Privacy Policy

Last updated: 30/07/2022

1. MESSAGE FROM THE BOARD OF DIRECTORS

It is with great pleasure that we present the Privacy Policy of W Bertolo – Ladders and Stepladders
Industry. When you use our website, we collect information and you provide us your personal data
through our online forms. We are committed to keeping this data secure through protection systems.

In this sense, this privacy policy document explains in a clear and accessible way how your
information and your data will be collected, used, shared and stored by our systems.
Acceptance of our policy will be made when you access or use our website or our services. This will
indicate that you are aware of and in full agreement with our use of your information and data.

In this way, we intend to ensure a transparent and upstanding business approach, which we believe
is essential to strengthen our business, maintain a healthy business environment, and contribute to
building a more ethical society.

2. WHICH DATA IS COLLECTED BY WBERTOLO

During your online/offline experience with W Bertolo, we can collect different types of personal data,
in an automatic way with the objective of monitoring and controling, or provided directly by you, for
example, during your registration.

See below for personal data collected and in which situation.
For your registration:

Full name;
Photo
CPF number;
ID number;
E-mail address;
Cell Number;
Date of birth;
Data regarding your business address.

Informations concerning orders, deliveries and payment methods:

Billing address;
Delivery address;
Payment methods : IBAN or credit card details;
Information about you that has been made public by you or is publicly available;
Information that we collect from third parties, for example name, filiation, date of birth, CPF, telephone number, address, etc.
Information that we receive from partners for the delivery of products purchased on W Bertolo’s partner platforms;
Information, provided by you voluntarily, such as through communications with W Bertolo in
social networks or in comments and evaluations of products.
Copies of documents sent by you as proof of residence, bank details or copy of an identity
document, generally used to prove your registration or validation of your identity.

3. HOW WE USE YOUR PERSONAL DATA

We use personal data to ensure quality customer service and a better shopping experience.

Listed below all the purposes for which we may use your personal data:
Registration data:

To perform the fulfillment of requests and questions in our Call Center.
To correctly identify the user.
To send the purchased products or marketing campaigns.
To contact you, if necessary. This contact may cover various subjects, such as communication
about promotions and offers, answers to questions, responses to complaints and requests,
updates on orders placed, and delivery information.
To assist in the diagnosis and solution of technical problems.
To query your information on credit bureau databases.
To carry out investigations and measures to prevent and combat illegalities, fraud, financial crimes, and crimes of money laundering and/or financing of terrorism.
To ensure compliance with legal or regulatory obligations or to guarantee the regular exercise of W Bertolo’s rights. In these cases, we may even use and present the information in judicial and administrative proceedings, if necessary.
To collaborate with the fulfillment of a court order, a competent authority or an inspection agency.

4. WITH WHOM WE CAN SHARE PERSONAL DATA

W Bertolo works in partnership with several companies in Brazil. We may share the information of
the Holders in the following hypotheses:

With partner companies and suppliers, in the provision or development of services aimed at
the Holder.
With authorities, governmental and regulatory entities or other third parties, either to
comply with legal provisions or for the protection of W Bertolo’s interests in any kind of
conflict, including lawsuits and administrative processes.
In case of transactions and corporate changes involving W Bertolo, in which case the transfer
of information will be necessary for the continuity of the services.
By court order or by the request of administrative authorities that have legal competence to
request it.

5. STORAGE AND SECURITY OF PERSONAL DATA

W Bertolo uses the necessary and legally required resources to preserve the privacy of the personal
data collected. We adopt several precautions in compliance with the laws in force, such as :

Uses industry-standard methods to encrypt and anonymize the data collected;
Has protection against unauthorized access to its systems;
Only authorizes the access of previously established persons to the location where the
collected information is stored;
Those who come into contact with personal data must undertake to maintain absolute
secrecy. Breach of confidentiality will result in civil liability and the person responsible will be
held accountable under current legislation;
Maintenance of inventory indicating time, duration and identity of the person responsible for
accessing the data;

Besides the technical efforts, W Bertolo also adopts institutional measures aiming at the protection
of personal data, in such a way that it keeps a program of governance in privacy, constantly updated.
Additionally, W Bertolo encourages the users to take the appropriate measures to protect their
personal data and passwords, being certain that such information is personal, non-transferable and
of the exclusive responsibility of the users.

6. INTERNATIONAL TRANSFER OF PERSONAL DATA

Some of your personal data can be transferred to other countries, for example, when we use
computational services in cloud for processing or storage of data, located outside Brazil.

W Bertolo observes also, in these situations, all the requirements established in the legislation in
force, and adopts the best practices of the market in order to guarantee the protection and privacy
of your personal data.

7. YOUR RIGHTS AS A HOLDER OF PERSONAL DATA

Transparency about the treatment of your personal data is a priority for Wbertolo.
In addition to the information provided in this Privacy Policy, you can also exercise the rights
provided in the General Law of Data Protection, among them:

Confirmation of the existence of personal data processing.
Access to personal data.
Revocation of consent.
Correction of incomplete, inaccurate or outdated personal data.
Deletion of personal data processed with consent or unnecessary, excessive or when you
understand that any point of the LGPD has not been met.
Information about the possibilities and with which companies, partners and other
institutions we may share, or receive personal data concerning you.
Information about the possibility of not giving consent and the consequences of not giving
consent, when applicable.

All requests will be handled free of charge, and will be subject to a prior assessment of your identity
and the feasibility of fulfillment, in order to comply with any obligations that prevent the complete
fulfillment of the requests of the right holders.

8. RETAINING AND DELETION

We will treat your personal data with high levels of protection and guarantee your privacy, through out our
business relationship.
Browsing our platforms and using our services, or potential customer with whom we share our offers
of products and services.
When applicable, and if you have choosen to delete your personal data from our database, W Bertolo
may retain some your personal data for additional periods to comply with legal or regulatory
obligations, for the regular exercise of W Bertolo’s rights, possible lawsuits, audit purposes of various
kinds, or other periods defined and substantiated by legal bases that justify the conservation of this
data.

9. CHANGES IN THE PRIVACY POLICY

W Bertolo reserves the right to change this policy as often as necessary, aiming to provide you with
more security and convenience and to improve your experience.
Please note the importance of consulting our privacy policy periodically.
To facilitate, the date of the last update is indicated on the top of this page.
Any material changes that may require your consent will be indicated in the new privacy policy.

10. APPLICABLE LAW

This document is governed and shall be interpreted by the laws of the Federative Republic of Brazil,
specifically, General Data Protection Law – Law 13.709/2018.

11. CONTACT WBERTOLO

If you have any question about this Privacy Policy or need to contact us concerning your personal data,
please do so by email on the following address : [email protected]

We are always available to answer to your questions and keep you informed!