Institutional

Privacy Notice Last update: August 5th, 2022

What is the objective of this policy?

Portobello is concerned about your privacy. Consequently, we protect your personal data, which is collected in order to facilitate the development of our activities and, especially, to keep a good relationship with you. We are aware that by collecting your data these are under our responsibility. Therefore, we have elaborated this Policy to let you know how your personal data is treated, and to guarantee you transparency in all actions we take..

Henceforth, we emphasize that if you do not have enough time available to fully read this Policy, or in case you have any doubts, you can get in touch through the email: privacidade@portobello.com.br.

When you use our website nd/or provide your personal data, we consider that you have understood this policy.

Which terms do you need to understand?

We have elaborated this policy in an easy and objective way in order to reach the main recipient: you!

However, we would like you to get familiarized with the following terms:

We: every time we use the expression “we” and its variations, we are referring to the company, which owns the website you are using.
Personal data: it comprehends all the information related to you, including information that immediately allow your identification (such as name, email or ID) as well as information that indirectly allow your identification (such as address and IP protocol).
Personal data treatment: when we use this expression and its variations we are referring to each and every action that can be accomplished with your personal data (for example: collection, processing, diffusion, assessment, storage, among others).
Aim: it is the purpose to which we use your personal data; the objective of the collection and treatment of personal data.
GLDP: abbreviation for the General Law of Data Protection - Brazilian legislation that guides all our actions while treating your personal data.
Legal bases: the hypotheses for data collection treatment to be justified, according to the GLDP.

Which personal data do we collect?

In order to carry our activities and keep our relationship with you, we need to collect your personal data. Most times you provide us with your personal data in the following situations:

Situation Personal data provided

Situation: Subscribing to our newsletter
Personal data provided: Name, email

Situation: Participation in contests and promotions
Personal data provided: Name, address, email, phone number

Situation: Participation in our events
Personal data provided: Name, phone, e-mail, city, area of operation, voice and video recording - if, eventually, you decide to use such features of the platform used to carry out the event.

Situation: Register your complaint on our "Ethics Hotline"
Personal data provided: Name, e-mail, telephone, position, place of work, image, voice and other personal data that may be included on the complaint.

Situation: Using our Virtual Specifier service
Personal data provided: Email, State

Situation: Requests permission to enter Grupo Portobello's physical facilities
Personal data provided: Name, company, license plates

Situation: Using the ‘Contact Us’ tab on the website
Personal data provided: Name, email, phone number, city, State, zip code

Situation: Using the ‘Contact - Sustainability’ tab on the website
Personal data provided: Name, email, phone number, company

Situation: Using our “Tour Virtual” (Inside Portobello) service
Personal data provided: Name, State, city, email, type of relationship with Portobello

Situation: Register for the benefits “Portobello+Arquitetura” Program
Personal data provided: Name, CPF, date of birth, nationality, gender, profession, professional registration record (CAU or CREA), address, personal and professional e-mail, telephone number, description/history of the professional performance, identification of your account on Facebook, Instagram and Pinterest

Situation: Use the “contact” tab in the space dedicated to “Portobello+Arquitetura”
Personal data provided: Name, CPF, email, phone number

Situation: Get in touch via online chat or by WhatsApp
Personal data provided: Name, CPF, email, phone number

Situation: To apply discount vouchers
Personal data provided: Name, CPF, email, phone, unit number

Situation: To request permission of entrance as a visitor
Personal data provided: Name, CPF, phone number

Situation: Sign you up for our promotions in order to receive coupons and/or discount vouchers on products
Personal data provided: Name, CPF, email, phone number

Situation: Participation in the “Future of Dreams” project
Personal data provided: Name, email

Conversely, there are situations in which we collect personal data from your activities (online or off-line) in other sources that store those personal data you decided to make known (e.g.: information from your media profile and social network). Personal data you do not provide, but which we treat from your activities in our website, are usually collected through automated technologies, such as cookies and web beacons, in the following situation:

Situation Personal data collected

Situation

During and after accessing/ using our website

Personal data provided

Log files
IP address
Location
Mobile device identifier
Information about your equipment
Consumer’s behavior
Behavior while interacting with available content
Duration of your access
Information about the content you search

What are the purposes of using your personal data?

Your personal data are used to meet different objectives, depending on the situation in which they are collected. Most times, the aim has to do with the relationship we keep with you after your interaction in our virtual environment and the methods we use to personalize your experience while you use our website.

Situation Purpose of using

Situation: Subscribing to our newsletter
Purpose of using: To send informative content and advertisement related to our products and practices; to keep analytical and statistical data about the interaction with our content.

Situation: Participation in contests and promotions
Purpose of using: To perform activities related to the contest or promotion you decided to interact with (e.g.: to make a draw, to send emails about the promotion, to give you a benefit to obtain a given product); to accomplish marketing activities.

Situation: Participation in our events
Purpose of using: To carry out your registration for the events you choose to participate in; to share your personal data, when strictly necessary, with platforms hired to hold events; to broadcast the events and make it possible for you to follow them; to identify your participation in our events and, when applicable, issue a certificate of participation; to send advertising and marketing content linked to the event and to the activities of the Portobello Group.

Situation: Register your complaint on our "Ethics Hotline"
Purpose of using: To register your complaint on our "Ethics Hotline"; to pursue inquiries about the facts indicated on your complaint; to contact you about the subject recorded on our "Ethics Hotline".

Situation: Using our Virtual Specifier service
Purpose of using: To enable you to receive the result of your specification.

Situation: Requests permission to enter Grupo Portobello's physical facilities
Purpose of using: To authorize the entrance of suppliers, service providers and visitors to the Group's physical environments.

Situation: Using the ‘Contact Us’ tab on the website
Purpose of using: To answer your requests; to assist your rights; to receive your suggestions.

Situation: Using the ‘Contact - Sustainability’ tab on the website
Purpose of using: To answer your requests and inquiries; to receive your suggestions.

Situation: Using our “Tour Virtual” (Inside Portobello) service
Purpose of using: To take a virtual tour through Portobello’s facilities; to identify the places you visited during your virtual tour

Situation: Register for the benefits “Portobello+Arquitetura” Program
Purpose of using: To keep your user profile registered in our benefits program and provide you with the respective benefits, under the terms of the regulation; to manage your account and activities, on the website, in which you chose to participate; to update your account when requested; to compute the volume and value of Portobello products that are sold in each of its projects; to send e-mails about the benefits program and keep your points balance updated; to conduct studies, based on your interaction with our channels, to guide commercial decisions; to display advertising and marketing content; to interact and communicate with you.

Situation: Use the “contact” tab in the space dedicated to “Portobello+Arquitetura”
Purpose of using: To respond to your requests and requests related to the “Portobello+Arquitetura” Program; to receive your suggestions.

Situation: Get in touch via online chat or by WhatsApp
Purpose of using: To respond to your requests or queries; to receive your suggestions; to identify you in the relationship programs maintained by the Portobelllo Group, aiming at a personalized and agile service.

Situation: To apply discount vouchers
Purpose of using: To make offers available to registered customers when purchasing products; To ensure that a customer does not apply the same discount voucher on more than one promotion; To establish contact with customers to present offers and products from Portobello Shop; To send invitation to registered customers in order to inform about the availability of a promotion or sale at a nearby local store;

Situation: To request permission of entrance as a visitor
Purpose of using: To authorize the entry of visitors into Portobello's physical facilities

Situation: Sign you up for our promotions in order to receive coupons and/or discount vouchers on products
Purpose of using: To provide coupons and/or discount vouchers to registered specifiers and their end customers in our promotional campaigns; to identify the specifier responsible for selling products to the end customer for scoring purposes in the Portobello+architecture program; to establish contact with registered specifiers about Portobello Shop offers and/ or products; to register the specifier in the Portobello Shop CRM journey.

Situation: Participation in the “Future of Dreams” project
Purpose of using: To enable your participation in the “Future of Dreams” application; to post your message on the “Future of Dreams” board; to send a message to the “Future of Dreams” email address and to receive an e-mail about it a year later; to allow you to download and share the messages posted on the “Future of Dreams” board.

Situation: During and after accessing/ using our website
Purpose of using: To accomplish marketing activities by analyzing which of our products might interest you; to identify the activities you perform when you visit our site and use its functionalities; to provide personalized content and/or services according to your profile and characteristics; to personalize your experience while using our website; to keep and, in some cases (read the section ‘who do we share your personal information with?’), to share analytical and statistical data on the visits and characteristics of visitors to our site in order to quantify and track the results of our interaction with you.

Besides the aims specified above, we would like to inform you that we treat your personal data with the support of the following legal basis from GLDP:

Legitimate interest - when we conclude that there is a significant concern to treat your data in order to develop our activities since such treatment generates some type of benefit to you or in case you have interacted with us in a different moment.
Consent - when you expressly authorize your data to be treated for a clearly and specifically informed aim at the moment of collecting consent; it is important to remind that it is possible to remove the consent anytime you wish.
Fulfilling legal obligation - when we treat your data because the Law forces us to do so;
Implementation of contracts - when we keep some kind of contract with you.

For how long do we keep your personal data stored?

We keep your personal data stored until the aim (information provided in the items above) to which they were collected is reached. After the aim is reached, your personal data is removed. However, you can ask for your personal data to be removed at anytime, especially in the following cases: a) you decide to cancel the consent you gave us; b) you consider that unnecessary and excessive personal data are being treated; c) you consider that we do not fulfill the regulations of the GLDP.

Every time you request your personal data to be removed, we will do the possible to assist your demand. However, in some circumstances your personal data will not be removed, especially in the cases in which personal data are treated because the Law itself forces us to do so (e.g.: if you ask for the removal of the IP address within the period of 6 months after having accessed our website, we cannot remove it because the Law states that we must keep it for 6 months)

What measures de we use to guarantee the safety of your personal data?

We understand that from the moment we collect your personal data, we are entirely responsible for treating and storing them according to the rigid protocols of cyber security. The following are part of the actions we take to keep your data safe: a) protection against unauthorized access; b) restricted access, only allowed to our employees, suppliers and partners who really need to access them due to the roles they perform; c) demanding via contract that all our employees, suppliers and partners should have appropriate knowledge about data protection and act according to the GLDP; d) the Management System of Data Protection and Privacy of Information - SGPD/SGPI; e) frequent security check of our internal systems of storage (including tests against invasions of hackers); f) complementary technical measures and automated security control, based on the best practices related to information safety, following the patters ISO27001/27701, NIST and OWASP.

Who do we share your personal information with?

We share your personal data with companies from the same business group and other brands controlled by us:

Portobello Shop
Pointer
Portobello+Arquitetura
Officina Portobello
Archtrends
Mineração Portobello

We also share your personal data with: a) our suppliers and partners, which are often hired to treat part of some personal data we collect (in these cases we always demand, in contract, that your data are protected and kept secret, under constant safety, physical and cybernetic); b) social media; c) authorities and public institutions legally involved in our internal processes; d) our franchisees and distributors; e) in case of fusions or acquisitions, for the companies involved in the corresponding negotiations.

If you inform in our forms that you wish to receive communications from Portobello Group, your personal data will be shared for this purpose with the other companies of the business group indicated above.

If you need more information about your personal data sharing, do not hesitate to contact us - privacidade@portobello.com.br

Are your personal data transferred to other countries?

We transfer your personal data to other countries only when we hire third parties to storage certain data and, specifically, when these third parties keep their servers in other countries. We demand contractually that these third parties must adopt appropriate patterns, which are able to guarantee physical and cybernetic safety to your personal data and your privacy.

What are your rights?

In compliance with the LGPD, at any time you can request that the following rights be met by accessing the Privacy Request Form available on our website or by clicking here.

Information about whether your personal data was treated or not;
Access to your personal data, in case they are treated by us;
Correction of incomplete personal data, which may not be correct or updated;
To block, anonymize or remove unnecessary personal data or data that you consider to be treated in an irregular way;
Data portability, when applicable;
Removal of personal data, even those that are treated in a regular way;
Information about your data sharing with other companies or public entities/ institutions;
Information about the consequences of not agreeing with certain treatment of personal data (e.g.: when you do not accept our cookies, you have the right to know the consequences of not accepting);
Canceling the consent;
Disagreement in relation to any treatment of data you consider irregular.

What do we expect from you?

In addition to the actions we implement in our internal control to protect your personal data, it is essential that you also keep them safe. We recommend you not to share or keep your ID/user and password logged in to our website in public places (shared computers, use of free Wi-Fi networks in malls, airports or cafés, for example, i.e., places in which cyber security may not be appropriate). We recommend you not to choose the option of reminding your username or password while using the website or the applications. Furthermore, always make sure that you have logged out when you are no longer using our features, especially if your equipment is shared or if you have accessed our website from public equipment.

It is important to remember that sensitive personal data must not be inserted in text fields while you use our website, since none of the features in this virtual environment demands the insertion of such data.

We suggest that when attending our events, if you do not wish to have your image and/or voice recorded, you should disable such features if they are available on the platforms through which the events are held.

We also expect you to understand this Policy and if you have something to contribute, please send us a message: privacidade@portobello.com.br.

How to contact us

We have stated above, but it is worth repeating: you can contact us at anytime, in order to:

Request information;
Make suggestions.

Just send an email to: privacidade@portobello.com.br.

Updates to this policy

You are invited to read this Policy periodically, since it may be updated in order to improve the relationship we have with you, and enhance the actions we implement in order to keep your data safe and your rights assisted.