Fluxys Brasil SA (hereafter: we, us or Fluxys), a public limited company in the process of being incorporated under Brazilian law, is committed to protecting and respecting your privacy.
This policy sets out the basis on which any information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your information and how we will use it.
- Information we collect from you;
- Uses made of your information;
- Legal basis;
- Disclosure of your information;
- Your rights;
- Security of collected information;
- Retention of your information;
- External websites;
- Identity of data controller – contact details.
1. Information we collect from you
We will collect and process the following information about you:
Information you give us.
This is information about you that you give us e.g. by filling in forms on http://www.fluxys.com.br (hereafter: our website) or by corresponding with us by phone, email or otherwise. It includes information you provide to us with a view to managing and executing contracts we have with you or your company, information required for our corporate housekeeping. The information you give us may include your name, date of birth, address, email address, phone number, nationality, identity card, financial and credit card information.
Information we collect about you.
During each of your visits to our website we will automatically collect the following information:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- your device ID, device type;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), web pages you viewed or searched for, page response times, downloaded files, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used;
- your location (region).
3. Uses made of your information
We use the information we hold about you in the following ways:
Information you give to us.
We will use this information:
- to carry out our obligations arising from any contracts entered into with you/your company and to provide you with the information and services that you or your company request from us;
- to notify you/your company about changes to our services;
- to organise events;
- to ensure that the content from our website is presented in the most effective manner for you and for your computer/device;
- to follow up on a report about a (potential) emergency situation;
- to comply with our obligations in connection with corporate housekeeping.
Information we collect about you.
We will use this information:
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer/device;
- to allow you to participate in interactive features of our website, when you choose to do so;
- as part of our efforts to keep our website safe and secure.
4. Legal basisYour information is being collected and processed on the following legal bases:
- if it is necessary for pursuing our legitimate interests, insofar as these interests are not overridden by your fundamental rights and freedoms, e.g. we use your information to know your preferences so as to be able to better personalise our website, to prevent fraud and to secure our website, as well as for corporate housekeeping purposes, as part of normal business operation;
- if it is necessary for performing the contract we have with you or with the company for which you are employed, e.g. the collection of personal data in connection with contracts under which you or the company for which you are employed provide(s) services or material to us or perform(s) work for us;
- when you consented to this, e.g. if you have given your prior express consent by means of completing a subscription form (with the possibility of unsubscribing at any time) with a view to sending you newsletters and/or financial information or by means of completing an online contact form with a view to being invited to Fluxys events or visiting our infrastructure.
5. Disclosure of your information
You agree that we have the right to share your information with selected third parties including:
- other entities within the Fluxys group;
- public authorities (including judicial and police authorities);
- banks and insurers;
- our suppliers of IT-related services;
- our suppliers of marketing-related services;
- analytics and search engine providers that assist us with the improvement and optimisation of our website, e.g. Google.
We will also disclose your information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets;
- if we or almost all of our assets are acquired by a third party, in which case information held by us about our customers may be one of the transferred assets;
- if we are under a duty to disclose or share your information in order to comply with any legal obligation or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with public authorities (including judicial and police authorities) in the event of, for example, a cybersecurity incident;
6. Transfer of your information
If we transfer such information outside of Brazil, we will make sure that the information is protected by the safeguards in accordance with the applicable data protection legislation
7. Your rights
You have certain rights regarding the information we hold about you. These rights can be exercised by contacting us as set out below:
- you have the right to access the information we keep about you – this is because we want you to be aware of the information we have about you and to enable you to verify whether we process your information in accordance with the applicable data protection laws and regulations;
- you have the right, under certain circumstances, to block or stop the further use of your information. When processing is restricted, we can still store your information, but we can no longer use it;
- if your information is inaccurate or incomplete, you have the right to request the rectification of your information;
- you have the right, under certain circumstances, to request the deletion or removal of your information from our systems;
- you have the right to lodge a complaint about the way we handle or process your information with your national data protection authority;
- if our processing of your personal information is based specifically on your consent, you have the right to withdraw that consent at any time. This includes your right to withdraw consent to our use of your information for direct marketing purposes;
You also have the right to object to certain types of processing, including processing for direct marketing purposes.
However, note that we may need to retain certain information, for example for security, legal or administrative purposes (e.g. keeping of accounting records).
For all requests set out above, please contact us by sending an email to the email address mentioned in section 12 below. This email needs to have in the subject line “data privacy request” and include a copy of your identity card or another proof of your identity (e.g. driver’s licence) to help us prevent unauthorised individuals from accessing, changing or deleting your information. We will respond to your request as soon as practically possible. If it appears that we need more than one month (from receipt of your request) to deal with your request, we will let you know.
8. Security of collected information
All information you provide to us is stored on our secure servers.
We have implemented a number of security features throughout our website in order to prevent the unauthorised release of or access to collected and/or received information. We have endeavoured to create a secure and reliable website for you, but note that the confidentiality of any communication or material transmitted to or from us or any other party via our website or email cannot be guaranteed. We accept no responsibility or liability for the security of information transmitted via these methods.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Finally, we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Retention of your information
In particular, we will only keep:
- your information relating to your online query for as long as needed to provide you with the requested information;
- information relating to you that we collect as mentioned above or that you provide to us for as long as it is required to fulfil the purpose for which it was collected;
- the processing of your information is necessary in connection with any actual or potential dispute (e.g. we need this information to establish or defend legal claims), in which case we will keep your information until the end of such dispute; and/or
- the retention is necessary for us to comply with any legal or regulatory obligation (e.g. for tax or security purposes), in which case we will keep your information for as long as required by that obligation.
10. External websites
12. Identity of data controller – contact details
If you feel that your rights have been breached in the context of the processing of your personal data, , please contact us so we can remediate such breach.