SANTA HELENA’S PRIVACY POLICY


Santa Helena protects your privacy and the safety of your data, and it is committed to respect the privacy of all Holders, showing the way we protect the privacy of the Holder when accessing our Websites.

This Policy makes it clear to Holders and other interested parties the types of the collected data, method, Treatment, storage, and reason for collection, in addition to informing how the Holder may manage or delete his/her personal data. For this reason, we recommend You to read our Policy thoroughly.

When using our Websites and/or our services, You acknowledge and accept all the terms and conditions contained in this Policy, and freely and spontaneously agrees to being bound to it. Likewise, You agree that your Personal Data might be collected and used by Santa Helena, which might be stored/collected by Us.

In addition, this Policy might be changed at any time, at the sole and absolute discretion of Santa Helena.

A.DEFINITIONS

For the purposes of this Privacy Policy, the terms herein established and used will have the meanings provides below:

Natural or legal person, of public or private law, who treats personal data on behalf of the controller;

Policy Designation provided by this Privacy Policy;
Consent Free manifestation by which the holder agrees with the treatment of his/her personal data for a given purpose;
You or Holder Natural person who navigates Santa Helena’s Websites, being the holder of the personal data object of treatment;
Websites Santa Helena’s Websites in which this Policy is applicable, including their respective subdomains and hotsites;
Controller Designation provided by law to the natural or legal person, of public or private law (in the case of Santa Helena), who is in charge of making decisions related to the treatment of personaldata;
Children and Adolescents Definition provided in Article 2 of Law No. 8,069, dated July 13, 1990, i.e.:
“For the purposes of this Law, a child is someone who has not completed twelve years of age, and an adolescent is someone aged between twelve and eighteen years old.”
Anonymized Data Data related to a holder who cannot be identified, considering the use of reasonable technical means available at the time of its data treatment, which help the Controller creating better experiences to the Holder when navigating websites;
Personal Data) Information related to an identified or identifiable natural person, including information that identify, describe, that is related to and/or that might be reasonably related, directly or indirectly, to the Holder, alone and/or in combination with other information provided and/or collected by Us.
Sensitive Personal Data Personal data about racial or ethnic origin, religious background, political opinions, enrollment in a union or in a religious, philosophical, or political organization, data related to health or sex life, genetic or biometric data, when related to a natural person;
Information Anonymized Data showing the behavior of Holders in websites, i.e., the pages shown and navigated by the Holder in websites, his/her time of stay and the pathway covered;
IP Internet Protocol, an address attributed to every device (cell phone, personal computer, tablet, etc.) in order to identify it within the world wide web;
General Personal Data Protection Law or LGPD [Lei Geral de Proteção de Dados Pessoais, in Portuguese] Law No. 13,709, dated August 14, 2018 known as the General Personal Data Protection Law;
Operator
Hotline Natural or legal person, of public or private law, who treats personal data on behalf of the controller;
Treatment All the operation performed with personal data, such as those related to the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, or control of information, modification, communication, transfer, diffusion or extraction;

B. HOLDER’S RIGHTS AND PREFERENCES

As provided in the law, Santa Helena gives the Holder the rights related to the treatment of his/her personal data, including:

• Confirmation of the existence of treatment of his/her personal data;

• Access to the data collected via Websites;

• Correction of his/her data, if they are incomplete, inaccurate or outdated;

• Portability of his/her data, by means of the holder’s express request, as provided in the applicable law;

• Information about the possibility of not providing his/her consent, as well as being informed about the consequences, in case of refusal;

• Information about the public and private entities with which your data were shared;

• Possibility of revoking the consent for the treatment of certain personal data, as well as of requesting the elimination of the treated data based on the consent.

In those cases in which the holder requests the elimination of data or the revocation of his/her consent, the access to Websites and to their functions may be compromised or might become unavailable.

C. WHICH INFORMATION DO WE COLLECT?

Santa Helena may collect Personal Data including, but not limited to, your name, email, marital status, credit card number, address and geopositioning, data and number of personal documents (ID card, individual taxpayer registration, functional identity number, passport, etc.), IP address of your personal equipment/device, Information about the exhibited pages, time of stay and pathway covered by You in our Websites.

Santa Helena may eventually collect Sensitive Personal Data from the Holder, especially those required for creating marketing campaigns, such as your personal preferences, among others, when we will inform you in advance and will collect your specific authorization, at your sole discretion, for that purpose.

Personal Data from Children and Adolescents

Santa Helena does not recommend that Children and Adolescents access or use the Websites. Therefore, if, eventually, any Personal Data from a Child or Adolescent is (i) accidentally collected by Santa Helena, (ii) voluntarily provided by a Holder who is a minor, and/or (iii) if Santa Helena is induced to error in the collection of Personal Data by the Child or Adolescent, as soon as the situation and the Holder’s age is confirmed, these Personal Data will be immediately excluded from our databases.

Exceptionally, under the terms of Paragraph 3 of Article 14 of LGPD, Personal Data from Children or Adolescents might be stored when they are voluntarily provided to Santa Helena, or if Santa Helena is induced to error by those participating in the Treatment of your Personal Data, so that, when Santa Helena considers it to be necessary and at its exclusive discretion, the parents or legal representative of the Child or Adolescent might be contacted in order to report the situation and, when possible, to identify them (their parents or legal representative). When such identification is not possible or after the situation is reported to the parents or legal representative of the Child or Adolescent, their respective Personal Data will be continuously excluded from our databases.

If we become aware that we collected personal data from a child or adolescent, we will take the reasonable measures to eliminate the personal data in question. To that end, it might be necessary to eliminate the account related to that child or adolescent.

D. HOW DO WE COLLECT YOUR INFORMATION AND PERSONAL DATA?

We collect your Information and your Personal Data when You voluntarily:

•Subscribe in the Websites or use the services provided by our Store: when the Holder subscribes in the Platform or uses the services provided by our physical stores, we collect certain personal data, such as email, name, individual taxpayer registration number, telephones, date of birth.

•By executing the Services: when executing the Services, the following data provided by the Holder will be collected: full address with Zip Code, addressee’s name and financial information.

•By using the Platform: when the Holder uses the Platform, we collect personal data about your use of the Platform automatically or semiautomatically.

•Complete forms and navigates in our Websites;

•Contact our Hotline by phone, communication Apps, social networks from third parties and/or email;

•Contact us or are contacted by email, telephone or communication Apps (WhatsApp, Skype, Zoom, for example);

•Contact us or are contacted in person, to perform, for example, registrations, marketing campaigns and/or opinion polls, upon obtaining consent for the collection of Personal Data, obtained physically or digitally;

•Use our app for smartphones or tablets; or

•Upon the use of platforms and social networks from third parties.

E. USE OF COOKIES

We use cookies to optimize your experience during navigation.

In addition to the Personal Data voluntarily submitted by You, we use other technologies to collect Information and Personal Data, such as Cookies.

What are “Cookies”?

Cookies are small files or information that a website may send to a browser, which might be stored in its hard disk so that we can identify you when you return to the Website. Cookies may improve your online experience, saving your personal preferences while you visit our Website. They do not contain identifiable Personal Data. It is possible to set up your computer to notify you when you receive a cookie, or to completely disable cookies. You can also exclude your cookies when you leave the Website. For more information on how to do this, see section “help” in your browser or access http://www.allaboutcookies.org or http://aboutcookies.org.

Although You are not obligated to accept cookies when accessing our Websites, if you set up your browser to reject cookies, you will not be able to use all of their applications and functions.

Which cookies do we use?

Essential cookies - these are essential for accessing specific areas of our website. They allow navigating the website and using its applications, such as accessing safe areas of the website via login. Without these cookies, services that require them cannot be provided.

Analytical cookies - these are used to analyze the way users use the website and to monitor its performance. This allows us to provide a high quality experience when personalizing our offer and to rapidly identify and correct any issues that may arise. For example, we use performance cookies to know which are the most popular pages, which is the most effective method for linking pages, or to determine the reason why some pages are receiving error messages. Based on the use of the website, we can also use these cookies to highlight articles or services of the website we consider to be interesting for the users. These cookies are only used for creation and statistical analysis purposes, never collecting personal information.

Functionality cookies - these allow us to remember the user’s preferences. For example, cookies avoid typing the user’s name every time he/she accesses the website. We also use functionality cookies to provide advanced services to the user, such as making comments to an article. In a few words, functionality cookies store the user’s preferences related to the use of the website, so that it is not necessary to go back and set up the website at every visit.

Third-party cookies - these are used to measure the success of apps and the efficacy of the advertisement from third parties in our website.

Advertising cookies - these are used to guide advertising based on the interests of each user and on the number of his/her visits, making it possible to limit the number of times the advertisement is exhibited. These cookies help measure the efficacy of advertising.

F. HOW DO WE USE YOUR INFORMATION AND PERSONAL DATA?

The Information and Personal Data collected from you will be used by Santa Helena for the following purposes:

• Offering a personalized experience when You use our Websites;

• Exhibiting personalized advertising when you visit our Websites;

• Performing marketing campaigns;

• Better understanding your interests and needs;

• Improving our products and services;

• Providing the products, information and services You request;

• With safety, credit or fraud prevention purposes;

• Providing to you an effective customer service;

• Contacting you about topics we believe are of your interest;

• Inviting you to participate in researches and providing feedbacks to us;

• Improving the contents, functionality and usability of our Websites;

• Periodically sending Newsletters about topics that are of your interest, related to Santa Helena and animal health;

• Improving our promotional and marketing efforts;

• Customer Service, via Hotline or other contact channels, both internal or from third parties (including social networks);

• Meeting contractual and/or legal obligations; and

• For any other purpose identified in an applicable Privacy Warning or other agreement between Santa Helena and You.

G. SHARING DATA WITH THIRD PARTIES

Santa Helena will not disclose and/or assign your Personal Data and/or Sensitive Personal Data to third parties with no legal bond with Santa Helena (e.g., agreement). However, we can share your Personal Data and/or Sensitive Personal Data with third parties who provide services to Santa Helena, such as providers of data processing and storage services, companies contracted to provide marketing services, and others, which will act on behalf of Santa Helena as Operators, which have obligations related to privacy, confidentiality and Personal Data protection. Likewise, if requested by the competent authority as per its legal duties, or by governmental order, decree, regulation or rule, or in case of violations or suspected violations of this or of the Law, Santa Helena may be asked to make available the Information and Personal Data stored by us. However, Santa Helena is committed to strictly reveal the requested Information and Personal Data to meet the requested purposes.

Anonymized Data, such as statistical reports on the access, use of the Website (and other Information) and market trends, that do not reveal the identity of the Holders, may also be shared with subcontracted parties or commercial partners of Santa Helena.

As Santa Helena develops and grows, by means of, but not limited to, a corporate transaction, such as the acquisition, incorporation, merger, split up, or by means of selling or purchasing companies, products and/or assets, the Holder’s Personal data might be transferred. In such transactions, the Information and Personal data from customers and Holders are usually one of the transferable assets of the business.

H. PERSONAL DATA AND/OR SENSITIVE PERSONAL DATA RETENTION

Santa Helena retains Personal data and/or Sensitive Personal Data for as long as necessary in order to comply with the purposes provided in this Policy or until the Holder eventually requests the exclusion of this data, when possible and applicable. In this hypothesis, even after the request for exclusion, Santa Helena may retain the stored Personal Data for the prescriptive terms provided in the law.

I. SAFETY

Santa Helena is dedicated to protecting the personal data of our Holders. To this end, technical and organizational measures are implemented to help protecting the safety of your personal data; however, it must be observed that no system is 100% safe. Therefore, we would like to inform that we use the following tools and mechanisms for Digital Safety:

• We use technological mechanisms to provide protection against unauthorized access to systems, with these systems being considered a controlled and safe environment;

• We grant access to personal data storage areas only for previously authorized personnel;

• We use access authentication mechanisms for systems containing personal data; and

• Protective technical measures, such as Firewall and endpoint.

The password protects the User’s account, and this is why encourage the User to use a strong password in his/her accounts (using, when possible, capital and lowercase letters, numbers and special characters, avoiding the use of words or dates), to limit the access to the computer or browser, to not access our Platform in public or shared computers, and to end the session by clicking “Exit” after using the Platform.

J. CONTACTS AND REQUESTS

For any doubts or clarifications about this policy and our privacy practices, suggestions, complaints, requests to access, removal or correction of Personal Data, please contact us using the following communication channels attaching a proof of your identity (such as ID card, Driver’s License or similar document):

Person in charge of treating personal data: Eduarda Gil Email: eduarda.gil@santahelena.com

Telephone: (16) 3934 1000 - extension 1253

Address: Rua Paraguai, 1275 - Vila Elisa, Ribeirão Preto - SP, 14075-350, care of Setor de Segurança da Informação.

All requests will be responded within the legal terms and complaints will be investigated with the due waiver. If the request is registered by a person who is not you, with no proof of evidence that it is a legitimate request on your behalf, the request will be rejected.

K. LAW

This Policy will be governed and interpreted according to the Laws of the Federative Republic of Brazil, especially the General Personal Data Protection Law, regardless of the Laws in place in other Countries and territories.

L. VALIDITY AND UPDATE

The Holder declares he/she understands and irrevocably accepts that Santa Helena may, with no prior notice and at our sole discretion, change, include or remove any terms or conditions presented in this Policy.

Any changes to this Policy will immediately become effective. For this reason, we recommend that You frequently access this Policy.

This Policy became effective on December 20, 2020. All updates to the way we treat your Personal Data will be made in this Privacy Policy, which may be changed at any time.