Privacy Policy
Grupo CBO (“Grupo CBO” or “Company”) is committed to acting in a transparent manner and according to ethical principles. This Privacy Policy is designed to reinforce Grupo CBO’s commitment to the security and privacy of personal data of all individuals related to Grupo CBO (“Data Subject(s)”) and state how their data are treated by the Company.
This Privacy Policy must be read and interpreted in conjunction with Grupo CBO’s Code of Ethical Conduct.
For more information on the processing of personal data carried out within the scope of Grupo CBO’s activities, please contact the Head of Data Protection at privacidade.lgpd@grupocbo.com.br.
- ABOUT US
Grupo CBO (CBO Holding S.A., corporate taxpayer’s ID (CNPJ) 14.882.295/0001-81, and its subsidiaries) is a fast-growing navigation and logistics company. It is currently one of the largest national groups specializing in supporting offshore oil exploration and production platforms. It has the second largest fleet in Brazil (35 vessels), as well as headquarters and a support base strategically located in Niterói and Macaé (RJ).
- GENERAL CONCEPTS
In this Privacy Policy, we adopt the following concepts:
Personal Data: all the information that enable the identification of the Data Subject. For example, name, individual taxpayer’s ID (CPF), email, telephone, picture and biometrics, among others.
Sensitive Personal Data: personal data related to racial or ethnic origin, religion, political opinion; membership of unions or religious, philosophical or political organizations; and data concerning the health or sex life, as well as genetic or biometric data of the Data Subject.
Processing of Personal Data: any operation, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction, involving personal data.
Head of Data Protection: Darcy de Paula (privacidade.lgpd@grupocbo.com.br), who was appointed by the Company to act as an interlocutor with Data Subjects and the National Data Protection Authority (ANPD).
- WHICH PERSONAL DATA DO WE COLLECT?
The collection of Personal Data by Grupo CBO varies according to the purpose of the information and the interaction of the Data Subject with the Company, always following the best data security and secrecy practices.
We list below the nature of Personal Data processed, depending on the interaction with Grupo CBO:
Registration and identification data:
- Name, email, telephone number and other data can be provided in the Contact Us, IR Contact and/or the Ethics Hotline sections;
- Name, email, telephone number, address, personal document data are also used to identify the legal representatives of clients, suppliers and business partners;
- Additional data such as individual taxpayer’s ID (CPF), date of birth, gender, marital status, address, declaration of disability, skills, knowledge, background and professional experience may be provided in the Work with Us section; and
- Social security data, personal identification documents, bank details, photo, parents, education, data and documents of dependents, race, exams, medical certificates and health conditions, biometrics, infractions, penalties and lawsuits, in addition to the other information listed above, are required of employees and, occasionally, contractors, for the management of human resources, health and safety, as well as compliance with legal obligations and in accordance with applicable law.
Technical data:
- Information about your device (computer, laptop, cell phone, etc.); electronic identifiers; cookies; physical location (based on IP address or geolocation); and
- Other similar technical information that may be collected when the Data Subject accesses Grupo CBO’s website or app.
Access to the information is restricted to authorized employees with a legitimate business reason. Employees who misuse such information, violating this Privacy Policy, will be subject to the penalties of Grupo CBO’s disciplinary process.
Grupo CBO reinforces its commitment to the security and privacy of Data Subjects and the processing of Personal Data in compliance with the current legislation and the purposes stated in this Policy.
- USE OF COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small files stored on your computer or mobile device that enable Data Subjects to have a faster, more convenient and/or customized viewing experience. They may also be used to recognize you as a previous visitor to our website or app, to automatically fill out forms on the website, or to display advertising in line with your interests, for example.
Grupo CBO may occasionally use cookies, and users may at any time activate mechanisms in their browser to inform them when they are activated or prevent them from being activated.
Grupo CBO’s website currently uses two cookies:
The Google Analytics cookie is used to help improve the website by collecting and reporting information about how you use it without identifying you directly, and the Vimeo cookie is used to enable video playback, maintaining your language preference and volume adjustment, for example.
The website may also contain links or frames from other websites that may or may not be partners of Grupo CBO and associates. These links and frames are made available with the sole purpose of providing an additional benefit to users. It is worth noting that the inclusion of these links and frames does not mean that Grupo CBO is aware of, agrees with or is responsible for them or their respective content. Therefore, the CBD Group shall not be held liable for any loss or damage suffered as a result of the use of these links or frames.
Whenever other organizations are hired to provide support services, they will be required to comply with the Grupo CBO’s privacy standards.
- FOR WHAT PURPOSE DO WE COLLECT PERSONAL DATA?
Grupo CBO processes Personal Data of the Data Subjects for the following purposes, always supported by statutory basis in accordance with the current legislation:
- Candidate recruitment, selection and maintenance in the résumé bank (Work with Us);
- Formalization of hiring, layoffs, vacations and leaves of absence of employees, including for the purposes of provision of benefits and compliance with legal, tax and social security obligations;
- Promotion of cultural and inclusive diversity at the Company;
- Management of professionals, working tools, activity support tools, personal team motivation and talent retention;
- Internal and external training;
- Compliance with health, safety and environmental normative instructions and regulations and their respective management, recording and control;
- Analysis of incidents;
- Fulfillment of requests (Contact Us and Ethics Hotline) communication and submission of requested information;
- Submission of Company information (mailing list and IR Contact), disclosure of Company information and calling of shareholders’ meetings;
- Formalization and registration of corporate acts;
- Work in administrative and court proceedings and preparatory or mitigating measures;
- Selection, tendering and registration of counterparties with their respective legal representatives, and formalization and management of contracts; and
- Medical and nursing care in general.
Sensitive Personal Data of children or adolescents are processed only when necessary for specific and legitimate purposes in accordance with applicable law.
- HOW LONG DOES GRUPO CBO KEEP PERSONAL DATA?
Personal Data are kept in compliance with the principles of purpose and need.
Termination of Personal Data Processing will occur in the following cases: (i) when the purpose for which the Personal Data of the Data Subject were collected has been achieved and/or the Personal Data collected are no longer necessary or relevant to the achievement of such purpose; or (ii) when the Data Subject is within his or her right to request the termination of the Processing and the deletion of his or her Personal Data and does so; or (iii) when there is a legal order to this effect. In cases of termination of Personal Data Processing, except in the cases provided for in applicable law or in this Privacy Policy, the Personal Data will be deleted.
For specific information on the data retention periods, the Data Subject may contact the Grupo CBO’s Head of Data Protection through our Privacy Channel.
- WITH WHOM DO WE SHARE PERSONAL DATA?
During Personal Data Processing, Grupo CBO may share Personal Data of Data Subjects with regulatory bodies, public agents, third parties or relevant business partners to enable to the provision of services and maximize service and operational quality and efficiency.
Personal Data may be shared with the following third parties:
- Grupo CBO affiliates;
- Service providers and business partners of the Grupo CBO who Process Personal Data on behalf of Grupo CBO, as the data processor; and/or
- Authorities as required by law or when reasonably necessary or justified to protect the rights, environment, property and/or security of Data Subjects, third parties and/or Grupo CBO.
Except for the cases described above, Grupo CBO shall not share Personal Data with other individuals or companies, unless the respective Data Subject requests or has given prior consent to such sharing.
- INTERNATIONAL TRANSFER
The Personal Data processed by Grupo CBO for the purposes described above may be shared with and processed by foreign authorities, suppliers, providers and/or business partners outside Brazil.
Such countries may not require an adequate level of protection for your personal information as compared to national law.
In any case of international data transfer, Grupo CBO will use reasonable efforts to ensure adequate protection, always in compliance with applicable data protection legislation.
- WHAT ARE THE RIGHTS OF DATA SUBJECTS?
The Data Subjects have the following rights:
- To obtain confirmation of the existence of Personal Data Processing by Grupo CBO;
- To access the Personal Data processed by Grupo CBO;
- To request the correction and update of any incorrect or incomplete Personal Data;
- To request anonymization, blocking or deletion of any unnecessary and excessive data, as well as any data processed in non-compliance with Brazil’s General Data Protection Law LGPD;
- To request the portability of Personal Data to another provider of a similar service or product;
- To request the erasure of Personal Data processed on the basis of your consent, except where the law authorizes the retention of such data on another basis;
- To request information about with whom Grupo CBO shared the use of your Personal Data;
- To request information about the possibility of not consenting to the Processing of your Personal Data and the consequences of this action; and
- To revoke consent.
To exercise their rights, Data Subjects should contact our Head of Data Protection, through the communication channel stated at the end of this Privacy Policy.
- HOW DO WE PROTECT PERSONAL DATA?
Grupo CBO uses technical and procedural measures to protect Personal Data against unauthorized or illegal Processing and against accidental loss, destruction or damage.
Personal Data are treated and stored with respect for security and confidentiality procedures.
- PROCEDURE IN THE CASE OF PERSONAL DATA VIOLATION
Any violation of Personal Data or possibility of violation must be urgently and immediately reported to the Head of Data Protection, who will be responsible for conducting the initial analysis and for directing the adoption of appropriate measures necessary to preserve the security of data and information.
Service providers, suppliers or partners who store or process Personal Data on behalf of Grupo CBO, in case of data violation or possibility of violation of Personal Data, shall immediately notify Grupo CBO, identifying the Personal Data that are or may have been compromised, as well as follow the Grupo CBO’s instructions about the procedures to be implemented.
- CHANGES TO THIS POLICY
Grupo CBO reserves the right to change this Privacy Policy at any time by posting the updated version on our website. Data Subjects will be notified in case of any material changes to this Privacy Policy.
- QUESTIONS AND REQUESTS
Any questions related to this Privacy Policy or the way Grupo CBO processes your Personal Data may be sent to Darcy de Paula at privacidade.lgpd@grupocbo.com.br.