1. OBJECTIVE

The purpose of this Personal Data Protection and Privacy Policy is to establish guidelines, principles and concepts to be followed by all persons and entities that relate to the TELLESCOM GROUP with regard to the security and privacy of personal data processed within the scope of its activities, in accordance with the General Data Protection Law (Law No. 13,709/2018 – LGPD) and related legislation.

Furthermore, it reflects our cultural identity and the commitments we make to all those who have dealings with us, representing a commitment to acting responsibly, ethically, transparently and with respect for all the publics with whom we have dealings.

Our reputation and credibility are the most important assets we have, and the ethical principles that guide our actions contribute to maintaining GRUPO TELLESCOM’s image as a solid and reliable company in the eyes of our Customers, Suppliers, Partners in general, Shareholders, Public Bodies and the Community in which we operate.

2. SCOPE

This Policy applies to all personal data processed by GRUPO TELLESCOM, including the data of:

  • Customers, prospects and partners;
  • Service providers and suppliers;
  • Users of the websites, landing pages and digital channels maintained by the company.

3. TYPES OF DATA PROCESSED

Depending on the relationship with the data subject, the following information may be collected:

  • Registration data (name, CPF/CNPJ, e-mail, telephone);
  • Professional data (company, position, history);
  • Navigation and digital interaction data (cookies, IP, preferences);
  • CVs and data provided in selection processes;
  • Data required for the execution of contracts and services.

We inform you that your rights as a data subject are provided for in article 18 et seq. of the LGPD, which include:

  • Right to confirmation of the existence of processing and access to data;
  • The right to anonymize, block or delete data that is unnecessary, excessive or processed in breach of the law;
  • Right to rectification of incomplete, inaccurate or outdated data;
  • Right to data portability to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;
  • The right to information about the possibility of not giving consent and the consequences of refusing to do so, as well as to revoke consent given; e,
  • Right to object to data processing.

4. PURPOSE OF TREATMENT

Personal data is used for:

  • Execution of contracts and delivery of services;
  • Communicating with clients and leads via e-mail, telephone or social networks;
  • Compliance with legal, regulatory or contractual obligations;
  • Recruitment, selection and people management purposes;
  • Improving the browsing experience in the company’s digital environments.

Practical example of treatment as a data operator:

When GRUPO TELLESCOM develops an institutional website for a client, including forms that collect visitors’ names, e-mail addresses and telephone numbers, this data is sent directly to the systems of the contracting company, which acts as the controller of the personal data, under the terms of the LGPD. In this relationship, GRUPO TELLESCOM acts as the operator of the data, processing it on behalf of and under the instructions of the controller, without retaining, using or sharing it for its own purposes. Good security practices, confidentiality and compliance with legal requirements are applied to ensure the integrity of this data.

Responsibilities of the Controller:

  • You are responsible for determining the purposes and means of data processing.
  • It decides what will be collected, why it will be collected, how it will be stored and who will have access to it.
  • It must also provide the public Privacy Policy on the website, appoint a LGPD officer and keep a record of the legal bases.

Operator responsibilities:

  • It acts on behalf of the client, providing technical services (e.g. form creation, temporary hosting, CRM connection).
  • You don’t decide the end use or the treatment objectives – you just implement the tools.
  • You are obliged to follow the instructions of the controller (client) and adopt security, confidentiality and non-retention measures.

5. PROCESSING DATA ON LEGAL ENTITIES

Although the LGPD applies to the data of natural persons, GRUPO TELLESCOM also ensures the confidentiality and security of commercial and strategic data received from legal customers, as well as information relating to its customers’ customers, when accessed in the context of the provision of services.

This data includes:

  • Commercial and operational briefings;
  • Mailing lists and contacts for campaigns;
  • Information on contracts, projects and operational flows;
  • Documents and files shared via secure platforms.

All this data is treated under strict confidentiality criteria, with access restricted to the teams involved, and used exclusively for the purposes agreed in the contract. GRUPO TELLESCOM undertakes not to store or use such data for its own purposes or for purposes other than those provided for in the established commercial relationships.

6. DATA SHARING

GRUPO TELLESCOM does not sell personal data. It may be shared with:

  • Suppliers and partners contracted to perform the services;
  • Marketing, automation, hosting and CRM platforms;
  • Public authorities, under legal obligation.

In all cases, third parties are subject to confidentiality and data security commitments.

7. INFORMATION SECURITY

The company adopts administrative, technical and organizational measures to protect personal data against unauthorized access, leakage, destruction or loss. These measures include:

  • Access control to systems and documents;
  • Internal confidentiality policies;
  • Data encryption and backup;
  • Vulnerability monitoring.

8. SECURITY INCIDENT RESPONSE PLAN

In the event of a security incident that could result in significant risk or damage to data subjects, GRUPO TELLESCOM will follow the following procedures:

  • Immediate internal notification to the data governance team;
  • Opening an investigation to identify the origin and extent of the incident;
  • Adoption of corrective and mitigating measures;
  • Communication to affected owners, where applicable, with guidelines and service channels;
  • Notification to the National Data Protection Authority (ANPD), as required by the LGPD.

All incidents are recorded and documented for auditing, recurrence prevention and legal compliance purposes.

9. OWNERS’ RIGHTS

The holder of personal data has the following rights guaranteed by the LGPD:

  • Access to data;
  • Correction of incomplete or outdated data;
  • Anonymization, blocking or deletion of unnecessary data;
  • Information on use and sharing;
  • Revocation of consent, where applicable.

Requests should be sent to: <email-DPO>

10. OTHER USES OF THE DATA COLLECTED

Regardless of whether it is personal and/or non-personal information, GRUPO TELLESCOM may use the data and information contained in the register for the following activities:

  • Answering any questions and requests;
  • Compliance with a legal or judicial order;
  • Constitute, defend or regularly exercise rights in the judicial or administrative sphere;
  • Ensuring the safety of employees, customers, partners and users of our digital channels;
  • Keeping up-to-date records of clients, partners and users of our digital channels in order to contact them by landline, cell phone, e-mail, SMS, direct mail, social networks and media, or other means of communication;
  • Promoting the services of commercial or non-commercial partners, informing them of new opportunities, products and benefits;
  • Generate analysis and studies, whether statistical or identifiable, based on the usage behavior of the tools, website, products and services of GRUPO TELLESCOM;
  • Generate analyses and studies, whether statistical or identifiable, based on the data reported and collected from authorized gadgets;
  • To improve the use and interactive experience when browsing our digital channels (website, application and the like), products and services of GRUPO TELLESCOM, as well as other tools and platforms launched/incorporated by GRUPO TELLESCOM.

The data absorbed may only be accessed by professionals duly and previously authorized by GRUPO TELLESCOM, respecting the need to which they will be submitted, the relevance to the objectives of GRUPO TELLESCOM and the interests of users, as well as preserving their privacy.

11. RIGHT TO OBJECT

If you wish to object to the processing of your personal data, please contact us, free of charge, at <email-DPO>, in accordance with the guidelines in this policy.

GRUPO TELLESCOM will make every effort to respond to such requests within a short period of time. However, the customer, partner and user will be aware that, even in the event of a request to delete data, the minimum storage of information determined by Brazilian law will be respected and that the data may be provided by court order or request from a legal authority.

12. VALIDITY AND REVISION

This policy comes into force on the date of its publication. It may be updated from time to time to meet legal or operational requirements.

TELLESCOM INDÚSTRIA E COMÉRCIO EM TELECOMUNICAÇÃO SOCIEDADE UNIPESSOAL LTDA
CNPJ/MF No. 10.217.017/0001-59
SITE: https://tellescom.com.br

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