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    LIASA’s PRIVACY POLICY

    1. INITIAL CONSIDERATIONS

    This Privacy Policy (“Policy”) contains information about the way Ligas de Alumínio S.A. – LIASA company (“LIASA”) deals with, totally or partially, in an automated way or otherwise, Users’ personal data (“Data Subject(s)”) that interact with LIASA for any reason, such as, for example, through the use of the Company’s websites or, even, in person, by phone, email, agreement, information registration, among other means of communication. Furthermore, it aims at explaining about the types of data that are collected, the purposes of the collection and how the Data Subject may update, manage, or exclude those pieces of information.
    This Privacy Policy was prepared in accordance with Federal Law no. 12.965 of April 23rd, 2014 (Internet Civil Regulatory Framework) and Federal Law no. 13.709, of August 14th, 2018 (General Law of Personal Data Protection – LGPD).
    As a condition to interact with LIASA, the Data Subject represents it has read that Policy and, therefore it is aware of and agrees to its content. In the event of disagreement, please get in touch with LIASA’s Data Protection Officer.
    Note that LIASA reserves the right to change its Privacy Policy, in order to adapt it or update it, at any time, without the need for communicating it previously to Data Subjects. Therefore, it is advisable to read it from time to time.

     

    2. DEFINITIONS

    For the purposes of this Policy, the following definitions apply:
    a. Personal data: information in connection with the identified or subject to being identified natural person or corporation;
    b. Sensitive personal data: personal information about race or ethnic origin, religion, political opinion, union or religious, philosophic, or political membership, health- or sex life-related information, genetic or biometric or face recognition information, when related to an individual;
    c. Anonymized data: data related to a subject whose identification is not possible with the use of reasonable and available technical means at the time of their treatment;
    d. Subject: an individual or legal entity to whom the personal data under treatment relates. The data Subject may vary according to the relationship established with LIASA, especially, without limitation:
    d.1. LIASA’s Employee/Associate It is the Subject that, by operation of the established employment relationship, supplies its personal data to LIASA, such as: full name, document data (copy of documents), civil status, address, bank data, biometry, facial recognition, professional background (C.V.), family status, wage amount, discounts, absences from work and their reasons, any diseases and accidents, among other data.
    d.2. Contracting Party/Service Provider/Supplier: It means the Subject who, by operation of the established trade relationship, supplies its personal, its members’, agents’, employees’, and legal representatives’ personal data, so that the commercial relationship is reasonably established, as well as to make possible the performance of legal and contractual obligations.
    d.3. LIASA website’s visitor: It means the Subject who, due to its navigation on LIASA’s website (www.liasa.com.br) uses the website forms, on the “Contact” page, in order to supply its data to LIASA.
    e. Data Controller: an individual or legal entity governed by public or private law, in charge of decisions concerning the treatment of personal data. In this case, the legal entity in charge of treating the collected personal data is Ligas de Alumínio S.A. company. – LIASA, with head office at Av. Dr. José Patrus de Sousa, no. 1000, Industrial District, in Pirapora, State of Minas Gerais, Postal Code 39.274-012 and administrative offices at Rua Matias Cardoso, no. 169, Santo Agostinho district, in Belo Horizonte, State of Minas Gerais, Postal Code 30170-050;
    f. Operator: an individual or legal entity governed by public or private law, that carries out the treatment of personal data on behalf of the data controller;
    g. Person in Charge: an individual, appointed by the data controller and operator, that operates as a communication channel between data controller, data subjects and the Brazilian Authority of Data Protection (ANPD, initials in Portuguese). The communication channels with LIASA’s Data Protection Officer are: by email: privacidade@liasa.com.br or personally or by letter at the following address: Rua Matias Cardoso, 169 – 8º andar CEP 30170-050 – Santo Agostinho – Belo Horizonte/State of Minas Gerais;
    h. Consent: a free, informed and express statement whereby the subject agrees to the treatment of their personal data for a specific purpose;
    i. Treatment: every operation carried out with personal data, such as those concerning the collection, production, receiving of, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, erasure, data assessment or control, modification, communication, transfer, diffusion or retrieval;

     

    3. COLLECTED INFORMATION AND PURPOSES

    3.1. Subjects will be informed on which personal information is being collected before its actual collection, and whether to supply these data remains at the Subject’s criterion, that will also be aware of the consequences of their decision.
    3.2. Information that may be collected includes, without limitation, (i) name; (ii) email addresses; (iii) mail address; (iv) telephone number; (v) documents and personal identification documents, including biometry and facial recognition and (vi) information about third-parties, such as company members, legal representatives, employees, agents, among other persons.
    3.3. Any collection of information will be made through ethical and legal means, and it may have one or more purposes, such as, for example, for the compliance with LIASA’s commitments and legal obligations. In any case, the pieces of information will be stored in accordance with strict security and confidentiality standards.
    3.4. LIASA will not disclose, without previous consent, any personal information that directly identifies the Subject, except in cases in which the disclosure is required (as it will be seen below); to protect and defend the rights of LIASA or to protect the interests of the remaining Subjects.
    3.5. The Subjects’ sensitive data, as defined in Articles 11 and following Articles of the Personal Data Protection Law, such as: (i) data that disclose race or ethnic origin, political opinions, religious or philosophic beliefs, or union membership of the Subject; (ii) genetic information; (iii) biometric and facial recognition information; (iv) the Subject’s data in connection with health; (v) the Subject’s data in connection with criminal convictions or violations or related civil commitments, as a rule, will be collected by means of the Subject’s previous consent.
    3.6. The collection of sensitive personal data without the Subject’s consent will only be conducted whenever required, due to legitimate interest or in case of events set forth in law, among other events, as follows: (i) for the performance of a legal or regulatory obligation; (ii) for the conduction of studies by a research agency, and, in this case, whenever possible, the personal data anonymization will be ensured. (iii) whenever required for the performance of an agreement or preliminary procedures in connection with an agreement to which the Subject is a Party, at the data Subject’s request; (iv) for the regular enjoyment of rights in a court, out-of-court or arbitration proceeding, and the latter in accordance with Brazilian Law no. 9307 of September 23rd, 1996 (Arbitration Law); (v) for the protection of the Subject or third-party data’s life or physical integrity; (vi) for the protection of health, in a procedure conducted by health area professionals or sanitary entities; (vii) whenever required to meet the controller’s or third party’s legitimate interests, except if the data Subject’s fundamental rights and freedom prevail that require personal data protection; (viii) for the protection of credit, including in relation to provisions in the corresponding laws.
    3.7. Occasionally, other types of data which are not expressly set forth in the Privacy Policy may be collected, provided they are supplied upon the Subject’s consent, or, further, that the collection is allowed or provided for in law.

     

    4. TREATMENT OF PERSONAL DATA

    4.1. The treatment of personal data will only be carried out in order to make possible, chiefly, but without exclusivity: (i) the identification and contact with the Subject for the purposes of commercial or labor relationship; (ii) the preparation of commercial agreements and issuance of collections or payments on behalf of the Subject; (iii) the performance of legal or contractual obligations; (iv) the supply of products and services, in a remunerated way or free-of-charge; (v) the structuring, conduction of test, promotion and communications on products and services, whether tailor-made to the Subject’s profile.
    4.2. The purpose of the collection of the Subject’s personal data through the website is to make easy, streamline, and meet the commitments established with the Subject and enforce the requests made through filling out the forms. The website retrieves the Subject’s data by means of the answers to the forms in the “Work with Us” pages (data that may be collected: name, email, area of expertise and curriculum), “Ethics Channel” (data that may be collected: name and email) and “Get in touch with us” (name and e-mail), only to allow the Subject to get in touch with LIASA.

     

    5. THE DATA SHARING

    5.1. LIASA is hereby authorized to share the Subject’s personal data with other data treatment agents, (among them: Contracted Parties, Government, Prosecution Office, Authorities, Service Providers and other third-parties which are required to warrant and bear legal obligations and commitments made, commercial partners, payment or financial institutions, our branches, court actions, even if arbitration proceedings, and etc.) that are required to meet the purpose set forth in this Policy, subject to the principles and guarantees established in Law no. 13709 of 2018.
    5.2. The Subject’s personal information will only be disclosed to the public, subject to the cases of protection of the company’s interests in any type of conflict, including lawsuits; transactions and corporate amendments involving the company; court order or petition from administrative or government authorities that have competent jurisdiction for its request.

     

    6. SAFETY MEASURES

    6.1. LIASA is committed to upholding the steadiness and functionality of safety, technical, and administrative measures, that allow the protection of personal data from non-authorized accesses and unexpected or unlawful destruction, loss, change, communication situations or any other way of improper treatment, as well as discriminatory processing of information.
    6.2. For the sake of safety, the solutions to be adopted are those that take into account: (i) the physical and logic data protection, (ii) the use of reasonable techniques that are available to do so, (iii) the nature of the solution, (iv) the scope, (v) the context, (vi) the purposes of the treatment, and (vii) the risks to the Subject’s rights and initiatives. Note that the applied techniques are continuously reviewed, for achieving full effectiveness.
    6.3. The Company’s website uses the SSL certificate (Secure Socket Layer) that ensures that personal data have a safe and confidential transmission, so that the data transmission between the server and the Subject, and in feedback, is made fully in a code-written or encrypted way.
    6.3.1.However, since no available service is fully guaranteed against hacking, LIASA is not liable for third-parties’ exclusive fault, such as in case of hackers or crackers attack, or the Subject’s exclusive fault, such as in the event that the own Subject transfers their data to a third-party.
    6.3.2.If the data treatment is carried out by companies hired by LIASA, said companies must be subject to and comply with the provisions in this Privacy Policy.
    6.3.3.LIASA further undertakes to inform Subject within reasonable time in case of occurrence of any type of security breach of their personal data that may be a high risk to their rights and personal freedom, as well as, in compliance with Article 48 of Law no. 13.709, it will inform the Data Protection National Authority (ANPD) about any security incident that may entail a risk or relevant damage to Subject.

     

    7. THE SUBJECT’s RIGHTS

    7.1. Subject has the following rights, granted by the Personal Data Protection Law and other applicable laws to the issue:
    A)Right of confirmation and access: it is the Subject’s right to get the confirmation whether the personal data that are relate to it are the purpose of a treatment and, if this is the case, the right to access its personal data:
    B)Right of rectification: it is the Subject’s right to get, without undue delay, the rectification of inaccurate personal data that are related to it;
    C)Right to data erasure: it is the Subject’s right to have its data erased, provided such right is not in conflict with LIASA’s right and/or legal obligation to maintain and store the data;
    D)Right to the limitation to data treatment: it is the Subject’s right to limit the treatment of its personal data, and it may achieve it whenever it denies the data accuracy, when an unlawful treatment is involved, when the site no longer needs the data for the intended purposes, and when it is against the data treatment and in case of treatment of unnecessary data;
    E)Right to opposition: it means the Subject’s right, at any time, to refuse, for reasons in connection with its private situation, the treatment of personal data that are related to it, provided such right is not in conflict with LIASA’s right and/or legal obligation to maintain and keep the data;
    F)Right of data portability: it is the Subject’s right to receive personal data related to it and that it has supplied, in a structured format, which is commonly used and automatically read, and the right to send said data to another person;
    G)Right to not being submitted to automated decisions: it is the Subject’s right to not be subject to any decision made exclusively on the basis of automated treatment, including the profiling, that produces effects on its legal sphere or significantly affects it on a similar way.

     

    8. THE DATA MODIFICATION OR EXCLUSION

    8.1.Subject warrants and is liable for the veracity, accuracy, effectiveness, and authenticity of personal data and undertakes to keep them duly updated. In order to modify your personal data or even request their exclusion, just get in touch with LIASA’s Data Protection Officer.
    8.2.Subject is aware that the company complies with the requirements of Law 13.709/2018 and its personal data will be kept in storage while they are useful for the purposes they were collected, for statistical review or due to a legal order.

     

    9. THE EFFECTIVENESS

    9.1.LIASA may keep and treat Subject’s personal data during the whole period they are applicable to reaching the purposes listed in this Policy.
    9.2.Subjects’ personal data may be kept after the end of their treatment in the following cases: (i) for the performance of a legal obligation, Liasa’s legal or regulatory protection; (ii) for the study by a research agency, provided, whenever possible, the anonymization of data is warranted; (iii) for the transfer to a third-party, provided the data treatment requirements are complied with, as set forth in law; (iv) for the exclusive use of the data controller, and its access by a third-party is prohibited, and provided they are anonymized data.
    9.3.Anonymized personal data, without the possibility of being associated with the individual, may be maintained for an indefinite time.

     

    10. THE CONSENT

    10.1.When Subject establishes a connection with LIASA, especially upon the use of the website’s services, Subject consents to this Privacy Policy. This consent may be revoked by Subject, at any time, by request to LIASA’s Data Protection Officer and provided it does not conflict with LIASA’s rights and obligations.

     

    11. THE APPLICABLE LAW AND VENUE

    11.1.11.1. The Brazilian Law will be fully applied to the resolution of conflicts arising out of this instrument. Any conflicts must be filed with the venue of the Judicial District of Pirapora, state of Minas Gerais.

     

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