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    Privacy Notice

    This Privacy Notice applies to the users (“You” or “User”) of products or services provided by Ecorodovias Infraestrutura E Logística S.A. and its affiliated companies (“EcoRodovias” or “We/Us”) in Brazil.

    The Privacy Notice informs You of how EcoRodovias processes your personal data in connection with its products and services. This includes general information on what type of personal data is collected and used, for what purposes, how long it will be used, with whom it can be shared and what your rights are regarding your personal data. You may receive additional information about the use of your personal data depending on the product, service or company affiliated to EcoRodovias offering such product or service. Unless otherwise informed to You, EcoRodovias is responsible for processing the personal data referred to in this Privacy Notice.

    Collection and use of your personal data

    Depending on the products or services that You use and on your interaction with EcoRodovias, We may collect and use your personal data.

    The following personal data categories can be processed: Registration and identification data: name, email, telephone, identification document number and/or copy, gender, marital status, date of birth, full address;

    Financial data: bank branch and account, among others;

    Technical data:  information about your device, electronic identifiers, cookies, physical location (based on your IP address) and other similar technical information;

    Data related to your use of EcoRodovias products or services:  data on traffic tickets, records of requests and complaints, your vehicle data, unique identifier numbers related to the use of service, your image;

    Sensitive personal data: data related to health, biometric data and others. Personal data collected may be obtained directly by EcoRodovias from You, provided or shared by third parties, or obtained through publicly available databases. EcoRodovias will ensure that all personal data is collected in compliance with law and as strictly necessary for the purposes informed in this Privacy Notice.

    Purposes for processing your personal data

    EcoRodovias processes your personal data for the following purposes:

    • To supply products or services, including in highways and ports;
    • To fulfill User requests;
    • To receive and collect money, collect taxes and tolls, including through automatic payment devices;
    • To reimburse Users, when applicable;
    • To manage the safety of EcoRodovias’ services, including monitoring through video and image;
    • To provide, maintain and monitor the website, apps and other digital platforms of EcoRodovias;
    • To communicate with You, including to send information requested by the User and/or to send promotional messages;
    • To manage relations with Users, including through advertising and marketing actions;
    • To manage the messages received through the “Talk to Us” section of the EcoRodovias website;
    • To conduct surveys about User satisfaction with the products and services offered by EcoRodovias, through different channels;
    • To roll out processes related to the social and environmental impact of the activities of EcoRodovias, including for compliance with legal or contractual obligations of EcoRodovias;
    • To launch social projects jointly with communities or other partner organizations;
    • To provide information requested by regulatory and police authorities about incidents at services managed by EcoRodovias, in strict compliance with the legal or regulatory obligations of EcoRodovias;
    • In cases when Users personally visit any EcoRodovias unit;
    • To prevent and combat frauds of any type, including avoiding charges of any nature;
    • To register vehicles exempt from tolls upon request from eligible Users;
    • To provide vehicle maintenance and removal services;
    • To provide mechanical assistance services, change tires and deploy the EcoRodovias contingency plan in case of operational emergency;
    • To provide emergency services of any nature to protect the life and physical integrity of Users;
    • To monitor general traffic, especially heavy vehicles;
    • To protect public property, third-party property and the regular exercise of rights of EcoRodovias, including at the administrative, legal or arbitration spheres;
    • To audit the products and services of EcoRodovias pursuant to legal obligations, including in the context of concession agreements, permits or authorizations;
    • To respond to authorities in case of lawsuits or administrative proceedings, in compliance with legal, regulatory or other duties required under bidding processes from EcoRodovias.

    Apart from the above purposes, we may process your sensitive personal data in the following cases:

    • Provision of primary or pre-hospital care to Users;
    • Access to electronic identification and authentication systems in connection with the products and services of EcoRodovias; and
    • For the regular exercise of EcoRodovias’ rights, including under contracts and lawsuits or administrative proceedings;

     

    With whom we share your personal data

    EcoRodovias will not share your personal data with third parties, except for the purposes listed above, in the following cases:

    • With affiliated companies within the EcoRodovias Group;
    • With service providers and business partners of EcoRodovias that process personal data on behalf of EcoRodovias, without the right of independent use of such personal data;
    • With service providers and business partners of EcoRodovias to combat toll evasion and other illicit conduct with risk of high damage, in the interests of EcoRodovias and to protect third parties.

     

    • With the Government, in compliance with legal and contractual obligations, including under concession agreements, permits or authorizations;
    • With police authorities and other government authorities, as required by law or when reasonably necessary to protect the rights, property and/or safety of the User, third parties and/or EcoRodovias; and
    • When we have obtained your consent to share your personal data.

    Where your personal data is processed

    The personal data of Users may be processed in Brazil or other countries, such as the United States, always in compliance with contractual obligations related to confidentiality, integrity, information security and other applicable legal safeguards required by law.

    Keep in mind that countries may have laws and protection levels related to personal data that differ from those in Brazil. EcoRodovias will adopt the measures required by law for any international transfer of personal data, to ensure the protection of the rights of personal data Subjects when such data is transferred to other countries.

    How we protect your personal data

    EcoRodovias adopts and maintains a continuous process of improving the technical and organizational measures to safeguard personal data and prevent security incidents, leaks or improper use of personal data.

    EcoRodovias applies physical security procedures for access to its offices and premises. We also adopt information security measures, such as security software, continuous monitoring of equipment, network and servers of EcoRodovias, control and maintenance of records of access to systems and apps used in EcoRodovias, among others.

    Employees, service providers and business partners of EcoRodovias are bound by confidentiality obligations. Only employees and service providers that need access to personal data to perform their activities have access to such personal data.

    For how long is your personal data kept

    EcoRodovias retains your personal data for the time necessary to achieve the purposes listed in this Privacy Notice, including to comply with legal and contractual obligations under concession agreements, permits or authorizations. For specific information on data retention periods, You can contact the personal data protection officer of EcoRodovias by sending an email to canaldeprivacidade@www.ecorodovias.com.br.

    What are your rights and how to exercise them

    Pursuant to Federal Law 13,709/18 – General Personal Data Protection Law, the User has the following rights, which may be exercised in certain circumstances upon a request, pursuant to article 18 of said law:
    • confirmation of processing of your personal data;
    • access to your personal data;
    • correction of incomplete, inaccurate or outdated personal data;
    • anonymization, blocking or deletion of unnecessary and excessive data or data that was not processed in compliance with the GDPL;
    • portability of personal data to another product or service supplier, subject to the regulations of the national authority;
    • request for deletion or anonymization of personal data processed based on your consent, except when law authorizes the maintenance of such data for other reasons;
    • information on public and private entities with which EcoRodovias has shared your personal data;
    • information on the possibility of not consenting to the processing of your personal data and the consequences of such an action; and
    • withdrawal of your consent.

     

     

    Updated to this Privacy Notice and Contact Information

    EcoRodovias takes the rights of Users seriously and will, pursuant to law, facilitate the fulfillment of requests to exercise the rights.

    This Privacy Notice may be updated from time to time. All changes will take effect starting from the date of update, unless otherwise informed to You. We will employ efforts to inform you of updates to this Privacy Notice, especially through our website.

    For comments, questions or requests for additional information on this Privacy Notice and/or other issues related to personal data protection conducted by EcoRodovias, contact the department personal data protection officer by sending an email to:  canaldeprivacidade@www.ecorodovias.com.br.

    Frequently Asked Questions

    What is the General Personal Data Protection Law (GDPL)?

    The General Personal Data Protection Law (Federal Law 13,709/18), or GDPL, establishes the rules for processing the personal data of a Subject, that is, a living natural person.

    What is personal data and sensitive personal data?

    Personal data is information that identifies or allows the indirect identification of the Subject. Examples of identifying Personal Data: name, unique document number (RG/CPF/CNH), email, telephone etc.; Examples of Personal Data that enable indirect identification: IP, geolocation, license plate etc.
    Sensitive Personal Data refers to Personal Data that may result in some of discrimination of the Subject. E.g.: race or ethnicity, religious conviction, political opinion, membership of trade union or religious, philosophical or political organization, information related to the health or sexual life, genetic or biometric information.

    What is Personal Data Processing?

    Processing means all and any operation carried out with your Personal Data, from collection to disposal.

    Do EcoRodovias Group companies process Personal Data?

    Yes, EcoRodovias Group companies process Personal Data. Data is processed in diverse situations, depending on how the Subject interacts with EcoRodovias Group companies. For example, these process the personal data of highway users, clients of EcoPorto and EcoPátio, job applicants, employees, interns, apprentices, workers, suppliers and investors (natural persons).

    Do EcoRodovias Group companies share Personal Data?

    EcoRodovias Group companies do not share the Personal Data of Subjects with third parties, except in cases established by law. The following list shows a few situations when Personal Data can be shared:

    • Between the companies of EcoRodovias Group;
    • With the service providers and business partners of EcoRodovias Group;
    • With the Government to comply with legal/regulatory and contractual obligations, including under concession agreements, permits or authorizations;
    • With police authorities and other government authorities, as required by law or when reasonably necessary to protect the rights, property and/or safety of people; and

    When we have obtained your consent to share your personal data.

    Do EcoRodovias Group companies comply with GDPL?

    Yes, the EcoRodovias Group companies comply with GDPL  EcoRodovias Group is aware of the significance of privacy and the importance of the Personal Data of Subjects and hence adopts several technical and administrative measures to protect them. It also adopts transparency practices by providing Privacy Notices on its websites and apps.

    What are the Subject’s Rights?

    Subjects have several rights assured by the GDPL, such as:

    • Access: right to know what Personal Data is processed.
    • Confirmation of Processing:right to know if Personal Data is processed.
    • Rectification: right to rectify incorrect, inaccurate and/or outdated Personal Data.
    • Deletion: right to request the deletion of Personal Data. Note that, depending on the context, Personal Data may be retained by EcoRodovias Group companies to comply with legal and/or regulatory obligations or to safeguard their rights and interests if they become defendants in lawsuits.

     

    How can Subjects exercise their Rights provided for in the GDPL?

    Subjects may exercise their rights established in the GDPL by sending their request to one of the following channels:

    • Privacy Portal;
    • Email: canaldeprivacidade@www.ecorodovias.com.br; or
    • Physical correspondence to: ECORODOVIAS CONCESSÕES E SERVIÇOS S.A., C/O: Data Protection Officer, Rodovia dos Imigrantes, (SP-160), s/n, Km 28,5, Jardim Represa, São Bernardo do Campo/SP, CEP: 09845-000.