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Naturafrig

Naturafrig Privacy Policy

Naturafrig, in full transparency and respect for its employees, suppliers, partners, carriers, service providers, and customers, presents this Privacy Policy to inform about how it processes personal data collected in the course of its activities, in accordance with the Brazilian General Personal Data Protection Law Lei Geral de Proteção de Dados Pessoais (Lei nº 13.709/2018 – LGPD) and other laws applicable to the meat processing industry.

1. Objective

The purpose of this Policy is to clarify how personal data is collected, used, stored, shared, and protected by Naturafrig, guaranteeing transparency, security, and the exercise of data subjects' rights.

2. Coverage

It applies to all personal data processed by Naturafrig, including employees, job applicants, suppliers, service providers, carriers, business partners, visitors, customers, and other individuals with whom the company has a relationship.

3. Definitions

For the purposes of this Policy, the following definitions are adopted:

1. Data Subject The individual to whom the personal data processed by Naturafrig refers.
2. Third parties External parties who interact with Naturafrig, including suppliers, service providers, carriers, customers, business partners, and others who have access to personal data.
3. Personal Data Any information relating to an identified or identifiable individual, such as name, CPF [Individual Taxpayer's Registry], ID, address, telephone number, e-mail address, bank details, among others.
4. Sensitive Personal Data Information on racial or ethnic origin, religious conviction, political opinion, trade union membership, health data, sex life, genetic or biometric data.
5. Data Processing Any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation, control, or modification.
6. Data Protection Officer (DPO) – Person designated by Naturafrig as the communication channel between the controller, the data subjects, and the ANPD.
7. National Data Protection Authority (ANPD) – Body responsible for ensuring, implementing, and monitoring compliance with the LGPD.
8. Information Security – Technical, administrative, and physical measures to protect data against unauthorized access, loss, destruction, or alteration.

4. Data Collected

Naturafrig only collects the data necessary to carry out its activities and comply with legal or regulatory obligations. Examples:

1. EmployeesFull name, ID, CPF, Voter Registration Card, Reservist Certificate (where applicable), dependents' details, proof of education, proof of address, e-mail address, driver's license, criminal record, admission and periodic exams, bank details, biometric data, occupational health information, and video surveillance images.
2. Suppliers and Service Providers: Name, CPF, ID, contact details, bank details, tax and employment documents, health records.
3. CarriersName, CPF, driver's license, vehicle license plate, tracking data, entry/exit video surveillance images.
4. Visitors: Name, CPF, ID, security camera images.
5. Customers and Business Partners: Name, CPF, contact details, tax and bank details (where applicable).

5. Purpose of Treatment

Personal data is processed for legitimate and specific purposes, such as:

1. Complying with legal and regulatory obligations (including MAPA [Brazilian Ministry of Agriculture and Livestock] and health agency requirements).
2. Executing contracts and internal HR, logistics, production, and sales processes.
3. Ensuring physical and property security at the units (including the use of video surveillance and access control).
4. Meeting traceability, certifications, and audit requirements.
5. Processing payroll, benefits, and labor obligations.
6. Complying with quality and animal welfare programs, when collecting data linked to individuals.
7. Responding to requests from data subjects and the ANPD.

6. Legal Bases

Naturafrig may process personal data on the following bases:

1. 1. Compliance with a legal or regulatory obligation.
2. Execution of a contract or preliminary procedures related to a contract.
3. Regular exercise of rights.
4. Consent of the data subject (where applicable).
5. Naturafrig's legitimate interest, with due regard for fundamental rights and freedoms.
6. Protection of the life and physical safety of the data subject or third parties.
7. Fraud prevention and systems security.

7. Data Sharing

Data can be shared with:

1. Government and supervisory bodies (e.g., MAPA, Receita Federal [Brazilian Federal Revenue Service], Ministry of Labor).
2. Financial institutions for payment processing.
3. Benefit companies (e.g., food, transportation, health insurance).
4. Logistics partners and carriers, when necessary for the delivery or collection of goods.
5. Information technology and systems support service providers.
6. Auditing and certification companies.

Sharing will always be limited to what is necessary to fulfill the stated purpose.

8. Data Retention and Deletion

Personal data will be kept for the time necessary to fulfill the purposes of processing or for the period required by law or regulation. After this period, they will be deleted or anonymized, except when their maintenance is permitted by legal or regulatory obligation.

9. Rights of Data Subjects

Under the terms of Article 18 of the LGPD, data subjects have the right to:

1. Confirmation of processing.
2. Access to data.
3. Correction of incomplete, inaccurate, or outdated data.
4. Anonymization, blocking, or deletion of unnecessary or excessive data.
5. Data portability to another provider.
6. Deletion of data processed with consent, where applicable.
7. Information on sharing.
8. Information on the possibility of not providing consent and its consequences.
9. Withdrawal of consent.

Requests can be made through the channels indicated in this Policy.

10. Information Security

Naturafrig adopts appropriate technical, administrative, and physical measures to protect personal data against unauthorized access, misuse, alteration, improper disclosure, or destruction. These measures include:

1. Physical and logical access control.
2. Security camera monitoring.
3. Training of employees in good safety practices.
4. Use of up-to-date software and encrypted systems.

11. Data Protection Officer

The DPO is responsible for responding to requests from the data subjects and the ANPD:

Roberto Aparecido Ferreira
E-mail: [email protected]

12. Policy Updates

This Policy may be updated at any time due to changes in legislation or in Naturafrig's operations. The current version will always be available on the official website.

13. Final Provisions

1. Violations or suspected violations of this Policy should be reported to the Naturafrig Ethics Line.
2. Failure to comply with this Policy may result in disciplinary measures, contractual sanctions, and other applicable legal measures.