ROYAL CICLO INDÚSTRIA DE COMPONENTES LTDA, with its registered office at Estrada Blumenau, No. 5,564, Bela Aliança, Rio do Sul, SC, ZIP code 89,161-260, registered under CNPJ No. 00.637.261/0001-17 ("ROYAL" or "We"), understands that respecting peoples privacy is important and seeks to ensure compliance and adequacy with Law No. 13.709/2018 (General Data Protection Law or LGPD).
Royal is committed to preserving the privacy and security of personal data of all natural persons with whom we interact, primarily our customers, suppliers, partners, service providers, and employees ("Users," "You," or "Data Subjects").
Therefore, ROYAL presents the Privacy Policy ("Policy") with the aim of clarifying how it handles personal data and ensuring ways for Data Subjects to exercise their rights, etc. Our employees are also ensured the transparency provided for in the LGPD in a separate document available internally with our Data Protection Officer.
It is very important that you read and fully understand this Privacy Policy, and if you have any questions, please contact us for further clarification through the channels provided at the end of this document.
Database: A structured set of personal or anonymized data, located in one or more locations, in electronic or physical form;
LEGAL BASES: Hypotheses provided for in the LGPD that authorize the processing of personal data, such as consent, contract performance, compliance with legal obligations, etc.
CONSENT: The free, informed, express, and unequivocal manifestation by which the USER agrees to the use of their personal or anonymized data
CONTENT: Any information, data, communications, software, photos, videos, graphics, music, sounds, and other materials and services that can be viewed by USERS on ROYALs websites, platforms, and related entities. This includes messages, conversations, chat, and other original content;
CONTROLLER: A natural or legal person, public or private, responsible for decisions regarding the processing of personal data. For the purposes of this Policy, ROYAL will predominantly act as the Controller
COOKIES: Cookies are small text files containing a string of characters that can be stored on your computer or mobile device and uniquely identify your browser or device. We may use technologies such as cookies, pixels, and local storage to deliver, protect, and understand products, services, and advertisements;
PERSONAL DATA: Information related to a natural person capable of identifying or making them identifiable. Example: Name, CPF (Brazilian ID), image, RG (Brazilian ID card), address, etc.;
SENSITIVE PERSONAL DATA: Data of Data Subjects related to racial or ethnic origin, religious beliefs, political opinions, membership in a union or religious, philosophical, or political organization, health or sexual life data, genetic or biometric data, etc.;
Data Protection Officer: A person identified as our channel of communication with Data Subjects and the National Data Protection Authority (ANPD) with respect to data protection and privacy under the LGPD;
IP (Internet Protocol): A set of numbers that identifies the USER'scomputer on the Internet;
LOGS: Records of USER activities performed on ROYAL's PLATFORMS;
DATA MESSAGES: Information generated, sent, received, stored, or communicated electronically, optically, or by similar means. For example: registration forms, Electronic Data Interchange (EDI), Internet, email, chats, and other communication methods;
OPERATOR: A natural or legal person, public or private, that processes personal data on behalf of the controller;
PLATFORMS: All websites, e-commerce platforms, offered or used by ROYAL. You can check the privacy policies of these Platforms to better understand how your data is processed there;
DATA SUBJECT: Any natural person identified or identifiable to whom the processed Personal Data relates.
PROCESSING: Refers to any and all operations involving Personal Data, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, deletion, evaluation, or information control, modification, communication, transfer, dissemination, or extraction, among other processes, involving personal data carried out by ROYAL.
As a rule, ROYAL will act as the Controller of the personal data under its power, and in some cases may share them with other controllers or Operators, as explained further below. The Personal Data Processed by ROYAL can be classified by origin as:
Data Provided by the data subject: Data provided by You when you use our platforms, visit our stores and factories, purchase products, or fill out forms with us.
Data collected or generated by our Platforms: In this category are all the information we will generate or collect about you indirectly (in the background or through third parties) whenever you interact with the website, including background-collected browsing information, usually through cookies. Further information on Cookies will be provided in a specific section below in this policy.
| When does the processing occur?? |
What data is processed? | For what purposes? |
|---|---|---|
| Registration and use of our Platforms |
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| Purchase orders and related activities |
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| Marketing and Advertising |
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| Communications (Customer Service, Delivery, etc.) |
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| Sponsored Athlete Registration |
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Data Provided by Job Applicants, Independent Sales Representatives: When you apply for a job or become a product representative for ROYAL, your data will be processed as follows:
| When does the processing occur? |
What data is processed? | For what purposes? |
|---|---|---|
| Job Applicants at ROYAL Companies |
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| Purchase Orders and Related Activities |
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| Marketing and Advertising |
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ROYAL may also share with third parties, always under its supervision, the personal data listed above in the following cases:
1. Anti-fraud and credit analysis: We may share data such as CPF, email, telephone, etc., with specialized companies, to analyze the customers purchasing profile, confirm the Owners identity and verify the veracity of the data provided when registering on the Platforms, in order to avoid fraud. ;
2. Logistics and Delivery: During the logistics management procedure for the delivery of goods, we may share data such as name, address, email and telephone number with transport companies that partner with ROYAL or with online platforms and/or delivery and transport applications;
3. Advertising and marketing: With marketing companies, to develop campaigns and forward materials to Holders, as well as with analytics tools, such as Google;
4. Advertising and marketing: Other shares: Enable compliance with contracts signed between Holders and ROYAL, through bill generation, billing, ISO certification companies, law firms, notary offices, auditing, customer service, accounting, etc.;
5. Management of Online Platforms: We may also share your data with development and hosting companies, to manage and maintain the computing infrastructure that ensures the functioning of our platforms;
6. With public bodies or private bodies: When performing a typically public activity to comply with a legal determination or obligation, such as information shared with Detran when transferring vehicles, with tax agencies, when responding to legal requests, for example;
ROYAL may carry out international data transfers to other countries, such as the United States of America and to countries in the European Union and Latin America, in order to carry out some of the activities involved in the services provided to you, as well as to obtain information that can contribute to the improvement of our services.
In any case of sharing with partners located in other countries, we contractually establish that the partner has the duty to maintain the standard of data protection and information security compatible with this privacy policy, as well as law 13,709/2018, in order to that your data is always protected under these terms.
By emailing [email protected] the User may request:
Confirmation of the existence of treatment;
access to your personal data processed by ROYAL;
correction of incomplete, inaccurate or outdated data;
anonymization, blocking or deletion of unnecessary, excessive or processed data that does not comply with the provisions of the LGPD;
data portability to another service or product provider, subject to commercial and industrial secrets;
information from public and private entities with which ROYAL shared data use;
revocation of consent (when the processing is based on this legal hypothesis);
request the review of decisions made solely on the basis of automated processing of personal data that affect your interests, including decisions intended to define your personal, professional, consumer and credit profile or aspects of your personality.
We will respond to your request within the legal deadline. However, if there is a legal basis, some requests may be partially met or even denied, in which case we will provide the necessary clarifications and justifications.
Your personal data described above will be kept by ROYAL or authorized third parties for as long as necessary to fulfill its purposes, that is, the storage period is not unique in such a way that it depends on what is necessary to fulfill its purposes. , in addition, your data will also be maintained: (i) in the event of legitimate interest, as legally defined; and (ii) when law or public authority so determines.
The maintenance of data after the termination of a contractual relationship will be carried out, whenever possible, in an anonymized manner, that is, without the data allowing its holder to be identified.
Do not provide information such as bank or financial passwords via email or other messaging applications (e.g. WhatsApp, Telegram, etc.);
Communicate to ROYAL any and all suspected or confirmed violations of this Policy, such as the misuse of your personal data by third parties;
Consult ROYAL whenever you receive information or communications about promotions, campaigns and surveys received by email, to verify their veracity;
Provide ROYAL with true and complete information and always keep it updated;
If you wish to exercise any right in relation to your personal data, contact ROYAL by email [email protected];
Adopt cybersecurity measures on functional devices when interacting with the website, such as using strong passwords and periodically changing them; updating antivirus, firewalls and others;
Refrain from interacting with ROYAL through any form of illegal processing of third party personal data;
For any matters related to the processing of personal data carried out by you, ROYAL may be contacted as your Personal Data Protection Officer:
Name: Karina Ketlen Hobus Censi
Phone: 47 3531-5700
Email: [email protected];
Any controversial issues arising from this Policy will be submitted to the competent jurisdiction of the District of Rio do Sul – SC.
This Policy was published on November 14, 2023 and may undergo updates that will be widely communicated by ROYAL.