PRIVACY POLICY

he purpose of this Data Privacy Policy (“Policy”) is to demonstrate the commitment of South Cargo do Brasil Transportes Internacionais Ltda.l, a legal entity governed by private law, regularly registered with the CNPJ under No. 22.863.181/0001-1, headquartered at Rua Eng. Luiz Berrini, n. 1500, Conjunto 131/132, São Paulo/SP, hereinafter referred to simply as SOUTH CARGO, with the privacy and protection of personal data collected in the development of its activities, establishing rules and guidelines for carrying out data processing operations and making public its rules on collection,  recording, storing, using, sharing, enriching, and deleting data in accordance with the provisions of Law No. 13,709/18 (General Data Protection Law – LGPD). 

1. OBJECTIVE

The document aims to meet the legal requirements related to personal data processing operations in order to ensure the legality of internal procedures. 

2. APPLICABILITY

This Policy is intended for all personal data subjects, including customers, employees, visitors, business partners, third parties or service providers, senders, recipients, job applicants, and other data subjects who are interested in our services.

3. GLOSSARY

Personal data: information related to the identified or identifiable natural person.

Sensitive personal data: personal data on racial or ethnic origin, religious conviction, political opinion, membership in a union or organization of a religious, philosophical or political nature, data related to health or sex life, genetic or biometric data, when linked to the natural person.

Holder: natural person to whom the personal data refers.

Controller: person who is responsible for decisions regarding the processing of personal data.

Operator: person who processes personal data on behalf of the controller.

Person in charge: person appointed by the controller and operator to act as a communication channel between the controller, the data subjects, and the National Data Protection Authority (ANPD).

Processing: any operation carried out with personal data (such as collection, reception, use, access, reproduction, storage and deletion, among others).

Blocking: temporary suspension of the processing operation, by keeping personal data or the database.

Deletion: deletion of personal data stored in a database.

National Data Protection Authority (ANPD): public administration body responsible for ensuring, implementing, and supervising compliance with the LGPD.

4. WHAT PERSONAL DATA WE COLLECT

For the regular development of our activity, we collect personal data from our customers and legal representatives, employees, visitors, third parties or service providers, always respecting the principles of the General Data Protection Law, such as data minimization, purpose and transparency.

Within this concept, we collect and process the following personal data:

Data Category	Collection Method	Category Description
Customer data	Information provided by the holder	These are personal data of the legal representatives and/or employees of our clients, provided by the holder himself. This data is necessary to establish a contractual relationship between the parties. The category includes, among others, the full name, nationality, address and official document numbers.
Data of candidates and/or employees	Information provided by the holder	These are the personal data provided by the holder or collected during the selection process or at the time of hiring. The category includes, among others, the full name, age, address, telephone number, gender, official document numbers and professional history.
Employee performance data	Information produced within the scope of the Employment Contract	These are personal data produced by South Cargo, together with the employee, regarding their performance. The category includes, among others, attendance control, evaluations, vacations, benefits, labor and social security complications, promotions, warnings and the employee’s entire history.
Employee financial data	Information provided by the holder	These are personal data provided by the data subject in relation to the fulfillment of contractual and financial obligations to employees. The category includes, among others, bank details, remuneration history, form of compensation of remuneration, nature and components of remuneration.
Employee health data	Information provided by the holder	These are personal data provided by the holder regarding the employee’s health. The category includes, among others, admission, periodic and dismissal exams, visits to the ward, pathologies, medical certificates, medical reports, absences and leaves justified for health reasons.
Third-party data	Information provided by the holder	These are personal data provided by the holder in relation to the execution of various services on South Cargo’s premises, such as registration of visitors, commercial representatives, participation in events. The category includes, among others, the full name, official document numbers, address, e-mail and telephone number.
Sender Data	Information provided by the sender itself or its collaborators	Shipper’s contact details, preference or delivery method and shipment details
Recipient Data	Information provided by the recipient to the sender	Contact details and delivery address of the recipient.

5. WHY DO WE USE YOUR DATA?

1. To provide services to you
2. To communicate with you 
3. To comply with our legal and regulatory obligations

Personal data is collected for the purpose of identifying our customers, employees and other data subjects, assisting in the management, administration, service, expansion and improvement of our products and services.

Personal browsing data on our website is also collected  through cookies. The data collected in this way may involve information about the holder’s device, geolocation data, access logs to the internet application (such as IP, date and time), time of use of the platform, duration of access, clicks and terms searched, upon consent of the holder in our banner.

As circumstances require, personal data may also be collected for (i) health protection; (ii) credit protection; (iii) legitimate interests or any other hypothesis provided for in article 7 of Law 13,709 of 2018.

6. HOW WE PROTECT PERSONAL DATA

Our responsibility is to take care of your personal data and use it only for the purposes described in this Policy. To ensure your privacy and the protection of your personal data, we have adopted security and governance practices appropriate to our market and information security systems.

We have a governance and privacy program, rules of good practice, internal policies and procedures that establish the conditions of organization, operating regime, educational actions, supervision and risk mitigation mechanisms and other aspects related to the processing of personal data, as well as promoting training and educational actions for our employees.

Our measures to preserve data from unauthorized access, use, alteration, disclosure or destruction include the physical and logical protection of assets, access management, adherence to secure software development and internal compliance policies that insert security into the lifecycle of our services.

All of these controls are continually reviewed to keep up with and react to the context of threats on the internet. Still, it is not possible to guarantee that our services will be completely inviolable. But rest assured: we have teams prepared to detect and respond promptly in the event of an event or incident that compromises the security of your data or our services.

7. COMPLIANCE WITH THE RIGHTS OF THE HOLDER

 South Cargo guarantees the holders of all personal data that they control the exercise of the rights conferred by the LGPD. All requests made will be carefully addressed, but in order to secure personal data, the identity of the requester may be verified before responding to the request. Please note that the rights of the holders described below may be subject to legal limitations.

Under the LGPD, the data subject or their legally constituted representative may contact us at any time to obtain:

a) Confirmation and Access

It allows you to check whether any processing activity is carried out with your personal data and, if so, to request a copy of the personal data we hold about you.

b) Correction

Allows you to request the correction of incomplete, inaccurate or outdated personal data about you.

c) 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 ceases to be personal data; (b) block your data, temporarily suspending the possibility of us processing it; and (c) delete your data, in which case we will delete all your data without the possibility of reversal, except in the cases provided for by law.

d) Portability

You have the right to request, upon express request, that you or a third party of your choice be provided with your personal data in a structured, interoperable format for transfer to another provider, provided that it does not violate our company’s intellectual property or business secret.

e) Information about sharing

You have the right to know the public and private entities with which your data is shared, if applicable. 

f) Information on the possibility of not consenting

It allows you to have clear and complete information about the possibility and consequences of not providing consent. Your consent, where required, must be free and informed. Therefore, whenever we ask for your consent, you are free to deny it – although in these cases, we may have to limit our products, business, and experiences.

g) Revocation of consent

You have the right to withdraw your consent in relation to processing activities that are based on this legal basis. However, this will not affect the lawfulness of any processing previously carried out. If you withdraw your consent, we may not be able to provide you with certain products and experiences, but we will let you know when we do.

To have access to your data or request compliance with any other right, the holder may do so by contacting us through the following channels:

(i) Data Officer: Gordion Consultoria Empresarial Ltda.
Responsible: Guilherme Berkenbrock Camargo
(ii) email:
privacidade@southcargo.com 
(iii) Privacy Channel: 
https://southcargo.com/politica-de-privacidade/

8. COM WHO WE SHARE PERSONAL DATA WITH

The database is our responsibility, and its sharing, when necessary, will be done within the limits and purposes of our business and the purposes for which they were collected, always within the limits of this Privacy Policy.

Under no circumstances will the personal data collected be sold and/or assigned without the express and prominent consent of the holder.

Internally, the data we collect are accessed only by duly authorized professionals, respecting the principles of proportionality, necessity and relevance for the objectives of better service to the holder, in addition to the commitment to confidentiality and preservation of privacy under the terms of this Privacy Policy.

The data collected by South Cargo may be shared among the companies of the economic group and eventually with duly evaluated third parties that follow our security, confidentiality and data protection standards.

Our Suppliers and Partners

We have the help of suppliers who can process the personal data we collect as long as the sharing is appropriate for the purpose of collection. We always seek to carefully evaluate our suppliers and establish contractual obligations with them for information security and personal data protection, with the aim of minimizing risks for the data subject.

Public authorities

Regulatory Authorities, Federal Revenue, Ministries and other national authorities for the fulfillment of legal or regulatory obligations.

9. INTERNATIONAL DATA TRANSFER

The personal data we collect may eventually be transferred to other countries, mainly because the main cloud solution providers are located on foreign soil, as well as to group companies located in other countries. 

These transfers only involve companies that demonstrate compliance with applicable laws and maintain a similar or even more stringent level of adequacy than that provided for in Brazilian law.

If you have any questions regarding which companies these are, please contact our company’s Data Protection Officer (DPO) through our Privacy Portal or directly.

10. RETENTION PERIOD

Personal data is stored only for as long as necessary to fulfill the purposes for which it was collected, unless there is any other reason for its maintenance, such as compliance with any legal, regulatory, contractual obligations, among others, as long as they are based on a legal basis. 

Of course, there is always your right to request the deletion of the data, according to the item “What are your rights as a HOLDER of Personal Data?”.

11. HOW TO CONTACT OUR DATA PRIVACY TEAM?

We have a Privacy Portal and a Data Protection Officer (DPO) who are available at the following contact addresses:

Data Protection Officer:
Gordion Consultoria Empresarial Ltda.
Responsible: Guilherme Berkenbrock Camargo

Contact email:
privacidade@southcargo.com

Privacy Portal:
https://southcargo.com/politica-de-privacidade/

12. VALIDITY

This Policy will come into force as of November 2024 and will be valid until the date of its update and/or repeal.

COOKIES POLICY

We use cookies to improve the performance and your user experience on our website.

What are cookies?

Cookies are small text files that a website, when visited, places on the user’s computer or on their mobile device, through the internet browser (browser). The placement of cookies will help the website recognize your device on a next visit. We use the term “cookies” in this policy to refer to all files that collect information in this way.

The cookies used do not collect information that identifies the user. However, if you are already our customer, we may monitor your visits to the website provided that you have at least once initiated your browsing from some communication sent by us, e.g. SMS and email.

Cookies also collect generic information, such as how users arrive and use the websites or the area of the country/countries through which they access the website, etc.

Cookies only retain information related to your preferences.

At any time, the user can, through his internet browser (browser), decide to be notified about the reception of cookies, as well as block their entry into his system.

Refusal to use cookies on the website may result in the impossibility of accessing some of its areas or receiving personalized information.

What are cookies for?

Cookies are used to help determine the usefulness, interest and number of uses of websites, allowing faster, more efficient navigation and eliminating the need to repeatedly enter the same information.

What types of cookies do we collect and what are they used for?

Below we list all the cookies found when setting the cookie banner on the respective website. 

Platform / Category	Cookie	Description	Expiration
Bing / Microsoft / Marketing	MUIDB	Identifies unique web browsers that visit Microsoft websites. These cookies are used for advertising, website analytics, and other operational purposes.	1 year
Google Analytics / Analytics	_ga_HRPD21WFY7	ID used to identify users	2 years
Polylang / Functional	pll_language	Saves the chosen language.	1 year
Amazon / Marketing	__trf.src	Records how the user arrived at the site to allow the payment of referral commissions to partners.	1 year

Strictly necessary or functional cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set up in response to actions you take that correspond to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the website will not work. These cookies do not store any personally identifiable information.

Performance or analytical cookies
These cookies allow us to count visits and traffic sources so that we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and to see how visitors move around the site. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our website.

Advertising/marketing cookies
These cookies may be set through our website by our advertising partners. They may be used by these companies to build a profile about your interests and show you relevant advertisements on other websites. They do not directly store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will have less targeted advertising.​​

Controlling cookies

You can change your cookie preferences at any time through our cookie management tool, which is identified on our website by the floating icon below:

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