Privacy Policies
Solupack Sistemas de Embalagens Ltda. is committed to compliance with laws protecting the privacy of customer and general public data. This page is designed to provide information on how we adhere to data protection standards, what information we collect while you are browsing our communication channels, and how this information is collected, used, and protected by us, in accordance with Law No. 13,709/2018 (General Data Protection Law - "LGPD"). The use of our products and services, as well as our platforms and other interaction channels provided, is conditioned upon acceptance of this Privacy Policy, including with respect to our employees.
1. Source of Personal Data
Solupack Sistemas de Embalagens Ltda. will have access to personal data in the following situations:
Through interaction with a customer: When the customer provides and inputs personal data necessary for the provision of services and use of products provided by Solupack Sistemas de Embalagens Ltda.
Interaction with its employees: When its employees and collaborators of any nature use its systems and platforms to fulfill the duties and obligations arising from the contractual relationship they have.
2. Types of personal data and sensitive personal data collected
Without prejudice to the commonly collected and processed data of its employees for the purposes of the legal relationship they have, Solupack Sistemas de Embalagens Ltda. may also collect the following personal data:
Names and contact details, such as first and last name, email address, postal address, phone number, and other similar contact details, such as bank details;
Device information, such as information about your device, such as IP address, location, or provider;
Usage information and browsing history, such as information on how the user navigates within our services, their browsing history, and which elements of Solupack Sistemas de Embalagens Ltda.'s services are most used;
Sensitive personal data, if collected by Solupack Sistemas de Embalagens Ltda., will have its purpose separately informed to the User, who must consent to Solupack Sistemas de Embalagens Ltda. using them in a specific manner, and in case of disagreement, the data will be automatically deleted from Solupack Sistemas de Embalagens Ltda.'s databases.
Solupack Sistemas de Embalagens Ltda. does not collect data from minors, except with the authorization of parents or guardians. If collected without authorization, as soon as Solupack Sistemas de Embalagens Ltda. becomes aware, it will immediately delete the collected data, following the rules of the Terms of Use and this Privacy Policy.
3. Utilization of collected personal data
When collected, Solupack Sistemas de Embalagens Ltda will use the personal data to:
Provide and enhance contracted services;
Fulfill a legal or regulatory obligation;
Manage the relationship with Users;
Configure and manage User accounts;
Provide technical assistance, support, and training to the User;
Contact Users;
For internal research and development purposes, and to improve, test, and enhance the features and functions of Solupack Sistemas de Embalagens Ltda services;
Provide Users with marketing, advertising, and propaganda, including from partner companies of Solupack Sistemas de Embalagens Ltda, as permitted by law;
Meet internal and external audit requirements, including information security obligations of Solupack Sistemas de Embalagens Ltda;
Send email messages to: a) confirm or cancel requests made through the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, additions of new data sources, and improvements to the platform.
To exercise the rights of Solupack Sistemas de Embalagens Ltda, including, but not limited to, privacy, security, networks, systems, and properties of Solupack Sistemas de Embalagens Ltda and/or third parties;
To comply with requests from courts, law enforcement authorities, regulatory bodies, and other public institutions and government authorities, including, but not limited to, any rules applicable outside the user's country of residence;
To exercise the rights of Solupack Sistemas de Embalagens Ltda and to defend against any legal actions, as well as to comply with any legislation or regulation applicable to Solupack Sistemas de Embalagens Ltda or third parties with whom we work, as well as to ensure the proper fulfillment of contracts entered into between Solupack Sistemas de Embalagens Ltda and its users.
4. Sharing of personal data with third parties
The User accepts and agrees that Solupack Sistemas de Embalagens Ltda may share their personal data with the following categories of recipients:
Companies that provide access to or are responsible for the registration on which the user relies;
Partner companies, such as third-party service providers and other companies that assist us in providing our services or may take actions on our behalf, protecting our rights, users, systems, and services;
Third parties to whom Solupack Sistemas de Embalagens Ltda owes satisfaction or has authorization to disclose information by law (Example: government agencies, regulatory agencies, judiciary, and other public authorities);
Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of Solupack Sistemas de Embalagens Ltda's business, in which case the User's data will be considered an asset and transferred in a potential negotiation;
Third parties who need the data to protect the rights of Solupack Sistemas de Embalagens Ltda;
Any individual or legal entity to whom the User requests the portability of their data.
5. International Transfer of Personal Data
Solupack Sistemas de Embalagens Ltda does not intend to transfer any personal data of the User collected outside of Brazil, and it is certain that unless the hypotheses below are met, Users will be informed in advance by email, on which occasion the user may accept or refuse the transfer, and in case of disagreement, may have their access rights blocked by Solupack Sistemas de Embalagens Ltda.
The international transfer of data described in the General Data Protection Law (LGPD) lacks the designation of guidelines to be established by the National Authority for Data Protection (ANPD), and when defined, Solupack Sistemas de Embalagens Ltda will commit to fully comply with them.
6. Protection of Personal Data
Solupack Sistemas de Embalagens Ltda utilizes appropriate technologies and procedures to protect any personal data collected (including administrative, technical, and physical protections) according to the level of risk and the service provided, having a legally responsible team to handle the secure management of data in accordance with legal provisions, regulatory requirements, technology changes, among other relevant factors that may influence the way personal data is protected.
Solupack Sistemas de Embalagens Ltda makes every reasonable market effort to ensure the security of its systems and collected data, using highly qualified and reputable internet providers, database servers, and storage, as well as security certificates (SSL) and unauthorized access protection software for systems, as well as standard methods to encrypt and anonymize collected data.
This Policy represents Solupack Sistemas de Embalagens Ltda's effort to safeguard User information. However, due to the nature of the internet itself, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing stored information, which is why, if this occurs, Solupack Sistemas de Embalagens Ltda will be responsible within the limits provided by law.
Solupack Sistemas de Embalagens Ltda, within a reasonable period to be defined by the National Data Protection Authority ("ANPD"), must report to the ANPD and the affected User the occurrence of a security incident that may entail a relevant risk or damage to the affected User, mentioning, at least:
the description of the nature of the affected personal data;
information about the involved data subjects;
indication of the technical and security measures used to protect the data, considering trade secrets;
risks related to the incident;
reasons for any delay in reporting, if the communication was not immediate; and
the measures that have been or will be adopted to reverse or mitigate the effects of the damage.
Treatment of Data and Solupack Sistemas de Embalagens Ltda's Responsibility
7. Solupack Sistemas de Embalagens Ltda will have its responsibility for data processing as follows:
When it comes to personal data provided directly by its Customers, Solupack Sistemas de Embalagens Ltda will act as Processor and will operate without interference in the processing methods indicated by the Controller, but under the terms of the LGPD (General Data Protection Law).
Solupack Sistemas de Embalagens Ltda will be the Data Controller of personal data of its employees, processing them based on Contract Performance, Compliance with legal or regulatory obligations, and also, in specific and determined situations, on Consent.
Solupack Sistemas de Embalagens Ltda may adopt different legal bases for different processing activities of personal data.
8. Deadline for Processing Personal Data
Solupack Sistemas de Embalagens Ltda calculates the retention period of personal data according to the following criteria:
Period necessary to fulfill the purpose of the collection;
The moment when the Customer/User ceases to use the services of Solupack Sistemas de Embalagens Ltda;
The moment when consent is revoked or a request for deletion of personal data is made by the Data Subject;
The time necessary to demonstrate compliance with the duties and obligations of Solupack Sistemas de Embalagens Ltda;
The period required by law, regulations, court decisions, etc.;
Determination of the National Data Protection Authority;
Compliance with a legal or regulatory obligation by the Controller;
Perfect execution of the contract;
Needs related to compliance with the legal system, as well as for any judicial disputes;
Transfer to a third party, provided that the requirements for data processing stipulated by law are respected; or
Exclusive use by the controller, with no access by third parties, and provided that the data is anonymized.
9. User Rights
According to the Brazilian General Data Protection Law, the User will have the following rights regarding the processing of their personal data:
Right to Confirmation: The User may confirm whether Solupack Sistemas de Embalagens Ltda processes any of their personal data;
Right of Access: The User may make a written request to obtain details of how their information is being used, as well as to have a copy of said information;
Right to Correction: The User may correct or remove any of their data that is incomplete, inaccurate, or outdated;
Right to Anonymization, Blocking, or Deletion: The User may request the anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data, observing, therefore, other legal norms;
Right to Erasure: The User may request the erasure of some data, except those for which the law authorizes their conservation;
Right to Information: The User may request information from public and private entities with which Solupack Sistemas de Embalagens Ltda has shared their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data;
Right to Opt-Out of Marketing: The User may, at any time, request to unsubscribe from receiving advertisements and other materials through the link provided in the marketing email sent.
Right to Data Portability: The User may request that their personal data be transferred to themselves or third parties, except for those that have already been anonymized and deleted by Solupack Sistemas de Embalagens Ltda.
Right to Withdraw Consent: The User may revoke any consent previously given to Solupack Sistemas de Embalagens Ltda to use their personal data. The User is aware that the cancellation will not affect the use or sharing of data that occurred prior to the revocation request.
The rights set forth in this chapter are not absolute, and the User, whenever they wish to exercise them, must contact Solupack Sistemas de Embalagens Ltda through the following channel:
Solupack Sistemas de Embalagens Ltda undertakes to respond to such requests as soon as possible and at no cost to the User, within a maximum period of 15 (fifteen) days from the receipt of the request, unless a longer period is necessary to respond due to complexity, factual or legal reasons, in which case the User will be notified.
Solupack Sistemas de Embalagens Ltda will immediately inform the data processing agents with whom it has shared User data about the correction, deletion, anonymization, or blocking of data, so that they repeat the same procedure.
Confirmation of the existence or access to the User's personal data provided in this chapter will be provided electronically or in an express manner, in a simplified format or by means of a clear and complete statement, indicating the origin of the data, the absence of a record, the criteria used, and the purpose of the processing, always observing the commercial and industrial secrets of Solupack Sistemas de Embalagens Ltda.
10. Cookies
Solupack Sistemas de Embalagens Ltda and potential partners may use cookies and similar technologies to store and manage User preferences, offer targeted advertising, enable content, and collect analytical and usage data, for example. The use of cookies and other tracking technologies is a standard on websites and platforms, through which information about User activities on the platform, websites, or other services is collected.
A cookie is a small text file placed on a computer or other device, used to identify the User, the device used, and to collect information, and may perform the following functions:
Necessary Cookies: essential to allow the User to navigate a platform and use its features.
Performance Cookies: they collect information on how the User uses the Solupack Sistemas de Embalagens Ltda platform and are used to improve navigation and enhance the User experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the previously visited website, the number of visits, the average duration of the visit, and the pages viewed.
Functional Cookies: they allow the platform to remember choices the User has made (such as their username or ID, language preference, or the area or region where the User is) and provide enhanced and more personalized features.
Advertising Cookies: they track the User's browsing habits and are used to provide targeted advertising. These cookies also limit the number of times you see an ad and measure the effectiveness of advertising campaigns. They also remember that the User has visited a website, and this information is shared with other organizations, such as advertisers.
Solupack Sistemas de Embalagens Ltda uses necessary and performance cookies.
At any time, the User may disable Cookies through their browser settings, installing plugins available on the market, or by using other technologies they deem necessary.
In addition to cookies, Solupack Sistemas de Embalagens Ltda uses other tracking technologies, such as:
Web Server and Platform Logs: Solupack Sistemas de Embalagens Ltda servers automatically collect certain information to assist, manage, and protect the services offered, as well as to analyze usage and improve the User experience. The information collected includes:
IP address and browser type;
Device information, including Unique Device Identifier (UDID), MAC address, Identifier for advertisers (IFA), and similar identifiers assigned by us or by third parties;
Device operating system and other technical data;
The city, state, and country from where you are accessing the BRASIL RISK platform, including for fraud prevention;
Information or text typed;
Links and buttons clicked;
Social Media Connections: Some of Solupack Sistemas de Embalagens Ltda services may include social media features, such as Facebook's "Like" buttons and widgets; "Share" button and interactive mini-programs.
Solupack Sistemas de Embalagens Ltda may allow the User to choose to use their own social media logins to access some of the services offered, in which case Solupack Sistemas de Embalagens Ltda may receive and store authentication information from these services.
11. Contact Information
Questions, comments, suggestions, and/or complaints regarding this Privacy Policy, as well as any need for information, change, or deletion of personal data, may be made by the User directly to Solupack Sistemas de Embalagens Ltda via email:
12. Changes
Solupack Sistemas de Embalagens Ltda seeks constant updates and improvements, so this Privacy Policy may be updated at any time, always aiming for better provision and protection of users.
In the event of changes affecting the purpose and duration of the User's personal data processing, they will be informed via the email registered in our services or through the platform itself with a 30 (thirty) days' notice. If there is disagreement with the changes, the User may revoke the consent provided, being unable to use Solupack Sistemas de Embalagens Ltda services.
If in the future Solupack Sistemas de Embalagens Ltda intends to change its policy regarding data sharing with third parties, it will send a notice 30 (thirty) days in advance to the user's registered email, and if the user disagrees with the sharing, they may continue to use Solupack Sistemas de Embalagens Ltda services.
Users are advised to periodically read this policy to stay updated on its content.
13. Legislation and Jurisdiction
This Policy shall be governed, interpreted, and enforced in accordance with the laws of the Federative Republic of Brazil, regardless of conflicts of laws with laws of other states or countries, with the Courts of São Paulo being competent to settle any doubts arising from this instrument, with the waiver of any other, however privileged it may be.
All rights reserved.
