Privacy and data protection policy

Last updated on: 28/Jul/2022

This WEBSITE is maintained and managed by FSK – F. SCHWANKE KRANTTECHNIK EIRELI, a private legal entity enrolled with the CNPJ/MF [Company Taxpayer’s Number/Ministry of Finance] under No. 19.990.077/0001-84, headquartered at Rua Frederico Augusto Ritter, 5125, Distrito Industrial, CEP [Postal Code] 94931-800, in the city of Cachoeirinha, Rio Grande do Sul, Brazil.

For any questions that may arise during your relationship with FSK, or regarding the interpretation of this PRIVACY POLICY, please feel free to contact us via email: contato@fsk.net.br

1. WHAT DO YOU NEED TO KNOW TO UNDERSTAND THIS DOCUMENT?

1.1 In order to fulfill our commitment to PERSONAL DATA protection, it is essential that you are able to understand some useful concepts and definitions when reading this policy:

  1. BROWSER COOKIES: text files containing information that may be stored on your devices when you access the FSK website, and that identify your device for the purposes indicated herein.
  2. PERSONAL DATA: information pertaining to an individual capable of identifying such natural person when analyzed individually or within a context.
  3. PURPOSE: purpose for which we use your personal data; the purpose behind a processing activity.
  4. LEGAL BASIS: list of cases in which data processing is authorized by the Brazilian General Data Protection Law.
  5. WEBSITE: public virtual environment maintained by FSK, which may be accessed through the link www.fsk.net.br.
  6. HOLDER, YOU or USER: the individual to whom the PERSONAL DATA refers.
  7. PROCESSING/TREATMENT: every activity we perform with your PERSONAL DATA, from collection and storage to classification and deletion.

2. WHAT IS THE APPLICATION AND PURPOSE OF THIS PRIVACY POLICY?

2.1 This PRIVACY POLICY applies to all activities that characterize the processing of personal data carried out by FSK in the performance of its commercial activities, provision of virtual content and relationship with customers or potential customers.

2.2 This PRIVACY POLICY aims to consolidate FSK’s commitment to guaranteeing personal data protection, pursuant to Brazilian legislation. Through this document, FSK intends to:

  1. Show USERS which personal information FSK uses in its operations;
  2. Demonstrate the legitimate purposes for which we use such information;
  3. Inform USERS on how FSK preserves their privacy; and
  4. Clarify the rights and options of USERS as holders of personal data in relation to FSK’s practices.

3. WHAT ARE YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA BY FSK?

3.1 In compliance with current legislation, FSK grants you the following rights regarding data processing activities:

  1. Confirmation of personal data processing;
  2. Access to data used by FSK;
  3. Correction of your personal data in case of incompleteness, inaccuracy or outdatedness;
  4. Portability, upon express request;
  5. Information about the possibility of not giving your consent when applicable, as well as receiving information about the consequences in case of denial;
  6. Information about sharing your personal data with third parties;
  7. Possibility of revoking your consent, as well as requesting the deletion of data processed in accordance with this legal basis.
  8. Anonymization, blocking or deletion of overprocessed personal data or data processed in disagreement with the Law or with this PRIVACY POLICY.

3.2 The rights described above may be exercised at any time through a request emailed to: contato@fsk.net.br

4. HOW AND WHY DO WE PROCESS YOUR PERSONAL DATA?

4.1 In compliance with Brazilian legislation, FSK only processes PERSONAL DATA for legitimate purposes, related to its business activity, and expressly informed in this PRIVACY POLICY, in light of the following general purposes:

  1. Ensuring the full execution of commercial agreements, including payment, logistics and support steps.
  2. Transmission of institutional communications related to our customers’ or potential customers’ journey in their relationship with FSK.
  3. Verification of USERS’ identity and authenticity, in order to provide an adequate level of security for our WEBSITE and any operations conducted in the virtual environment.
  4. Targeted offer of products and special conditions based on the interests of each USER;
  5. Collection of statistical information and behavioral patterns to improve our services, develop new business fronts and offer a personalized browsing experience.
  6. Ensuring compliance with legal or regulatory obligations, or even the regular exercise of FSK’s rights, including in administrative and court proceedings, if necessary, in addition to collaborating with the fulfillment of a court order or inspection by a competent public agency or authority.

4.2 All operations that involve the use of PERSONAL DATA by FSK will be associated, in addition to a legitimate purpose, with a legal basis provided for in the General Data Protection Law that provides the necessary support for the processing activity, such as:

  1. Execution of a contract or preliminary activities when we process PERSONAL DATA to ensure the smooth progress of your purchase;
  2. Compliance with legal obligation, when we follow determinations set out by laws such as the Consumer Protection Code (Law 8078/90), Internet Civil Framework (Law 12695/14), General Data Protection Law (Law 13709/18), and others applicable to our relationship and operation.
  3. Consent, when USERS positively express their free agreement with the processing of their data for a certain purpose;
  4. Regular exercise of FSK rights, whenever necessary, including in judicial and administrative proceedings;
  5. Legitimate interest, when we conclude that a certain treatment is imperative for the development of our activities, provided that it generates some type of benefit for you, and that you have interacted with us at another time.

4.3 Specific consultation on PERSONAL DATA processing operations may be carried out upon an express request by DATA HOLDERS, under the terms provided for in this PRIVACY POLICY

5. BROWSER COOKIES

5.1 FSK uses COOKIES to ensure the proper functioning of its institutional WEBSITE, as well as to enable the personalization of content, browsing experience and advertising targeting.

5.2 The use of BROWSER COOKIES by FSK is bound by the terms of this PRIVACY POLICY and the existing guidelines within Brazilian legislation. In general, COOKIES are divided into three categories, according to their application:

  1. a. Necessary Cookies: They are essential for the website to function in accordance with the visual and security features designed by FSK, and cannot be refused when visiting our WEBSITE.
    Cookie Provider Term Description
    rc::a Google Permanent HTML Cookie. Used to distinguish real users from bots.
    rc::c Google Session HTML Cookie. Used to distinguish real users from bots.
    li_gc LinkedIn 2 Years HTTP Cookie. Saves user preferences regarding non-essential cookies provided by LinkedIn.
  2. b. Analytics and Preference Cookies: they help FSK understand how visitors engage with the website and consequently improve the experience in future updates.
    Cookie Provider Term Description
    _ga Google Analytics 2 years HTTP Cookie. Used to distinguish users, it records a unique ID for visitor statistics.
    _gat Google Analytics 24 hours HTTP Cookie. Used to control Google Analytics request rate.
    _gid Google Analytics 24 hours HTTP Cookie. Registers a unique ID to generate statistical data on website usage by visitors.
    collect Google Analytics Session Pixel Tracker. Sends collected statistical data on both device and behavior to Google Analytics.
    lang LinkedIn Session HTTP Cookie. Used to record users’ language preferences.
    AnalyticsSy ncHistory LinkedIn 29 days HTTP Cookie. Used to record data synchronization preferences.
  3. c. Advertising cookies: used to make our advertisements more engaging and valuable to FSK customers and potential customers. Some applications include the selection of INDIVIDUAL relevance-based advertising, analysis of campaign performance and prevention of repeated ads.
    Cookie Provider Term Description
    _trf.src fsk.net.br 1 year HTTP Cookie. Registers user origin for statistical purposes and marketing computation.
    ads/ga-aud iences Google AdWords Session Pixel Tracker. Used to rank the propensity to convert visitors into customers according to the words used in the search.
    bcookie LinkedIn 2 years HTTP Cookie. Pertaining to LinkedIn share buttons and ad tags.
    bscookie LinkedIn 2 years HTTP Cookie. Regarding actions performed on the website.
    lidc LinkedIn 24 hours HTTP Cookie. Used to select the best LinkedIn data center.
    UserMatch History LinkedIn 29 days HTTP Cookie. Used for LinkedIn Ads ID synchronization purposes.
    fbc FacebookAds 3 months HTTP Cookie. Used when a user arrives on the website from an ad, and the destination URL includes the click identifier “fbclid”
    fbp FacebookAds 3 months HTTP Cookie. Used to distinguish and track unique users on the website.

5.3 YOU may prevent cookie setting at any time by adjusting your browser settings. Learn how to do this by accessing the link corresponding to your browser: internet explorer | mozilla firefox | safari | google chrome | microsoft edge | opera. Please be advised that COOKIES are used to offer a better browsing experience, and that their deactivation will also reach “necessary” cookies, which may affect certain features and resources of this and other websites.

6. WHAT DATA IS PROCESSED BY FSK AND WHAT ARE THE PURPOSES OF EACH TREATMENT?

6.1 To make the application of this PRIVACY POLICY tangible in the activities performed by FSK, we present below the types of data processed and the purposes related to their treatment:

Activity CONTACT AND COMMUNICATION WITH FSK
Treatment Agent FSK – F. SCHWANKE KRANTTECHNIK EIRELI
Position Personal Data Controller
Collection Procedure FSK may collect data relating to this activity through: (i) form on the website www.fsk.net.br; (ii) telephone call; (iii) contact by instant messaging application; (iv) messages on FSK’s social media and networks; and (v) contacts via corporate email
Personal Data Processed in the Activity The contact form currently found on the website www.fsk.net.br collects identifying information, such as (i) name, (ii) cell phone number, (iii) email address, (iv) company; (v) position; and (vi) other data that may be shared in the “message” field.
Purpose of Treatment Establishment of commercial contact and sending of communications and offers related to FSK activity.
Sharing Data eventually shared will only reach third parties who occupy the position of Personal Data Operators, that is, strategic business partners who are only authorized to perform specific operations as per their contracting purposes.
Activity CONTRACTING (PURCHASE AND SALE / SERVICES)
Treatment Agent FSK – F. SCHWANKE KRANTTECHNIK EIRELI
Position Personal Data Controller
Collection Procedure Personal data processed as a result of FSK’s contracting activities are provided directly by our customers or by third parties expressly indicated as their representatives throughout the negotiation.
Personal Data Processed in the Activity Data processing may include the following categories: (i) registration data, such as name, company and position; (ii) contact details, such as postal address, e-mail and telephone numbers; (iii) financial data pertaining to the contract; (iv) authentication data for validation of digital signatures; (v) other non-sensitive personal data that may be necessary for the performance of FSK’s activities.
Purpose of Treatment Contracting of services and purchase and sale of equipment marketed by FSK.
Sharing Data eventually shared will only reach third parties who occupy the position of Personal Data Operators, that is, strategic business partners who are only authorized to perform specific operations as per their contracting purposes.
Activity NAVIGATION ON THE WEBSITE FSK.NET.BR
Treatment Agent FSK – F. SCHWANKE KRANTTECHNIK EIRELI
Position Personal Data Controller
Collection Procedure Cookies automatically collect personal data during the browsing session, in accordance with the authorizations or preferences indicated by USERS.
Personal Data Processed in the Activity The processing may include the following data: (i) geographic location; (ii) browser type; (iii) pages consulted and session duration; (iv) preferences.
Purpose of Treatment The information collected by browsing cookies is used by FSK to (i) ensure the proper functioning of our website; (ii) enable browsing experience customization, (iii) implement improvements in the functionality of our website, (iv) target certain advertising content about FSK from the interaction of users.
Sharing Data eventually shared will only reach third parties who occupy the position of Personal Data Operators, that is, strategic business partners Activity NAVIGATION ON THE WEBSITE FSK.NET.BR who are only authorized to perform specific operations as per their contracting purposes.

7. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

7.1 In accordance with Brazilian legislation, FSK only maintains and processes PERSONAL DATA for as long as necessary either to fulfill the purposes indicated herein or legally. To determine the appropriate retention period, consideration is given to the volume of information, the nature, application, purpose and sensitivity of the PERSONAL DATA processed by FSK.

7.2 Once the purpose for which the use of certain PERSONAL DATA has been fulfilled, it will be deleted from our environments or anonymized, so that the associated person is no longer identifiable. As a result of requests made by DATA HOLDERS, FSK may perform these procedures at any time, except in cases where maintenance is authorized and/or determined by current legislation, including for tax, audit and accounting obligations, or situations in which that maintenance is necessary for our legitimate business interests.

8. WHO DOES FSK SHARE YOUR PERSONAL DATA WITH?

8.1 For the development of some activities, FSK may contract services from other companies, and, eventually, these business partners will need access to PERSONAL DATA controlled by FSK. This access will only be given to the strictly necessary extent and will always be linked to a legitimate purpose already informed. Similarly, we will make sure that this PRIVACY POLICY and the legislation involving data protection will be complied with by the business partner, and that the processing activities performed do not exceed the limits of the commercial agreement or the provisions agreed herein.

8.2 In light of the provisions of the above clause, the third parties that may have access to your personal data include: (i) judicial, administrative or governmental authorities, including the judiciary and other public administration bodies or agencies; (ii) business partners for the stages of logistics, corporate management tools, customer relationships and sending virtual or physical communications; (iii) service providers not directly related to FSK’s business activities, such as information security companies, systems operation and hosting, accounting offices, law firms, database organization, research or statistical analysis, and marketing and financial, payment or credit analysis institutions;

8.3 INTERNATIONAL TRANSFER. For strategic and structural reasons of the Internet, even though FSK is based in Brazil, it is possible that some information is processed on servers located abroad. In the event of an international data transfer, we ensure that FSK will take all contractually applicable measures to guarantee the security and integrity of the information, as well as ensure that the business partner is committed to the levels of security and compatibility with both this privacy policy and the Brazilian law.

9. HOW DOES FSK GUARANTEE PERSONAL DATA SECURITY?

9.1 FSK adopts practices to maintain the security of PERSONAL DATA stored in its physical and digital environments, committing to use technical and organizational measures that are sufficiently adequate for the protection of such information and compatible with its nature and sensitivity, always observing the state of the available technique.

9.2 All PERSONAL DATA eventually collected and processed are stored in secure and controlled environments, with security measures in place to prevent unauthorized access and sharing or situations of loss or alteration in data integrity. However, despite FSK’s efforts to protect PERSONAL DATA controlled by the company, it is common knowledge that no security system is absolutely secure. In this sense, FSK disclaims any liability for any damage and/or losses resulting from invasion of its website, its physical or digital environments, and other failures pertaining to the security of PERSONAL DATA processed by FSK, to the extent and proportion allowed by Brazilian legislation, unless there is evidence of willful misconduct.

9.3 Always remember that protecting your privacy is a joint commitment. With that in mind, we recommend taking some preventive measures, such as: (i) notifying FSK of any and all suspected violations of this PRIVACY POLICY; (ii) confirming, through official FSK channels, the veracity of any communications received about promotions, campaigns, surveys or a form to be filled out, especially if received through channels not recognized by YOU; (iii) always providing FSK with truthful and up-to-date information; (iv) adopting cybersecurity measures on your devices, such as updating systems, using antivirus software and creating strong passwords; (v) not making payments allegedly requested by FSK without first certifying the authenticity of the charge and the accuracy of bank details.

10. GENERAL PROVISIONS

10.1 FSK strives to improve its customers’ experience. As a result, practices involving PERSONAL DATA treatment may change over time, with the inclusion or replacement of features or services. Whenever any relevant condition of this nature occurs, we will update our PRIVACY POLICY, and the changes will be considered valid, effective and binding upon publication of the new version on our WEBSITE.

10.2 This PRIVACY POLICY shall be interpreted in accordance with Brazilian legislation, with the jurisdiction of Cachoeirinha/RS [State of Rio Grande do Sul], or the district of residence of each USER, resulting from consumer relations, being elected to resolve any doubts, pending issues or divergence of the application or interpretation hereof.

10.3 Communications from FSK through its official channels are considered valid, effective and sufficient for the dissemination of any positioning, announcement or matter related to the company’s activities and the provisions set forth in this PRIVACY POLICY.

11. CONTACT FSK

11.1 After reading this Privacy Policy, whenever YOU have questions or wish to interact with us on a matter involving personal data processing, please email us at:contato@fsk.net.br

Last updated on: 28/Jul/2022