Privacy Policy

Version of: october 2021

The Grano Trading Privacy Policy (“Policy”) was created to demonstrate the commitment of Grano Trading Exportadora e Importadora LTDA., a company registered with CNPJ/ME n. 03.977.522/0001-36 (herein referred to as “Grano”, “we” or “our”), with the security and privacy of the information collected from our users, who are the holders of their personal data (“Holder”, “User” or simply “you”).

The Policy clarifies the general conditions for the collection, use, storage and other forms of treatment and protection of personal data on our website www.granotrading.com (“Site”), in accordance with the Brazilian legislation currently in force regarding privacy and protection of personal data in Brazil, including, but not limited to, Law No. 12.965, of April 23, 2014 and Decree No. 8771, of May 11, 2016 (“Marco Civil da Internet”) and Law No. 13.709, of August 14, 2018 (“General Data Protection Law” or “LGPD”).

For the purposes of this Policy, Grano is qualified as a holding company, as it stores your personal information, and decisions regarding the treatment of your personal data collected by us are incumbent on us. To maintain direct contact with you, Grano has designated a Personal Data Processing Officer to manage a communication channel. If you have any doubts related to the activities of processing personal data under our responsibility or questions and comments regarding this Policy, please send an email to dpo@grupofarroupilha.com, for the attention of Gabriela Glitz (“In charge”).

You can contact Grano Trading through our Website, through the Privacy Center, correspondence or by calling the telephone number:

By using our Site, you freely, informed, unequivocally, expressly and fully express your agreement with this Policy. We recommend that you read it carefully.

1. SCOPE
2. INFORMATION WE COLLECT
3. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
4. PURPOSE OF DATA COLLECTION
5. SHARING PERSONAL DATA
6. RIGHT OF PERSONAL DATA HOLDERS
7. HOW WE STORE AND PROCESS PERSONAL DATA
8. INTERNATIONAL TRANSFER OF PERSONAL DATA
9. INFORMATION RETENTION TIME
10. TERM AND CHANGES
11. COMMUNICATION POLICY.
12. CONNECTIONS (LINKS) TO OTHER SITES

1. SCOPE

This Policy applies to all users of the Site, and your personal data will be collected whenever you:

• Visiting or interacting with the Grano website;
• Contact us through our service channels

2. INFORMATION WE COLLECT

Important: You are not obligated to provide us with your information, however, without providing certain information when requested, you will not be allowed access to some features. In addition to the data you inform us, whenever you interact with our Site, information will be collected automatically. Such information is generally not identifiable, however, when combined with other data generating the ability to associate with you, it will be treated by Grano as personal data.

The nature and purpose of the personal data we collect may differ depending on the area of ​​the Site accessed.

Within the limits allowed by applicable law, Grano may process the following personal data that you inform us:

Contact information: phone, sector and message.

As previously informed, Grano may automatically collect the information listed below, even if you have not actively interacted with us:

Geolocation: Precise or approximate location determined from your mobile device’s IP or GPS address, depending on your device’s settings.

Log data and information from your device: details about how you used the Site (which pages were visited; the order in which they were visited; which links were clicked; as well as whether you clicked on links to third-party applications), IP address or other unique identifier (Device Identifier), access dates and times, hardware and software information, your device information, unique identifiers, fault data.

Cookies and similar technologies: in accordance with our Cookie Policy.

Please note that the personal data listed above will be collected by Grano and further processed only as necessary to achieve the purposes set forth herein.

We do not collect, store or otherwise intentionally treat excessive or unnecessary personal data for the provision of our services and use of our Site, as well as data considered sensitive (those relating to your racial or ethnic origin, religious conviction, political opinion, affiliation to union or organization of a religious, philosophical or political nature, health or sexual orientation, as well as genetic data) and minor data without the consent of the person responsible. As a result, we ask that you refrain from sharing such data with us. If we become aware that this data was collected and inadvertently processed, it will be deleted from our records.

3. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The classification of the legal basis of the data stored and processed by Grano listed in Section 2 occurs through analysis of the specific context in which we collect them.

The data processed by Grano tends to be collected only:

• With your consent;
• For a legal or regulatory obligation;
• For the regular exercise of rights in legal proceedings;
• When the processing of personal data is in accordance with Grano’s legitimate interests, always with attention to its interests related to data protection or fundamental freedoms and rights. There will also be a need to process your data to protect your interests or those of third parties.

4. PURPOSE OF DATA COLLECTION

The collection of information has the sole and exclusive purpose of maintaining and improving the services provided to offer you a better experience. In this way, as necessary, the information collected will be used for the following purposes:

• Answer any questions, requests for information about Grano and contact us;
• Transfer of your information to business partners and content providers, when legally authorized and to achieve the specific purpose;
• Improve our Site;
• Transfer to government authorities when the request is made through judicial intimation, court orders or other legal processes to establish or exercise our legal rights or protect our property; to defend against legal claims or as required by law;
• Send you promotional messages, marketing, prospecting, market research, opinion of our services, or our partners.

5. SHARING PERSONAL DATA

When necessary to achieve the purposes described in Section 4, Grano may share your personal data with the third parties listed below, aiming at the correct provision of the services offered, the security of storage of your personal data and a better experience with Grano. Whenever carried out, data sharing will be carried out within the limits and purposes of our business, in accordance with the purpose of the processing of personal data and in accordance with what is authorized by applicable law. In this way, your data can be shared with:

• Software platforms and tools for managing the provision of services offered by Grano;
• Computer service providers, information technology and service providers focused on ensuring the security of information within Grano;
• Marketing and advertising companies and website developers;
• Tax authorities and government, police, public and judicial bodies for the purpose of responding to complaints, investigations, judicial measures and legal proceedings; as well as complying with legal, regulatory and tax obligations.

6. RIGHTS OF PERSONAL DATA HOLDERS

In the form and within the limits of the applicable legislation, you, as holder of personal data, may contact us to exercise your rights, in order to request:

• confirmation of the existence of processing of your personal data;
• access to your data;
• the correction of your incomplete, inaccurate or outdated data;
• the anonymization, blocking or deletion of your data that are unnecessary, excessive, or treated in breach of the provisions of applicable legislation;
• the portability of your data to another service or product provider, subject to commercial and industrial secrets;
• the elimination of your personal data, except in the cases provided for in the applicable legislation, to exercise rights pertaining to Grano and to comply with legal requirements;
• information on public and private entities with which Grano has shared its data;
• information about the possibility of you not providing consent and about the consequences of your refusal;
• the revocation of your consent, when you have provided us, safeguarding the public interest that may justify the continuity of the treatment or the existence of another legal basis that authorizes it; and
• opposition to any processing of personal data based on one of the cases in which their consent is waived, provided that the provisions of applicable legislation have not been complied with and that the public interest that may justify the continuity of the processing has been safeguarded.

Your request can be made through our Privacy Center, available at www.riobrilhantecafe.com. We will analyze your request and deal with it as soon as possible, considering the terms and conditions provided for in the applicable legislation. If it is not possible to respond immediately to your request, we will indicate the factual and legal reasons that prevent us.

Grano is not responsible for the correctness, veracity, authenticity, completeness and updating of the data provided by the Holder, not even for the possible misuse of information published by him or for fraud resulting from the breach of personal passwords.

It is your sole responsibility to provide only correct, true, authentic, complete and updated information, as well as to ensure the confidentiality of your password, when applicable, not disclosing it to third parties.

7. HOW WE STORE AND PROCESS PERSONAL DATA

Rio Brilhante maintains in a controlled and secure environment the personal data collected in order to meet specific purposes, as explained in Section 4. The personal data collected is kept confidential, with strict access control, through authentication mechanisms.

Rio Brilhante adopts security, technical and administrative measures to keep all stored data secure. Specifically with respect to the data collected through our Site, they are stored, processed and protected through the best practices of hosting, processing, backup and encryption, according to their respective criticality.

Even so, the Owner must be aware that no security system on the Internet is guaranteed against unwanted intrusions, and Rio Brilhante’s commitment is limited to the adoption of recommended protection measures according to available techniques.

8. INTERNATIONAL TRANSFER OF PERSONAL DATA

Rio Brilhante may transfer some of your personal data to service providers and partners located abroad, including cloud service providers. When your personal data is transferred out of Brazil by Rio Brilhante, we will take measures appropriate to ensure adequate protection of your personal data in accordance with the requirements of applicable data protection laws, including by entering into appropriate data transfer agreements with third parties where necessary.

9. INFORMATION RETENTION TIME

We store and maintain your information: (i) for as long as required by law; (ii) until the end of the processing of personal data, as mentioned below; (iii) for the time necessary to preserve the legitimate interest of Rio Brilhante, as the case may be; (iv) for the time necessary to safeguard the regular exercise of rights by Rio Brilhante in judicial, administrative or arbitration proceedings. Thus, we will treat your data, for example, during the applicable statute of limitations or as necessary to comply with a legal or regulatory obligation.

The termination of the processing of personal data will occur in the following cases:

1. When the purpose for which the Data Subject’s personal data were collected is achieved and/or the collected personal data are no longer necessary or relevant to the achievement of such purpose;
2. When the Holder has the right to request the end of the treatment and the deletion of his personal data, and does so; and
3. When there is a legal determination in this regard.

Observing the principle of necessity, some data submitted through the Site may be deleted from our records through routine record keeping. We are under no obligation to store personal data indefinitely and we disclaim any liability arising out of or related to the destruction of such personal data.

Upon termination of the processing of your personal data, except in the cases established by applicable law or by this Privacy Policy, they will be deleted from Rio Brilhante’s database. If deletion is not possible in the first instance, the data will be securely stored and isolated from further processing until deletion is possible.

10. TERM AND POLICY CHANGES

Our Site, in its entirety or in each of its tabs and sections, may be unilaterally terminated, suspended or interrupted by Rio Brilhante, at any time, and without need for prior notice, in which case we will inform you where the information contained therein will be made available, which access is your right in accordance with the legislation in force.

This Privacy Policy may be updated or changed at any time, with the changes being prominently informed on our Site.

11. COMMUNICATION POLICY

We seek to prevent the sending of unsolicited emails by restricting communications with you to matters that are relevant or of particular interest to you.

When you register, we can contact you through the means of communication informed there.

If you prefer not to receive any more information from us, you can request to unsubscribe through the unsubscribe link contained in the email or in the message received (opt out), or request through our Site.

You should be aware that many fraudsters try to use traditional brands to obtain personal information such as passwords and financial data. Rio Brilhante WILL NEVER REQUEST YOUR PASSWORD AND/OR FINANCIAL DATA THROUGH E-MAIL OR TELEPHONE CONTACT. IN THE EVENT OF ANY OTHER SUSPECTED ATTITUDE, SEND YOUR QUESTION OR ALERT BY E-MAIL TO dpo@grupofarroupilha.com.

12.  CONNECTIONS (LINKS) TO OTHER SITES

Our Site may contain links or frames from other sites. These links or frames seek to provide additional benefits to the content and services offered to the User.

We clarify that the inclusion of these links on our Site does not mean that Rio Brilhante is aware of, agrees with or is responsible for the content of these links and frames. It is important to emphasize that our objective is to only provide links or frames of reputable and trustworthy companies, and Rio Brilhante is not responsible for the information, products and services obtained by the User on these sites, nor for the commercial practices and privacy policies adopted by these companies, and Rio Brilhante cannot be held responsible for any losses and damages or loss of profits suffered as a result of the use of these resources.

To the extent that the linked sites are not part of our Site, we do not control, recommend or endorse those sites and their content, products, services, policies and their privacy practices; we do not have access to their personal data collected and processed by them and their advertising policies, cookies and terms of use. Therefore, we recommend that you carefully read these documents from third party sites.

By accessing our Site and interacting with us, you agree and accept the terms set forth herein.