Who are we?
Truman Stakeholders Negócios de Impacto Ltda. ("Truman"), a limited liability company, enrolled with the CNPJ/MF No. 44.325.121/0001-89, headquartered in Sao Paulo/SP, at Rua Joao Baldinato, 109, cj. 84i, Vila Suzana, CEP 05630-080, is a technology and sustainable solutions promotion company, working to generate positive socioeconomic impact and foster the 17 United Nations Sustainable Development Goals (SDGs), as well as its 169 universal goals, offering services mainly related to e-commerce and acceleration of socio-environmental initiatives and projects.
Truman is committed to protecting your privacy. This commitment reflects our value of earning and maintaining the trust of our customers, business partners, and third parties who share your Personal Data with us.
If you want to contact us, just send an email to:[email protected]].
What is the role of this Privacy Policy?
This Privacy Policy (“Policy”) aims to disclose the general conditions applicable to the processing of personal data processed by Truman, through access to the website [www.trumanstakeholders.com.br] (“Platform"), by the guidelines of the General Data Protection Law (Federal Law No. 13.709/2018 -LGPD”).
The conditions outlined in this Policy apply only to the Platform and do not apply to any other web address and/or third-party applications that the User may access from the Platform.
This Policy is an integral part of our Terms of Use.
Definitions
To facilitate the reading and understanding of this Policy, some important definitions are indicated in the table below.
| Defined terms | Meaning |
| Anonymization | Process whereby the data loses the possibility of association, directly or indirectly, with an individual, considering the reasonable technical means available at the time of Processing. |
| ANPD | National Data Protection Authority, is the body responsible for monitoring compliance with the LGPD. |
| Truman | Truman Stakeholders Negócios de Impacto Ltda. |
| Personal Data | Any information related to the natural person, directly or indirectly, identified or identifiable. |
| Sensitive Personal Data | Special category of Personal Data relating to racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical, or political nature, relating to health or sex life, genetic or biometric data relating to the natural person. |
| Policy | This Privacy Policy. |
| Subscriber | The natural person to whom the Personal Data refers, such as former, current, or potential customers and their employees, contractors, business partners, and third parties. |
| Treatment | Any operation performed with Personal Data, such as collection, production, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, modification, transfer, dissemination, or extraction. |
| User or You | Website Visitor(s) who contact Truman Stakeholders by completing the available forms, registering, or just browsing the Website. |
| Platform | Tool (website and application) designed to form an ecosystem that allows people to offer, sell, buy, pay, send products, and perform other business activities with applied technology developed by Truman Stakeholders. |
Who is responsible for your information?
Truman Stakeholders is responsible for the Personal Data (and the Controller, for the LGPD) that it originally collects through its Platform. This may also be explained in separate privacy notices available when your Personal Data is first collected by Truman.
Quick Read
Truman processes the Personal Data of Users, who eventually demonstrate an interest in the services provided and made available by the Platform, mainly related to electronic commerce and acceleration of socio-environmental initiatives and projects.
Truman Stakeholders uses Personal Data collected through its Platform to contact and offer services to Users. In addition, Truman, for its purposes, also uses such information to analyze and improve the way it provides these services, as well as to create new products and services to be offered to Holders.
The Holder of the Personal Data collected by Truman Stakeholders has important rights guaranteed by the LGPD, which may be exercised by You.
The primary point of contact at Truman Stakeholders for questions regarding the Processing of your Personal Data is [[email protected]].
When and how do we treat your data?
The Personal Data processed by Truman have as their predominant purpose the establishment of a contractual relationship or the management, administration, provision, expansion, and improvement of the services provided to the Holder, via the Platform, adapting them to their preferences and tastes, as well as the creation of new services and products to be offered to the Holders.
Truman Stakeholders, in some cases, may also process Personal Data when necessary to comply with legal or regulatory obligations.
In addition, Truman may also process Personal Data based on its legitimate interest, always within the limit of what is expected by the Holder, especially taking into account the relationship already existing between You and Truman, and never to the detriment of your fundamental rights and freedoms.
We will only process your Personal Data for the purposes for which we collect it unless we reasonably deem it necessary to use it for another purpose, as long as it is compatible with the initial one.
If you choose not to provide certain Personal Data when requested, we may not be able to comply with the contractual obligations and perform the contract we have entered into with you (such for example, processing payments and responding to inquiries), and even be unable to perform the provision of the contracted services, as well as, we may be prevented from complying with our legal and regulatory obligations.
In cases where your consent is necessary for the performance of a given activity, we will inform you of the consequences arising from your failure to provide it.
We take reasonable and appropriate physical, technical, and administrative measures to safeguard the information we process.
What data do we process and for what purpose?
During your experience on the Platform, Truman Stakeholders may process different types of Personal Data, automatically or provided directly by You.
See in the table below what Personal Data may be collected, in what situations they are collected, and for what purposes:
| PERSONAL DATA COLLECTED | PURPOSES |
| Dados de navegação: data collected through cookies or device IDs, including IP, date and time of access, geographic location, browser type, duration of the visit, and pages visited. Dados sobre o dispositivo de acesso: model, manufacturer, operating system, phone company, and browser type. | Website operation: enable essential features such as translation, and responsiveness of the website/application to the desktop/mobile, among other functions. |
| Dados básicos de cadastro: email, name, phone. | Relationship Ruler: make contact, send status notifications, leads received (in the case of Waste Managers), among others. |
| Initiative registration: CNPJ card, trade name, corporate name, address, area of operation, and other information (depending on the type of company)* *In the case of MEI, EI, SLU, or Eireli, in which the corporate name contains the name of the data subject and/or his CPF | Approval on the platform: analyze business data to approve it on the platform as a sustainable initiative. Accelerate Impact Business: increase business visibility with an institutional page composed of information about the initiative and a section with products and services. |
| Registration of waste managers (Legal Entity and Individual): Name, Telephone, Email, CNPJ, Company name, Address, and other information. | Waste sale: release access to the marketplace and advertise waste. |
| Registration of customer or buyer of waste or accelerator of initiatives: Name, E-mail, telephone, CPF, and address. | Waste purchase: release access to the marketplace and the purchase of waste. Seed purchase: Accelerate business through the purchase of seeds. |
| QI Tech account opening: NP Brazilian Identity Card (RG) or Driver’s License PJ List of company representatives An identification document (RG or CNH) is required for each representative Company Bylaws PDF PDF of the Minutes of the company's election (mandatory only for companies S.A.) | Waste purchase: generate payment instrument for credit to the waste manager's account. |
Sensitive Personal Data
In addition to the Personal Data listed above, we may also process the Sensitive Personal Data of our Users, as described below:
| PERSONAL DATA COLLECTED | PURPOSES |
| Indication of link with governmental and/or religious organizations: Name of the link organization, CNPJ, and Legal Representative | Verify that the businesses to be integrated have links with governmental and/or religious organizations, to verify adherence to the Platform. |
Personal Data of Children and Adolescents
Truman Stakeholders does not process the Personal Data of children and adolescents. Our Platform is not directed to children or adolescents, and Truman Stakeholders directs its services to children under the age of 18.
Third parties data
If You share Personal Data with Truman Stakeholders regarding other individuals, You declare that You have the competence to do so and declare that You have a legitimate legal basis for doing so, such as obtaining the necessary consent to authorize the use of such information under the terms of this Policy.
Use of cookies and other technologies
- Cookies
Like many companies, we may use cookies. Cookies are text files stored on the hard drive of your device, when you access certain websites and platforms, and that aim to facilitate your queries.
We use cookies to obtain information about, for example, whether you have visited our website before or whether you are a new visitor, and to help us identify the parts and sections of the website in which you are most interested. Cookies allow you to improve your online experience by saving your preferences while you visit a specific website.
- Web beacons
Certain pages of our website contain "web beacons" (also known as internet tags, pixel tags, and clear GIFs). These web beacons allow you to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies added by third parties.
We use log files to store the data collected through web beacons. With both cookie and web beacon technologies, the information we collect and share is anonymous and not personally identifiable. They do not contain your name, address, phone number, or email address.
For how long do we retain your Personal Data?
The length of time we retain your Personal Data depends on the purpose for which it was obtained and its nature. We will retain your Personal Data for the period necessary to fulfill the purposes described in this Policy unless a longer retention period is permitted by law.
We may store your Personal Data for longer periods in specific circumstances so that we have an accurate record of your business with us, in case of any complaints or disputes, or if we reasonably believe that there is a potential dispute, so that we can exercise our rights in judicial and administrative proceedings.
Do we share your personal data?
Truman Stakeholders may share your Personal Data with different government authorities, institutions or agencies (or similar), suppliers (for example, a third-party company that provides storage and hosting of applications, files, and data), as well as third-party service providers that process Personal Data on behalf of Truman Stakeholders (such for example, accountants, auditors, consulting, etc.), and business partners, to comply with our contractual obligations or in the context of the possible sale or restructuring of the business.
Whenever we share your Personal Data, we will limit it to the minimum necessary, as well as not allow our service providers to use such data for purposes other than the contracted party.
Whenever your Personal Data is processed by third parties, Truman will ensure that the third parties always do so following the provisions of the LGPD.
International transfers
As a rule, Truman Stakeholders does not share your Personal Data internationally.
In the event of an international transfer, Truman Stakeholders will adopt the necessary safeguards so that the Personal Data of its suppliers have the same level of protection that Truman adopts for its own Personal Data, and, whenever necessary, Truman will use the international data transfer mechanism required by data protection laws.
We have security measures in place to protect your information
The security of your Personal Data is important to us, and Truman Stakeholders has implemented reasonable physical, technical, and administrative security standards to protect Personal Data from loss, misuse, alteration, or destruction. We protect your Personal Data from unauthorized access, use, or disclosure using security technologies and procedures such as encryption and limited access.
The mechanisms employed by Truman Stakeholders to ensure the inviolability of data include, but are not limited to: (i) data encryption processes at rest; (ii) authenticated access via Access Token and (iii) data encryption in transit (SSL).
Truman Stakeholders recommends that the User keep their password in total secrecy, avoiding its disclosure to third parties. Truman Stakeholders will never ask for the User's password outside our Platform.
Truman Stakeholders has internal procedures to react to suspected personal data breaches and notify the User and the competent authorities. In addition, accounts with suspected violations are automatically blocked by Truman Stakeholders to prevent improper access. To unblock an account, the User must contact Truman Stakeholders at: [email protected].
What are the rights of the Platform User?
The LGPD grants the Personal Data Subject several rights, which Truman Stakeholders fully respect. Below are indicated such rights, so that You can exercise them upon request to Truman Stakeholders:
- Right of Confirmation: right to confirm whether Truman Stakeholders processes your Personal Data
- Right of Access: right to access your Personal Data held by Truman Stakeholders
- Right of Correction: right to request the correction of incomplete, inaccurate, or outdated data
- Right to Anonymization, Blocking, or Deletion: right to request the anonymization, blocking, or deletion of unnecessary, excessive, or processed data in violation of the provisions of the law
- Right of Portability: right to request the portability of Personal Data to another service provider
- Right of Deletion: right to delete Personal Data processed with your consent, to the extent permitted by law
- Right to Information: right to receive from Truman Stakeholders information about the public or private entities to which your Personal Data has been shared and about the possibility of not providing consent and the consequences of refusal
- Right of Revocation of Consent: right to request, by a free and facilitated procedure, the revocation of your consent concerning the Processing of your Personal Data
Users' requests will be treated with special care so that Truman Stakeholders can ensure the effectiveness of the Holders' rights. In all cases, to exercise your rights, please contact [email protected].
We emphasize that the User may be asked to prove his identity, to ensure that the sharing of Personal Data is only done with its Holder
You should be aware that, in certain cases, your request may not be immediately fulfilled, and Truman Stakeholders may not be able to fulfill such request due to any impediment due to the need to comply with legal or contractual obligations.
Third-Party Websites & Apps
This Policy applies exclusively to the services provided by Truman Stakeholders on its Platform. If You click on any link available on our Platform and are redirected outside of it, We encourage You to read the specific terms and policies of that third-party website before proceeding with navigation.
We are not responsible for the privacy practices of other websites.
Registration Cancellation
The User will receive communications related to Truman Stakeholders' services. To unsubscribe and stop receiving messages, change your settings or follow the instructions in the email, text message, notification, or other message type, through the following channel: [email protected].
If you have canceled your subscription to no longer receive any communication from Truman Stakeholders, due to the traffic on our servers, the User may still receive communications already scheduled in the shooting queue. However, no new triggers will be scheduled from the time you request to unsubscribe.
Terms of Usage
Your use of Truman Stakeholders' products and services, and any disputes arising therefrom, is subject to this Privacy Policy as well as our Terms of Use. Please visit our Terms of Use, which explains other terms governing the use of our products and services.
Contact Us
If you have any questions, would like more information about our Personal Data processing practices and privacy, would like to discuss options for deletion or withdrawal of consent, would like to make a complaint about a legal violation of this Policy, or would like to exercise any of your rights under the LGPD, please contact us at: [email protected].
Changes to this Policy
Truman Stakeholders may modify this Privacy Policy at any time, according to the purpose or need, such as for the adequacy and legal compliance of a provision of law or rule that has equivalent legal force, the version in force being always the most recent, being certain that the new policy will enter into force 1 (one) day after being published on the Platform.
São Paulo/SP, August 4, 2023
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