Privacy statement
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1. INFORMATION ABOUT OUR ORGANISATION AND WEBSITE
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MARUBENI Brasil S.A. (“Marubeni”, “we”, “us” and “our”) is committed to protect the privacy of its customers, employees and partners, as well as to ensure that all Personal Data processed by Marubeni is processed in accordance with the legal standards of protection and security required by the Data Protection Laws.
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This Privacy Statement (this “Statement”) explains who we are, how we collect, share and use Personal Data about you, and how you can exercise your privacy rights. Our website is operated by Marubeni Brasil S.A., which is registered in Brazil under company register number 60.884.756/0001-72 and registered office address at Avenida Paulista, 854, 12th floor, Bela Vista, São Paulo-SP.
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Any terms in Capital Letters in this Statement shall have the meaning ascribed to them in the General Data Protection Law (Federal Law No. 13.709 / 2018, “LGPD”).
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Questions relating to this Statement or additional information request should be sent to our Data Protection Officer (“Encarregado de Proteção de Dados” or “DPO”). The DPO is the person appointed by Marubeni who acts as a communication channel between Marubeni, the Data Subjects and the Data Protection National Authority (“ANPD”), and is the professional in charge of informing and counselling Marubeni.
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Marubeni’s DPO is Mr. Daisuke Sasaki and can be reached by e-mail at dpo-br@marubeni.com.
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2. HOW WE PROCESS YOUR PERSONAL DATA
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We have set out below the categories of individuals about whom we collect and process Personal Data and a description of the types of Personal Data that we may collect from them:
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Website Users
We may ask you to supply Personal Data at certain points on our website, such as your name, email address and other information. The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data. For example, we may ask you to provide your contact details when you enquire about particular products and/or submit enquiries to us. We will then use the information we have collected to respond to your enquiries or requests.
We also collect any information you may choose to provide in your communications with us. Such information may be used to facilitate activities in the course of our business. We may combine such information with other Personal Data we collect.
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Information collected automatically about our website users and Cookies
In addition to the information you knowingly provide, we may collect certain information automatically from your device. In some countries, including Brazil, this information may be considered Personal Data under applicable Data Protection Laws. Specifically, the information we may collect automatically may include domain names, your IP address, device type, unique device identification numbers, broad geographic location (e.g. country or city-level location), along with usage statistics (e.g. types of web browsers and operating systems used) and browsing history (e.g. how your device has interacted with our website, including the pages accessed and links clicked).
Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for internal analytics purposes and to improve the quality and relevance of our website to our visitors.
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Cookies
We may collect your Personal Data (including Personal Data mentioned above) using cookies and similar tracking technology. We use authentication cookies to identify you when you visit our website; status cookies to help us determine whether you are logged in to our site; personalization cookies to store information about your preferences; security cookies as one of the security measures used to protect data owner accounts, including preventing the fraudulent use of login credentials and to protect our website and services in general; advertising cookies to help us show you ads that will be relevant to you; analytics cookies to help us analyze the use and performance of our website and services; consent cookies to store your preferences regarding the use of cookies in general.
Servers hosted by third party service providers (which may be located outside Brazil) may automatically log data about your visit to our website based on your IP address. Marubeni uses this information to see where the website is being used in the world and to ensure seamless coverage.
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Job Applicants
If you apply to Marubeni for a job, you may give us Personal Data about you (including your CV). Your information may be used by Marubeni for recruitment purposes. You may also provide details of referees. Please note that you are responsible for obtaining the referees’ consent, for referring them to this privacy statement and ensuring they are aware that their details will be forwarded to, and used by, Marubeni for reference purposes.
No Sensitive Personal Data such as race, ethnicity or religious preferences are collected or stored in any way by us.
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Customers and prospective customers
If you work for one of our customers (or a prospective customer or are otherwise interested in our products and services and have provided us with Personal Data such as your name), you will provide us with some Personal Data about you such as your name and business contact details. We may process this data to contact you and inform you about our products and services and other marketing activities (“Contact Data”); to communicate with you during the execution of our services, including to ensure the feasibility and facilitate the conclusion and execution of the business ("Service Data"); in transactions, including purchases of goods and services, that you make with us (“Transaction Data”).
You may tell us at any time that you do not wish to receive such communications from Marubeni by contacting us via our DPO.
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Suppliers, Vendors, Business Advisors
If you work for one of our suppliers, vendors or business advisors, you will provide us with some Personal Data about you such as your name and business contact details. We may process this data to contact you and inform you about our products and services and other marketing activities (“Contact Data”); to communicate with you during the execution of our services, including to ensure the feasibility and facilitate the conclusion and execution of the business ("Service Data"); in transactions, including purchases of goods and services, that you make with us (“Transaction Data”); and conducting internal audits and other internal control activities related to contracts, business management, due diligence, reporting activities to meet our financial and accounting requirements, risk management and corporate assessments ("Audit Data").
Marubeni may receive Personal Data from third party sources in the context of screening in accordance with Marubeni’s and statutory bribery rules, to validate notice provisions and signatories in contracts and to prepare various briefing documents.
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Other Information
In general, we will use the Personal Data we collect from you only for the purposes described in this Statement or for purposes that we explain to you at the time of collecting your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable Data Protection Laws.
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3. WHAT ARE YOUR RIGHTS?
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You have the following rights in regard to your Personal Data processed by Marubeni, upon request:
- You have the right to know about Marubeni’s processing of your Personal Data and to verify whether that processing is lawful.
- You have the right to request access to your Personal Data under Marubeni’s control.
- You may request that Marubeni rectify your Personal Data if it is incomplete, inaccurate, or out-of-date.
- You may request that Marubeni anonymize, block access, or delete any unnecessary or excessive Personal Data, as well as any Personal Data processed in noncompliance with the provisions of the Data Protection Laws of Brazil.
- You have the right to request the portability of your Personal Data to another service or product provider, subject to commercial and industrial secrecy, and pursuant to the regulation of the ANPD.
- You have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- You have the right to request the deletion of your Personal Data, within the scope and technical limits of the activities, when you withdraw your consent and there are no other legal grounds for processing it.
- You may oppose the processing carried out based on one of the situations of waiver of consent, if you believe there is noncompliance with the provisions of LGPD.
- You have the right to request review of decisions taken solely on the bases of automated processing of Personal Data that affects your interests, including decisions intended to define your personal profile or aspects of your personality.
- You have the right to come directly to Marubeni for resolution of a complaint. We encourage and welcome you to come to Marubeni first to seek resolution of any complaint. You also have the right to petition against processing of your data by a Marubeni entity before the relevant supervisory authority. The Data Subject may also petition, regarding your data, before consumer-defense entities in Brazil.
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You may exercise any of the above rights free of charge through an express request to Marubeni via our DPO. Requests should be made in writing and preferably, electronically. Requests can also be sent by post clearly marked for the attention of the DPO to
- Marubeni Brasil S.A.
- Avenida Paulista, 854, 12º andar - Bela Vista - São Paulo - SP - Brasil - CEP 01310-913
- Email: dpo-br@marubeni.com
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In some instances, you may be able to partially manage your requests themselves, for example, setting your cookie preferences.
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4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
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Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. We will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your interests which is essential for your life or those of another person.
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If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as notifying you of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
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If you have questions or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us via our DPO.
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5. HOW DOES MARUBENI KEEP MY PERSONAL DATA SAFE?
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Transmission of information via the internet is not always secure. We cannot guarantee the security of your data while being transmitted to our site; any transmission is at your own risk. However, after we have received your information, Marubeni uses security, technical and administrative measures able to protect Personal Data from unauthorized accesses and accidental or unlawful situations of destruction, loss, alteration, communication or disclosure. The measures we take are designed to provide a level of security appropriate to the risk of processing your Personal Data.
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Marubeni regularly provides training to all individuals on their data protection responsibilities. Individuals whose tasks require regular access to Personal Data and/or are responsible for implementing our data protection policies and/or respond to Data Subject requests receive additional training to help them understand their obligations and how to comply with them.
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However, Marubeni shall not be held liable for any damages arising due to solely the fault of third parties, such as in the event of an attack by hackers or crackers, or when the Data Subject is solely responsible, such as in the case where the Data Subject transfers their data to third parties or exposes their Personal Data to third parties.
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6. TRANSFERS OF PERSONAL DATA
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Marubeni does not sell or transfer your personal data to third parties for marketing purposes.
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In order to conduct our business, including marketing activities, we may need to share your personal data with other companies within the Marubeni Group, and/or third-party service providers that process data on our behalf. When we do this, we will take steps to ensure that your Personal Data is protected, such as imposing contractual restrictions on the ability of the recipient to process your Personal Data and contractually requiring them to apply security measures to protect it.
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Since the Marubeni Group operates globally, Marubeni may want to transfer your Personal Data to other countries. However, while it is in our control, Marubeni always seeks to ensure that your Personal Data receives the same level of protection as it would had it stayed within Brazil, including seeking to ensure that it is kept secure and used only in accordance with our instructions and for the agreed purpose(s). Marubeni has Binding Corporate Rules (“BCR”) to internally regulate data sharing within the Marubeni Group, including a description of the rights of Data Subjects and the protections and safeguards that will be applied to this sharing of Personal Data.
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7. HOW LONG DOES MARUBENI KEEP MY DATA?
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As a general rule, Marubeni will keep your Personal Data for as long as is strictly necessary to achieve the purposes for which it was collected and to comply with applicable legislation. The exact period of time will depend on the purpose for which we collect your data; for example, while some cookies may be erased as soon as you close your browser and job applicants’ data will normally be kept only during the screening process, and Brazilian laws (such as the Brazilian Civil Code) may require us to Transaction Data for at least five years. After the applicable retention period, we will either delete your data or anonymize it.
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8. HYPERLINKS AND EMBEDDED FUNCTIONALITY
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Our website may contain links to content or other functionality provided by third parties which is outside our control and is not covered by this Statement. If you access other websites using links or use other embedded functionality provided by third parties, the operators of those websites may collect information from or about you which will be used by them in accordance with their privacy statements or policies, which may differ from ours. We encourage you to read the privacy information provided by the operators of those websites. We do not accept any responsibility or liability for those policies.
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9. UPDATES TO THIS STATEMENT
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The present version of this Statement was last updated on December 26th 2020.
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Marubeni reserves the right to modify these rules at any time, especially to adapt them to the new regulations of the Data Protection Laws. We will place any updates on our webpage. By continuing to use our website after such changes have been made, you acknowledge and agree that you have read, understood and accept the changes.
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