INTRODUCTION Coats is based in the UK and is a world leader in the production and marketing of industrial textiles, offering innovation, digital solutions and sustainability values.
Above all, it is concerned about the privacy of any data subject where the processing of their personal data is under the responsibility of Coats, including but not limited to its employees, customers, service providers, partners, representatives and resellers, candidates. , customers. , prospects or anyone else who may interact with your products and services.
Therefore, this Policy aims to define Coats’ data protection guidelines, demonstrating our commitment to handling your personal data with security, privacy and transparency. It also explains how we collect, use, disclose and store your personal data, as well as what rights you have as a data owner.
2.1. LGPD: General Law for the Protection of Personal Data (Law 13.709 / 18) that provides for the processing of personal data, even in digital media, by a natural or legal person under public or private law, in order to protect the rights of freedom and privacy and free development of the personality of the natural person;
2.2. Treatment: any operation or set of operations in which Personal Data and / or Sensitive Personal Data are used, such as those related to obtaining, production, reception, classification, use, access, reproduction, transmission, distribution, treatment, archiving, storage , elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;
2.3. Personal data: all the information that makes the person identifiable or identifiable;
2.4. Sensitive personal data: personal data related to racial or ethnic origin, religious beliefs, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, data related to health or sexual life, genetic or biometric data, when are linked to a natural person
2.5. Owner: natural person whose Personal Data and / or Sensitive Personal Data are being processed
2.6. You: owner of personal data
2.7. Controller: It is the treatment agent that defines the rules for the processing of personal data.
2.8. Operator: It is the treatment agent hired by the Responsible who carries out the processing of personal data on behalf of the contracting company (or at its request) observing all the definitions indicated by the company (Responsible) that determined the treatment.
2.9. National Data Protection Authority or ANPD: body of the national public administration responsible for supervising, implementing and supervising compliance with the General Data Protection Law throughout the Brazilian territory;
2.10. DPO (“Data Protection Officer”) or Manager: the person responsible for coordinating compliance with the Data Protection Policy and the applicable local legal / regulatory requirements will also act as a channel with the Interested Parties and the National Data Protection Authority.
3. PRIVACY STATEMENT OF PERSONAL DATA
The practices described in this Policy apply to the processing of your personal data in Brazil and are subject to applicable local laws, with emphasis on Law No. 13,709 / 2018 (General Data Protection Law, or “LGPD”) from its entry into force.
Coats does not collect and process personal data without need, specific purpose or any other legal justification compatible with Brazilian law.
When in the role of Operator of Personal Data, Coats will respect the guidelines specified by the Controller and will respect the current legislation on Data Protection and the rules contractually presented by the Controller, provided that in accordance with Brazilian law, as well as complying with the purposes for which your personal data was collected. Thus, we clarify that the way in which your personal data is handled will be described in the policies of said companies, and you must request your rights regarding the processing of personal data directly from them.
In addition, complying with information security requirements, personal data will be processed only by those people who have the level of privilege and need access, thus ensuring that your data is not seen by employees or service providers of Coats outside the purpose for which they are intended.
4. THE PERSONAL DATA WE PROCESS AND THEIR REASONS
Prospect Personal Data: If you are interested in our products and services and subscribe to our website to receive access to free video classes, recipe information, participate in physical and digital events, we may collect personal data such as full name, email , telephone, city and state, and surname, with your express and unequivocal consent, which may be revoked at any time, to facilitate our communication and provide information about products, services, advertisements, offers, promotions and maintain effective and efficient communication, enabling new businesses to buy and sell our materials;
Personal data of suppliers and partners: If you work for one of our various supplier companies from which we purchase goods and services, or for one of our distributors, agents, other intermediaries or partners with whom we cooperate, we collect personal data such as identification documents such as CPF and CNH, contact information such as email, telephone, bank details for tax purposes, when necessary, so that we can make contact, carry out transactions, billing, business and maintain effective and efficient communication while managing our business;
Candidates’ personal data for recruitment and selection: If you apply for a job offer to work at Coats, we may collect personal data such as your full name, contact information (email or phone) or data that is directly relevant to the position. available. so that we can understand if there is compatibility and suitability of the candidate in a company selection process;
Personal Data of Employees and Dependents: If you work with us, we collect personal data and sensitive personal data so that you can fully exercise your functions, as well as so that we can identify you, include you in the benefits – when there is adhesion, so that it is possible to guarantee our security , for our legitimate interests, to comply with legal, regulatory, contractual and / or social security obligations, so that the exercise of our rights is possible;
Former Employee Personal Data: If you have previously worked for Coats, your personal data may need to be retained after contract termination so that we can comply with legal, regulatory, contractual and / or social security obligations and to make it possible the exercise of our rights, so that we do not keep your personal data without any of these justifications;
Personal data of the visitors of the facilities: if you visit any of our branches or facilities to have access control and guarantee our security;
5. WHAT TYPES OF COOKIES DO WE USE
Cookies are small files created by websites that the user visits and stored on their switch or mobile device. Among the uses, they are mainly used to make the websites work properly and / or more efficient, and also to provide information to the owners of these websites.
Cookies facilitate the process of adapting our website to your personal needs, facilitating its use whenever possible. They also favor receiving comments on our customers’ satisfaction.
Coats uses the following types of cookies on its website
6. GENERAL PRINCIPLES OF COATS FOR THE PROCESSING OF PERSONAL DATA
Coats handles personal data always in accordance with the law and for legitimate and specific purposes and that will always be communicated to the owner. In addition, the information collected will only serve the purposes indicated, in a strictly appropriate manner and without deviations. In addition, the principle of data minimization will always be respected, that is, the data collected and processed will not be excessively.
The owner will always have free access to the personal data collected and processed by Coats, safeguarding industrial secrets and confidential information. In turn, Coats will always aim to guarantee the quality of personal data and transparency in data processing, respecting the principle of non-discrimination, security and prevention of personal data.
7. LEGAL FOUNDATIONS
We need to treat your personal data as specified in the item “PERSONAL DATA WE HANDLE AND ITS REASONS” above when you, for example, fulfill an employment contract with Coats or consent to the processing of your personal data, clearly and unequivocally, by registering at our Crafts website to receive product information, recipes, and promotions.
For more information on the guidelines we follow in responding to your requests for personal data, we recommend that you read our Policy on Responding to Requests from Personal Data Subjects.
The owner can exercise their rights by submitting the request by sending an email directly to the DataProtection.BR@coats.com.
We emphasize that most of these rights are not absolute and we follow the legal provisions.
In addition, in order to confirm your identity in connection with your request, we may ask for more information about you, which will be discarded once the purpose of responding to the request is completed.
Any request must be sent to us, preferably in writing, with clarification on what information you wish to receive. We will respond to your request as soon as possible. If we are unable to comply with your request regarding access to your information, we will provide you with reasons for doing so.
9. EXCHANGE OF PERSONAL DATA AND INTERNATIONAL TRANSFER OF PERSONAL DATA
In no case does Coats sell or sell your personal data to third parties. But, always making sure that only in case of strict need to do so, Coats can be asked to disclose your personal data when required by law, a legal request or a decision of the authorities. This disclosure may, for example, be made to the police, federal tax service, or other government authorities.
10. STORAGE AND DISPOSAL OF YOUR PERSONAL DATA
Coats will use your Personal Data for as long as necessary to fulfill the purposes for which your Personal Data was collected, as described in this policy, or to comply with applicable legal requirements.
When at the end of the processing of your Personal Data, these will be eliminated following the parameters and technical limits of the activities, being only authorized the conservation of the personal data in the situations that are foreseen in the current legislation.
Coats takes appropriate technical and organizational measures to help protect the security of your personal data. In this sense, it provides training to employees to raise awareness about the importance of the issue of data protection and privacy, has and applies the Code of Ethics to employees, which is in full compliance with current legislation on protection of personal data , in addition to the Data Protection Policy and the Information Security Policy, without prejudice to other internal regulations aimed at respecting the privacy of the holders.
It also has the Policy for Responding to Incidents of Violation of Personal Data, which guarantees the investigation, complaint and action against possible incidents where there is loss, theft, damage or inadequate access to confidential information or personal data and signed Confidentiality Terms, which make official commitment. of employees with the non-disclosure of each and every confidential data related to Coats and the holders of personal data.
Therefore, we consider all data and personal information as an asset of the organization, which has great value and must be treated with responsibility, transparency and integrity.
12. ON THE PERSONAL DATA OF CHILDREN AND ADOLESCENTS
Coats does not process the personal data of children and adolescents, except in cases where there is a legal provision or when there is specific and outstanding consent given by at least one of the parents or legal guardian, in accordance with current legislation.
If we discover that any processing of this type of personal data has taken place inadvertently, we will delete the personal data of that child or adolescent from our records immediately, securely and with a record of this processing.
Whoever notices deviations from the guidelines set out here, can also report on the aforementioned channel, which will be received and analyzed so that the necessary measures are taken promptly.
15. DOCUMENT REVIEWS
This policy must be reviewed annually or according to the understanding and decision of the Personal Data Protection Management Committee.