Privacy Policy

In order to demonstrate transparency and comply with applicable legal obligations, ADONAI fulfills its duty to inform the purpose of the use of the Data Collected by the company and the rights of the Natural Persons (NP) who are the owners of such data.

This Privacy Policy is supplemented by other Policies, Processes, and Best Practices that are internally adopted by ADONAI. In case of any doubt or concern regarding the processing of Personal Data, you may contact the DPO (Data Protection Officer) through the Privacy Channels identified below.

Controller of the Collected Personal Data

ADONAI QUÍMICA S.A. (ADONAI), CNPJ 02.703.755/0003-40, headquartered in the city of Santos, State of São Paulo, located at Margem Esquerda do Porto Organizado de Santos, Área de Tanques, Ilha Barnabé, is responsible for the processing of the collected Personal Data.

Objectives of this Policy

ADONAI makes every effort to provide adequate protection measures in all its operations and to implement the most consistent, effective, and rigorous policies and procedures. Recognizing the importance of your privacy, we developed this Policy to inform you about the conditions under which we process and protect your Personal Data. This Policy also describes your rights and how you may contact us to exercise them or ask any questions regarding the protection of your Personal Data.

Definitions

ANPD (BRAZILIAN NATIONAL DATA PROTECTION AUTHORITY): Brazilian public administration body responsible for overseeing, implementing, and monitoring compliance with the General Data Protection Law throughout Brazilian territory.

EMPLOYEE: Refers to leadership members, managerial staff, direct and indirect employees, contractors, interns, and apprentices carrying out activities at ADONAI.

COLLECTION: For the purposes of this policy, it is the process of gathering Personal Data.

CONTROLLER: Natural or legal person, under public or private law, responsible for decisions regarding the processing of personal data.

COOKIES: Information files stored on computers or mobile devices through internet browsers. These files allow a website to “remember” the user’s actions and preferences for a certain period of time.

PERSONAL DATA: Information related to an identified or identifiable natural person. Personal Data includes: first and last name, age (date of birth), address, e-mail, IP address, job title, identification number such as CPF, RNE, passport number, among others.

SENSITIVE PERSONAL DATA: According to Brazilian legislation, sensitive personal data refers to racial or ethnic origin, religious belief, political opinion, union membership or affiliation with religious, philosophical, or political organizations, data concerning health or sexual life, genetic or biometric data linked to a natural person.

DATA PROTECTION OFFICER (DPO): Also referred to as the Data Protection Officer, responsible for coordinating and ensuring compliance with the Data Protection Policy and applicable local legal/regulatory requirements, as well as acting as the main communication channel with Data Subjects and the National Data Protection Authority (ANPD).

SUPPLIER: Natural or legal person providing a product or service to ADONAI.

LGPD: General Personal Data Protection Law (Law No. 13,709/2018).

OPERATOR: Natural or legal person, under public or private law, that processes personal data on behalf of the Controller.

PROCESSING: Refers to any operation performed with Personal Data from the moment of collection.

CONSENT FORM: Document collecting the Data Subject’s consent for the processing of Personal Data for specific purposes.

PERSONAL DATA SUBJECT (Data Subject): Natural person to whom the Personal Data being processed refers.

Collection of Personal Data

ADONAI collects Personal Data in the following situations:

Candidate Evaluation for Job Openings

This section explains how Personal Data is processed in relation to individuals applying for a job position, participating in recruitment events, or undergoing evaluation by ADONAI or associated companies.

Purpose: ADONAI collects this information to evaluate candidates applying for positions within the company.

How Data is Collected:

• Through direct contact with ADONAI via phone number, e-mail, fax, or through the website adonaiquimica.com.br or other events;
• Through personal referrals;
• Through service providers such as recruitment and selection companies;
• Through social media such as LinkedIn.

Collected Personal Data: first and last name, date of birth, CPF, ID card or RNE, e-mail, phone data, address, educational background, and employment history.

Payroll Processing

This section details how Personal Data is processed when hiring individuals under the Brazilian CLT employment regime.

Purpose: ADONAI collects this Personal Data for:

• Employee payroll processing;
• Sending employee data for payroll processing;
• Receiving payroll processing results;
• Sending income and withholding information to prepare DIRF and other legal obligations;
• Processing employee benefits such as health insurance, transportation, and meal benefits;
• Ensuring security within company facilities.

How Data is Collected: Employees provide Personal Data to ADONAI’s Human Resources Department at the time of hiring.

Collected Personal Data: All legally required information for employment records, payroll movements such as worked hours, delays, absences, vacations, medical leave, medical certificates, admission and periodic examinations, transportation vouchers, dependents, security camera footage, etc. Personal data of spouses and dependents may also be collected.

Supplier and Service Provider Contracting

ADONAI collects Personal Data from representatives of suppliers and service providers.

Purpose:

• Contract formalization for the acquisition of goods or services;
• Maintaining updated records;
• Ensuring logistics and facility security.

How Data is Collected: Through the Finance/Purchasing Department or through adonaiquimica.com.br.

Collected Personal Data: Full name, ID card, CPF, date of birth, job title, financial history, and security camera footage.

Customer Contracting

ADONAI collects Personal Data from customer representatives.

Purpose:

• Providing contracted services according to signed agreements;
• Maintaining updated records;
• Ensuring logistics and facility security.

How Data is Collected: Customers provide Personal Data to ADONAI representatives for contract formalization and invoicing.

Collected Personal Data: Full name, ID card, CPF, date of birth, job title, e-mail, phone information, and driver’s license number.

Information Provided Through the Website

Individuals may access ADONAI webpages through adonaiquimica.com.br.

Purpose: Responding to inquiries and requests.

How Data is Collected: Through communication channels available on the website where visitors can submit questions and comments.

Collected Personal Data: Any information voluntarily provided by the website visitor.

Other Automatically Collected Personal Data

ADONAI automatically collects certain information when users visit the website in order to personalize and improve the browsing experience.

Cookies

ADONAI uses cookies to automatically collect information that helps identify user preferences and improve application performance and personalization.

Statistics

The website uses Google Analytics, a web analytics service provided by Google, to generate statistical reports. Information collected may include IP address, referring website, and device type. IP addresses are masked within ADONAI systems and used only when necessary for technical troubleshooting, site administration, or understanding user preferences.

Social Media

The website includes links to social networks such as Facebook and Instagram. Social media helps create a more user-friendly environment and promotes the website through content sharing.

Legal Basis for Processing Personal Data

ADONAI processes Personal Data in accordance with the legal bases established by the LGPD and in a manner compatible with the purpose of collection. Personal Data is processed:

• In managing contractual relationships with customers, suppliers, business partners, and employees;
• Under the legitimate interest of ADONAI or third parties, provided legal requirements are met;
• In compliance with legal or regulatory obligations;
• When necessary for the regular exercise of rights in judicial, administrative, or arbitration proceedings;
• Based on prior consent from the Data Subject, when required;
• To protect the life or physical safety of the Data Subject or third parties.

Sharing of Personal Data

ADONAI restricts access to Personal Data only to authorized professionals who need access to provide requested services. However, Personal Data may be shared in the following situations:

• With ABA Infra Group, ADONAI’s holding company, for operational support;
• With authorized service providers such as technology and IT consultants;
• With customers or partners requiring information such as INSS and FGTS contributions to ensure labor rights;
• With successors or buyers in mergers, acquisitions, or asset sales;
• To comply with laws, regulations, or court orders;
• To respond to requests from regulatory authorities or law enforcement agencies;
• To protect ADONAI’s rights or investigate fraud and security threats;
• To protect the legitimate interests and personal safety of employees and users.

Storage of Personal Data

ADONAI stores collected Personal Data in secure environments, ensuring confidentiality:

• Only for as long as necessary to fulfill the purposes for which the data was collected;
• For longer periods when required by law or regulation;
• Data may later be securely deleted or anonymized for statistical purposes;
• Data may be stored by third-party providers located in Brazil or abroad;
• Data may be stored through cloud computing and future technologies while maintaining appropriate security standards.

Sensitive Personal Data

Whenever strictly necessary, Sensitive Personal Data will be collected according to legal requirements and based on applicable legal grounds under the LGPD or through prior, explicit consent from the Data Subject.

Processing Personal Data of Children and Adolescents

Personal Data of minors will only be collected according to legal requirements and always with authorization from a parent or legal guardian.

International Transfer of Personal Data

Collected Personal Data may be transferred to recipients located outside Brazil. Whenever international transfers occur, appropriate measures will be adopted to ensure adequate protection in compliance with the LGPD.

Exercise of Rights Under the LGPD

Provided there is no legal restriction, Data Subjects may exercise the following rights:

• Confirmation of processing existence;
• Access to Personal Data;
• Correction of incomplete, inaccurate, or outdated data;
• Anonymization, blocking, or deletion of data;
• Request temporary suspension of processing operations;
• Information about data sharing with third parties;
• Revocation of consent;
• Data portability.

Additional Information

For questions, complaints, requests, or concerns regarding the processing of Personal Data, the Data Subject may contact the Data Protection Officer (DPO), Juan Musso, through the following e-mail:

CLICK HERE

Changes to this Privacy Policy

This Privacy Policy may be updated over time. This Privacy Policy was last updated on September 25, 2024.

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