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For natural persons (data subjects) in BRAZIL (BRAZIL), when we collect and use personal data (information) about you, we may be subject to the General Data Protection Law of the Brazil (“LGPD”) and responsible as a ‘data controller’ for such personal data. Below you will find the additional specific provisions applicable to you in BRAZIL; including your rights to your data as it may be processed by TCS.
How we will use your personal information
Where the LGPD is applicable to TCS, we are only permitted to process your personal data on the basis of certain legal requirements which are outlined in the applicable legislation. As such, you will find below the valid legal bases which permits us to process your personal data for the fullfilment of one of the below purposes (which are outlined more specifically above in our general notice).
To ensure access to our website and online services
- Under the LGPD, the lawful basis for this processing is our legitimate interest in enabling and improving our website and online services, or consent, where requested and obtained.
To answer your queries, support and contact requests
- Under the LGPD the lawful basis for this processing may be for the performance of a contract with you or to take steps at your request before entering into a contract with you, or for our legitimate interests in behaving as a responsible organization in dealing with these matters, or consent, where requested and obtained.
Subscriptions to our promotional communications
- Under the LGPD the lawful basis for this processing is our legitimate interest in promoting its brand, products, initiatives and values or consent, where requested and obtained.
To administer events and activities
- Under the LGPD the lawful bases for this processing is our legitimate interest in organizing and running such events, or consent, where requested and obtained.
To manage, adiminster and fulfill the obligations under contracts, and regulations
- Under the LGPD and depending on the processing activity, the lawful bases for this processing may be for the performance of a contract with you or to take steps at your request before entering into a contract with you, our legitimate interest in providing services to your company or employer, or legal obligation.
To promote TCS brand, products, initiatives and values with marketing communications
- Under the LGPD the lawful basis for this processing are TCS’ legitimate interests in promoting its brand, products, initiatives and values, or consent, where requested and obtained.
Transferring Brazil Data Subject information outside Brazil for LGPD
We may transfer the personal data we collect about you to one of more countries outside /BRAZIL, including India, in order to perform one of the activities listed above (see "How we will use information about you"). Where there isn't an adequacy decision by the Brazilian authorities in respect of those countries - meaning that these are not deemed to provide an adequate level of protection for your personal data - we have put in place the appropriate measures to ensure that your personal data will be secure. These measures include Data Transfer Agreements based on the European Commission's Standard Contractual Clauses and LGPD. If you require further information about these protective measures, you can request it from our Data Protection Officers (see contacts below).
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
Get a confirmation whether TCS process or not your personal data.
Request access to your personal data (commonly known as a “data subject access request”). You can ask us to have easy and free access of the personal data we hold about you.
Request correction of the personal data that we hold about you. You can ask us to update any incomplete, inaccurate or out of date information we hold about you corrected.
Anonymization or blocking of the personal data which are not necessary, excessive or not in accordance with applicable laws.
Request deletion of your personal data. You can ask us to delete or remove your personal data where there is no legal basis for us that allows us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground and if such data processing is not based on other legal basis .
Revoke your consent to processing of your personal data.
Data portability: you can ask us, upon express request, in accordance with National Data Protection Authority’s regulation, to transfer your data from one service provider to another, always respected business and industrial secret.
Be informed of which public or private entities your personal data is or was shared with.
Know the possibility of not give your consent to have your personal data processed by us and the consequences of denying it.
Right to avoid automated decision-making: You have the right to have a decision that affect your interests reviewed if it’s based solely on automated processing.
What we may need from you
If you exercise one of the above rights, we may need to request specific information from you to help us confirm your identity and that you are entitled to make such a request. This is to ensure that personal data is not disclosed to any person who has no right to receive it.
Data Protection Officer
We have appointed Data Protection Officers (DPOs) to oversee compliance of TCS with applicable data protection laws and with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the DPO in your region:
Data Protection Officer for Brazil: Luiz Paulo Cortez
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Data Protection Officer for LATAM
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