The following is the Minerva S/A Privacy Notice. We respect your right to privacy and we safeguard your personal data.
We have outlined below our personal data collection, use, and sharing practices. To fully understand your rights, we recommend that you read this Privacy Notice.
Please note that through the use of this website, contract services, enter into a partnership, become a collaborator or investor, you acknowledge that you are expressly aware of this Privacy Notice. If you do not agree or are not comfortable with any aspect of this Privacy Notice, you may at any time exercise your right as a data subject to object to this data handling. We reserve the right to modify this Privacy Notice at any time. Therefore we recommend that you review it as often as possible.
PRIVACY AND DATA PROTECTION
Minerva S/A fully respects your right to privacy and endeavors to protect your personal data in accordance with current legislation. To this end, all personal information about you is handled by Minerva S/A with complete transparency and based on applicable legal provisions.
Whenever you use this website, contract services, enter into a partnership, become a collaborator or investor, your personal data will be used as described in the chapter “Collection and Use of Personal and Sensitive Data”. Please note, however, that in the event that your personal data is collected or shared, it will be used only for lawful, clear and timely informed purposes, allowing you to clearly understand what will be done with your information.
COLLECTION AND USE OF PERSONAL AND SENSITIVE DATA
The following information may be collected, used and stored according to a specific purpose and justified legal basis pursuant to the relationship Minerva S/A has with each type of data subject that establishes a relationship with Minerva S/A. Data may also be collected regardless of the method, whether online, offline, or by phone, as detailed below:
- Personal contact information – This includes any information that the User provides that allows Minerva S/A to contact him/her, such as full name, postal address, e-mail, social network details or telephone number.
- Account login information – QAny information that is necessary to grant the User access to the specific account profile, for example but not limited to e-mail address, username, password in irrecoverable format and/or security question and answer.
- Demographic information and interests – Any information that describes demographic data or behavioral characteristics of the User. Examples include but are not limited to date of birth, age or age range, gender, geographic location, family or lifestyle information.
- Technical information about the computer/mobile device utilized by the User – Any information regarding the computer system or other electronic device that is used by the User to access one of the Minerva S/A websites, such as IP address used to connect a computer or device to the Internet, type of operating system and web browser version and type In addition, Users’s mobile device information, as permitted, unique device phone ID, advertising ID, geographic location and other similar mobile device data.
- Website/Communication Usage Information – As the User browses and interacts with Minerva S/A websites, Minerva S/A uses automatic data collection technologies to capture specific information about the user’s actions. This includes, but is not limited to, information on which links are clicked, pages or content viewed and time spent, likewise statistical information about interactions with the tool, such as content response times, download errors and length of visits to particular pages. This information is captured using automated technologies such as Cookies (Browser Cookies, Flash Cookies). You may object to the use of such technologies
- Market research and consumer feedback – This includes information that the User voluntarily shares with Minerva S/A, regarding their experiences in using the products and Services.
- User-generated content- – Refers to any content that the User creates and shares with Minerva S/A by means of physical or electronic upload (uploads to websites or e-mail).
- Financial and payment information – Any information, such as debit or credit card data (cardholder’s name, card number, expiration date, etc.) or other forms of payment (if available), that Minerva S/A requires to provide Services, make payments to employees and suppliers, and profit distribution. In all cases, Minerva S/A or its payment processing service providers handle financial and payment information in compliance with applicable laws, regulations and security standards. Minerva S/A will also carry out public consultations with credit protection agencies for enrollments.
- Teleservice calls – Communications with Teleservice may be recorded or listened to, in accordance with applicable law, for local operational needs such as quality assurance audits or training. Where required by law, the User will be informed when recording is carried out at the start of the call.
- Sensitive Personal Data – Concerning employees, Sensitive Personal Data may be collected when necessary to comply with labor practices, such as health plan payments negotiated through union collective agreements. Furthermore, children’s data may also be collected for the same reason as described above, with prior authorization from the authorized parent (employee).
Below is a data table, legal basis, objective and types of users of some of the handling examples carried out by Minerva S/A:
|User Type||Data Used||Intended Use||Legal Basis|
|Employees||Name; RG; CPF; Complete address; PIS number; CNH number; Voter ID number; Bank information (agency and account); Health plan financial history; Spouse’s name; Marital status; Nationality; Place of birth; Reservist number; Education; CTPS number; Image; Fingerprint biometrics; Sex; Self-declared ethnicity; Voice; IP; Geolocation; e-mail; telephone; occupation; date of birth.||Collective bargaining compliance; e-social registration; employment contract fulfillment; company security; work activity development; income tax declaration; digital signature; payment of union dues.||Fulfillment of legal obligation; legitimate interest; fulfillment of contract; exercise of legal rights.|
|Job Applicants||Name; ID; CPF; Complete address; PIS number; CNH number; Voter ID number; Reservist number; Education; employment history; self declared PCD.||Participation in job selection process; maintenance of interim file for job interview.||Contract fulfillment.|
(Individuals and Legal Representatives)
|Name; RG; CPF; Full Address; Financial Data (Branch and Account); Marital Status; Nationality; Voice; IP; Geolocation; E-mail; Telephone; Occupation; Gender; Date of Birth; Credit History.||Contractual fulfillment; company security; Digital Signature; financial/tax statements; browsing data; customer service; target surveys; credit analysis; due diligence.||Compliance with legal obligation; legitimate interest; contract fulfillment; consent*; credit protection.|
|Vendors and Service Providers (Individuals and Legal Representatives)||Name; RG; CPF; Full Address; Financial Data (Branch and account); Marital Status; Nationality; Voice; IP; Geolocation; e-mail; telephone; occupation.||Contractual fulfillment; company security; Digital Signature; financial/tax statements; browsing data; carrying out due diligence; background analysis.||Fulfillment of legal obligation; legitimate interest; contract fulfillment; consent*.|
|Investors||Name; e-mail; relationship profile; company represented.||Information via e-mail.||Consent*.|
|Children and Adolescents
( Employee Dependents)
|Name; RG; CPF; Complete address; Parents’ names; Health plan financial history; Date of birth.||Fulfillment of the parent’s collective agreement; Payment processing.||Normal application of rights, according to the contract.|
* To best serve our clients, consumers, investors and suppliers, Minerva gathers personal data upon legal basis of consent through your registration on the Contact Us page (or Mailing List in the case of investors). This data is used to promote products and services, and for promotional purposes based on your preferences and with authorization. You may withdraw your consent directly via the emails you receive, by clicking on the unsubscribe link at the bottom of the page.
Your information may also be used to perform surveys via call, text message or e-mail, based on a legitimate interest, in order to improve the services provided. This information may also be used to reply to any requests or inquiries you submit through our channels, or to notify you of any transactional issues, such as details of a Minerva service contract or information on open protocols, in which case use will be based on the existing contractual or pre-contractual relationship with the company.
From time to time Minerva S/A may use the data to comply with legal stipulations or for administrative actions before regulatory agencies, subject to case-by-case analysis and within the limits of the need and purpose of the situation.
All personal data requested is held in a confidential and secure format and will not be used for any purpose other than those described above. Minerva S/A regards all individuals as equal and does not carry out any data processing that may result in discriminatory acts or persecution of the data subject.
For data processing activities in which we rely on consent as the basis for processing your data, you have the right to revoke your consent at any time.
For processing activities based on legal or contractual requirements, you may request for your data to not be processed for this purpose. However, this is by no means an absolute right and may be superseded by our statutory obligations. In other cases, requesting that data not be processed for a specific purpose may obstruct the execution of a contract or the provision of a service to you.
You also have the right to request:
- A copy of what data we maintain about you (Right of Access);
- To have any errors in the data we maintain about you corrected (Right to Rectification);
- Deletion of your data except in cases in which we are required to retain it, subject to the transparency and security of your personal data retained (Right of Exclusion);
- Stop processing for specific purposes (Right to restrict processing);
- A copy of your personal data in a structured, commonly used and machine-readable format that allows you to re-use your personal data for your own purposes across different services (Right to Data Portability);
- If ever a decision is taken based on your data using artificial intelligence, you may request that this process be re-evaluated by a person. Concerning this right, Minerva S/A informs that the final result may be the same, however a technical reasoning will be provided regarding the decision (“Right to Review Automated Decision);
All requests, provided they are understood, will be answered within 15 calendar days of receipt. If the request is not understood for any reason, clarification of the request will be solicited, in which case the deadline will begin to run from the time of the clarification request. All replies shall include an explanation of reasons, so that in the event of partial or no response is given, you will still be informed accordingly.
Please send all requests by email to the Data Protection Officer in writing to firstname.lastname@example.org
We reserve the right to ask you to provide additional information in order to allow us to reliably authenticate your identity.
WHO DO WE SHARE YOUR INFORMATION WITH
We do not share your information with third parties beyond those stated in this Notice. We may share your information under the following circumstances:
Consent: Your information will be shared with those third parties for which you have given permission;
We may at times share information about our suppliers and service providers with clients for the purpose of performing risk management and sustainability audits, due diligence or compliance audits.
Regulatory and Inspection Agencies: We may, from time to time, share your information in compliance with a regulatory standard or law that requires compliance, such as data provided to the Brazilian Internal Revenue Service. In the event this information must be shared, the data subject will always be presented the legal norm that requires such compliance.
WHERE PERSONAL INFORMATION IS STORED
Generally, all personal data is stored on our servers located within Brazil. However, in some circumstances, it may be necessary for us to transfer certain information to servers located outside of Brazil. You should be aware that privacy protections in certain jurisdictions may not be equivalent to those in Brazil. We only transfer your personal information to storage facilities outside Brazil where legal safeguards ensure that it is subject to adequate levels of protection under Brazilian law for personal data protection.
Data retention is the filing or storage of personal data regardless of the medium used, whereby the duration varies according to the purpose for which the data is used. Minerva S/A retains personal data only for the duration necessary to meet specific purposes and in accordance with applicable legal and regulatory obligations.
We guarantee that we will not keep personal data for any longer period than strictly necessary and will periodically review our registries.
COOKIES USED ON OUR WEBSITES
A cookie is a small file consisting of letters and numbers that is placed on your computer or other device. The cookies used by this Site are referred to as “necessary” or “essential” cookies, allowing you to navigate this Site and use its services and features. Without these strictly necessary cookies, the Site will not function as smoothly as desired, as a result it may not be possible for us to provide certain services or features associated with the Site.
Minerva S/A utilizes other Cookies in addition to those that are deemed essential or necessary, such as:
- Session cookie – used to identify a specific visit to our site. These are cookies that expire after a short period of time or once you have closed your browser having used our services;
- Persistent cookie – remains on your devices for a period of time specified in the cookie. We use these cookies where it is necessary to be able to identify you over an extended period of time;
These Cookies are used for the purposes of:
We may occasionally use “third party cookies,” i.e., cookies that are set by software or other third party owned platforms to, for example, perform statistical analysis of page usage, page interactions and site paths, or for the purpose of delivering Internet advertisements using an online advertising vendor. Third party cookies may collect information about your online activities over time and across different websites after you visit our Sites.
Typically, the information collected as a result of using these Web technologies will not identify you by name. However, if you have created a user ID, for example, by signing up to access a password protected area on one of our Sites, we may link the information we collect using Web technologies to other information that personally identifies you.
Some features of our services may not work or will not be able to work properly without cookies. As a result, changing your browser settings to reject cookies may have a negative impact on the experience of using our site.
(a) discontinue your visit to our site.
(b) use the settings described above to reject cookies.
You can find out more about deleting and blocking cookies using the “Help” feature in your browser.
We take our responsibility for security seriously, employing the most effective physical and technical measures. Our security policy is reviewed on a regular basis.
APPLICABLE LAW AND JURISDICTION
This Privacy Notice and all divergences therefrom are governed exclusively by Brazilian law and are subject to the exclusive jurisdiction of the Brazilian courts.
CONTACT THE DATA PROTECTION OFFICER (DPO)
If you have any questions regarding this Privacy Notice, our practices concerning the use of your personal data, or if you wish to exercise any of your rights as a data subject, please contact our Data Protection Officer, Alexandre Rocha Valeriano, by e-mail at email@example.com or by telephone at +55 17 3321-3355.
CHANGES TO THIS PRIVACY STATEMENT
We regularly review our privacy notice. This privacy notice was last updated on September 20, 2022.