PRIMAROTTA is under Accent-z general trading LLC License
1.1.1. System: It is the digital environment used by PRIMAROTTA, or any of its authorized commercial partners, to provide the Client with information about his Account, such as shopping cart, order data, order tracking, features, manual and warranty of the selected products , billing data such as delivery and billing address, among other information necessary for the supply of products.
1.1.2. Controllership: Natural or legal person, under public or private law, who is responsible for decisions regarding the processing of personal data.
1.1.3. Operator: natural or legal person, under public or private law, who processes personal data on behalf of the controller.
1.1.4. Person in charge: person appointed by the controller and operator to act as a communication channel between the controller, data holders and the National Data Protection Authority (ANPD).
1.1.5. Client: Natural or legal person who maintains a commercial relationship with PRIMAROTTA, or who has created an Account with, including through legal representation, whose access is exclusive through the insertion of a personal and non-transferable password, on one of its platforms, direct or controlled by third parties, holder of personal data.
1.1.6. Holder: Natural or legal person to whom the personal data refer, whether or not they are the Customer, as long as related to PRIMAROTTA products.
1.1.8. Account: It is the virtual registration made by the Client in the PRIMAROTTA system, or of its commercial partners, in which a “user” and a “password” are registered, with exclusive access through the insertion of a personal and non-transferable password.
1.1.9. Password: : Password created by the Customer in the PRIMAROTTA System access environment.
1.1.10. Personal Data: Information related to the identified legal or natural person.
1.1.11. Database: Structured set of personal data, established in one or several locations, in electronic or physical support.
1.1.12. Treatment: Any operation performed with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication , transfer, diffusion or extraction.
1.1.13. Consent Statement: Free, informed and unambiguous statement by which the Client agrees with the treatment of his personal data for a specific purpose.
1.1.14. Shared Use of Data: Communication, dissemination, transfer, national or international, interconnection of personal data or shared treatment of personal databases between PRIMAROTTA and any of its commercial partners.
1.1.15. Blocking: Temporary suspension of any processing operation, by keeping personal data or the database, as determined by PRIMAROTTA or at the request of the Client.
1.1.16. Elimination: Deletion of data or data set stored in a database, regardless of the procedure used, as determined by PRIMAROTTA or at the request of the Client.
2. GUIDING PRINCIPLES IN THE TREATMENT OF CUSTOMER DATA
2.1. PRIMAROTTA will observe the following principles in the treatment of Customer data:
2.1.1. Purpose: realização do tratamento para propósitos legítimos, específicos, explícitos e informados ao titular, sem possibilidade de tratamento posterior de forma incompatível com essas finalidades;
2.1.2. Adequacy: compatibility of the treatment with the purposes informed to the holder, according to the context of the treatment;
2.1.3. Necessity: limitation of the treatment to the minimum necessary for the accomplishment of its purposes, with coverage of the relevant data, proportional and not excessive in relation to the purposes of the data processing;
2.1.4. Free access: guarantee, to the holders, free and easy consultation on the form and duration of the treatment, as well as on the completeness of their personal data;
2.1.5. Data quality: guarantee, to the holders, of accuracy, clarity, relevance and updating of the data, according to the need and for the fulfillment of the purpose of its treatment;
2.1.6. Transparency: guaranteeing holders clear, accurate and easily accessible information about the treatment and the respective treatment agents, observing commercial and industrial secrets;
2.1.7. Security: use of technical and administrative measures to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or dissemination;
2.1.8. Prevention: adoption of measures to prevent the occurrence of damages due to the processing of personal data;
2.1.9. Non-discrimination: impossibility of carrying out the treatment for illicit or abusive discriminatory purposes;
2.1.10. Accountability: demonstration, by the agent, of the adoption of effective measures capable of proving the observance and compliance with the rules of protection of personal data and, even, of the effectiveness of these measures.
3. WHAT INFORMATION WILL BE COLLECTED
3.1. PRIMAROTTA collects personal data from the Client to supply and improve its products, with data being collected in accordance with the sources below:
3.1.1. Information provided by the Customer: We collect and store any information that the Customer provides in connection with the products.
3.1.2. Automated information: We automatically collect and store information about how you use the digital environment, including data about your interaction with products and content, most visited and desired items, browsing time, comments, clicks, using the cookie tool, obtaining information when the Client browses the website or accesses his Account.
3.1.3. Information from other Sources: We may receive information from the Client from other sources of treatment, such as tracking and confirmation of delivery by the transport companies, own or outsourced, as well as financial and credit protection systems, in order to correct and improve services and products, prevent fraud and default.
4. PURPOSE OF PERSONAL DATA COLLECTED
4.1. We use your personal data to operate, provide, develop and improve the products we offer to consumers, and for this purpose we apply the treatment to:
4.1.1. Product purchase and delivery: personal data will be used to receive and deliver orders placed by the Customer, process payment, communicate steps and conditions.
4.1.2. Technical assistance and improvements: we use the Customer’s personal data to provide technical assistance, after-sales and product improvement services, receiving and storing Customer experiences related to the purchase, delivery and use of the product.
4.1.3. Recommendations and personalizations: The Clients’ personal data are used to make recommendations for specific products, as well as to personalize navigation and indication of products and offers, with the sending of advertisements.
4.1.4. Compliance with legal obligations: the Client’s personal data may be used to comply with legal obligations or judicial decisions, within the limits imposed by law or by competent judicial bodies.
4.1.5. Communication: the Client’s personal data is used to contact them through different forms of communication (system messages, phone, e-mail, instant messaging applications, among others), related to the products.
4.1.6. Advertisements: we use your information to indicate specific products based on your preferences extracted from the sources of information used in data collection. We do not disclose your personal or identifiable data in advertising materials.
4.1.7. Fraud Prevention and Credit Analysis: We use your personal data to prevent fraud that third parties may attempt to employ using personal data, we also use it for credit analysis, in order to provide security to consumers, PRIMAROTTA and third parties. We may use scoring to analyze and manage default risks.
5.1. In order for our system to identify your browser and / or your device and thus provide the products, the cookie tool or other identifiers will be used in the collection of automated data, providing more information about interests and personalization, including:
5.1.1. Recognize when you access the system. This allows you to receive personalized product recommendations, view products of interest, be able to use simpler purchasing tools and other advantages.
5.1.2. Know your preferences. This allows, for example, to know whether or not you want to receive personalized advertising, advertisements, among others.
5.1.3. Conduct research to improve PRIMAROTTA products or our way of interacting with the customer.
5.1.4. Prevent fraudulent activity and improve the security of the website.
5.1.5. Interaction with other systems and databases.
6. DATA SHARING
6.1. Information about our consumers is an important tool in our business and that is why we deal with it at the highest and most current levels of confidentiality and security, and we DO NOT sell any personal data. We share data with business partners only for the purposes below:
6.1.1. Transações envolvendo terceiros: data sharing will only be used within the limits and in the interest to supply PRIMAROTTA products, such as delivery address for carriers, credit, resellers, technical assistance.
6.1.2. Between group companies or subsidiaries: we may share information and personal data with other companies in the group or controlled by PRIMAROTTA, exclusively for the supply or improvement of products.
6.1.3. Protection of PRIMAROTTA or third parties: we may share information and data for the protection of PRIMAROTTA itself or others, notably in cases of fraud or suspected fraud, as well as credit risk analysis.
6.1.4. Availability in credit protection databases: we may share some Client information to databases of credit protection systems in cases of delay or default, according to specific regulations and legislation.
7. SECURITY AND DATA STORAGE
7.1. Your security and privacy are extremely important and we take strict consideration into the development of our system, so we have adopted security, technical and administrative measures capable of protecting personal data from unauthorized access and accidental or illicit situations of destruction, loss, alteration, communication or any form of inappropriate or illicit treatment, including:
7.1.1. Security of your personal information during transmission, using encryption protocols and software.
7.1.2. Payment card industry data security standards when dealing with credit card data.
7.1.3. Physical, electronic and procedural copies related to the collection, storage and disclosure of your personal information.
7.1.4. Requesting proof of identity before we disclose your personal information.
7.2. We emphasize that it is important that you protect yourself against unauthorized access to your password and to your computers, devices and applications. Be sure to sign out when you are finished using a shared computer.
8. CLIENT RIGHTS
8.1. By allowing PRIMAROTTA to collect, store and process your personal data, you should know that ownership will be guaranteed and the fundamental rights of freedom, confidentiality, intimacy and privacy will be guaranteed, and you can at any time upon request obtain:
8.1.1. Confirmation of the existence of treatment;
8.1.2. Access to collected and processed data;8.1.3. Correction of incomplete, inaccurate or outdated data;
8.1.4. Anonymizing, blocking or deleting unnecessary, excessive or treated data in non-compliance with the LGPD;
8.1.5. Data portability to another service or product supplier, upon express request, in accordance with the regulations of the national authority, subject to commercial and industrial secrets;
8.1.6. Elimination of personal data processed with the consent of the holder;
8.1.7. Information from public and private entities with which the controller shared data use;
8.1.8. Information about the possibility of not giving consent and about the consequences of the refusal;
8.1.9. Revocation of consent.
8.2. The Client may object to treatment carried out based on one of the hypotheses of waiver of consent.
8.3. The aforementioned rights will be exercised upon the express request of the Client or legally constituted representative.
8.4. In the event of the impossibility of immediate adoption of the measure, PRIMAROTTA will send the holder an answer in which he can:
8.4.1. Communicate that it is not a data processing agent and indicate, whenever possible, the agent; or
8.4.2. Indicate the reasons of fact or of law that prevent the immediate adoption of the measure.
8.5. Confirmation of existence or access to personal data will be provided, upon request by the holder:
8.5.1. In a simplified format, immediately; or
8.5.2. By means of a clear and complete declaration, indicating the origin of the data, the lack of registration, the criteria used and the purpose of the treatment, observing the commercial and industrial secrets, provided within up to 15 (fifteen) days, counted from the date of the holder’s application.
8.5.3. Information and data may be provided:
8.5.4. By electronic means, safe and suitable for that purpose; or
8.5.5. In printed form.
8.6. The disclosure of confidential information will only be made to the holder, by forwarding the request with a copy of an updated identification document with photo, or to a representative legally constituted by a proxy with a notarized signature.
9. ADEQUACY OF INFORMATION TECHNOLOGY LEGISLATION AND PRACTICES
9.1. PRIMAROTTA is constantly improving its internal processes and products, and is in compliance with Law no. 13,709 / 2018 (LGPD), upon its entry into force, adhering to the principles and mechanisms of data processing to achieve the objective and protection that the law provides to the holders and controllers.
9.2. PRIMAROTTA has its own Information Technology department and is also outsourced, which have extensive knowledge of the legislation and their legal obligations as controllers or assistants in the treatment of Customers’ personal information.
10. LIMITATION OF LIABILITY
10.1. PRIMAROTTA is not responsible for malicious practices or for the misuse of content on other sites, as well as for failures in data security or illegalities committed by third parties, whether being commercial partners or not, committing to offer the best in terms of security to the services that each Client accesses, acquiring modern and effective assets, applying methodologies designated as best practices and adopting measures available in the state of the art in favor of information security.
10.2. PRIMAROTTA is not responsible for the stability or security of the services of internet and hardware providers connected to it.
10.3. Data from your internet package may be consumed when accessing or using services related to the System, which are the responsibility of the Client.
10.4. By consenting to the present, you also agree to grant PRIMAROTTA an unrestricted, irrevocable and free license, without receiving royalties or indemnities, mentions, descriptions or thanks, in the event of providing feedback and ideals for the development of improvements or new products, whose copyright will be the total and exclusive property of PRIMAROTTA, which will be able to take advantage of them in the best way it sees fit, including derivatives, regardless of any reservation to the contrary made by the Client in the media (verbal, physical or electronic), without being obliged to pay indemnity, compensation or refund.
10.5. At its sole discretion, PRIMAROTTA may grant bonuses, vouchers, mentions, thanks, to Client who provide information that results in the improvement or creation of a new product, the decision of which will be the responsibility of the controllership and will be communicated to the Client.
10.6. The commercial partners may have their own privacy policies, being up to the Client to consent or not to said policies, and PRIMAROTTA is not responsible for the loss, deterioration, misuse, fraud or any other form of damage or illicit caused to the Client by business partners.
11. END OF DATA PROCESSING
11.1. There is no term deadline for the treatment of personal data collected and stored by PRIMAROTTA, reserving the right to communicate the closure at any time, regardless of prior notice. Termination, however, may only occur in the following cases
11.1.1. Verification that the purpose has been achieved or that the data is no longer necessary or relevant to achieve the specific purpose sought;
11.1.2. End of the treatment period;
11.1.3. Communication by the holder, including in the exercise of his right to revoke consent;
11.1.4. Determination of national authority.
11.2. Personal data will be deleted after the end of its treatment, within the scope and technical limits of the activities, with conservation authorized for the following purposes:
11.2.1. Compliance with legal or regulatory obligation by the controller;
11.2.2. Study by research body, guaranteed, whenever possible, the anonymization of personal data;
11.2.3. Transfer to a third party, provided that the data processing requirements set forth in this Law are respected; or
11.2.4. Exclusive use of the controller, access by a third party is prohibited, and provided the data is anonymized.
12.2. In this case, PRIMAROTTA Will communicate in its various service channels, as well as highlight any changes that are made on its website.
13. CONTROLLER, OPERATORS AND PERSONNEL IN CHARGE
13.1. Controllership will be exercised by any of the directors of PRIMAROTTA, who are responsible for the final decision, in an unappealable manner, with regard to data processing.
13.2. The information technology sector will be the operator of PRIMAROTTA in the treatment of personal data, which may request support from subcontractors.
13.3. Those in charge will be the managers of the sales, marketing, after-sales departments, commercial partners, logistics, new product development engineering and customer service, each gaining access to instances of agreement and within the limits of the exercise of their functional activities.