Ecorodovias makes forward-looking statements, estimates and intentions which are subject to risks. Any forward-looking statements, estimates and intentions involve risks and uncertainties, which may cause real results to be materially different from those in these statements and estimates and that intentions and plans may not materialize.
The observations in relation to forward-looking statements also include information about possible or foreseen operating results, as well as sentences preceded, followed or containing the verbs “believe”, “may”, “will”, expect”, “intend”, “plan” or similar expressions.
Forward-looking statements are based on the beliefs and assumptions of the Company management, and on information currently available to the Company. They involve risks, uncertainties and assumptions because they relate to future events and therefore depend on circumstances that may or may not occur in the future. Investors should understand that general economic conditions, industry conditions and other operating factors could also affect the future results of the Company and could cause results to differ materially from those expressed in such forward-looking statements.
ECORODOVIAS – PRIVACY NOTICE TO INVESTORS
This Notice of Privacy Rights applies to investors (“You” or “Investor”), whether a holder of shares, debentures or any other financial asset or security (“Financial Assets”) of EcoRodovias Infraestrutura e Logística S.A. and its affiliated companies (“EcoRodovias” or “Us”) in Brazil.
The purpose of this Privacy Notice is to inform You about how EcoRodovias uses your personal information as an Investor and with regard to your Financial Assets. This includes generation information on what types of personal information are collected and used, for what purposes, for how long, with whom it may be shared and what rights You have with regard to your personal information.
We emphasize that the purposes described in this Privacy Notice include those to comply with or demanded by government agencies and entities in their regulation of the financial market, such as the Securities and Exchange Commission of Brazil (CVM) (“Regulatory Authorities”).
Collection and use of your personal information
EcoRodovias may collect the follow information from its Investors: full name, e-mail address, government numbers and/or document, position of Financial Assets and shareholdings in EcoRodovias, bank account, bank branch, other financial information, full address, date of birth, nationality, sex, profession and level of education.
The personal information collected may be obtained directly from You, provided or shared by third parties or from public databases. EcoRodovias will be diligent to ensure that any collection of personal information from third parties or public databases is made in compliance with the law and based strictly on the need to fulfill the purposes informed in this Privacy Notice.
Purposes for using your personal information
EcoRodovias will use your personal information for the following purposes:
- Complying with its legal and contractual obligations with the Investor;
- Establishing a channel of communication with its Investors who are shareholders of EcoRodovias, through which Investors can ask questions and open requests with EcoRodovias;
- Diagnosis of the base of Investors who are debentureholders of EcoRodovias, with basic information on the debentureholders, classification of the positions of the largest debentureholders, contact and relations;
- Managing relations with Investors, including to notify them of meetings, events and conference calls in their interest;
- Information on the meetings to be held in compliance with the applicable laws and regulations;
- Notifying and updating Investors on material information related to the Financial Assets, within the limits required by law (including through regulations issued by the Regulatory Authorities);
- Information on the volume of Financial Assets held by the Investors, income statements, renegotiation of outstanding amounts and other information required for EcoRodovias to manage its relations with Investors;
- Reports on changes in the shareholder base of EcoRodovias, which are shared with financial institutions involved in managing the shareholder base, bookkeeping and other financial services related to the Financial Assets;
- Monitoring the shareholder base of EcoRodovias for identifying any illegal activities or irregularities, for the purposes of legal and regulatory compliance and with the limits of the applicable legislation;
- In cases in which Investors visit in person a unit of EcoRodovias, the collection of information on the identity and the images recorded for the purposes of personal safety and facilities security;
- For conducting audits, including in the context of the applicable regulatory requirements;
- For preventing and controlling fraud of any kind;
- For the normal exercise of the rights of EcoRodovias, including in connection with contracts and lawsuits and administrative and arbitration procedures; and
- Responses to the authorities in connection with lawsuits and administrative procedures in the fulfillment of legal and regulatory obligations and any other legal demand made to EcoRodovias.
With whom we share your personal information
EcoRodovias does not share personal information with third parties, except for the purposes listed above, in the following cases;
- With affiliated companies that are part of the EcoRodovias group;
- With the service providers and business partners of EcoRodovias that process personal information on behalf of EcoRodovias, without the right to the independent use of the personal information;
- To the Regulatory Authorities in the fulfillment of legal obligations or for the normal exercise of the rights of EcoRodovias;
- To government authorities, as required by law or when reasonably necessary to protect the rights, property and/or the security of the Investor, of third parties and/or of EcoRodovias; and
- When we have obtained your consent to share your personal information.
Where your personal information is used
The personal date of Investors may be used in Brazil as well as in other countries, such as the United States of America, always in compliance with the contractual obligations related to confidentiality, ethics, information and other applicable legal protections required by law.
Remember that other countries have legislation and levels of data protection different from those in Brazil. EcoRodovias will adopt all measures required by law for any international transfer of personal information to protect the rights of the owners of the personal information when it is transferred to other countries.
How we protect your personal information
EcoRodovias adopts and maintains a process for continually improving the technical and organizational measures for the security of personal information and for preventing incidents involving the security, leak and undue use of personal information.
EcoRodovias adopts physical security procedures for authorizing access to its offices and facilities. It also adopts information security measures, such as implementing security software, continually monitoring the equipment, network and servers of EcoRodovias, the control and safekeeping of records of access to the systems and applications used in EcoRodovias, among others.
The employees, service providers and business partners of EcoRodovias are bound by nondisclosure requirements. Only employees and service providers with a need to access personal information for the performance of their activities have access to such personal information.
For how long we keep your personal information
EcoRodovias maintains your personal information for the period required to fulfill the purposes listed in this Privacy Notice, including to comply with legal and contractual obligations. For specific information on the period for which information is retained, You can contact EcoRodovias through our communication channel for the person responsible for personal data protection by sending an e-mail to: email@example.com.
What are your rights and how to exercise them
In accordance with Federal Law 13.709/18 – General Personal Data Protection Law (LGPD), Investors have the following rights, which may be exercised in certain contexts by request, in accordance with Article 18 of said law:
- confirmation of the existence of the use of your personal information;
- access to your personal information;
- correction of personal information that is incomplete, inaccurate or outdated;
- anonymization, blocking or elimination of information that is unnecessary, excessive or that was treated in breach of the LGPD;
- portability of personal data to another supplier of a service or product, subject to the regulations of the national authority;
- request for deleting or anonymizing personal information used based on your consent, except when the law authorizes maintaining the information for other reasons;
- information on public and private entities with which EcoRodovias conducts the shared use of your personal information;
- information on the possibility of not consenting with the use of your personal information and the consequences of such action; and
- revocation of your consent.
EcoRodovias takes the rights of its Investors seriously and will facilitate, in accordance with the law, the fulfillment of all requests for exercising rights. EcoRodovias may reasonably require personal information from investors to confirm their identity and for authentication in the context of the exercise of their rights, which is performed for the security of the Investor.
To exercise their rights, Investors should contact the person responsible for personal data protection at EcoRodovias through the following channel: firstname.lastname@example.org.
Updating of this Privacy Notice and Contact Information
This Privacy Notice may be updated from time to time. All changes shall come into effect as of the date of their revision, unless we communicate otherwise to You. We will make efforts to communicate any updates of this Privacy Notice, especially through our website.
Privacy Notice Revised on 08/21/2020.