Privacy & Cookie Policy
PRIVACY POLICY, INFORMATION CONFIDENTIALITY AND PERSONAL DATA PROCESSING
1. Introduction
The purpose of this Policy is to state the commitment of the Nuno//Fracht Group to privacy and confidentiality of information to which it has access in the course of its activities. It also underscores our commitment to protection, transparency and clarity regarding its use, in accordance with applicable laws and regulations. This Policy will be applied to individuals, whose data protection falls under the scope of the Brazilian “Lei Geral de Proteção de Dados” (General Data Protection Law) No. 13,709/18, as well as to legal entities with regard to confidentiality and information secrecy agreements.
2. Who are we?
Combining the tradition and experience of Nuno and Fracht AG, Nuno//Fracht acts as a complete logistics integrator in the transportation of international cargo.
Today, Nuno//Fracht has 6 offices and 180 employees. Globally, the Fracht Group has more than 2,000 employees throughout 147 offices around the world, with a presence on all continents and an expanding presence in the African market.
In Brazil, Nuno//Fracht operates with excellence all over the country and we are physically present in São Paulo, Rio de Janeiro, Santa Catarina and Rio Grande do Sul.
3. About the personal data collected from employees and others who are linked to the Nuno//Fracht Group
| What is collected? | What is it collected for? |
| Registration data | |
| Full name / Company name | The internal registration within the systems which is used by the Human Resources Department to monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Carrying out registration in the operational systems of the Department to which the employee is assigned; Registration with insurers and/or health and life insurance providers, corporate and health occupational benefit suppliers; preparation of powers of attorney and/or business cards/representation (if applicable); Punctual provision to the Facilities area for the purposes of booking business trips; Usage by the IT Department for internal user control, e-mail account, skype account, corporate system, network account and eventual availability on the internal network, “Intranet”. |
| ID Card (National Identification Document) | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration in the operational systems of the Department to which the employee is assigned; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers; preparation of powers of attorney (if applicable); Punctual provision to the Facilities area for the purposes of booking business trips. |
| CPF/CNPJ (Individual Taxpayer ID/Company Tax ID) | Carrying out internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Carrying out registration in the operational systems of the department to which the employee is assigned; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers; Drawing up powers of attorney (if applicable); Providing the Facilities area with the necessary information for booking business trips; Utilized by the IT Department regarding the registrations in the internal Atlantis and Intranet systems. |
| Gender | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers; Utilized by the IT Department regarding the registrations in the internal Intranet systems. |
| Ethnicity | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers. |
| Sexual Orientation | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; |
| Place of birth | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers. |
| The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration in the operational systems of the Department to which the employee is assigned; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers; Punctual provision to the Facilities area for the purposes of booking business trips. | |
| Education | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; |
| Contact telephone number | Carrying out internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Carrying out registration in the operational systems of the department to which the employee is assigned; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers; Drawing up powers of attorney (if applicable); Punctual provision to the Facilities area as needed for the delivery/pickup of corporate items and for any business travel bookings; Utilized by the IT Department regarding registrations in the internal Atlantis and Intranet systems. |
| Home address | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Provision to the Facilities area as needed for the delivery/pickup of corporate items; Usage by the IT Department regarding registrations in the internal Atlantis and Intranet systems. |
| Photo | Internal registration within the Human Resources Department, making it possible to identify the person as an “employee” and allowing access to the physical and virtual facilities of the Nuno//Fracht Group; Registrations of fairs, internal and business events that can be published on the intranet and social networks for brand engagement. |
| Labor call history | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; |
| Position/function | Carrying out internal registration with the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration in the operational systems of the department to which the employee is assigned; Registration with health and life insurance companies and/or operators, suppliers of corporate and occupational health benefits; preparation of powers of attorney (if applicable); Usage by the IT Department for internal user control and availability on the internal Intranet system. |
| Physical and behavioral characteristics | Internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; |
| Medical history | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration with health and life insurance companies and/or operators, corporate and occupational health benefits suppliers; |
| CTPS (Brazilian Work and Social Security Card), Voter ID, PIS number, CNS (National health card), Military status, Civil status, Payment Passport | The internal registration within the systems used by the Human Resources Department, which will monitor the employee’s professional development; Carrying out the necessary registrations by the Human Resources Department with the Bodies linked to the Ministry of Labor and issuing the employee’s labor/social security documents; Registration with health and life insurance providers, corporate and occupational health benefits providers. |
| Passport | The internal registration within the systems used by the Human Resources Department to book trips on behalf of the company, if applicable. |
| Data on dependents (full name, date of birth, gender, ID, social security number, ethnicity, place of birth, medical history) | Carrying out the necessary registrations by the Human Resources Department within the agencies linked to the Ministry of Labor; Completion of registrations with insurers and/or health and life insurance providers. |
| Bank details | |
| Bank, branch number, current account number, identified digit (if applicable), PIX key (if applicable) | Registering with the Finance Department for payments of salaries, bonuses, benefits and reimbursements (if applicable) |
| Digital identification data | |
| IP address | Corporate control of the tools delivered by the Nuno//Fracht Group, in accordance with the internal Code of Ethics. |
| Screens accessed | Corporate control of the tools delivered by the Nuno//Fracht Group, in accordance with the internal Code of Ethics. |
| Session ID | Corporate control of the tools delivered by the Nuno//Fracht Group, in accordance with the internal Code of Ethics. |
| Cookies | Corporate control of the tools delivered by the Nuno//Fracht Group, in accordance with the internal Code of Ethics. |
| Biometric data | |
| Fingerprints | Registration and access to the physical premises of the Nuno//Fracht Group. |
You are solely responsible for the accuracy and veracity of the data provided, and remain liable for any inconsistencies or inaccuracies reported to the Nuno//Fracht Group.
You acknowledge and consent to the sharing of your data for the purposes outlined above, as well as for any potential Nuno//Fracht Group internal organizational needs.
4. How your data is protected and what precautions you should take
You are responsible for the confidentiality of your personal data and should always be aware that sharing passwords and access data violates this Policy and may compromise the security of your data.
Thus, it’s very important that you protect your data from unauthorized access to your computer, account or password, and make sure you always close your computer’s tabs when stepping away from your equipment.
Internally, the personal data collected is only accessed by duly authorized professionals, adhering to the principles of proportionality, necessity and relevance to the objectives of the performed activities, in addition to the commitment to confidentiality and the preservation of its privacy under the terms of this Policy.
In the event that third-party companies process any personal data that is collected on behalf of the Nuno//Fracht Group, they must comply with the stipulated conditions in this policy and with information security standards, without exceptions.
5. The way your personal data and activity logs are stored
Personal data collected and activity logs are stored in a secure environment for as long as the relationship last between the parties, unless there is a deletion request or the consent to access is revoked.
You may, at any time, request information about your data from the Human Resources, Finance and Information Technology Departments, request any rectifications and object or even revoke your consent to access and use of such data.
6. Regarding the data whose owners are legal entities or individuals not directly linked to the Nuno//Fracht Group
It is common for logistics integrators to have access to the contact details of their clients’ representatives, suppliers, service providers and any assistants in order to carry out their internal activities.
With regard to the individuals whose information Nuno// Fracht Group employees will have access to, it should be clarified that their data protection rights are also protected by the guidelines of this Policy.
With regard to the legal entities whose information Nuno// Fracht Group employees will have access to, it should be clarified that they will be treated with confidentiality and secrecy, observing the specifics of each case.
7. Final provisions
In order to monitor compliance with data privacy regulations, Nuno//Fracht Group has set up a General Protection Law Committee, also known as a Data Protection Officer (DPO) or Data Officer, with the professionals Ana Godoi, representing the Human Resources Department, Arthur Moura, representing the Information Technology Department and Natalia Caetano representing the Legal Department.
This Policy is subject to constant improvement and enhancement. We reserve the right to modify it at any time, depending on the purpose or need, such as to adapt and comply with a provision of law or a rule that has equivalent legal force.
In the event of updating the present document and there’s a requirement for a new data collection, you will be notified through the official contact channels to express your consent and be aware of the purpose of the collection.
If any point of this Policy is deemed inapplicable by a data or judicial authority, the other conditions will remain in full force and effect.
This Policy will be interpreted in accordance with the Brazilian law, in the Portuguese language, and the São Paulo/SP court will be elected to settle any dispute involving it.
NUNO//FRACHT Group
Denise Aparecida Alves
Glossary
Personal Data: Data relating to an identified or identifiable natural person.
Sensitive Personal Data: personal data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data relating to health or sex life, genetic or biometric data, when linked to a natural person.
Processing: any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Data subject: natural person to whom the personal data being processed refers;
Controller: a natural or legal person, whether governed by public or private law, who is responsible for decisions relating to the processing of personal data;
Operator: a natural or legal person, governed by public or private law, who processes personal data on behalf of the controller
Data Protection Officer (DPO): person appointed by the controller and operator to act as a communication channel among the controller, data subjects and the National Data Protection Authority (ANPD);