Privacy Policy

TRIUNFO DO BRASIL INDÚSTRIA E COMÉRCIO LTDA., a legal entity of a company incorporated under private law, with its head office at Rod. PR 151 - Km 424, s/n, Coxilhão do Meio, São João do Triunfo/PR, CEP: 84.150-000, registered with the CNPJ under No. 04.504.045/0001-54 ("TRIUNFO"), hereby represented under the terms of its Articles of Association, striving for transparency and the maintenance of a relationship of trust throughout the production and marketing chain of its product - organic yerba mate - aims, through this Privacy Policy ("Privacy Policy"), to provide important information and clarifications on the processing of data from customers, resellers and visitors to the website - https://loja.triunfodobrasil.com/ ("Website").

    This policy will demonstrate: 

• Which subjects' data will be collected;
• The purpose(s) of such collection; and
• How such data will be protected while TRIUNFO.

    In addition, it should be noted that all TRIUNFO's actions are always in compliance with the provisions of the General Personal Data Protection Law - Federal Law No. 13,709/18 ("LGPD").

    DEFINED TERMS

    Consent - means the free, informed and unequivocal authorization that the Data Subject grants for the Processing of Data, in accordance with the Purpose previously stipulated. Consent may be revoked at any time. Revocation does not cancel the processing previously carried out.    

    Data - means data, whether personal or not, that identifies, refers to, describes, can be used to contact, or can be linked, directly or indirectly, to the individual to whom it refers.

    Purpose - means the objective that TRIUNFO intends to achieve with Data Processing.

    Data Subject - means the natural person who will have their Data Processed by TRIUNFO, and may refer to customers, resellers and visitors to the Website.

    Data Processing - means the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, communication, transfer, dissemination or extraction of the Data of natural persons.    

    User - means customers, resellers and visitors to the Website.

1. THE DATA COLLECTED AND ITS PURPOSE

    For the effective supply of products, as well as in order to customize the User experience, TRIUNFO may collect the following Data:

1.1) To register as a customer on the website:

• Full name;
• E-mail;
• Phone (optional); and
• Password.

• Enable the User to register on the Website;
• Allow identification and contact with the User;
• Assisting in the diagnosis and solution of problems related to the products supplied by TRIUNFO;
• To comply with a legal obligation and/or safeguard TRIUNFO's legitimate interests; and
• To guarantee the security of Data Subjects and prevent fraud.

1.2) To buy products on the website:    

• E-mail;
• CPF or CNPJ;
• Full name;
• Phone;
• Address and zip code;
• If someone else is going to pick up the order at the store: Full name of the third party picking up the order; and
• In the case of "Credit Card" purchases: Card details (number, printed name, expiration date, CVV, CPF or CNPJ of the cardholder);

• Allow identification and contact with the User;
• Allow the User to buy and sell products;
• Help with any questions or requests about purchases;
• Enable the User to carry out transactions and payments within the Website;
• Generate invoices and deliver orders to the User's home;
• Send marketing communications by e-mail or telephone;
• To comply with a legal obligation and/or safeguard TRIUNFO's legitimate interests; and
• To guarantee the security of Data Subjects and prevent fraud.

1.3) To register as a reseller on the website:

• Company name;
• Address;
• CNPJ | CPF;
• Full name of the individual;
• E-mail;
• Phone (optional); and
• Password.

• Enable the User to register on the Website;
• Allow identification and contact with the User and potential resellers;
• Assisting in the diagnosis and solution of problems related to the products supplied by TRIUNFO;
• Send marketing communications by e-mail or telephone;
• To comply with a legal obligation and/or safeguard TRIUNFO's legitimate interests; and
• To guarantee the security of Data Subjects and prevent fraud.

1.4) For all visitors to the website:

• Hardware data of the User's device (model, manufacturer, Internet service provider, operating system);  
• Access data (log in/log out, time, location, IP and means of access);
• Cookie data. 1)     

• Developing new features and improvements to enhance the user experience;
• To comply with legal obligations and/or safeguard TRIUNFO's legitimate interests; 
• Analyze User behavior on the Website;
• Send marketing communications by e-mail or telephone;
• To guarantee the security of Data Subjects and prevent fraud;
• To guarantee the best possible functioning of the Website and other TRIUNFO mobile applications on the most diverse devices, as well as to optimize TRIUNFO's own performance;
• Identify the User and his/her preferences, including information about: (a) how the Website's resources are visited by third parties; (b) the User's behavior; and (c) standard Internet and device information;
• Assisting TRIUNFO's security system.

    Cookies. These are text files sent when accessing TRIUNFO's Website and/or other mobile applications. They store browsing patterns and history in order to recognize the User on future visits, providing a customized experience based on their preferences. In addition, the use of cookies allows TRIUNFO to carry out research and diagnostics to improve the content and products/services of the Website, as well as providing tools to prevent fraudulent activities. 

    If the User wishes to know more about cookies, including how to deactivate them, they should go to https://www.allaboutcookies.org/ and/or directly in their default browser, if Internet Explorer:https://support.microsoft.com/pt-br/help/17442/windows-interne t-explorer-delete-manage-cookies; if Mozila Firefox: https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-que-os -sites-usam; if Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.PlatformDe sktop&hl=en-BR.

    About the Data Collected. All Data that TRIUNFO collects is treated as confidential and will only be used for the purposes described above and/or authorized by the User.

    It should be noted that the User may choose not to share certain information with TRIUNFO, as shown in the "Cookies" section, but in this case, this decision may deprive him/her of part of the functionalities provided by TRIUNFO. 

2. DATA CONTROLLERS AT TRIUNFO'S HEAD OFFICE.

    Treatment is carried out:

• By TRIUNFO, already qualified above, now the Controller, responsible for making the decisions regarding Data Processing;
• By Mr. Roberto Andrade Dias, with contact e-mail [roberto@grupogadens.com.br], specialized Operator who has the necessary experience for Data Processing and is responsible adopting the appropriate security measures; and
• By Ms. Carolline Portela, e-mail [dpo@grupogadens.com.br], in charge of acting as a communication channel between TRIUNFO, the User and the National Data Authority - ANPD.

3. SHARING DATA WITH THIRD PARTIES.

    TRIUNFO does not lend or sell User Data to anyone. However, it may share it - when really necessary - with:

• Partners, Service Providers and Suppliers: companies responsible for developing and managing the information system (e-mail, telecommunications networks and providers), partner companies such as carriers and third parties responsible for the logistics and delivery of orders placed on the Website, credit card administrators, if applicable, payment institutions, among others, contractually linked to TRIUNFO, and other service providers who act, directly or indirectly, to provide any of its functionalities and improve service to the User;
• Authorities: entities and bodies of Public Administration, including regulatory bodies, for inspections and controls relating to compliance with tax and civil obligations, and other state authorities and similar authorities, including judicial and arbitration authorities, which are entitled to access personal data by law; 
• Software: companies responsible for the software and other technologies present in TRIUNFO with the aim of improving security, analyzing and solving technical problems and curbing fraud;
• Advertisers/Advertising/Marketing Networks: companies responsible for TRIUNFO's marketing and advertising with the specific purpose of personalizing services and products consumed by the User, in order to improve their experiences with TRIUNFO;
• Holding GGH ADMINISTRAÇÃO E PARTICIPAÇÕES SOCIETÁRIAS S.A. (CNPJ no. 34.801.552/0001-10): a company belonging to the same economic group, with the following purposes: (i) developing new products and services; and (ii) offering products and services that meet the interests and profiles of visitors, based on statistical data.

    Therefore, the sharing of Data with third parties seeks to serve the User's own interest, having legitimate purposes, within the limits contained herein.

    Furthermore, whenever possible, in order to comply with legal, regulatory or contractual obligations, personal data will be anonymized by TRIUNFO prior to said sharing.   

4. OF DATA STORAGE BY TRIUNFO.

    The Data will remain retained for the time necessary for TRIUNFO to fulfill the Purposes for which it was collected. Therefore, all Data collected will be deleted from TRIUNFO's servers, or anonymized, when: (a) they are no longer necessary for the provision of its products/services; and/or (b) requested by the User, except for any legal obligation to retain data or the need to safeguard TRIUNFO's rights.

5. INTERNATIONAL DATA TRANSFER.

    TRIUNFO is based in Brazil and follows Brazilian data protection legislation. , it does not directly transfer the Data to other countries. 

6. TRIUNFO'S SECURITY POLICY.

    TRIUNFO recognizes that it is responsible for taking care of the User Data to which it has access and using it only for the purposes described in this Privacy Policy. Therefore, in order to guarantee that the Data is kept secure, restricted and confidential, it has adopted appropriate security and governance practices such as:

• Standard and market methods for encrypting and anonymizing the Data collected; 
• Software to protect against unauthorized access to systems; 
• Authorization of access only to persons previously approved by TRIUNFO to the places where it stores confidential information; 
• Internal policies for responding to incidents involving Data; 
• Entering into contractual documents with employees and partners who have access to the information, in order to establish the obligation to maintain the absolute secrecy and confidentiality of the Data accessed, under penalty of civil and criminal liability, in with Brazilian legislation.

    Although TRIUNFO makes every effort to preserve your privacy and protect your Data, the User's total security is something that does not depend solely on TRIUNFO's actions and processes. 

    TRIUNFO cannot guarantee that User Data will not be intercepted or accessed through illegal acts, hardware or software failures, among other factors. 

    Therefore, if the User identifies something that compromises the security of the Data, they must immediately notify TRIUNFO so that, in the event of an incident with the Data that is actually under its custody, TRIUNFO can act in an agile and effective manner, in accordance with its own Incident Response Plan Involving Personal Data.   

7. THE RIGHTS OF THE DATA SUBJECT.

    TRIUNFO ensures that the User, as Data Subject, may request, at any time, confirmation, correction, modification, portability, deletion, sharing information and access to their Data, which will be analyzed and considered by TRIUNFO in order to take the necessary measures.

    In compliance with the applicable legislation regarding Data Processing, TRIUNFO guarantees that the User may exercise the following rights:

• Confirmation of the existence of treatment; 
• Data Access;
• Correction of incomplete, inaccurate or outdated data;
• Anonymization, blocking or deletion of unnecessary, excessive or non-compliant data;
• Data portability to another provider, upon express request;
• The deletion of data processed with consent;
• Obtaining information about the public or private entities with which TRIUNFO has shared your Data;
• Information about the possibility of not providing consent, as well as the consequences of not doing so; and
• Revoking consent.   

8. THIRD-PARTY LINKS.    

    TRIUNFO may provide links to other websites on the Internet in order to improve the User's browsing experience. However, TRIUNFO is not responsible for the content of other websites and/or how they collect, process and transfer User Data.

    We recommend that each User consult the respective privacy policies of such websites before providing their Data. 

9. THE USER'S CONTACT WITH TRIUNFO.

    If the User, as Data Subject, would like more information about Data Processing or if he/she has any questions, comments or suggestions regarding this Privacy Policy, he/she should contact TRIUNFO through the person in charge, Mrs. Carolline Portela, by e-mail [dpo@grupogadens.com.br].   

10. OF ANY CHANGES TO THE PRIVACY POLICY.

     TRIUNFO reserves the right to update or modify this Privacy Policy at any time in order to guarantee its commitment to transparency with the User. We therefore recommend that you visit this page periodically so that you are aware of any changes made. In the event of any significant changes requiring new authorizations, we will notify you.

11. FORUM

    The jurisdiction of Curitiba/PR is hereby elected for the resolution of any dispute or controversy involving this Privacy Policy, except in the case of specific jurisdiction determined by law.

    ATTENTION: Acceptance of this Privacy Policy will be made checking the box corresponding to the option "I accept TRIUNFO's Privacy Policy".

    WE EMPHASIZE THAT BY ACCEPTING THE PRIVACY POLICY YOU ARE GRANTING YOUR CONSENT TO THE ENTIRETY OF THE PROVISIONS CONTAINED HEREIN, ACCEPTANCE BEING AN ABSOLUTE AND INESCAPABLE CONDITION FOR CONTRACTING TRIUNFO AND USING THE WEBSITE.

    [ ] I ACCEPT TRIUNFO'S PRIVACY POLICY.