At Trapp, privacy and security are priorities and we are committed to transparency in the processing of our users’/customers’ personal data. Therefore, this Privacy Policy lays out how we collect, use and transfer information on customers or others who visit or use our website.

By using our services, you understand that we will collect and use your personal information in the ways described in this Policy, under the rules of Law No. 10.406/2002 (Brazilian Civil Code), in Law No. 12.965/2014 (Civil Framework of the Internet), Law No. 13.709/2018 (General Data Protection Law – LGPD) and other relevant legislation.

As such, Metalúrgica Trapp, hereinafter referred to simply as “Trapp”, enrolled in the National Corporate Taxpayer Registry of the Brazilian Finance Ministry (CNPJ/MF) under No. 83.238.832/0001-78, in the role of Data Controller, is bound by the provisions of this Privacy Policy.

1. Which data do we collect about you and for which purpose?

Our site collects and uses some of your personal data in order to enable the provision of

services and enhance the user experience.
1.1. Personal data that may be provided by the site user:

– Full Name / Gender / E-mail / Telephone Number / Country / Postal Code / State / Date of Birth.

Purpose of data collection:

Full name – For identification and contact.
Gender – For identification and contact.
E-mail – For contact in order to answer questions and send advertising and publicity material.
Telephone number – To contact the user when necessary.
Country – For proper addressing in the organizational structure.
Postal Code – For sending correspondence, parts and products.
State / City / District / Address / – For proper addressing in the organizational structure.
Date of birth – For sending celebratory messages, advertising.

2. In which situations do we collect site user data?

– When the user uses the contact form.
– When the user signs up for the Gardening Club.
– When the user sends a résumé to the company.

2.1. – These data are collected for the following purposes:

So that the user can be identified when contacting our Customer Service Channel and so that we can respond to your requests.
To send advertising and publicity e-mails.

For us to analyze, identify and contact the data subject, in the event of a possible job opening.

2.2. Consent

We process your personal data on the basis of your consent. Consent is the free, informed and unambiguous expression of consent by which you authorize Trapp to process your data.

Thus, in line with the General Data Protection Law, your data will only be collected, processed and stored with your prior and express consent.

Your consent will be obtained in a specific manner for each purpose described above, evidencing Trapp’s commitment to transparency and good faith with its users/customers, following relevant legislative regulations.

By using Trapp’s services and providing your personal data, you are aware of and consent to the provisions of this Privacy Policy, and you know your rights and how to exercise them.

At any time and without charge, you may revoke your consent.

It warrants emphasis that revoking consent for data processing may prevent proper performance of some website functions that depend on the operation. Such consequences will be informed in advance.

3. What are your rights?

Trapp assures the data subject rights of its users/customers pursuant to Article 18 of the General Data Protection Law. You can thus, free of charge and at any time:

Confirm the existence of data processing, in a simplified manner or in a clear and complete format.
Access your data and request a legible copy thereof, in printed form or by secure and reliable electronic means.
Correct your data, by requesting an edit, correction or update.
Limit your data when unnecessary, excessive or processed in breach of the law through anonymization, blocking or deletion.
Request the portability of your data, through a report of your registration data that Trapp processes.
Delete your data that have been processed with your consent, except in cases provided for by law.
Revoke your consent, disallowing the processing of your data.
Be informed about the possibility of not providing consent and the consequences of refusal.

4. How can you exercise your rights as data subject?

To exercise your rights as a data subject, you should contact Trapp through the following available channels:

Telephone: (47) 2107-8800
e-mail: [email protected]

In order to ensure your proper identification as personal data subject for the data being requested, we may ask for documents or other evidence that can prove your identity. In this scenario, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by Trapp will be used and stored as long as necessary for the provision of service or for the purposes listed in this Privacy Policy, taking into account the rights of data subjects and controllers.

In general, your data will be kept for the duration of the relationship between you and Trapp. Once the personal data storage period has elapsed, such data will be deleted from our databases or anonymized, with the exception of the cases legally provided for in article 16 of the General Data Protection Law, namely:

I – compliance with legal or regulatory obligations by the controller;

II – study by a research organization, guaranteeing, whenever possible, the anonymization of personal data;

III – transfer to a third party, provided that the data processing requirements set forth in this Law are met; or

IV – exclusive use by the controller, with no third party access allowed, and provided that data are anonymized.

In other words, personal information about you that is indispensable for compliance with legal, judicial and administrative determinations and/or to exercise the right of defense in judicial and administrative processes will be kept, despite the deletion of other data.

Trapp’s storage of collected data reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions that are able to guarantee the confidentiality, integrity and inviolability of your data. We also have security measures in place that are appropriate to the risks and control access to the information stored.

6. What do we do to keep your data secure?

To keep your personal information secure, we use physical, electronic and managerial tools geared toward protecting your privacy.

We apply these tools taking the nature of the collected personal data into consideration, as well as the context and purpose of the processing, and the risks that possible breaches would pose for the rights and freedoms of the data subject related to collected and processed data.

Among the measures we use, we can highlight the following:

Only authorized persons have access to your personal data.

Access to your personal data is allowed only after a non-disclosure agreement.

Your personal data are stored in a secure and reliable environment.

Trapp is committed to following the best practices to prevent security incidents. However, it warrants mention that no virtual page is entirely secure and risk-free. It is possible that, despite all of our security protocols, problems may occur that are exclusively the fault of third parties, such as cyber attacks by hackers, or also as a result of the user/customer’s own negligence or carelessness.

In the event of a security incident that could generate relevant risk or damage to you or any of our users/customers, we will notify those affected and the National Data Protection Authority about the occurrence, in accordance with the provisions of the General Data Protection Law.

7. With whom might your data be shared?

In the interest of preserving your privacy, Trapp will not share your personal data with any unauthorized third party.

Only in the following situations may your data be shared:

I – Legal determination, request, requirement or court order, with competent judicial, administrative or governmental authorities.

II – In the event of corporate transactions, such as mergers, acquisitions and takeovers, automatically.

III – Protection of Trapp’s rights in any kind of conflict, including legal.

7.1. International data transfer

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. Under these conditions, in any case, your personal data will be subject to the General Data Protection Law and other Brazilian data protection legislation.

In this regard, Trapp is committed to always adopting effective cybersecurity and data protection standards, using its best efforts to ensure and comply with legislative requirements.

By agreeing to this Privacy Policy, you consent to such sharing, which will occur in accordance with the purposes described herein.

8. Cookies or browsing data

Trapp makes use of Cookies, which are text files sent by the platform to your computer and stored on it, which contain information related to your navigation through the website. In short, Cookies are used to enhance the user experience.

By accessing our site and consenting to the use of Cookies, you acknowledge and accept the use of system for collecting browsing data with the use of Cookies on your device.

Trapp uses the following Cookies:
Required or Strictly Necessary: to help make the website useful by enabling basic functions such as navigation and page access, to protect areas of the website, and also to record your consent. The website may not function properly without these cookies;

Performance: these cookies gather information on how visitors use the website, allowing for identifying which pages are visited most often and any errors that occur during access, aiming to improve the performance of the website;

Preference: these cookies enable a website to remember information that changes the way the website behaves or looks, such as your preferred language or the region where you are located;

Functional: these allow for implementing audio and video content on the website, in addition to registering information about your interaction with this content;

Statistics: these help us understand how users interact with the website, gathering and disclosing information anonymously (or not);

Advertising: these cookies are used to follow visitors through websites, tracking and storing their preferences and what they view.

We use YouTube features to incorporate videos into the website. This feature allows for identifying which videos you have watched so YouTube can set your video preferences and show you ads within YouTube itself.

You may, at any time and without charge, change permissions, block or refuse Cookies. However, revoking consent for certain Cookies may prevent some features of the platform from working properly.

9. Change to this Privacy Policy

The current version of the Privacy Policy was last formulated and updated on: 4/14/2022.

We reserve the right to modify this Privacy Policy at any time, primarily in order to adapt it to changes on our website or in law. We recommend that you review it frequently.
Any changes will be effective as soon as they are posted on our website, and we will always notify you of changes.
By using our services and providing your personal data after such changes, you consent to them.

10. Liability

Trapp establishes the liability of agents acting in the data processing processes in accordance with articles 42 to 45 of the General Data Protection Law.

We are committed to keeping this Privacy Policy up to date, meeting its provisions and ensuring compliance.

In addition, we are also committed to seeking technical and organizational conditions that are able to securely protect the entire data processing process.

If the National Data Protection Authority requires action to be taken in relation to the data processing performed by Trapp, we pledge to comply with such action.

10.1 Liability disclaimer

As mentioned under Section 6, although we adopt high security standards in order to prevent incidents, no virtual page is entirely risk-free. In this sense, Trapp is not liable for:

I – Any consequences arising from user negligence, carelessness or deficiency with regard to their individual data. We only guarantee and accept responsibility for the security of the data processing processes and fulfillment of the purposes described herein.

We emphasize that users are responsible for the confidentiality of their access data.

II – Malicious actions by third parties, such as hacker attacks, unless deliberate or grossly negligent conduct by Trapp is proven.
We emphasize that in the event of security incidents that could generate relevant risk or damage to you or any of our users/customers, we will notify those affected and the National Data Protection Authority about the occurrence and take all necessary actions.

III – In the case of untruthful information entered by the user/customer in the records required to use Trapp’s services, any consequences arising from false information or information entered in bad faith are entirely the user/customer’s responsibility.

11. Data Protection Officer

Trapp provides the following channels for you to contact us to exercise your rights as a data subject:

E-mail: [email protected]
Telephone: (47) 2107-8800

If you have any questions about this Privacy Policy or the personal data we process, you may contact our Personal Data Protection Officer, Fernando Augusto Carvalho da Silva, through the following channels:

DPO e-mail: [email protected]