Privacy Policy

CEI – TRADE, EXPORT AND IMPORT OF MEDICAL MATERIALS LTD. (THE COMPANY)
INFORMATION PRIVACY AND CONFIDENTIALITY POLICY

These terms of the INFORMATION PRIVACY AND CONFIDENTIALITY POLICY (“Privacy Statement”) apply to the use of the services offered by THE COMPANY through its website.

In offering its services, THE COMPANY processes, collects, stores and, in some cases, discloses information about registered persons/partners and visitors (“Users”) of websites and/or mobile applications (websites, devices, products, services, stores and applications, etc.), as detailed herein (“Platforms” and “Services”, respectively).

This document forms part of the General Terms and Conditions of Website Use. It is necessary that the User give their voluntary, express and informed consent to this Privacy Statement, which is an essential requirement for contracting and/or establishing any type of relationship with THE COMPANY.

This Privacy Statement applies to all data processing services and operations carried out by THE COMPANY, including any of its subsidiaries or affiliated companies, with THE COMPANY being responsible for and the controller of the processing of Users’ data on its Platforms through its subsidiaries or affiliates.

THE COMPANY collects personal information from its Users so that they may make the best possible use of the company’s services. Such information may be:

a) provided by the User (when registering or providing information when using any of the services);
b) collected automatically (when browsing/interacting with pages or using services – cookies and other unique identifiers are used, collecting certain types of information when the browser/device accesses the company’s services); and
c) collected through other reliable sources (such as information from carriers/postal services regarding deliveries, for example).

PURPOSES OF PERSONAL DATA COLLECTION

THE COMPANY collects Personal Information for the following purposes:

To provide the products, services and/or benefits offered on its website and possibly on other platforms.
To receive and organize orders, deliver products and services, process payments and provide information about orders, products, services and promotional offers.
Identification, registration in systems and communication with the user, in compliance with legal requirements.
To provide the products, services and/or benefits that the user requests or contracts through the platform.
To prepare and maintain a record of transactions carried out, inform the user about them and provide proper monitoring.
To provide support and respond to user comments, complaints and suggestions.
To correct errors and improve usability and effectiveness of services.
Judicial and/or extrajudicial debt collection.
To offer services and functionalities that best meet users’ needs and personalize services and user experience on the website.
To contribute to the security of relationships, communications and transactions between platform users.
To improve and develop services.
To conduct internal studies on interests and behaviors in order to offer better services and products and carry out statistical studies.
To create profiles by analyzing various variables such as behavior or interactions on the platform, analysis and prediction of economic capacity, preferences, interests, transaction history, behavior and location, among others, in order to improve commercial and promotional initiatives of the platform, display advertising or promotions, banners of interest, news, improve content offerings and articles, and personalize content, presentation and services.
To offer services and functionalities that best meet users’ needs and personalize services to make the experience between user and platform as comfortable as possible.
To improve commercial and promotional initiatives and analyze visited pages and searches performed by users to enhance the offer of content and articles and personalize content, its presentation and services.
To provide information through different channels (email, text messages (SMS), push messages, phone calls or any other means of communication) about improvements or new functions or services of the platform.
To comply with legal obligations and requirements of competent authorities.
To detect and prevent fraud, abuse and crimes in order to protect the security of users and the platform, maintaining its sustainability.
To claim the rights of THE COMPANY in case of violation of its Terms and Conditions.
To allow other users or third parties to claim their rights.
To cooperate with intellectual property owners in exercising such rights, whether their own or those of third parties, as well as cooperating with investigations of violations of such rights.
To make advertising and promotional announcements and contacts, including contacting users through different channels (email, SMS, push notifications, telephone calls or other means of communication) for advertising and/or promotional purposes of products and services of THE COMPANY and/or third parties.
To carry out any type of marketing activity, advertising, commercial prospecting and/or market research.
To use data for another specific purpose that will be communicated to the user, depending on the user’s consent, which may later be revoked at any time.

SHARING OF PERSONAL INFORMATION

THE COMPANY does not sell or otherwise commercialize information that identifies its users, nor does it transfer or share such information with third parties, except as indicated below.

THE COMPANY may assign, transmit and/or transfer Users’ Personal Information in the following cases:

Third-party transactions:
Services, products, applications or functionalities and technologies provided by third parties for use in or through the services of THE COMPANY, as well as relationships with companies with financial or commercial activities with which collaborative or partnership relationships are maintained, in order to offer promotions, products and services from such companies or co-branding initiatives. This also applies to companies that provide or may provide services to THE COMPANY, such as customer service, logistics, providers, delivery, transportation, communication and marketing, data analysis and security, dispute resolution, payment processing, among others.

Companies within the same group:
Companies belonging to the same economic group as THE COMPANY, operating under the same internal processes and policies, whether subsidiaries, parent companies or affiliates.

Protection and security:
For the purpose of complying with the law; enforcing or applying the Platform’s Terms of Use and other protocols and agreements; or protecting the rights, property and safety of THE COMPANY, its users or third parties, including the exchange of information with public bodies and other companies and organizations for fraud protection, security and risk reduction. Information may be provided to competent public authorities, even without a judicial order, for the following purposes:

a) to collaborate in investigations and report fraud, piracy, intellectual property violations or any other illegal acts, as well as any activity or circumstance that may generate legal liability for users and/or THE COMPANY;
b) to safeguard public interest, the administration of justice, the recognition, exercise or defense of a right in judicial or administrative proceedings and/or dispute resolution;
c) to comply with any applicable law, regulation or legal provision, or any mandate from a competent authority.

Users and/or visitors in general:
Other users and/or visitors of the Website, in order to provide a quality service to the end consumer by supplying information that allows them to make informed purchasing decisions appropriate to their interests.

By accepting these terms, the User provides express and informed consent for THE COMPANY, if necessary, to assign, transmit or transfer Personal Information to the recipients described in this Privacy Statement.

If necessary, THE COMPANY may share the User’s Personal Information with third parties not mentioned here, requesting prior and express consent, unless there is legal authorization or obligation allowing such sharing without consent.

DATA RETENTION

Users’ Personal Information will be maintained by THE COMPANY for as long as necessary to fulfill the purposes for which it was collected, as well as to comply with legal or regulatory requirements or during the statutory limitation period for possible legal and/or contractual liabilities. After this period, the data will be deleted or anonymized so that no individual can be identified, as permitted by the regulations of each country.

There may be automated decisions regarding Users’ data and information, based on algorithms and computer programs without human intervention. Such decisions may be subject to human review if necessary.

COOKIES AND TRACKING

In order to recognize the browser or device used and to offer and improve services, THE COMPANY uses cookies and other identifiers. On the company website/page (www.ceigroup.com.br/pt-br), trackers such as doubleclick.net and google-analytics.com are used.

USER RIGHTS

If there are any questions or objections regarding the collection and processing of personal information, the User should contact THE COMPANY through the means indicated on the platform.

In addition, subject to applicable law, the User has the right to:

request access to their personal data
correct and delete personal data
request data portability
object to the processing of their personal data
request restriction of processing in certain cases.

USER RESPONSIBILITY

It is important that the User pay attention to their responsibility scope and protect themselves against unauthorized access by safeguarding their login credentials and protecting their computers, devices and applications. Users should not disclose their login details to third parties and should always log out when using shared computers.

The User will be responsible for all acts carried out through the use of their login and password and must change them immediately if there is suspicion of misuse by third parties.

THE COMPANY shall not be responsible for misuse of Users’ Personal Information by third parties if such third parties have collected and/or processed such information directly.

Conduct considered spam and indiscriminate sending of messages between users of the platform is prohibited.

THE COMPANY is not responsible for the use that any user or other person may make of information published on its website and platforms. Users agree that the company will not be responsible for losses or damages resulting from negotiations between users.

SECURITY

THE COMPANY complies with industry regulations and standards regarding security measures applicable to Users’ Personal Information and shall not be responsible for illegal interceptions, breaches of its systems or databases, or use by unauthorized persons. Nor shall it be responsible for improper use of information obtained through such means.

DATA SUBJECT PORTAL

THE COMPANY provides a Data Subject Portal, a page developed to handle requests from Data Subjects (Clients), managed by the DPO (Data Protection Officer), responsible within the company for handling requests from data subjects and from the ANPD (Brazilian National Data Protection Authority).

POLICY CHANGES

If there are changes to these Terms regarding how Personal Information is managed, the User will be notified through usual communication channels such as email or application messages. Lack of user interaction will be considered acceptance of the new version of the policy.

APPLICABLE LAW

This Privacy and Information Confidentiality Policy is governed by the laws applicable at the present date. In the event of any controversy or dispute related to the interpretation, validity, execution or compliance with these Terms, it shall be resolved by the competent legal courts according to the applicable matter.

I acknowledge and agree with the above Terms.