DATE OF LAST UPDATE: March 10, 2021.


We, from TTG Brasil, are committed to safeguarding your privacy and protecting your personal data. We want to explain to you a little more about how we process such data.

Why does TTG process my personal data?
TTG is committed to always offering the best services, believing in the power of choice of our customers and suppliers. When it comes to personal data protection, there is not only respect and responsibility towards the safety of your data and respect for your privacy, but also our commitment to you being in control of your personal data.

We collect your personal information mainly to provide the contracted services. For doing it, we collect the data you send for registration in our Systems, or when you contact or interact with us, through our employees or contact channels.

These are just a few examples that show how our activities need to use personal data in a legitimate way and within your expectations. We take protection of your data seriously, and this policy describes how it is collected, used, shared and stored. If after reading this Policy you still have questions, feel free to contact us. For a better understanding of the terms used in this policy, please read item 8 - “Basic Concepts”.
Contact channel
Email: sh-privacidade@ttgbrasil.com

1. HOW DOES TTG COLLECT YOUR PERSONAL DATA AND WHAT KIND OF DATA IS COLLECTED?


The kind of Personal Data and the way TTG collects it depend on how you relate to us and why.

To learn more about what data and its respective purposes, see our Personal Data Table provided below, where you can identify, according to your reality, how your data is processed by us.

If you have any questions about this point, feel free to contact us through the channels indicated in this Policy, so we can explain you more about how, when and why we use Personal Data.

Origin

Contracts

Legal Base


Contract signing and legal obligation compliance.

Credit protection and consent

Catho (application platform)

Consent
We do not intend to directly collect Personal Data from children or adolescents except with the specific and clear consent of their parents or legal guardians.

2. WITH WHOM DOES TTG SHARE YOUR PERSONAL DATA?

Sometimes we need to share your Personal Data with third parties that provide services on our behalf. This is the case, for example, of services we hire for hosting our databases or for audits. Below we describe some situations, within the context of TTG, in which we may share your Personal Data:

Our suppliers. We can use the help of suppliers who can process Personal Data we collect. We always seek to carefully evaluate our partners and enter into contractual obligations to protect Personal Data and information security, aiming at minimizing risks to Data Holders.

Analytics. Data stored by TTG may be used for statistical purposes (analytics), so that TTG can better understand the customers using our Services, as well as the suppliers providing some service to us. Such data are pseudonymizable and do not seek to identify or make Personal Data Holders identifiable, but only to better understand the profile of customers and suppliers, in order to improve our performance and customize products more aligned to your interests.

Public authorities. We have to comply with the laws. Thus, if an authority with legal powers for it, such as the Public Prosecutor's Office or Environmental Bodies, requires TTG to provide given Personal Data for, i.e., meeting regulatory needs, we need to share such information. We are against any abuse of office and, if TTG understands that a particular order is abusive, we will always privilege your privacy.

Protection of rights. In addition, we reserve the right to share any Personal Data we believe is necessary for meeting a legal obligation, enforce our Terms of Use, or protect TTG's rights, our employees and customers.

Affiliated companies. We may share information with other parts of TTG, for the specific purpose of providing its services or other legitimate interests, if applicable. This processing is always carried out according to our instructions and complying with our Privacy Policy and all other appropriate safety and secrecy measures.

We make efforts to protect your Personal Data, but unfortunately, we cannot guarantee the correct processing of such information by third parties, who use, disclose and protect Personal Data according to their respective Privacy Policies.

If you have any questions regarding the identity of these companies or our suppliers, feel free to contact us through the channels indicated in this Policy.

3. DOES TTG TRANSFER PERSONAL DATA TO OTHER COUNTRIES?

As mentioned in the item above, we may share your personal information with TTG employees, representatives and affiliated companies or partners based in and out of your country of residence, to provide TTG services to you. We may, for example, transfer your Personal Data to the company responsible for hosting our databases, whose headquarters are abroad.

These transfers encompass only companies showing compliance with applicable data protection laws and maintaining a compliance level similar or stricter than that provided for in the applicable Brazilian laws. In addition, the Data transferred may only be processed under the terms of this Policy and TTG's corporate rules for the provision of our Services or performance of the company's purpose.

If you have any questions regarding the identity of these companies, feel free to contact us through the channels indicated in this Policy.

4. WHAT ARE YOUR RIGHTS AS A PERSONAL DATA HOLDER?

The Personal Data is yours and Brazilian law guarantees you have different rights related to it. We are committed to the fulfillment of these rights and, in this section we will explain how you can exercise them with TTG. Brazilian law guarantees you the following rights:

Confirmation and Access: It allows you to check that TTG process your Personal Data and, if so, request a copy of such information we have about you.

Correction: It allows you to request the correction of your incomplete, inaccurate or outdated personal data.

Anonymization, blocking or deletion: It allows you to ask us to (a) anonymize your data, so that it can no longer be related to you and therefore cease to be Personal Data; (b) block your Data, temporarily suspending our ability to process it; and (c) delete your Data, when we will delete all your Data without the possibility of reversion, except in the cases provided for by law.

Portability: You have the right to ask, upon express request, TTG to provide you, or a third party of your choice, with your Personal Data in a structured and interoperable format, for transfer to another service or product provider, provided that it does not violate the company's intellectual property or business secret.

Sharing information: You have the right to know the public and private entities with which TTG uses shared data. We will keep the list of the kinds of partners with which we share Data in this Policy always up to date. In any case, if you have questions or want more details, you have the right to ask us for this information.

Information about the possibility of not giving consent: It allows you to have clear and complete information on the possibility and consequences of not giving consent. Your consent, when necessary, must be free and informed. Therefore, whenever we ask for your consent, you will be free to deny it - even if, in such cases, we may have to limit our Services.

Consent revocation: You have the right to withdraw your consent for processing activities that are based on consent. However, it will not affect the legality of any previously performed processing. If you withdraw your consent, we may not be able to provide certain Services, but we will notify you when this occurs.

Opposition: The law authorizes the processing of Personal Data even without your consent. If you do not agree with such processing, in some cases, you can oppose it by requesting an interruption.

WHENEVER YOU EXERCISE YOUR RIGHTS, TTG MAY REQUEST SOME ADDITIONAL INFORMATION FOR THE PURPOSE OF CHECKING YOUR IDENTITY, AIMING AT PREVENTING FRAUDS. WE DO THIS TO ENSURE THE SAFETY AND PRIVACY OF USERS OF OUR SYSTEMS AND OF THOSE WHO CONTACTED US BY E-MAIL OR PHONE, FOR EXAMPLE. BESIDES, SOME COMPLEX REQUESTS MAY NOT BE RESPONDED IMMEDIATELY, BUT TTG UNDERTAKES TO RESPOND TO ALL REQUIREMENTS WITHIN A REASONABLE TERM AND ALWAYS IN COMPLIANCE WITH APPLICABLE LAW.

If you have any questions on these issues or on how you can exercise these rights, feel free to contact us through the channels indicated in this Policy.

5. HOW LONG WILL PERSONAL DATA BE STORED?

Your Personal Data is stored only for as long as it is necessary to meet the purposes for which it was collected, unless there is any other reason for keeping it, for example, compliance with any legal, regulatory, contractual obligations, among others, provided they have grounds on a Legal Basis.

Keep in mind that, whenever possible, we will consider your right to request the deletion or opposition to data processing, as described in item 5 above.

6. WHAT ARE OUR RESPONSIBILITIES AND HOW DO WE PROTECT YOUR PERSONAL DATA?

Our responsibility is to take care of your Personal Data and use it for lawful purposes, as described in this Policy. And in order to guarantee your privacy and the protection of your Personal Data, we have adopted the safety practices suitable for our market, including:
  • controls and privileges of access to Personal Data, so that each employee can only access data strictly necessary for the performance of their duties; and
  • preventive control and monitoring of security incidents, including data leakage, carried out by our Information Security team and by automated tools acknowledged by the market.

We work to protect your Personal Data, but unfortunately, we cannot guarantee complete safety.

Unauthorized use by third parties, hardware or software failure not under TTG Brasil's control and other factors may compromise the safety of your Personal Data. For this reason, its performance is fundamental for keeping a safe environment for all. You can help us by adopting good security practices regarding your data (such as, for example, not sharing passwords with third parties), and if you identify or become aware of something that compromises the safety of your data, please contact us through our Person in Charge (Data Protection Officer), whose contact channels can be found below.

7. HOW TO TALK ABOUT PERSONAL DATA WITH TTG?

If you believe your Personal Data has been used in a way incompatible with this Privacy Policy or with your choices as the Holder of such data, or if you have any questions, comments or suggestions related to this Policy, please contact us. We have a Person in Charge (Data Protection Officer - DPO) who is available through the following contacts:

Person in Charge (DPO): Camila Scardova Menezes
Mailing address: Av Brigadeiro Faria Lima, 3477, 11º andar – 04538-133 – Itaim Bibi – São Paulo - SP
Email para contato: sh-privacidade@ttgbrasil.com

8. BASIC CONCEPTS: WHAT DO I NEED TO KNOW IN ORDER TO UNDERSTAND THIS POLICY?

In order to make your reading easier, we present some useful definitions for your interpretation:

LGPD: LGPD is the General Personal Data Protection Act. The act brings new rules and more protective principles for companies to process information from individuals, including you. The purpose of the act is for you to have more privacy, freedom, transparency and control over your personal data used by third parties.

Personal Data: It is the data relating to an individual, who is able to identify them or make them identifiable within a given context. The following are some examples of personal data: name, taxpayer registry, identity card, address, cell phone, email, IP address etc.

Sensible Data: It is any information about racial or ethnic origin, religious conviction, political opinion, membership at a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to an individual.

Processing: These are the purposes for which TTG uses of Personal Data, including, but not limited to, the following activities: collection, storage, consultation, using, sharing, classification, reproduction, processing and evaluation of such data.

Legal Base: It is the legal hypotheses authorizing TTG to process Personal Data: it may be your consent or meeting a legal obligation, for example.

Consent: It is the hypothesis authorizing the processing of Personal Data based on free, aware and unequivocal statement by the Holder when agreeing to the processing of their Personal Data for a specific purpose and informed by TTG.

Legal Interest: It is a Legal Base, as defined above. It authorizes processing of your data (even without your consent), whenever the use of such data is necessary to serve the legal interests of TTG or third parties. In the context of using marketing cookies, for example, we may use your Personal Data to offer advertising tailored to your interests. The Act sets that interests will only be considered legal if the way in which your data is used is not contrary to Brazilian laws and as long as there is effective transparency of such uses, as well as your rights are respected.

TTG or TTG: TTG Brasil Investimentos Florestais Ltda., limited liability company headquartered at Av. Brigadeiro Faria Lima, n.º 3477 – 11° Andar – Itaim Bibi – CEP 04538-133 – São Paulo – SP, enrolled with CNPJ/ME under no. 09.142.841/0001-08 and companies managed by TTG.

Data Holder: It is you: the individual referred to by the Personal Data, who can be a customer, employee, or user of our Systems.

System or Systems: They are websites, platforms and the applications of TTG owned by TTG.

Services: These are all services offered by TTG, with a financial and banking focus, including insurance, pension plans, brokerage, checking account.

Policy: It is this TTG's Privacy Policy.

9. CHANGES TO THE PRIVACY POLICY

As we are always looking to improve our Systems and Services, this Privacy Policy may undergo updates to reflect the improvements made. Therefore, we recommend that you visit this page periodically so that you are aware of the changes made. If relevant changes are made, we will inform you.

WHAT IS THE SCOPE OF THIS POLICY?
This TTG Brasil's data protection policy is extendable to all companies under its management.