Privacy Policy

At TORTUGA, privacy and security are priorities and we are committed to transparency in the processing of personal data of our users/clients. Therefore, this Privacy Policy establishes how the collection, use and transfer of information from customers or other people who access or use our website is carried out.

When using our services, you understand that we will collect and use your personal information in the ways described in this Policy, under the Data Protection standards (LGPD, Federal Law 13,709/2018), the consumer provisions of Federal Law 8078/1990 and other standards of the applicable Brazilian legal system.

Therefore, TORTUGA PRODUTOS DE BORRACHA LTDA, hereinafter referred to simply as TORTUGA, registered with the CNPJ under nº 00.934.658/0001-70, in the role of Data Controller, is obliged to comply with the provisions of this Privacy Policy.

1. What data we collect about you:

Our website collects and uses some of your personal data in order to enable the provision of services and improve the user experience.

1.1. Personal data provided by the holder

Name;

Telephone;

E-mail;

City;

State;

Country;

ZIP CODE;

1.2. Personal data collected automatically (if it exists)

2. How we collect your data

Registration carried out by the user/client;

2.1. Consent

It is based on your consent that we process your personal data. Consent is the free manifestation, informed and unequivocal expression by which you authorize TORTUGA to process your data.

Therefore, in accordance with the General Data Protection Law, your data will only be collected, processed and stored with prior and express consent.

Your consent will be obtained specifically for each purpose described above, demonstrating TORTUGA’s commitment to transparency and good faith towards its users/clients, following the relevant legislative regulations.

By using TORTUGA services and providing your personal data, you are aware of and consent to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

At any time and at no cost, you may revoke your consent.

It is important to highlight that revoking consent for data processing may result in the impossibility of adequate performance of some functionality of the website that depends on the operation. Such consequences will be informed in advance.

3. What are your rights?

The TORTUGA assures its users/clients of their rights provided for in article 18 of the General Data Protection Law. This way, you can, free of charge and at any time:

Confirm the existence of data processing, in a simplified way or in a clear and complete format

Access your data, being able to request it in a legible copy in printed form or electronically, secure and legitimate.

Correct your data when requesting editing, correction or updating of these.

Limit your data when unnecessary, excessive or treated in non-compliance with legislation through anonymization, blocking or deletion.

Request the portability of your data, through a registration data report that TORTUGA processes regarding you

Delete your data processed with your consent, except in cases provided for by law.

Revoke your consent, deauthorizing the processing of your data.

Find out about the possibility of not providing your consent and the consequences of refusal.

4. How can you exercise your rights as a holder?

To exercise your rights as a holder, you must contact TORTUGA through the following available means:

lgpd@tortugaonline.com.br

In order to guarantee your correct identification as the holder of the personal data subject to the request, we may request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by TORTUGA will be used and stored for as long as necessary to provide the service or for the purposes listed in this Privacy Policy to be achieved, considering the rights of data holders and controllers.

In general, your data will be kept as long as the contractual relationship between you and TORTUGA continues. Once the personal data has been stored for a period of time, it will be deleted from our databases or anonymized, except in the cases legally provided for in article 16 of the general data protection law, namely:

I – compliance with legal or regulatory obligations by the controller;

II – study by a research agency, guaranteeing, whenever possible, the anonymization of personal data;

III – transfer to a third party, provided that the data processing requirements set out in this Law are respected; or

IV – exclusive use of the controller, access by third parties is prohibited, and provided that the data is anonymized.

Therefore, personal information about you that is essential for complying with legal, judicial and administrative orders and/or for exercising the right to defense in judicial and administrative proceedings will be maintained, despite the deletion of other data.

The storage of data collected by TORTUGA reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions capable of guaranteeing the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and control access to stored information.

6. What do we do to keep your data safe?

To keep your personal information safe, we use physical, electronic and managing tools directed on protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the processing and the risks that possible violations would generate for the rights and freedom of the holder of the data collected and processed.

Among the measures we adopted, we highlight the following:

Only authorized people have access to your personal data.

Access to your personal data is only done after an agreement on confidentiality.

Your personal data is stored in a safe and appropriate environment.

TORTUGA is committed to adopting the best postures to avoid security incidents. However, it is necessary to highlight that no virtual page is entirely safe and risk-free. It is possible that, despite all our security protocols, problems that are solely the fault of third parties may occur, such as cyber attacks by hackers, or also as a result of the negligence or recklessness of the user/client themselves.

In the event of security incidents that could create significant risk or damage for you or any of our users/clients, we will communicate to those affected and the National Data Protection Authority about what occurred, in accordance with the provisions of the General Data Protection Law.

7. Who can your data be shared with?

In order to preserve your privacy, TORTUGA will not share your personal data with any third party.

Furthermore, there are also other hypotheses in which your data may be shared, which are:

I – Legal determination, request, requisition or court order, with competent judicial, administrative or governmental authorities.

II – Case of corporate transactions, such as merger, acquisition and incorporation, automatically.

III – Protection of TORTUGA’s rights in any type of conflict, including those of a judicial nature.

In this sense, TORTUGA is committed to always adopting efficient cybersecurity and data protection standards, in its best efforts to guarantee and comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will take place in accordance with the purposes described in this instrument.

8. Cookies: are responsible for storing or retrieving information related to each user’s navigation on our website. In most cases, this information does not identify the user personally and is used to offer a more personalized web experience.

Cookies and tracking technologies

We use technologies such as cookies, pixels and others to recognize your browser or device, understand more about your interests and then create features to improve your experience on our platform. Through this we are able to:

– Understand your preferences to send advertising only of interest to you

– Conduct research to improve our content according to what you are looking for

– Prevent fraudulent activities

– Improve security

Blocking or rejecting cookies may result in an incomplete experience on our website. But this option is viable if you want to disable them.

9. Changing this Privacy Policy

The current version of the Privacy Policy was formulated and last updated on 04/01/2021.

We reserve the right to modify this Privacy Policy at any time, mainly to adapt to any changes made to our website or in legislation. We recommend that you review it frequently.

Any changes will come into effect as soon as they are published on our website and we will always notify you of the changes that have occurred.

By using our services and providing your personal data after such modifications, you consent to them.

10. Responsibility

TORTUGA provides for the responsibility of agents who act in processes of data processing, in accordance with articles 42 to 45 of the General Data Protection Law.

We are committed to keep this Privacy Policy updated, observing its provisions and ensuring compliance.

Furthermore, we are also committed to seek technical and organizational conditions that are safely capable of protecting the entire process of data processing.

If the National Data Protection Authority requires the adoption of measures in relation to data processing carried out by TORTUGA, we undertake to follow them.

10.1 Exemption of responsibility

As mentioned in Topic 6, although we adopt high security standards in order to avoid incidents, no virtual page is entirely risk-free. In this sense, TORTUGA is not responsible for:

I – Any consequences arising from the negligence, recklessness or incompetence of users in relation to their individual data. We guarantee and are only responsible for the security of the process of data processing and the fulfillment of the purposes described in this instrument.

We emphasize that the user is responsible for the confidentiality of access data.

II – Malicious actions by third parties, such as hacker attacks, unless culpable or deliberate conduct by TORTUGA is proven.

We emphasize that in the event of security incidents that may create significant risk or damage for you or any of our users/clients, we will inform those affected and the National Data Protection Authority about what happened and take the necessary measures.

III – Inaccuracy of the information entered by the user/client in the records necessary to use TORTUGA services; Any consequences arising from false information or information entered in bad faith are the sole responsibility of the user/client.

Contact us

We remain at your disposal for any questions or suggestions about this Privacy Policy.

Through lgpd@tortugaonline.com.br we will always keep our communication open so you can stay in control of your personal data.