Privacy Policy

What are PERSONAL DATA?

Personal data is any information related to an identified or identifiable natural person, such as your CPF or RG for example. But beware: not all data initially obtained about you will be personal data, as only information that allows us to know exactly who you are is considered personal data.

What are SENSITIVE PERSONAL DATA?

Sensitive personal data are those personal data that have relevant potential for discriminatory use, even if they are not confidential data. Brazilian legislation considers sensitive personal data to be data concerning racial or ethnic origin, religious belief, political opinion, affiliation with a union or religious, philosophical or political organization, data related to health or sexual life, genetic or biometric data, when linked to a natural person.

What personal data do we process and why?

We are a company that provides integrated multimodal logistics solutions, and although we do not commercialize your personal data, we need to carry out various processing activities to enable the proper provision of our services. Personal data of our employees, service providers, business partners, and collaborators in general are examples of personal data that we need to process to comply with contracts, legal and regulatory obligations, promote security checks to protect the interests of the data subject and third parties, as well as for legitimate company activities.

The PERSONAL DATA that are the subject of processing are necessary for the purpose of each processing. This list of data may vary according to the specific purpose or legal requirement. Examples of PERSONAL DATA processing that we perform include: registration of employees’ name, CPF, CTPS, PIS, and domicile, sending data related to the employment contract with the
Public Administration, through platforms such as e-social; registration of identification data of service providers for financial and regulatory commitments; identification of self-employed carriers who need to enter loading and unloading areas, among others.

These are just a few examples that show how our activities need to use personal data, legitimately and within your expectations. We have a solid commitment to compliance with the rules governing privacy and data protection, and this Privacy Policy is the synthesis of that commitment.

What is a PERSONAL DATA PROCESSING AGENT?

A processing agent is the natural or legal person, whether public or private, who carries out personal data processing activities, either as Controller, who makes decisions regarding personal data processing, or as Processor, who processes personal data on behalf of the Controller.

What is LOG-IN’s role in personal data processing processes arising from its activity?

LOG-IN is the main processing agent in this case, acting as Controller for most of the processing processes arising from its business activity.

LOG-IN also acts as Processor in the processing of personal data by order of the Public Administration, through laws and regulations.

Occasionally, LOG-IN acts as Processor of data processing by request of some partner company or entity, when necessary to fulfill contracts entered into with them.

On what legal basis do we process your data?

According to the LGPD (General Data Protection Law – Federal Law No. 13709/2018), the processing of personal data to be lawful must be based on one of the established legal bases. In the case of the activities that we, at LOG-IN, carry out, we verify the classification for each type of different processing, but we always make sure to verify the appropriate legal basis for it. Thus, our personal data processing processes occur based on one of the following grounds:

• when necessary, by the data subject’s consent;
• for compliance with a legal or regulatory obligation by the controller;
• for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party;
• for the regular exercise of rights in judicial, administrative, or arbitral proceedings;
• for the protection of the life or physical integrity of the data subject or third party;
• when necessary to meet our legitimate interests or those of a third party;
• for credit protection.

Can personal data be shared?

The PERSONAL DATA we process preferably occur in our own systems and files. However, sometimes we need to share the data with service providers who assist us in storage, authenticity verification, compliance with legal obligations, defense of our rights in processes, for example.

In these cases, we take every care to require these companies and professionals to demonstrate a commitment to privacy and data protection and to adopt the best governance and security practices, ensuring the integrity of our Privacy Policy.

Some situations in which the sharing of personal data and their respective purposes may occur:

• With our data hosting service providers;
• With our document storage providers;
• With our external auditors;
• With health plan operators;
• With companies providing asset security, authentication, and registration validation services;
• With financial institutions and payment processing companies;
• hrough the use of social networks: some of our digital interactions, such as websites and profiles on social networks, allow you to register by logging in with your account through a third-party service, such as your profile on Facebook or Google. However, it is up to the data subject to decide whether to interact with us through these platforms, and each of them has its own policies and practices, over which we have no control or responsibility;
• With data companies, for some important purposes, such as preventing fraud, assisting in secure hiring, promoting protection of our employees and the cargo we store;
• With Public Authorities, to comply with laws and regulations.

LOG-IN, always observing the commitment to data protection legislation, may carry out other sharing hypotheses, whenever necessary and there is a legitimate legal basis.

What are your rights regarding personal data?

The General Data Protection Law (LGPD) gives the data subject, i.e., the natural person to whom the data refers, various rights, including the right to request from us, through our customer service channel, confirmation of the existence of processing, the list of processed data, as well as the correction of incomplete, inaccurate, or outdated data.

LOG-IN will respond in compliance with legal deadlines, on average 15 days, to requests from data subjects. For legal reasons, some requests may not be met, and we will inform the reasons for any denial.

Do we promote international transfer of your data?

As IT companies operate globally, certain processing, such as cloud storage, may require the transfer of your data to other countries.

Even in these cases, the data continues to be processed in accordance with the LGPD (General Data Protection Law) and other applicable laws and regulations. LOG-IN takes appropriate security measures and requires the same commitment from its suppliers, partners, affiliates, and service providers in order to comply with the best practices in data processing.

For how long will we retain your personal data?

We store the personal data of data subjects for as long as the registration remains active, such as during the validity of the employment contract, for example. After the relationship with us is terminated, we will still retain the data for the time strictly necessary to comply with our legal and regulatory obligations and to defend our rights in court, in accordance with the prescription and decadence rules of Brazilian legislation.

Does the use of our website include cookies and similar technologies?

Yes, as stated in our “cookie usage policy” provided to all users navigating our website.

What is our responsibility regarding the personal data we process?

In data processing where LOG-IN acts as the Controller, appropriate security practices are adopted according to the type of personal data and our type of activity.

We adhere to national and international information security guidelines, always striving to employ reasonable efforts to prevent any incidents. However, our commitment to adopting best practices does not prevent failures from occurring, motivated by fortuitous events or force majeure, especially by the criminal actions of third parties.

Whenever we identify any failures, we will take appropriate and necessary measures to correct and contain the effects, in collaboration with Public Authorities and with transparency.

Privacy Policies and Specific Terms of Use.

This Privacy Policy applies generally to LOG-IN and all its subsidiaries and affiliates. However, other specific Terms of Use and Privacy Policies may be provided for certain services and activities we develop. In case of any conflict between this Policy and any other more specific Term or Policy, the more specific Term or Policy shall prevail.

What if there is a change in the Privacy Policy?

Considering the continuous evolution of information technology and best security practices, as well as the possible enactment of new laws and regulations, this Privacy Policy may undergo updates to reflect the improvements made. Therefore, we recommend periodic visits to this page so that you can stay updated on the modifications made.

How to contact our Data Protection Officer?

The data protection officer is responsible for acting as a communication channel between the controller, data subjects, and the National Data Protection Authority (ANPD). You can contact them via email: privacidade@loginlogistica.com.br or by phone: +55 21 2111-6500.

This policy is governed, interpreted, and executed in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13,709/2018, regardless of the laws of other states or countries. The court of the capital of Rio de Janeiro is elected as the only competent authority to settle any doubts arising from this instrument.