Privacy Policy Agreement
 

This Policy applies to individuals who interact with PPA Group services. This Policy Agreement explains how your Personal Data is collected, used and disclosed by the PPA Group (PPA, Citrox and Celtron). It also tells you how you can access and update your Personal Data and take particular decisions about how your Personal Data is used.

 

This Policy covers our online and offline data collection activities, covering the Personal Data we collect through our various channels, including websites, apps, third-party social networks, Customer Service Center, points of sale and events. Please note that we may aggregate Personal Data from separate sources (website, offline event). As a part of this, we combine the Personal Data that was originally collected by different members of the PPA Group or distributing partners.  

 

If you do not provide us with the necessary Personal Data (we will indicate when appropriate, for example, by clarifying this information on our registration forms), we may not be able to provide you with our products and / or services.

 

This Policy Agreement provides us important information on the following areas:

 

  1. PERSONAL DATA SOURCES
  2. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT THEM
  3. . COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
  4. USES OF YOUR PERSONAL DATA
  5. DISCLOSURE OF YOUR PERSONAL DATA
  6. RETENTION OF PERSONAL DATA
  7. STORAGE AND / OR TRANSFER OF YOUR PERSONAL DATA
  8. ACCESS TO YOUR PERSONAL DATA
  9. YOUR CHOICES ON HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
  10. CHANGES TO OUR POLICY
  11. DATA CONTROLLERS AND CONTACT

 

 
 1 - PERSONAL DATA SOURCES

This Policy Agreement applies to Personal Data that we collect from or about you using the methods described below (refer to Section 2) from the following sources:

 

PPA websites. Consumer-oriented websites operated by or for the PPA Group, including websites that we operate under our own domains / URLs and minisites that we maintain on third-party social networks, such as Facebook (websites).

 
 

PPA mobile websites / apps. Consumer-oriented mobile websites / apps
operated by or for the PPA Group, such as smartphone apps
  
 

E-mail, text messages and other electronic messages. Interactions with electronic communications between you and the PPA Group.

  

PPA Customer Service Center. Communication with our Customer Service Center

 

Offline registration forms. Printed or digital records and similar ways in which we collect Personal Data, for example, mail, store exhibitions, contests and other promotions or events. 

 

Ad interactions. Interactions with our ads (for example, if you interact with one or more of our ads on a third-party website, we may receive information about such interaction).

 

Data created by us. During our interactions with you, we may create Personal Data about you (for example, records of your purchases on our websites).
 

Data from other sources. Third party social networks (such as Facebook, Google), market research (if the feedback is not anonymously provided), third party data aggregators, PPA Group promotional partners, public sources and data received when we acquire other companies.

 
 2 - PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT THEM

 

Depending on how you interact with the PPA Group (online, offline, by phone, etc.), we collect several types of information about you, as described below:

 

Personal contact information. They may include any information you provide to us that may allow us to contact you, such as your name, postal address, email, social media details or telephone number

 

Account login information. Any information that is necessary to provide you with access to your specific account profile. Examples may include your e-mail address, username, password in unrecoverable format and / or security question and answer.

 

Demographic information and interests. Any information that describes your demographics or behavioral features. Examples may include your date of birth, age or age group, gender, geographic location (for example, the ZIP code), favorite products, hobbies, interests and family or lifestyle information. 

 

Technical information about the computer / mobile device. Any information about the computer system or other device you use to access one of our websites or apps, such as the IP address used to connect your computer or device to the internet, the type of operating system and the type and version of the web browser. If you access a PPA Group website or app using a mobile device, such as a smartphone, the information collected will also include, whenever permitted, your phone's unique device ID, advertising ID, geographic location and other similar data from the mobile device.

 

Information on the use of websites / communication. As you browse and interact with our websites, we use automatic data collection technologies to collect certain information about your actions. This may include information such as which links you click on, which pages or content you view and for how long and other similar information and statistics about your interactions, such as content response times, download errors and duration of visits to certain pages. This information is collected by using automated technologies, such as Cookies (Browser Cookies, Flash Cookies) and web beacons, and also via thirdparty tracking. You have the right to object to the use of such technologies. For more details, refer to Section 4.

 

Market research and consumer feedback. This includes information that you voluntarily share with us about your experience of using our products and services.

 

Consumer-generated content. It refers to any content that you create and share with us on third party social networks or by uploading to one of our websites or apps, including the use of third party social network applications, such as Facebook. Examples may include photos, videos, personal stories or other similar content and media. Whenever permitted, we collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community resources, consumer engagement and third-party social networks. 

 

Third party social media information. It refers to any information that you publicly share on a third party social network or information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with us. Examples may include your basic account information (for example, name, email address, gender, date of birth, current city, profile photo, user ID, friend list etc.) and any other additional information or activities that you allow the third party’s social network to share. We receive your social media profile information (or parts of them) from third parties whenever you download an item or interact with a PPA Group web app on a third party social network such as Facebook, whenever you use a social media feature which is integrated with a PPA Group website (such as Facebook Connect) or whenever you interact with us through a third party social network. To learn more about how your information from a third party social network is obtained by the PPA Group or to choose not to share that social network information, visit the specific third party social network website. 

 

Financial and payment information. Any information we need to fulfill an order, or that you use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date etc.) or other payment methods (if available). In any case, we or our payment processing service providers handle financial and payment information in compliance with applicable laws, rules and security standards, such as the Payment Card Industry Secutiry Standards Council (“PCI DSS”). 

 

Customer Service Center Calls. Communications with a Customer Service Center may be recorded or heard, in accordance with applicable laws, for local operational needs (for example, for quality or training reasons). Payment card details are not stored. Whenever required by law, you will be informed of such recording at the beginning of your call. 

 

Sensitive Personal Data. We do not intend to collect or process sensitive personal data in the normal course of our activities. When it is necessary to process your sensitive personal data for any reason whatsoever, we will rely on your prior and express consent for any processing that is voluntary (for example, for marketing purposes). If we process your sensitive personal data for other purposes, we rely on the following legal bases: (i) crime detection and prevention (including fraud prevention); and (ii) compliance with applicable law (for example, to comply with our diversity reports).

 
 3 - COOKIES/ SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS

 

Cookies/ Similar Technologies. Refer to our Cookie Policy below to learn how you can manage your Cookie preferences and for detailed information about the Cookies we use and the purposes for which we use them.

 

What are Cookies? Cookies are small text files placed on your computer by websites you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to website owners.

 

How and why do we use Cookies? We use Cookies to improve the use and functionality of PPA websites to better understand how our visitors use the PPA Group websites, as well as the tools and services offered. Cookies help us to adapt the PPA Group websites to your personal needs, to make their use even easier, to receive feedback on consumer satisfaction and to communicate with you from other places on the internet. 
 

What types of Cookies are used on PPA's websites? 

We may use the following types of Cookies on the PPA Group websites: 

 

Session cookies - These are temporary cookies that are deleted once you close your browser. When you restart your browser and return to the website that has created the cookie, that website identifies you as a new visitor. 

 

Persistent Cookies - These Cookies remain in your browser until you manually delete them or until your browser deletes them according to the period of time established by the cookie. These Cookies will recognize as a visitor whenever you access it again. 

 

Necessary cookies Cookies that are strictly necessary for the operation of a PPA Group website. They allow you to browse through the website and use our resources. 

 

Cookies that send us information about you - These Cookies are placed on a PPA Group website and can only be read by that Website. They are known as “first party” cookies. 

 

We also place Cookies in advertisements from the PPA Group that are displayed on third party websites (For example, Facebook). We obtain information through these Cookies whenever you click or interact with the advertisement. In such situation, the PPA Group is placing a “third party” cookie. The PPA Group may use the information obtained by these Cookies to send you other advertisements that are relevant or interesting for you based on your previous online behavior. 

 

Cookies that send information to other companies - These cookies are placed on a PPA Group website by our partner companies (For example, Facebook or advertisers). They may use the data collected by these Cookies to anonymously send you targeted advertisements from other websites, based on your visit to the PPA Group websites. For example, if you use a social widget (For example, the Facebook icon) on a PPA Group website, it will register your “share” or “like”. Facebook (being the company that placed the cookie) will collect this data. 

 

Examples of Cookies placed on this Site: 

 

Cookie used /
type and
category

Objective

What data is
collected?

Details

Performance
Cookies

Type: Analytics Category: Persistent / Session / Third Party 

They help us understand how visitors interact with our website by providing information about the areas visited, time spent and any problems found, such as message errors. This helps us to improve the performance of our websites.

They do not
identify you as
an individual. All
data is collected
and aggregated
anonymously.
 

Google Analytics 
DoubleClick

Social Sharing Cookies (also known as “Third Party” Cookies or “Social Widgets”) Type: Social Media / Sharing Category: Third Party 

The social sharing offered on the website is performed by third parties. These third parties may place Cookies on your computer when you use social sharing features on the website, or if you have already logged in to them. These Cookies help to improve your experience on the website. They allow you to share comments / ratings / pages / beacons and help you access social networks and online social tools more easily. 

These Cookies may collect personal data that you have voluntarily disclosed, such as your username. 

Facebook 
Twitter 

Targeted Advertising
Type: Cross site tracking Category: Persistent / Session / Third Party 

These Cookies are used to deliver content through targeted advertising that is relevant to you and your interests, or to limit the number of times you see a specific ad. These Cookies also help us to measure the effectiveness of advertising campaigns on PPA Group and non-PPA Group websites. We may share this information with other parties, including our agencies. 

Most of these Cookies track users through
their IP
addresses.
 

DoubleClick 

Miscellaneous
Type: Flash Cookies Category: Persistent / Third Party 

Flash Cookies can store your preferences, such as volume control or high score in games, or display content based on what you see on the website to customize your visit. Our partners may provide some features on the website, such as promotions and games, and use Flash Cookies to collect and store your information. 

These Cookies may collect both anonymous and personal data. 

To learn more about how to manage privacy and storage settings for Flash Cookies, click here 

 

Other similar technologies. PPA Group websites also use other tracking technologies, including IP addresses, log files and web beacons, which also help us adapt the PPA Group websites to your needs. 

 

IP addresses. An IP address is a number used by computers on the network to identify your computer whenever you connect to the Internet. We may register IP addresses for the following purposes: (i) technical troubleshoot problems, (ii) maintainance of the protection and the security of the website, (iii) better understanding of how our websites are used, and, (iv) content better adapted to your needs, depending on the country you are in. 

 

Registry files. We may collect (or a third party on our behalf) information in the form of log files that record the website activity and collect statistics on the user's browsing habits. In general, these records are generated anonymously and help us collect (among other things) (i) the type of browser and the user's system; (ii) information about the user's session (such as its source URL, the date, time and which pages the user visited on our website and how long he stayed on it); and, (iii) other browsing or click count data (for example, website traffic report and single visitor count) 

 

Web beacons. We use web beacons (or transparent GIFs) on the PPA Group websitesWeb beacons (also known as "web bugs") are small sequences of code that allow the delivery of a graphic image on a web page in order to transfer data back to us. We use information from web beacons for a variety of purposes, including information about how a user responds to e-mail campaigns (for example, the time the email is opened, what link the user opens from the e-mail), website traffic reports, single visitor counts, advertising and e- mail auditing and reporting, and customization. 

 

Management of your Cookies / preferences. You must ensure that your computer's settings reflect whether you consent to accept Cookies or not. You can set your browser to warn you before accepting Cookies or simply refuse them. You do not need cookies to use or browse most of the PPA websites. Although you probably won't be able to access all of its resources in this case. Refer to the "help" button on your browser (for example, Internet Explorer, Firefox) to see how you can do this. Remember that if you use distinct computers in different locations, you will need to ensure that each browser is adjusted to your Cookie preferences. 

 

Since the web beacon is part of a web page, it is not possible to use the “opt- out” feature regarding that beacon, but you can make it ineffective by using the “opt-out” feature for Cookies placed by this beacon. 

 

Moreover, when available, you can decide whether to allow cookies to be placed on your computer or to opt-out cookies by visiting the following websites and selecting which company cookies you wish to decline: http://www.aboutads.info/choices/#completed or http://www.youronlinechoices.eu/ 

 
 4 - USE OF YOUR PERSONAL DATA 

 
 

The following paragraphs describe the various purposes for which we collect your Personal Data, and the different types of Personal Data we collect for each purpose. Please note that not all uses below will be relevant to all individuals. 

 

What we use your Personal Data for 

Our reason

Our legitimate interest

Customer service. We use your Personal Data for the customer service purposes, including responses to your inquiries. This usually requires the use of certain personal contact information and information about the reason for your inquiry (for example, order status, technical problem, product issue or complaint, general inquiries, etc.). 

Comply with contractual obligations;
Legal obligations; 
Our legitimate interests. 

Improve and develop new products and services; 
Be more efficient. 

Contests, marketing and other promotions. With your consent (whenever necessary), we use your Personal Data to provide information about products or services (for example, marketing communications or campaigns or promotions). This can be done by means such as e-mail, advertisements, SMS, telephone calls and postal correspondence to the extent permitted by applicable law. Some of our campaigns and Promotions run on third party websites and / or social networks. This use of your Personal Data is voluntary, which means that you can object (or withdraw your consent) to the processing of your Personal Data for these purposes. For more details on how to modify your marketing communications preferences, refer to Sections 9 and 10 below. For more information about our contests and other Promotions, refer to the rules or details posted about each contest / promotion. 

With your consent (whenever necessary); 
Comply with contractual obligations; 
Our legitimate interests. 

Analyze whichof our products and services may interest youand inform y ou about them; 
Define consumers fornew. 

Third party social networks: We use your Personal Data when you interact with third party social media functions, such as “like”, to serve you with advertisements and interact with You on third party social networks. You can learn more about how these functions work,  the profile data that We obtain about You, and find out how to cancel them (opt-out) by reviewing the privacy policies on the respective third party socialnetworks. 

Customization (offline and online). With your consent (whenever necessary), we use your Personal Data (i) to analyze your preferences and habits, (ii) to anticipate your needs, based on our analysis of your profile, (iii) to improve and customize your experience in our websites and apps; (iv) to ensure that the content of our websites / apps is optimized for you and your computer or device; (v) to send you targeted advertising and content, and (vi) to allow you to participate in interactive functions, when you decide to do so. For example, we remember your login, email address or screen name, so that you can log in quickly the next time you visit our website or so that you can easily retrieve the items you previously placed in your shopping cart. Based on this type of information, and with your consent (whenever necessary), we also show you specific content or promotions from the PPA Group fitted to your interests. The use of your Personal Data is voluntary, which means that you can object to the processing of your Personal   Data   for   this   purpose. For detailed information on how to opt-out, please refer to Section 10 below. 

With your consent (whenever necessary); 
Our legitimate interests. 

Analyze whichof our products and services may interest youand inform you about them; 
• Define consumers fornew products or services. 

Service to requests. We use your Personal Data to
process and ship your orders, inform you of the
status of your orders, correct addresses and
conduct identity verification and other fraud
verification activities. This involves the use of
certain Personal Data and payment information.
Other purposes in general (eg internal or market
research, analysis, security). In accordance with
applicable laws, we use your Personal Data for
other general business purposes, such as
maintaining your account, conducting internal or
market research and measuring the effectiveness
of our advertising campaigns. We reserve the
right, if you have accounts on the PPA Group, to
integrate these accounts into a single account.
We also use your Personal Data to manage and
operate our communications, IT and security
systems.
 

Comply with contractual obligations; 
With your consent (whenever necessary); 
Legal obligations; 
Our legitimate interests.

Improve and develop new products and services; 
Be more efficient; 
Protect our systems, networks and employees; 
Comply with legal obligations.

Legal grounds or merger / acquisition. If the PPA Group or its assets are acquired by, or merged with, another company, including due to bankruptcy, we will share your Personal Data with our legal successors. We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from the competent legal authority; (iv) to protect our rights, privacy, security or property; or (v) to enforce the terms of any agreement or the terms of our webite. 

Legal obligations;
Our legitimate interests. 

Comply with legal obligations;  
Protect ourassets and employees.

 
 5 - DISCLOSURE OF YOUR PERSONAL DATA 
 

In addition to the PPA Group members mentioned in the data controllers and contacts section (refer to Section 12), we share your Personal Data with the following types of third party organizations: 

 

Service providers. These are external companies that we use to assist us in operating our business (for example, order servicing, payment processing, fraud detection and identity verification, website operation, market research companies, support services, promotions, website development, data analysis, Customer Service Center etc.). Service providers and their selected employees are only authorized to access your Personal Data on our behalf, for the specific tasks that are required of them, based on our instructions, and are required to keep your Personal Data confidential and secure. 

 

Credit analysis / debt collection agencies. To the extent permitted by applicable law, credit analysis and / or debt collection agencies are external companies that we use to assist us in checking your credit status (particularly for orders placed by bank giro credit) or to collect past due bills (bank giro credits). 

 

Third party companies that use Personal Data for their own marketing purposes. Except in situations where you have given your consent, we do not license or sell your Personal Data to third parties for their own marketing purposes. Their identity will be revealed as soon as their consent is required. 

 

Third parties that use your Personal Data for legal reasons or due to merger / acquisition. We will disclose your Personal Data to third parties for legal reasons or in the context of a merger or acquisition (refer to Section 5 for more details).

 

 6 - RETENTION OF YOUR PERSONAL DATA 

 

In accordance with applicable laws, we will use your Personal Data for as long as it is necessary to satisfy the purposes for which your Personal Data have been collected (as described in Section 5 above) or to comply with applicable legal requirements. Personal data used to provide you with a personalized experience (refer to Section 5 above for more details) will be kept for the time permitted by applicable laws. 

 
 7 - DISCLOSURE, STORAGE AND / OR TRANSFER OF YOUR PERSONAL DATA 
 

We use appropriate measures (described below) to keep your Personal Data confidential and secure. Note, however, that these protections do not apply to information that you have chosen to share in public areas, such as third party social networks. 

 

People who can access your Personal Data. Your Personal Data will be processed by our employees or authorized agents, as long as they need access to such information, depending on the specific purposes for which your Personal Data have been collected (for example, our employees in charge of matters related to the customer service Center will have access to your purchase records). 

 

Measures taken in operational environments. We store your Personal Data in operational environments that use reasonable security measures to prevent unauthorized access. We follow reasonable protocols to protect Personal Data. The transmission of information over the internet, unfortunately, is not completely secure and, although we do our best to protect your Personal Data, we cannot guarantee the security of the data during transmission through our websites / apps. 

 

Actions we hope you will take. It is important that you also have a role in keeping your Personal Data safe. When creating an online account, please be sure to choose a password that is difficult for others to guess and never reveal your password to others. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose the option to remember your login ID, e-mail address or password and make sure that you really log out of your account whenever you log out of the computer. You must also use any privacy settings or controls that we provide on our website or app. 

 

Transfer of your Personal Data. Because of the international nature of our business, we may have to transfer your Personal Data within the PPA Group and to third parties, as mentioned in Section 6 above, in connection with the purposes set out in this Privacy Policy. For this reason, we may transfer your Personal Data to other countries, which may have different data protection laws and requirements than those that apply to Brazil.

 

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our controllers and all of its members controlled by them), to the extent reasonably necessary for the purposes informed and in accordance with the applicable legislation, as well as observing the bases treatment rules informed in this policy agreement. 

 

We may disclose your personal data to our insurers and / or professional consultants, to the extent reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice or entering, exercising or defending administrative, arbitrary and / or legal. Furthermore, we may disclose your data to our suppliers to the extent reasonably necessary to provide you with our products and / or services and ensure security in the use of our Services and in the use of your personal data, such as suppliers, marketing services and customer service, network providers and cloud services. 

 

 
 8 - YOUR RIGHTS 

 

Access to Personal Data. You have the right to access, review and request an electronic copy of the information we have about you. You are also entitled to request information about the source of your Personal Data. 

 

These rights can be exercised by email (privacidade@ppa.com.br ). If the request has been submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected . Please note that any identifying information provided by the PPA Group will only be processed in accordance with, and to the extent permitted by, applicable laws. 

 

Additional rights (for example modification, erasure of Personal Data). Where permitted by law, You may (i) request the erasure, portability, correction or revision of your Personal Data; (ii) limit the use and disclosure of your Personal Data; and (iii) revoke consent to any of our data processing activities. 

 

Please note that, in certain circumstances, we will not be able to delete your Personal Data without also deleting your user account. It may be necessary to retain some of your Personal Data after you request deletion, in order to meet our legal or contractual obligations. Applicable laws may also allow us to retain some of your Personal Data to meet business needs

 

When available, our websites may have a dedicated function by which you can review and edit the Personal Data you have provided. Please note that we ask our registered consumers to verify their identity (for example, login, e-mail address, password) before accessing or changing their accounts to prevent unauthorized access to their account. 

 

We hope to be able to answer questions you may have about how we process your Personal Data. However, if you have unresolved concerns, you have the right to complain to the relevant data protection authorities. 

 
 9 - YOUR CHOICES ON HOW WE USE AND DISCLOSE YOUR PERSONAL DATA 

 

We do our best to give you choices about the Personal Data you provide to us. The following mechanisms give you the following control over your Personal Data: 

 

 

Cookies / Similar Technologies. You manage your consent through (i) our consent management solution or (ii) your browser, to refuse some or all Cookies / similar technologies, or to alert you when they are being used. Refer to the Section 4 above. 

 

Advertising, marketing and promotions. You can consent to your Personal Data being used by the PPA Group to promote its products or services through checkboxes located on registration forms or by answering questions submitted by Customer Service Center representatives. If you decide that you no longer wish to receive such communications, you can cancel your subscription to receive marketing-related communications at any time by following the instructions provided in such communications. To unsubscribe from marketing communications sent by any means, including third party social networks, you can opt out at any time, canceling your subscription, through the links available in our communications, logging into our websites / apps or social networks from third parties and adjusting your user preferences by not filling in the relevant check boxes or by calling our customer service center. Please note that even with your unsubscription to our marketing communications, you will still receive administrative communications from us, such as orders or other transaction confirmations, notifications about your account activities (for example, account confirmations, password changes etc.), and other important non-marketing ads. 

 

Customization (offline and online): Wherever permitted by law, if you want your Personal Data to be used by PPA to provide you with a personalized experience or targeted advertising and content, you can indicate this through the relevant check boxes located on the form registration or responding to questions from Customer Service Center representatives. If you decide that you no longer want to benefit from this customization, you can opt out at any time by logging into the websites / apps and adjusting your user preferences in your account profile by not filling in the relevant checkboxes or calling our service customer service Center. 

 

Targeted advertising. We partner with ad networks and other service  providers (“Ad Providers”) that display ads on our behalf and other non- affiliated companies on the internet. Some of these advertisements are tailored to your interests based on information collected on the PPA Group websites or on non-affiliated websites over time. You can visit www.aboutads.info/choices to learn more about this type of advertising, and also to see how to opt out of advertising practices based on the interests of companies participating in the Digital Advertising Alliance's (“DAA ”) self-regulated program. Additionally, you can choose not to receive this type of advertising on mobile apps from companies that participate in the AppChoices app from DAA, by downloading the app from iOS or Android stores. You can also stop collecting accurate location data from a mobile device by accessing your device's location services settings.

 
 10 - CHANGES TO THIS POLICY AGREEMENT 

If we change the way we treat your Personal Data, we will update this Policy. We reserve the right to make changes to our practices and this Policy at any time. Please log in frequently to see any updates or changes to our Policy. 

 
 11 - CONTACT 

The PPA Group makes itself available to the holder in case of any doubts through the e-mail privacidade@ppa.com.br.