PRIVACY POLICY
Version28/01/2022
This Privacy Statement explains how Grupo Jacto collects and uses personal data and describes the rights the Individual has with respect to their personal data.
Grupo Jacto considers sensitive and relevant the personal data provided by you ("User") when using various websites, platforms, systems and applications ("Pages") of Grupo Jacto. The present Privacy Statement ("Policy") serves to regulate in a simple, transparent and objective way which data and information will be obtained as well as when they can be used.
1. WHAT DATA ARE COVERED?
In this Statement, "personal data" means any information relating to an Individual that can be identified directly or indirectly, specially by means of an identifier such as a name, an identification number, location data or an online identifier. Personal data also refers to one or more specific factors of an individual's physical, physiological, genetic, mental, economic, cultural, or social identity.
It also includes special categories of personal data (special category data) from which the data of an Individual can be determined or inferred.
2. HOLDER'S RIGHTS
It is important to emphasize that the Individual always has rights related to privacy and protection of their data, and Grupo Jacto, besides being concerned with the security of these data, is also concerned that the Individual has access and knowledge of all their rights. These will be available to the Individual through the link Portal Requisition for Customer Services from Data Subjects, where the Controller of Personal Data, Mr. Márcio Machado, will respond to data subjects via the link:
https://privacy-central.securiti.ai/#/dsr/3075d497-c253-43ce-82f9-d59b28166297
In addition, there is the Consent Preference Center which allows any data subject to access and update their data use consent preferences. To do so, access the link:
Thus, all the rights the data subject holds have been summarized with a brief explanation of each below:
• Access
This right allows the Individual to request and receive a copy of the personal data that Grupo Jacto holds about the data subject, as well as to request confirmation of how Grupo Jacto processes the personal data and/or any other information that is important to the Individual.
The Individual's identity will need to be confirmed before the data subject receives access to their personal data.
In case the Individual does not want to fill out the form made available on Grupo Jacto’s electronic channel, they may choose to write a registered letter, with the following items:
• Full name;
• Full address:
• Phone number for contact during working hours:
• CPF (tax payer registry) number:
• Eventually, file names or specific types of records to which the Individual requests access, including specific dates of those records, whenever possible.
The Individual should send the registered letter with the request to Máquinas Agrícolas Jacto S.A., Rua Doutor Luiz Miranda, nº 1.650, Bairro Pirajá, in the city of Pompeia, State of São Paulo, CEP 17580-000, to the attention of the Data Protection Officer at the Privacy Office.
All formal access requests will be directed to the Privacy Officer who will review each request. The Individual will be informed whether access to the requested records will be granted or denied and what exemptions apply. The Privacy Officer will also receive and solve all privacy complaints received by Grupo Jacto.
• Rectification
This right allows the Individual to request the correction, supplementation and/or rectification of their personal data, should they identify any error and/or mistake in them. However, to be effective this correction, Grupo Jacto must check the validity of the data that the Individual is providing.
If the Individual believes there is an error in their personal data, the Individual has the right to request that the information be corrected through the Data Holder Request Service Portal.
Grupo Jacto may request the Individual to provide documentation to show where Grupo Jacto files are incorrect. If the request is well-founded, Grupo Jacto will change the incorrect data within 30 (thirty) days and will inform the Individual as soon as the requested correction is completed.
Grupo Jacto will inform any person or organization to which their personal data has been disclosed within one year before the Individual requests correction and inform them of the correction or statement of disagreement.
• Deletion
This right allows the Individual to request Grupo Jacto to delete their personal data from Grupo Jacto's systems. All data collected will be deleted from the servers when the Individual so requests or when they are no longer necessary or relevant to offer the services provided by Grupo Jacto, unless there is any other reason for their maintenance, such as any legal obligation to retain data or the need to preserve them to protect the rights of Grupo Jacto.
Grupo Jacto does not store personal data without a predefined and documented purpose. Laws that require the deletion of personal data are followed if the reason for their collection and storage no longer exists.
Personal data that Grupo Jacto maintains is also based on the consent that the Individual has provided, should the Individual wish to be removed from Grupo Jacto's systems prior to the stated retention period.
If the Individual has registered their personal data with Grupo Jacto, they can deactivate their account at any time. For security reasons, Grupo Jacto has implemented a fifteen-day (15) grace period after the Individual requests deletion of the account; however, logging into the account during the grace period will reactivate the account. To avoid representation, once the account is deactivated and after the grace period has expired, the account will be irrevocably suspended.
• Objection to processing
The Individual also has the right to object to the data processing by questioning where and in what context Grupo Jacto is processing their personal data for different purposes. In certain situations, it may be demonstrated that Grupo Jacto has legitimate reasons for processing the Individual's data, which may override the Individual's rights if, for example, they are essential to the provision of Grupo Jacto's service.
• Data Portability
Grupo Jacto will provide the Individual, or a third party that the Individual has elected, with their personal data in a structured format and confirmation of the transfer to the required company.
The Individual may obtain and reuse the personal data held by Grupo Jacto for its own purposes in different services. Grupo Jacto allows you to easily move, copy or transfer personal data from one Information Technology environment to another, in a safe and secure manner, without impairing its usability. This right applies to personal data held by Grupo Jacto where the processing is automated and used, considering the provision of services, within the contract and/or relationship that the Individual has with Grupo Jacto or where such processing was based on the consent that the Individual provided to Grupo Jacto.
• Confirmation
Through this right it is possible to confirm whether there are personal data of the Individual in the databases of Grupo Jacto.
• Restriction of Processing or Withdrawal of Your Consent
This right allows the Individual to request to suspend the processing of their personal data in the following scenarios:
(a) if you want Grupo Jacto to establish the accuracy of the data; (b) when you need the data to be kept even if Grupo Jacto no longer needs it as necessary to establish, exercise or defend legal claims; or (c) if you object to the use of your data, but in this case, Grupo Jacto needs to check whether there are legitimate reasons to use it.
The Individual has the right to withdraw their consent through the channel for Responding to Data Subject Requests; however, this will not affect the legality of any processing done previously. If the Individual withdraws their consent, Grupo Jacto may not be able to provide certain services.
It may be necessary to request specific information from the Individual to help Grupo Jacto confirm their identity and ensure their right to access their personal data (or to exercise their other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it.
3. PURPOSES FOR WHICH GRUPO JACTO PROCESSES PERSONAL DATA
Grupo Jacto processes personal data for various purposes. This personal data is collected directly from the Individual, for example, if the Individual hires Grupo Jacto, if the Individual visits Grupo Jacto Pages, if the Individual submits their contact information to receive marketing communications from Grupo Jacto, or submits a job application through Grupo Jacto career website. Alternatively, Grupo Jacto processes the personal data of the Individual in the context and at the time the Individual provides the personal data. Finally, Grupo Jacto also obtains the Individual's personal data through publicly available sources, such as LinkedIn and other social media. This privacy notice is intended to cover all of the above scenarios.
3.1. VISITORS AND USERS OF GRUPO JACTO PAGES
The personal data we collect about the Individual when they visit or use Grupo Jacto Pages falls into several categories.
3.1.1. Information that the Individual voluntarily provides
Grupo Jacto collects personal data the Individual voluntarily provides through Grupo Jacto Pages, for example, when filling out online forms to hire Grupo Jacto, signing up for a newsletter, using one of the online referral tools, signing up to receive marketing communications, participating in surveys, or registering for events that Grupo Jacto hosts.
Grupo Jacto does not intentionally collect sensitive category data unless the Individual provides such data. While there may be free text boxes on the Pages where the Individual can enter any information, Grupo Jacto does not intend to process confidential information. The Individual is not required to provide, and should not disclose, sensitive personal information in the free text boxes. If the Individual chooses to provide any sensitive personal information in this manner, the Individual must acknowledge that they agree to the collection and processing of that sensitive information.
3.1.2. Information we collect automatically
When the Individual visits Grupo Jacto Pages, certain personal data is automatically collected from the Individual's device. Specifically, the data that is automatically collected includes information such as IP address, device type, unique device identification number, browser type, broad geographic location (e.g., location by country or city), and other technical information. Information is also collected on how the device interacted with Grupo Jacto Pages. Collecting this information allows Grupo Jacto to better understand the visitors to our Pages, where they come from and what content on the Pages interests them. Grupo Jacto uses this information for internal analysis purposes and to improve the quality and relevance of the Pages for visitors. Information will be collected using cookies and similar tracking technology as explained in the Cookie Policy.
The purposes for which Grupo Jacto processes the personal data of the Individual as a visitor or user are:
• To administer and manage Grupo Jacto Pages, including to confirm and authenticate the identity of the Individual, and prevent unauthorized access to restricted areas of Grupo Jacto Pages.
• To personalize and enrich the Individual's experience while browsing by displaying content that is most likely to be relevant and of interest to you;
• Analyze the data of visitors to the pages of Grupo Jacto.
• To determine the company, organization, institution or agency for which the Individual works or is otherwise associated with.
• Perform benchmarking and data analysis.
• Understand how visitors use the features and functions of Grupo Jacto Pages.
• Monitor and enforce the applicable terms of use.
• Conduct quality and risk management reviews.
• Any other purpose for which the Individual has provided information to Grupo Jacto.
The legal fundamentals for processing personal data of visitors to Grupo Jacto Pages are:
• Legitimate interest in the effective delivery of information and services to the Individual, and in the effective and lawful operation of Grupo Jacto's business.
• Legitimate interest in developing and improving Grupo Jacto Pages and the Individual's experience.
• Explicit consent of the visitor.
3.2. CUSTOMERS
When the Individual hires Jacto Group products or services, personal data is collected and used when there is a valid business reason to do so in connection with this instrument.
Most of the personal data that is collected and used to provide services and products is provided voluntarily by (or collected by Grupo Jacto from third-party sources at the request) of the customer. Therefore, if the Individual is a customer of Grupo Jacto, it will generally be clear to the Individual what personal data is collected and used.
Grupo Jacto uses the information collected:
• To render services or provide products.
• To manage and maintain contractual relationships.
• For accounting and tax purposes.
• For marketing and business development.
• To comply with legal and regulatory obligations.
• To establish, exercise or defend legal rights.
• For historical and statistical purposes.
The legal fundamentals for processing personal data of customers to Grupo Jacto Pages are:
• Contract execution.
• Compliance with a legal or regulatory obligation.
• Legitimate interest in providing the Individual with continuous, consistent and high-quality services and products and ensuring prompt payment of any fees, costs and debts for the services provided and products made available
3.3. INDIVIDUALS WHO COMMUNICATE WITH GRUPO JACTO BY EMAIL
Grupo Jacto uses a variety of tools to maintain the security of the Information Technology infrastructure, including email facilities. Examples of such tools are:
• Systems that check incoming emails to Jacto Group recipients for suspicious attachments and URLs in order to prevent malware attacks.
• Tools that provide endpoint threat detection to detect malicious attacks.
• Tools that block certain content or websites.
If the Individual corresponds via email with a Jacto Group recipient, their emails will be scanned by the tools that Jacto Group uses to maintain the security of the Information Technology infrastructure, which may result in authorized Jacto Group persons other than the intended recipient reading the content.
Legal reasons for processing personal data of individuals who correspond with Grupo Jacto via email:
• Legitimate interest in protecting the Information Technology infrastructure from unauthorized access or data leakage.
• Legitimate interest in analyzing email traffic
3.4. JOB APPLICANTS
Grupo Jacto collects information from and about candidates for employment opportunities available in companies belonging to Grupo Jacto. The information collected, how it is used and when it is collected may vary. In general, the data that Grupo Jacto collects about job applicants includes resumes ("CV"), identification documents, academic records, work history, employment information, and references.
Grupo Jacto uses the candidate's personal data to match their skills, experience and education with specific positions offered by Grupo Jacto. This information is passed on to the relevant hiring demanders and the people involved in the recruitment process to decide whether to invite the candidate for an interview. Grupo Jacto will collect more information if the candidate is invited to the interview phase (or equivalent) and other subsequent phases. This information includes interview notes, assessment results, feedback, and offer details.
As part of recruitment activities, including applications and integration, special category data is also collected from applicants where there is a legal obligation to do so. This information is relevant to the candidate's future employment in Grupo Jacto work environment or for the future provision of employment benefits, or with the explicit consent of the individual, where the collection of such information is permitted by law. For example, where permitted by the applicable law, Grupo Jacto will collect information about an individual's disabilities to analyze workforce diversity. Once integrated, an individual's provision of disability information will also be used to provide a suitable work environment.
Grupo Jacto recruiting tools and Pages contain privacy notices explaining why and how personal data is collected and processed by these Pages. Grupo Jacto encourages individuals using the recruitment tools and Pages to consult the privacy notices available on those tools and Pages.
Grupo Jacto collects personal data about candidates from the following sources:
• Directly from the Individual – for example, information that the Individual provided when applying for a position directly through Grupo Jacto's careers website
• From recruitment agencies – for example, when a recruitment agency that has the Individual's data contacts Grupo Jacto to suggest them as potential candidate;
• Through publicly available online sources – for example, if the Individual has a professional profile published online (e.g. on a professional networking website such as LinkedIn)
• By reference – for example, through a reference from an employee or former employee, or current employer, or someone the Individual has entrusted with the reference.
The legal fundamentals for processing personal data of job applicants to Grupo Jacto Pages are:
• Explicit consent of the applicant.
• Legitimate interest in attracting, identifying and pursuing talent.
• Legitimate interest in processing and managing applications for positions in Grupo Jacto, including candidate selection.
• Legitimate interest in hiring and integrating candidates, making an offer to successful candidates and performing pre-employment screening checks.
• Legitimate interest in managing Grupo Jacto's career websites (including performing statistical analysis).
3.5. SUPPLIERS
Grupo Jacto processes personal data about suppliers (including subcontractors and individuals associated with suppliers and contractors) to manage the relationship and contract, and to receive services from suppliers.
Personal data processed is generally limited to contact information (name, employer name, phone, email, and other contact details) and financial information (payment-related information).
The legal fundamentals for processing personal data of suppliers are:
• Contract execution.
• Compliance with a legal or regulatory obligation
• Legitimate interest in managing payments, fees and charges and collecting and recovering any money due to Grupo Jacto.
4. DATA SHARING
Grupo Jacto transfers or discloses the personal data that is collected to third-party service providers (and their subsidiaries and affiliates) that are hired by Grupo Jacto to support internal auxiliary processes.
Only third-party service providers who are obliged to maintain adequate levels of data protection, security and confidentiality, and who comply with all applicable legal requirements for the transfer of personal data outside the jurisdiction in which it was originally collected are used. For data collected in the European Economic Area (EEA) or concerning data subjects in the EEA, Grupo Jacto requires an appropriate transfer mechanism as necessary to comply with applicable law.
Grupo Jacto processes personal data of individuals:
• If required by applicable law.
• In connection with a reorganization or combination organization of Grupo Jacto with another organization.
• If Grupo Jacto believes that such disclosure is appropriate to enforce or apply terms of engagement and other agreements or otherwise protect and defend the rights, property or safety of Grupo Jacto.
• In order to comply with a legal proceeding, court order or other legal obligation, or a regulatory or governmental inquiry.
Or
• With the individual’s consent
Third party recipients of personal data include:
• Professional advisors, such as law firms, tax advisors or auditors.
• Healthcare and dental insurance companies.
• Tax, customs and excise authorities.
• Regulatory and other professional agencies.
• Credit reference agencies.
• The courts, police, and law enforcement agencies
• Government departments and agencies
• Service providers.
5. SAFETY
Grupo Jacto protects the confidentiality and security of the information it obtains in the course of its business. Access to such information is limited and policies and procedures are in place to protect information from loss, misuse, and improper disclosure.
6. KEEP YOUR DATA UPDATED
Grupo Jacto maintains the accuracy and integrity of the personal data that has been collected. It is important that the Individual informs about any updates to their contact information or other personal data so that Grupo Jacto has the most updated information. You can open a request through the Data Subject Request Portal.
7. RETENTION
Jacto Group's policy is to keep personal data only as long as is necessary for the purposes described. Retention periods may vary and are defined according to applicable regulatory requirements.
In order to meet professional and legal requirements, establish, exercise or defend legal rights, and for archival and historical purposes, Grupo Jacto needs to retain information for significant periods.
8. CONTACT GRUPO JACTO
If you believe that your personal data has been used in a manner inconsistent with this Statement or if you have questions, comments and/or suggestions, please contact us. We have a Personal Data Controller who is available through the Data Subject Request channel.
9. ALTERATIONS
We will update this privacy statement to reflect changes in our practices and services. Whenever we post changes, we will revise the "last updated" date at the top of this privacy notice. We recommend that you check this page from time to time to inform yourself of any changes to this privacy notice.
10. ABOUT THE PERSONAL DATA PROCESSING OFFICER (DPO)
Grupo Jacto appoints Mr. Márcio Machado as the person in charge for the management of personal data. Márcio Machado, who may be contacted through Data Subject Request channel at the link:
https://privacy-central.securiti.ai/#/dsr/3075d497-c253-43ce-82f9-d59b28166297
11. LAW AND JURISDICTION
This Policy shall be 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, and the jurisdiction of the court of Pompeia, State of São Paulo, shall be competent to settle any doubts and/or conflicts arising from this document.