provided by employees, clients, partners, and other individuals affiliated with FAXE ASSESSORIA ADUANEIRA SS LTDA will be treated confidentially and solely for the purposes specified. To keep personal information secure, we use physical, electronic (our servers), and managerial tools, guided by our security policies and standards for protecting your privacy.  

These tools are applied taking into account the nature of the personal data collected, the context, the purpose of the processing, and the risks that any violations would generate for the rights and freedoms of the data subject whose data is collected and processed.

Among the measures we have adopted, we highlight the following:  

• Only authorized personnel have access to the personal data of employees, clients, partners, and all other individuals who have any connection with FAXE ASSESSORIA ADUANEIRA SS LTDA;
• Access to personal data is granted only after a confidentiality agreement;
• Personal data is stored in a secure and reliable environment.

FAXE ASSESSORIA ADUANEIRA SS LTDA is committed to adopting the best practices to avoid security incidents. However, it is necessary to emphasize that no information transmission is completely secure and risk-free, and is susceptible to technical failures, viruses, or similar actions. It is possible that, despite all our security protocols, problems caused exclusively by third parties may occur, such as cyberattacks by hackers, or also as a result of negligence or recklessness on the part of the user/client.  

In the event of a security incident that may generate significant risk or harm to the holders of personal data, FAXE ASSESSORIA ADUANEIRA SS LTDA undertakes to make every effort to remedy the consequences of the event. Furthermore, we will notify those affected and the National Data Protection Authority about the incident, in accordance with the provisions of the General Data Protection Law.  

Cookies are text files sent by the platform to the user's computer and stored there, containing information related to browsing the site. This information relates to access data such as location and time of access and is stored by the user's browser so that the platform's server can read it later in order to personalize the platform's services.

Users and visitors of the FAXE.COM.BR platform acknowledge and accept that a system for collecting browsing data may be used through the use of cookies.  

For all collection of personal data, FAXE ASSESSORIA ADUANEIRA SS LTDA will always follow these rules:  

• Only information essential for the services offered will be collected;
• If it is necessary to collect other personal data, we will take due care to obtain your authorization to do so;
• Any authorization collected will be accompanied by the appropriate level of information;
• The personal data collected will only be used to fulfill the purposes informed by the data subjects.

By accessing our website and consenting to the use of cookies, the data subject acknowledges and accepts the use of a system for collecting browsing data, i.e., agrees to the use of cookies on their device.

FAXE ASSESSORIA ADUANEIRA SS LTDA uses the following cookies:  

• Persistent cookies remain on the user's and visitor's hard drive after the browser is closed and will be used by the browser on subsequent visits to the site. Persistent cookies can be removed by following your browser's instructions.
• Session cookies, on the other hand, are temporary and disappear after the browser is closed. It is possible to reset your web browser to refuse all cookies, however some platform features may not function correctly if the ability to accept cookies is disabled.

The Data Subject may, at any time and at no cost, change permissions, block or refuse Cookies. However, revoking consent for certain Cookies may prevent some platform features from functioning correctly.

Furthermore, the Data Subject can find more information about the Cookies we use and how they work in our Cookie Policy.

Consent is the free, informed, and unequivocal expression by which the Data Subject authorizes FAXE ASSESSORIA ADUANEIRA SS LTDA to process personal data.  

Thus, in accordance with the General Data Protection Law (LGPD), personal data will only be collected, processed and stored with the prior and express consent of the Data Subject, except in cases where another legal basis applies, such as for compliance with a legal or regulatory obligation, execution of a contract, credit protection, regular exercise of rights in judicial, administrative or arbitration proceedings, or other provisions of the law.

Consent will be obtained specifically for each purpose, demonstrating FAXE ASSESSORIA ADUANEIRA SS LTDA's commitment to transparency and good faith towards its employees, clients, partners, etc., in accordance with relevant legislation.  

By using the services of FAXE ASSESSORIA ADUANEIRA SS LTDA and providing personal data, the Data Subject is aware of and consents to the provisions of this Privacy Policy, and is also aware of their rights and how to exercise them.  

The Data Subject may, at any time, review and change their registration information. Furthermore, at any time and without any cost, the Data Subject may revoke the consent given to FAXE ASSESSORIA ADUANEIRA SS LTDA, except in situations where the processing is based on another legal basis.  

FAXE ASSESSORIA ADUANEIRA SS LTDA guarantees the rights foreseen in article 18 of the General Data Protection Law. Therefore, the Personal Data Subject may, free of charge and at any time:  

• Confirm the existence of data processing, in a simplified manner or in a clear and complete format;
• Access your data, being able to request it in a legible copy in printed form or through secure and reliable electronic means;
• Correct your data by requesting its editing, correction or updating;
• Limit your data when unnecessary, excessive or processed in violation of the law through anonymization, blocking or deletion;
• Request the portability of your data, through a report of registration data that FAXE ASSESSORIA ADUANEIRA SS LTDA processes regarding you;
• Delete your data processed based on your consent, except in cases provided for by law;
• Revoke your consent, disauthorizing the processing of your data;
• Be informed about the possibility of not providing your consent and about the consequences of refusal.

To exercise the rights provided for in the LGPD (Brazilian General Data Protection Law), the Personal Data Subject must contact FAXE ASSESSORIA ADUANEIRA SS LTDA via the following email address: lgpd@faxe.com.br  

In order to ensure your correct identification as the holder of personal data, we may request documents or other proof that can verify your identity. In this case, you will be informed beforehand.

The client/user guarantees and is responsible for the veracity, accuracy, validity, and authenticity of the information they provide to purchase our products or services. FAXE ASSESSORIA ADUANEIRA SS LTDA is not responsible for the insertion of false or inaccurate data, should any inaccuracy be detected.  

The current version of the Privacy Policy was last drafted and updated on: August 30, 2024.  

We reserve the right to modify this Privacy Policy at any time, particularly to adapt to any changes made to our website or by law. If we make any material changes to this policy, we will notify you.

Any changes will take effect upon publication on our website.

FAXE ASSESSORIA ADUANEIRA SS LTDA foresees the responsibility of the agents who act in data processing, in accordance with articles 42 to 45 of the General Data Protection Law.  

FAXE ASSESSORIA ADUANEIRA SS LTDA is responsible for the security of data processing and the fulfillment of the purposes described in this document.  

FAXE ASSESSORIA ADUANEIRA SS LTDA is committed to keeping this Privacy Policy updated, observing its provisions and ensuring its compliance.  

Furthermore, we undertake to seek technical and organizational conditions that are securely capable of protecting the entire data processing process. This includes, should the National Data Protection Authority (ANPD) require us to take measures regarding the data processing carried out by FAXE ASSESSORIA ADUANEIRA SS LTDA, we commit to complying with those measures.  

For the resolution of disputes arising from this instrument, Brazilian law shall be fully applied. Any litigation must be brought in the court of the headquarters of FAXE ASSESSORIA ADUANEIRA SS LTDA.  

Yours sincerely,  

 FAXE CUSTOMS CONSULTING LTDA.