MATTAR, on its own behalf and that of its collaborators (“MATTAR”), aware of the importance and duty of privacy regarding personal information and documents submitted by its external and internal users (hereinafter “Data Subjects”) across its various databases, including its websites and physical documents under its custody, acting as the Controller of the processing of such personal data, hereby establishes this Privacy Policy.
APPLICABILITY
This Privacy Policy applies exclusively to clients and personal data subjects of MATTAR.
APPLICABLE LAW
This Privacy Policy is governed by current Brazilian law, in particular Law No. 13,709/18 (“General Data Protection Law” – LGPD) and Law No. 12,965/14 (“Brazilian Internet Civil Rights Framework”).
DEFINITIONS
For the purposes of this Privacy Policy, the following definitions apply:
- Data Subject: a natural person (clients, collaborators, partners, suppliers, and service providers) to whom the personal data being processed relates;
- Personal Data: information relating to an identified or identifiable natural person. This may include, for example, name, address, email, phone number, debit/credit card number, IP address, and geolocation data;
- Sensitive Personal Data: a special category of personal data relating to racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical, or political nature, data relating to health or sexual life, and genetic or biometric data;
- Anonymized Data: information that, alone or in combination with other anonymized data, does not allow the identification of a person, taking into account the reasonable and available technical means at the time of processing;
- Database: a structured set of personal data established in one or more locations, in electronic or physical form;
- Processing of Personal Data: any operation performed on personal data, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction;
- Controller: a natural or legal person, under public or private law, to whom decisions regarding the processing of personal data belong;
- Processor: a natural or legal person, under public or private law, who processes personal data on behalf of the Controller;
- Data Protection Officer (DPO): a person appointed by the Controller and Processor to act as a communication channel between the Controller, data subjects, and the National Data Protection Authority (ANPD);
- User: persons who access or interact with activities offered on websites owned by MATTAR.
PURPOSE OF THIS PRIVACY POLICY
The purpose of this Privacy Policy is to inform Data Subjects about the guidelines for the collection, processing, storage, and protection of physical and digital information and documents collected by MATTAR or on its behalf, or submitted directly by Data Subjects through its digital and physical platforms, clarifying how Personal Data will be processed and what rights Data Subjects hold and how they may be exercised.
PROCESSING OF PERSONAL DATA
Data collected by MATTAR, including personal data, may be processed in compliance with the principles set forth in the General Data Protection Law and in good faith, and will be incorporated into the corresponding physical and electronic records or Databases for which MATTAR acts as Controller.
MATTAR clarifies that any Personal Data collected will only be processed where there is a legitimate and regular purpose, based on the Data Subject’s consent or on a legal basis, including where necessary to serve MATTAR’s legitimate interests, provided such interests do not conflict with the fundamental rights and freedoms of the Data Subject requiring the protection of personal data.
Data that undergoes anonymization during processing will not be considered Personal Data for the purposes of this Privacy Policy.
PURPOSE OF PERSONAL DATA PROCESSING
Personal data is processed by MATTAR to fulfill legal or regulatory obligations, for legitimate, specific, and explicit purposes, in accordance with applicable law, and for the performance of contracts to which the Data Subject is a party.
TYPES OF PERSONAL DATA THAT MAY BE COLLECTED AND PROCESSED
- Registration and/or contact data;
- Professional and/or legal data;
- Identification data issued by official bodies;
- Financial / payment data;
- Data Subject preferences (e.g., data based on browsing activity on owned or related websites).
METHODS OF PERSONAL DATA COLLECTION
- Provided directly by the Data Subject or their legal representatives: personal data entered, physically provided, or submitted when accessing one of MATTAR’s channels (website or applications) or when consulting, applying for, and/or engaging services provided by MATTAR;
- Collected directly by MATTAR with the Data Subject’s consent: data collected during commercial processes, marketing campaigns, or through authorized third parties, whether or not related to the prospecting and sale of services by MATTAR;
- Provided by contracted third parties: Personal Data received from third parties acting in partnership with MATTAR, such as data enrichment service providers, provided that expressly authorized by the Data Subject;
- Collected from public sources: data from public databases made available by authorities (such as the Brazilian Federal Revenue Service) or data explicitly made public by the Data Subject, subject to the protection of the Data Subject’s fundamental rights and freedoms;
- Collected automatically: information collected automatically and associated with personally identifiable information, using technological tools such as Cookies, of which the Data Subject will be informed.
RIGHTS OF THE DATA SUBJECT
Data Subjects are guaranteed the fundamental rights of freedom, privacy, and intimacy, and ownership of their Personal Data held in physical and electronic records, files, registrations, and any other information archived under the direct responsibility of MATTAR or its duly contracted service providers.
Data Subjects are also entitled to the following rights with respect to their Personal Data, in accordance with applicable law:
- confirmation of the existence of processing of their Personal Data;
- access to their Personal Data;
- correction of incomplete, inaccurate, or outdated Personal Data;
- anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed Personal Data;
- portability of their Personal Data to another service or product provider, upon express request, in accordance with national authority regulations, subject to trade and industrial secrecy;
- deletion of Personal Data processed with their consent, except as provided by law;
- information about the public and private entities with which MATTAR has shared their Personal Data;
- information about the possibility of withholding consent and the consequences of doing so; and
- revocation of consent for the processing of their Personal Data, in accordance with applicable law.
CONTACT CHANNEL FOR THE DATA PROTECTION OFFICER (DPO)
To ensure that Data Subjects may exercise their rights regarding Personal Data, MATTAR, in compliance with legal requirements, provides the following direct contact channel:
Contact email:
Data Subjects may submit a request at any time through the channel above and will receive a prompt response in accordance with applicable legal deadlines.
PERSONAL DATA PROTECTION MEASURES
MATTAR adopts all legally required security measures to protect Data Subjects’ Personal Data, including internal reviews of data collection, storage, and processing practices, as well as encryption and physical security measures.
Any incidents involving Personal Data that may cause harm to Data Subjects will be reported to the ANPD (National Data Protection Authority), and MATTAR will act effectively to remedy any resulting damages.
SHARING OF PERSONAL DATA
Personal Data may be shared, as permitted by law and/or with the prior consent of the Data Subject, with other companies within the same group, always in compliance with the purposes set out in this Policy and in applicable law.
Additionally, MATTAR may share data with duly contracted and authorized partner companies and suppliers for this purpose (‘Processors’), subject to contractual safeguards to ensure the security of Personal Data and the rights of the Data Subject.
COOKIES
Definition: Cookies are data files stored on a visitor’s device (via smartphone, tablet, or computer) that record user preferences, location, pages visited, and other information, offering a more convenient browsing experience.
Classification by duration:
- Session cookies: temporary cookies that remain active until the web page or browser is closed;
- Persistent cookies: remain active even after the browser is closed and may be used to remember users’ login credentials or to provide a better experience across different sessions.
Classification by purpose:
- Strictly necessary: essential to allow users to use the websites and services offered;
- Performance: collect anonymous information about how users use and interact with the websites;
- Functionality: allow the website to remember choices made by users and provide more personalized experiences;
- Analytics and advertising: allow the delivery of more relevant advertisements and information, and help measure the effectiveness of campaigns.
Data Subjects may manage or disable cookies directly through their browser settings. For instructions on how to do so, please consult the documentation of the browser being used.
ADDITIONAL PROVISIONS
The Data Subject warrants that the Personal Data provided to MATTAR is accurate and legitimate, free from any defects of consent, and undertakes to promptly notify MATTAR of any changes to such data.
Unless otherwise indicated, responses to questions about Personal Data are optional, and the absence of a response does not result in a reduction in the quality or scope of the corresponding services.
AMENDMENTS TO THIS POLICY
This Privacy Policy may, at MATTAR’s discretion, be updated and/or amended at any time, without prejudice to the rights of Data Subjects guaranteed by applicable law. Any amendments will be highlighted in the Policy and, where appropriate, may be the subject of a specific communication.