PRIVACY POLICY

PURPOSE

GSL METALÚRGICA operates based on quality and efficiency, maintaining its commitment to ethical and distinguished conduct in the market.

In this context, the PRIVACY POLICY of GSL METALÚRGICA was developed to demonstrate its commitment to the security and privacy of information collected from individuals who establish any relationship with the company, always ensuring transparency and clarity with each individual and society as a whole.

APPLICATION

This POLICY covers all personal data collection activities, both online and offline, conducted through various channels, including the website, social media, and customer service team. Thus, this PRIVACY POLICY applies to everyone who shares their personal data with the company in any way and clarifies the conditions for collecting, processing, sharing, storing, and deleting such data in compliance with the General Data Protection Law (LGPD – Law No. 13.709 of August 14, 2018).

DEFINITIONS

For the purposes of this policy, the following definitions and descriptions should be considered for better understanding:

PERSONAL DATA: All information related to an identified or identifiable natural person (individual), directly or indirectly. Examples include name, CPF (Brazilian Individual Taxpayer Registry), email address, phone number, photograph, health records, among others.

SENSITIVE PERSONAL DATA: Personal data related to racial or ethnic origin, religious beliefs, political opinions, union membership or affiliation with religious/philosophical/political organizations, health information or sexual life details, genetic or biometric data linked to an individual.

DATA SUBJECT: The person whose personal data is being processed.

PERSONAL DATA PROCESSING: Any operation performed with personal data such as collection, production, reception, classification, utilization, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

DATA PROCESSING AGENTS: The controller and operator.

CONTROLLER: A natural or legal person (public or private) responsible for decisions regarding personal data processing.

OPERATOR: A natural or legal person (public or private) that processes personal data on behalf of the controller.

DATA PROTECTION OFFICER: The individual appointed by GSL METALÚRGICA’s management to act as a communication channel between the controller, data subjects, and the National Data Protection Authority (ANPD).

DATABASE: A structured set of personal data established in one or more locations on electronic or physical media.

CONSENT: A free, informed, and unequivocal expression by which the data subject agrees to the processing of their personal data for a specific purpose.

ANONYMIZATION: The use of reasonable technical means available at the time of processing that render a piece of data incapable of being associated directly or indirectly with an individual.

PRINCIPLES OF DATA PROCESSING

GSL METALÚRGICA will comply with the following protection principles when processing personal data:

PURPOSE: Personal data will only be processed for legitimate purposes that are specific, explicit, and informed to the data subject without subsequent incompatible processing.

ADEQUACY: Personal data will be processed in a manner compatible with the purposes informed to the data subject and within the context of processing.

FREE ACCESS: GSL METALÚRGICA will ensure that data subjects have free and easy access to information about how their data is processed and its duration as well as its integrity.

NECESSITY: Data processing will be limited to what is strictly necessary for achieving its purposes with relevant and proportional scope without excessiveness.

DATA QUALITY: GSL METALÚRGICA will guarantee accuracy, clarity, relevance, and updating of personal data according to necessity and purpose fulfillment requirements.

TRANSPARENCY: Clear and accessible information regarding processing activities will be provided while respecting commercial and industrial secrets.

SECURITY: GSL METALÚRGICA will use technical and administrative measures to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication, or dissemination.

PREVENTION: GSL METALÚRGICA will adopt measures to prevent damages resulting from the processing of personal data.

NON-DISCRIMINATION: GSL METALÚRGICA will ensure that the processing of personal data cannot be carried out for unlawful or abusive discriminatory purposes. 

PERSONAL DATA COLLECTED

We use the personal data provided by the data subjects in accordance with the principles established in Article 6 of the LGPD, particularly emphasizing the principle of necessity, which establishes the limitation to the minimum necessary for achieving the intended purposes, in a proportional and non-excessive manner.

GSL METALÚRGICA collects Personal Data when you submit or provide it through one of the collection sources, and such data is processed in compliance with applicable laws.

Depending on the type of interaction with GSL METALÚRGICA, various types of information are collected, as described below.

• Identification Data:Full name; CPF; date of birth; mobile phone number; email address; residential address; etc.
• Professional Data:Work history; desired work sector; resume details.
• Sensitive Data:Health-related information indicating whether an applicant has a disability.

Occasionally, other types of data not expressly mentioned in this Privacy Policy may be collected, provided they are supplied with the user’s consent or if the collection is permitted based on another legal basis established by law. In any case, the data collection and the resulting processing activities will be disclosed to the website’s users. 

SOURCES AND PURPOSE OF PERSONAL DATA COLLECTION

The collection of personal data by GSL METALÚRGICA occurs through the sources identified below and for the purposes described:

Contact Us: Available on the website (https://www.gsl.com.br/en/contact/), this tool allows users to receive the necessary assistance for inquiries, complaints, compliments, and suggestions. The user must provide personal identification data (name and email) so that a response can be sent to their request.

Work With Us: This is the channel used by individuals interested in working at one of our establishments. They can register by sending information to our HR department. For registration, selection, and analysis of the candidate’s suitability for the position, personal identification data, professional and employment information, and health-related data are required.

COOKIES AND SIMILAR TECHNOLOGIES

GSL METALÚRGICA does not use cookies or similar technologies.

SHARING OF PERSONAL DATA

To provide adequate services, it may be necessary to share personal data with certain entities:

Service Providers: To operate the business, it is necessary to share data with operators and suppliers of essential services for our activities. These entities are also required to keep the data confidential and secure.

Third-Party Companies Using Personal Data for Their Own Marketing Purposes: It is important to note that we DO NOT license or sell personal data to third-party companies for their own marketing purposes.

International Transfers: There will be no transfer of personal data to other countries.

STORAGE OF PERSONAL DATA

The collected data is stored on our physical servers located at our facilities, as well as in cloud-based environments.

Personal data will be used for as long as necessary to achieve the purposes for which it was collected or to comply with applicable legal obligations, especially regarding sensitive health-related data. However, if there is any other reason for its retention or necessity to preserve such data to safeguard GSL METALÚRGICA’s rights, it will be maintained accordingly.

RIGHTS OF DATA SUBJECTS

In the context of its personal data processing activities, GSL METALÚRGICA reinforces its commitment to respecting the rights of data subjects, which include:

Right to Confirm the Existence of Processing: Data subjects can inquire whether GSL METALÚRGICA is conducting operations involving their personal data.

Right of Access: Data subjects can request and receive a copy of all personal data collected and stored.

Right to Rectification: Data subjects can request corrections to incomplete, inaccurate, or outdated personal data.

Right to Erasure: Data subjects can request the deletion of their personal data from databases managed by GSL METALÚRGICA unless there is a legitimate reason for its retention (e.g., legal obligations or research purposes). In such cases, GSL METALÚRGICA reserves the right to choose the deletion method while ensuring security and preventing recovery of the deleted data.

Right to Request Suspension of Unlawful Processing: At any time, data subjects may request anonymization, blocking, or deletion of their personal data deemed unnecessary, excessive, or processed in violation of LGPD by a competent authority.

Right to Object to Data Processing: In cases where processing is not based on consent, data subjects may object to GSL METALÚRGICA’s processing activities; these objections will be analyzed according to LGPD criteria.

Right to Data Portability: Data subjects may request that their personal data be made available to another service provider or product supplier while respecting trade secrets and technical limitations of GSL METALÚRGICA’s infrastructure.

Right to Withdraw Consent: Data subjects have the right to withdraw their consent at any time. However, this does not affect the legality of any processing carried out before withdrawal. If consent is withdrawn, certain services may no longer be provided; in such cases, users will be informed accordingly.

Penalties for Misuse: Professionals who misuse personal data are subject to penalties. Firewalls and antivirus programs are implemented to prevent information leaks.

SECURITY MEASURES

Access to collected personal data is limited internally only to authorized professionals who respect proportionality principles and business objectives while committing to confidentiality and privacy preservation under this policy.

GENERAL INFORMATION ABOUT THIS POLICY

Changes and Updates: Users acknowledge GSL METALÚRGICA’s right to amend this policy annually as needed (e.g., for legal compliance). Users should review this document when accessing websites or using services. If updates require new consent collection from users, they will be notified through provided contact channels.

Jurisdiction: This policy is interpreted under Brazilian law in Portuguese, with disputes resolved in Belo Horizonte/MG/Brasil jurisdiction.

VERSION – Document updated on April 10th, 2024