Privacy Policy

This privacy policy applies to information collected by AÇOS TORRES through its websites, products, and services. This policy has been drafted in the simplest possible way to facilitate your understanding, but if you still have questions, our contact channels indicated below are at your disposal.

AÇOS TORRES LTDA, registered with CNPJ under no. 07.171.871/0001-17, with headquarters in the City of São Paulo, State of São Paulo, at Rua General Eugênio de Melo, 238, Ipiranga, CEP 01553-010, (TORRES), recognizes and values the privacy of our customers and is committed to ensuring that our customers are informed about how their personal information will be used and kept secure.

Thus, this Privacy Policy establishes the terms for the collection, processing, and use of sensitive or non-sensitive information from customers and other individuals who access the Aço Torres website (https://acostorres.com.br) or any other digital communication channel, including its respective social media networks.

By consuming content, visiting the website, making purchases, or interacting in any way with TORRES, you are aware that your personal information will be collected in the ways described in this Policy, under the rules of the General Personal Data Protection Law (Federal Law 13.709/2018).

TORRES, in its role as Data Controller, is bound by the provisions of this Privacy Policy, namely:

1. Initial Definitions

Each time you read a capitalized term in this Policy, it means it is a specifically defined term.

Whenever the terms “TORRES”, “we” or “our” are mentioned, we are referring to the company TORRES; similarly, whenever the terms “you”, “your” are mentioned, we are referring to You.

This Privacy Policy applies to all TORRES customers, prospects, and job applicants.

We collect your personal data whenever you:

  • Browse the Torres website (https://acostorres.com.br);
  • Contract or use any of our products or services;
  • Contact us through our service channels or social media.

This Privacy Policy is applicable to other forms of personal data collection that enable the provision or improvement of our services.

The practices described in this Privacy Policy only 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 Personal Data Protection Law, or “LGPD”).

2. What data do we collect?

For registration on all TORRES digital channels, the following personal data may be requested:

  • Full name;
  • Email;
  • Phone number;
  • Address.

When you browse our pages, we also collect:

  • IP address of the device used to access the website;
  • Interactions performed and website usage profile;
  • Technical data, such as URL information, network connection, provider, and device;
    Cookies;
  • Device attributes, such as ID, operating system, browser, and model.

Some third parties receive part of this personal data to perform functions or services for TORRES, in accordance with their own policies, such as:

  • Acronis, cloud platform for backup;
  • Adopt, cookie management tool;
  • Centrix, manages VoIP telephony;
  • Google, marketing targeting tool;
  • Google Analytics, behavioral analysis tool;
  • Microsoft, office applications;
  • R2SIS, information technology service provider;
  • RH1000, our human resources management tool.

3. Data Collection Procedure

Personal data collection occurs through website browsing or by filling out forms intended for offering marketing communications and promotions or for purchasing products and services.

Consent will always be requested from the user who fills out the form, and from this consent, their personal data will be processed by TORRES, as consent is the free, specific, informed, and unequivocal manifestation that the user authorizes TORRES to process their data.

By providing their personal data, the user is aware of and agrees to the terms of TORRES’ Privacy Policy and may, at any time and without any cost, revoke their consent.

4. Purpose of Personal Data Use

TORRES uses your personal data to provide high-quality service and offer you the best products. Below, we detail the purposes for which we use your personal data:

  • Send promotional communications for products and services;
  • Provision of contracted services and offering of products;
  • Handling requests and inquiries;
  • Contact by phone, email, SMS, WhatsApp, or other communication channels;
  • Improvement of the services we provide;
  • For offering new products and services;
  • Operationalization of new products and services;
  • Marketing, prospecting, market research, opinion polls, and promotion of our products and services, or those of our partners, including enabling offers and sending information about products, services, news, features, content, updates, and other relevant events for maintaining the relationship with you;
  • Recommendation of new services, products, or application features, including partner services that may interest you;
  • Display of advertising, whether on our website, social media, or third-party websites;
  • Generation of statistics, studies, research, and surveys pertinent to activities and behavior in the use of products or services;
  • Prevention and resolution of technical or security issues;
  • Regular exercise of TORRES’ rights, including presenting documents in judicial, administrative, and arbitration proceedings, if necessary;
  • Compliance with court orders, competent authorities, or regulatory bodies;
  • Compliance with legal or regulatory obligations.

5. Sharing of Personal Data

TORRES may share the collected data with companies within our economic group, business partners, authorities, and regulatory bodies for different purposes, if necessary and requested.

Data sharing will only be done within the limits of our business and in accordance with this policy and current legislation.

We inform you that personal data collection forms may be hosted on third-party websites or platforms, and communication pieces sent may use electronic messaging systems provided by third-party companies that offer these services.

6. Retention and Deletion of Your Personal Data

As long as you are a TORRES Customer or Prospect, during the use of our products and services, and for the entire period that we store your personal data, it will be kept in a secure and controlled environment.

Where applicable, and even after the cancellation of services or products, we may store your personal data for an additional period for auditing purposes, compliance with legal or regulatory obligations, for the regular exercise of rights, or for the necessary period according to the legal basis that justifies data retention.

7. Your Rights as a Personal Data Subject

Upon the entry into force of the LGPD, you, as a personal data subject, can exercise your rights before the controllers of your personal data. We detail below how you can clearly and transparently exercise your rights, and our team will be ready to address any requests.

  • Confirmation of the existence of personal data processing
    The fact that you are a TORRES customer or prospect already means that we process your personal data, even if this processing includes, among others, the storage of personal data in a secure and controlled environment. You can ask us to confirm whether we process your personal data.
  • Access to personal data
    You can request that we inform and provide you with the personal data we hold about you.
  • Correction of incomplete, inaccurate, or outdated personal data
    If you verify that your personal data is incomplete, inaccurate, or outdated, you can request its correction or supplementation. For this, you will need to send a document that proves the correct and current form of the personal data.
  • Anonymization, blocking, or deletion of unnecessary, excessive, or LGPD non-compliant data
    If any personal data is processed unnecessarily, excessively for its intended purpose, or in non-compliance with the LGPD, you can request that TORRES anonymize, block, or delete such data, provided that the excess, lack of necessity, or non-compliance with the law is effectively proven.
  • Deletion of personal data processed with consent
    If you have given consent for the processing of your personal data for specific purposes (and not necessary for the provision of our services or delivery of our products), you may request the deletion of such personal data.
  • Information about companies with which TORRES has shared or from which it has received your personal data
    You can request with which third parties we have shared or from whom we have received your personal data.
  • Information about the possibility of not providing consent and the consequences of refusal
    If your consent is necessary to access or use a certain product or service, you can ask us to clarify whether it is possible to provide that product or service without your consent for the processing of your personal data, or what the consequences are of not providing consent in this case.
  • Revocation of consent
    If you have given your consent for the processing of your personal data, you can request the revocation of this authorization. The revocation of consent may result in the termination of the services provided, but it does not prevent the use of (i) anonymized data; and (ii) data whose processing is based on another legal hypothesis provided for in the LGPD.

To exercise any of these rights, we ask that you contact us via email at “privacidade@acostorres.com.br”. To effectively process your rights, we may request proof of your identity as a security, authentication, and fraud prevention measure.

8. Cookie Policy

We may record the activities you perform when using our website through Cookies. TORRES uses the Adopt application to manage cookies, which are text files sent to the equipment used by the user to access TORRES websites and stored therein.

A “cookie” is a line of information, usually small, that is identified by a name and can be transmitted to your browser by a website you connect to. Your web browser will keep it for a period and then return it to the server each time you connect to it.

We use 3 (three) types of cookies on our websites:

Necessary Cookies: These cookies are essential for you to use the features of our products and services. Without these cookies, the services you request, such as electronic payment, cannot be provided, and consequently, you will not be able to browse the websites, make purchases, etc.

Functional Cookies: These cookies are used to make the Website function as well as possible. They are typically configured to respond to actions you take or service requests, such as setting your privacy preferences, filling out forms, your chosen language, among other preferences. Normally, by not allowing these records, your user experience can be severely impaired.

Performance Cookies: We use these cookies to measure and improve the performance of our Site. They help us find out which pages are most or least visited and see how visitors navigate the Site. All information collected by such cookies is aggregated and therefore anonymous. You can refuse or delete these cookies at any time, but in this case, we will not be able to determine when you visit the Site and what your preferences are.

By accessing TORRES websites and consenting to the use of cookies, the user declares to know and accept the use of a navigation data collection system with the use of cookies on their access device, it being certain that the user can, at any time and without cost, change permission, block, or refuse the cookies used by the websites.

9. About Data Security

All collected information is stored on servers hosted on the company’s internal network, in public clouds such as Microsoft Azure, private clouds of information technology providers such as RH1000, and information technology service providers such as R2SIS. TORRES’ servers operate on modern and robust infrastructure following market-standard information security practices, in addition to active physical and logical security.

Personal data may also be stored by other technological means that may emerge in the future, always aiming at the improvement and enhancement of our services and security.

We treat the security of your personal data with the utmost care, using internationally adopted standards and best practices such as:

  • Continuous environment monitoring;
  • Continuous information security analyses and tests on our systems, performed by internal and external teams;
  • Periodic audits.

10. Changes to the Privacy Policy

TORRES reserves the right to modify this Privacy Policy at any time.

As we value transparency and our relationship with data subjects, whenever any relevant condition of this Privacy Policy is changed, these changes will be valid, effective, and binding after the new version is published on our website or sent to you by email.

By continuing to use our products and services after a change in the Privacy Policy, you will agree to the new conditions – but you can always express your disagreement through our service channels, if applicable.

In cases where changes to this Privacy Policy result in changes to personal data processing practices that depend on your consent, we will request your consent to the new terms of the Privacy Policy regarding the indicated data processing and purposes.

11. About Consent

Throughout this Privacy Policy, we inform you that some personal data will only be collected with your consent.

By reading this Privacy Policy and clicking, at the end, on “I have read, I am aware of the conditions for processing my personal data and I provide my consent, where applicable, as described in this Privacy Policy.”, you consent to the processing of personal data in the ways indicated herein.

It is worth remembering that the processing of your personal data is a necessary condition for us to provide our services and deliver our products to you. If you have any questions about any of the terms explained here, we are available through our service channels to assist you.

12. Have any questions? Contact us!

If, after reading this Privacy Policy, you still have any questions, or for any reason need to communicate with us regarding your personal data, you can contact our Data Protection Officer:

Officer: ABC Tecnologia Comércio e Serviços em Informática Ltda.
Phone: (11) 4393-2403
Email: privacidade@acostorres.com.br

We hope to have helped you better understand how we handle your data and we are available to clarify any questions and continue with honest and transparent work.

Revision 00 • Initial Issue • 11/19/2021 • Approved by the Privacy Committee