Note: This Privacy Policy only applies to users located  in the European Economic Area (EEA).  If you are located outside of the  EEA, please see our Non-EEA Privacy Policy.

The European Economic Area includes Iceland, Liechtenstein and Norway and the countries of the European Union: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom.

EEA Privacy Policy

FRONTLINER (referred to as “we”, “us” or “our” in this document) is the data controller and we are responsible for your personal data. References to our “Services” are references to the Websites and our associated services, social media channels, features, content, events and applications.

Please read the following to learn more about our privacy policy.  By  using or accessing the Services in any manner, or by otherwise providing us with your personal information, you  acknowledge that you accept the practices and policies outlined in this  privacy policy, and you hereby consent that we will collect, use, and  share your information in the following ways.

1. Definitions

The data protection declaration of FRONTLINER is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

1.1 Personal data means any information relating to an identified or  identifiable natural person (“data subject”). An identifiable natural  person is one who can be identified, directly or indirectly, in  particular by reference to an identifier such as a name, an  identification number, location data, an online identifier or to one or  more factors specific to the physical, physiological, genetic, mental,  economic, cultural or social identity of that natural person.

1.2 Data subject is any identified or identifiable natural person, whose  personal data is processed by the controller responsible for the  processing.

1.3 Processing is any operation or set of operations which is performed  on personal data or on sets of personal data, whether or not by  automated means, such as collection, recording, organisation,  structuring, storage, adaptation or alteration, retrieval, consultation,  use, disclosure by transmission, dissemination or otherwise making  available, alignment or combination, restriction, erasure or  destruction.

1.4 Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

1.5 Profiling means any form of automated processing of personal data  consisting of the use of personal data to evaluate certain personal  aspects relating to a natural person, in particular to analyse or  predict aspects concerning that natural person’s performance at work,  economic situation, health, personal preferences, interests,  reliability, behaviour, location or movements.

1.6 Pseudonymisation is the processing of personal data in such a manner  that the personal data can no longer be attributed to a specific data  subject without the use of additional information, provided that such  additional information is kept separately and is subject to technical  and organisational measures to ensure that the personal data are not  attributed to an identified or identifiable natural person.

1.7 Controller or controller responsible for the processing is the  natural or legal person, public authority, agency or other body which,  alone or jointly with others, determines the purposes and means of the  processing of personal data; where the purposes and means of such  processing are determined by Union or Member State law, the controller  or the specific criteria for its nomination may be provided for by Union  or Member State law.

1.8 Processor is a natural or legal person, public authority, agency or  other body which processes personal data on behalf of the controller.

1.9 Recipient is a natural or legal person, public authority, agency or  another body, to which the personal data are disclosed, whether a third  party or not. However, public authorities which may receive personal  data in the framework of a particular inquiry in accordance with Union  or Member State law shall not be regarded as recipients; the processing  of those data by those public authorities shall be in compliance with  the applicable data protection rules according to the purposes of the  processing.

1.10 Third party is a natural or legal person, public authority, agency or  body other than the data subject, controller, processor and persons  who, under the direct authority of the controller or processor, are  authorised to process personal data.

1.11 Consent of the data subject is any freely given, specific, informed  and unambiguous indication of the data subject’s wishes by which he or  she, by a statement or by a clear affirmative action, signifies  agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation  (GDPR), other data protection laws applicable in Member states of the  European Union and other provisions related to data protection is:

FRONTLINER
Caixa Postal 66.161
Sao Paulo - SP
Brazil

Email: gdpr@front-liner.com

3. Cookies

The Web pages of FRONTLINER don't use cookies.

4. Collection of general data

Our authoritative name servers don't log requests. The FRONTLINER Web and Proxy servers, and the CDN and the STORAGE providers, may gather standard technical data and store it in log files when a data subject or automated system calls up the website. The log files may include: (1) the date and time of access; (2) the Internet Protocol IPv4/IPv6 address; (3) the Autonomous System Number (ASN) of the Internet access provider (ISP) derived  from the IP address; (4) Non-Precise Geolocation data such as Country and City derived from the IP Address; (5) the Uniform Resource Identifier (URI); (6) the HTTP response status code; (7) the browser, the operating system, and the referrer reported in the HTTP request; and (8) any other similar data that may be used in the event of Internet attacks at the network edge or against our information systems.

When using these general data FRONTLINER does not draw any conclusions about the data subject. Rather, this  data is required to: (1) deliver the content of our website correctly; (2) optimize the content of our website as well as its advertisement; (3) ensure the long-term viability of our information  technology systems and website technology; and (4) provide law enforcement authorities with the information necessary for criminal  prosecution in case of a cyber-attack.

5. Registration on our website

The data subject has the possibility to register on the website of  the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input  mask used for the registration. The personal data entered by the data  subject are collected and stored exclusively for internal use by the  controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also  uses personal data for an internal purpose which is attributable to the  controller.

By registering on the website of the controller, the IP  address, date, and time of the registration are also stored. The storage of this data is necessary to secure the controller. This data is not  passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal  prosecution.

The registration of the data subject, with the voluntary indication  of personal data, is intended to enable the controller to offer the data  subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons  are free to change the personal data specified during the registration  at any time, or to have them completely deleted from the data base of  the controller.

The data controller shall, at any time, provide information upon  request to each data subject as to what personal data are stored about  the data subject. In addition, the data controller shall correct or  erase personal data at the request or indication of the data subject,  insofar as there are no statutory storage obligations. The entirety of  the controller’s employees are available to the data subject in this  respect as contact persons.

5.1 We May Transfer Your Personal Information Outside The European Economic Area

Whenever we transfer your Personal Information out of the European  Economic Area, we will comply with applicable data protection laws.

6. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of  storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is  subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Technical Data (as described in Section 4) will be retained as long as required by security, marketing, or statutory retention requirements.

7. Rights of the data subject


7.1 Right of confirmation - Each data subject shall have the right granted by the European  legislator to obtain from the controller the confirmation as to whether  or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

7.2 Right of access - Each data subject shall have the right granted by the European  legislator to obtain from the controller free information about his or  her personal data stored at any time and a copy of this information.  Furthermore, the European directives and regulations grant the data  subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data  have been or will be disclosed, in particular recipients in third  countries or international organisations;
  • where possible, the envisaged period for which the personal data  will be stored, or, if not possible, the criteria used to determine that  period;
  • the existence of the right to request from the controller  rectification or erasure of personal data, or restriction of processing  of personal data concerning the data subject, or to object to such  processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling,  referred to in Article 22(1) and (4) of the GDPR and, at least in those  cases, meaningful information about the logic involved, as well as the  significance and envisaged consequences of such processing for the data  subject.

Furthermore, the data subject shall have a right to obtain  information as to whether personal data are transferred to a third  country or to an international organisation. Where this is the case, the  data subject shall have the right to be informed of the appropriate  safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he  or she may, at any time, contact any employee of the controller.

7.3 Right to rectification - Each data subject shall have the right granted by the European  legislator to obtain from the controller without undue delay the  rectification of inaccurate personal data concerning him or her. Taking  into account the purposes of the processing, the data subject shall have  the right to have incomplete personal data completed, including by  means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he  or she may, at any time, contact any employee of the controller.

7.4 Right to erasure (Right to be forgotten) - Each data subject shall have the right granted by the European  legislator to obtain from the controller the erasure of personal data  concerning him or her without undue delay, and the controller shall have  the obligation to erase personal data without undue delay where one of  the following grounds applies, as long as the processing is not  necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based  according to point (a) of Article 6(1) of the GDPR, or point (a) of  Article 9(2) of the GDPR, and where there is no other legal ground for  the processing.
  • The data subject objects to the processing pursuant to Article 21(1)  of the GDPR and there are no overriding legitimate grounds for the  processing, or the data subject objects to the processing pursuant to  Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal  obligation in Union or Member State law to which the controller is  subject.
  • The personal data have been collected in relation to the offer of  information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject  wishes to request the erasure of personal data stored by FRONTLINER, he or she may, at any time, contact any employee of the  controller, who shall promptly ensure that the erasure request is  complied with immediately.

Where the controller has made personal data public and is obliged  pursuant to Article 17(1) to erase the personal data, the controller,  taking account of available technology and the cost of implementation,  shall take reasonable steps, including technical measures, to inform  other controllers processing the personal data that the data subject has  requested erasure by such controllers of any links to, or copy or  replication of, those personal data, as far as processing is not required. FRONTLINER will arrange the necessary measures in individual cases.

7.5 Right of restriction of processing

Each data subject shall have the right granted by the European  legislator to obtain from the controller restriction of processing where  one of the following applies:

  • The accuracy of the personal data is contested by the data subject,  for a period enabling the controller to verify the accuracy of the  personal data.
  • The processing is unlawful and the data subject opposes the erasure  of the personal data and requests instead the restriction of their use  instead.
  • The controller no longer needs the personal data for the purposes of  the processing, but they are required by the data subject for the  establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article  21(1) of the GDPR pending the verification whether the legitimate  grounds of the controller override those of the data subject.If one of the aforementioned conditions is met, and a data subject  wishes to request the restriction of the processing of personal data  stored by the FRONTLINER, he or she may at any time contact  any employee of the controller, who will arrange the restriction of the  processing.

7.6 Right to data portability - Each data subject shall have the right granted by the European  legislator, to receive the personal data concerning him or her, which  was provided to a controller, in a structured, commonly used and  machine-readable format. He or she shall have the right to transmit  those data to another controller without hindrance from the controller  to which the personal data have been provided, as long as the processing  is based on consent pursuant to point (a) of Article 6(1) of the GDPR  or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to  point (b) of Article 6(1) of the GDPR, and the processing is carried out  by automated means, as long as the processing is not necessary for the  performance of a task carried out in the public interest or in the  exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability  pursuant to Article 20(1) of the GDPR, the data subject shall have the  right to have personal data transmitted directly from one controller to  another, where technically feasible and when doing so does not adversely  affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the controller.

7.7 Right to object - Each data subject shall have the right granted by the European  legislator to object, on grounds relating to his or her particular  situation, at any time, to processing of personal data concerning him or  her, which is based on point (e) or (f) of Article 6(1) of the GDPR.  This also applies to profiling based on these provisions.

FRONTLINER shall no longer process the personal data in the  event of the objection, unless we can demonstrate compelling legitimate  grounds for the processing which override the interests, rights and  freedoms of the data subject, or for the establishment, exercise or  defence of legal claims.

If FRONTLINER processes personal data for direct marketing  purposes, the data subject shall have the right to object at any time to  processing of personal data concerning him or her for such marketing.  This applies to profiling to the extent that it is related to such  direct marketing. If the data subject objects to  FRONTLINER to  the processing for direct marketing purposes, FRONTLINER will  no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to  his or her particular situation, to object to processing of personal  data concerning him or her by FRONTLINER for scientific or  historical research purposes, or for statistical purposes pursuant to  Article 89(1) of the GDPR, unless the processing is necessary for the  performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may  contact any employee of the controller. In addition, the data subject is  free in the context of the use of information society services, and  notwithstanding Directive 2002/58/EC, to use his or her right to object  by automated means using technical specifications.

7.8 Automated individual decision-making, including profiling - Each data subject shall have the right granted by the European  legislator not to be subject to a decision based solely on automated  processing, including profiling, which produces legal effects concerning  him or her, or similarly significantly affects him or her, as long as  the decision (1) is not is necessary for entering into, or the  performance of, a contract between the data subject and a data  controller, or (2) is not authorised by Union or Member State law to  which the controller is subject and which also lays down suitable  measures to safeguard the data subject’s rights and freedoms and  legitimate interests, or (3) is not based on the data subject’s explicit  consent.

If the decision (1) is necessary for entering into, or the  performance of, a contract between the data subject and a data  controller, or (2) it is based on the data subject’s explicit consent, FRONTLINER shall implement suitable measures to safeguard the  data subject’s rights and freedoms and legitimate interests, at least  the right to obtain human intervention on the part of the controller, to  express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning  automated individual decision-making, he or she may, at any time,  contact any employee of the controller.

7.9 Right to withdraw data protection consent - Each data subject shall have the right granted by the European  legislator to withdraw his or her consent to processing of his or her  personal data at any time.

If the data subject wishes to exercise the right to withdraw the  consent, he or she may, at any time, contact any employee of the  controller.

8. Data protection for applications and the application procedures

The data controller shall collect and process the personal data of  applicants for the purpose of the processing of the application  procedure. The processing may also be carried out electronically. This  is the case, in particular, if an applicant submits corresponding  application documents by e-mail or by means of a web form on the website  to the controller. If the data controller concludes an employment  contract with an applicant, the submitted data will be stored for the  purpose of processing the employment relationship in compliance with  legal requirements. If no employment contract is concluded with the  applicant by the controller, the application documents shall be  automatically erased two months after notification of the refusal  decision, provided that no other legitimate interests of the controller  are opposed to the erasure. Other legitimate interest in this relation  is, e.g. a burden of proof in a procedure under the General Equal  Treatment Act (AGG).

Art. 6(1) lit. a GDPR serves as the legal basis for processing  operations for which we obtain consent for a specific processing  purpose. If the processing of personal data is necessary for the  performance of a contract to which the data subject is party, as is the  case, for example, when processing operations are necessary for the  supply of goods or to provide any other service, the processing is based  on Article 6(1) lit. b GDPR. The same applies to such processing  operations which are necessary for carrying out pre-contractual  measures, for example in the case of inquiries concerning our products  or services. Is our company subject to a legal obligation by which  processing of personal data is required, such as for the fulfillment of  tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In  rare cases, the processing of personal data may be necessary to protect  the vital interests of the data subject or of another natural person.  This would be the case, for example, if a visitor were injured in our  company and his name, age, health insurance data or other vital  information would have to be passed on to a doctor, hospital or other  third party. Then the processing would be based on Art. 6(1) lit. d  GDPR. Finally, processing operations could be based on Article 6(1) lit.  f GDPR. This legal basis is used for processing operations which are  not covered by any of the abovementioned legal grounds, if processing is  necessary for the purposes of the legitimate interests pursued by our  company or by a third party, except where such interests are overridden  by the interests or fundamental rights and freedoms of the data subject  which require protection of personal data. Such processing operations  are particularly permissible because they have been specifically  mentioned by the European legislator. He considered that a legitimate  interest could be assumed if the data subject is a client of the  controller (Recital 47 Sentence 2 GDPR).

10. The legitimate interests pursued by the controller

Where the processing of personal data is based on Article 6(1) lit. f  GDPR our legitimate interest is to carry out our business in favor of  the well-being of all our employees and the shareholders.

11. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data  is the respective statutory retention period. After expiration of that  period, the corresponding data is routinely deleted, as long as it is no  longer necessary for the fulfillment of the contract or the initiation  of a contract.

12. Provision of personal data as statutory or contractual  requirement; Requirement necessary to enter into a contract; Obligation  of the data subject to provide the personal data; possible consequences  of failure to provide such data

We clarify that the provision of personal data is partly required by  law (e.g. tax regulations) or can also result from contractual  provisions (e.g. information on the contractual partner). Sometimes it  may be necessary to conclude a contract that the data subject provides  us with personal data, which must subsequently be processed by us. The  data subject is, for example, obliged to provide us with personal data  when our company signs a contract with him or her. The non-provision of  the personal data would have the consequence that the contract with the  data subject could not be concluded. Before personal data is provided by  the data subject, the data subject must contact any employee. The  employee clarifies to the data subject whether the provision of the  personal data is required by law or contract or is necessary for the  conclusion of the contract, whether there is an obligation to provide  the personal data and the consequences of non-provision of the personal  data.

13. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

14. Revision of the Privacy Statement

We may amend this privacy policy from time to time without notice.  All such changes will take effect  once they have been posted on the Website. Use of data we collect is subject to the privacy policy in effect at the time such data is collected.

Last updated: July 16, 2019

Appendix: DSGVO / GDPR / RGPD - EUR-Lex 32016R0679

  • O Regulamento (UE) 2016/679 do Parlamento e do Conselho Europeu,  de 27 de abril de 2016, relativo à proteção das pessoas singulares no  que diz respeito ao tratamento de dados pessoais e à livre circulação  desses dados (“RGPD UE”) obriga-nos a informar os interessados do Espaço Económico Europeu (“EEE”) acerca de determinados aspectos relativamente  ao tratamento de dados que efetuamos. Se estiver a aceder aos nossos  serviços online a partir de um estado-membro do Espaço Económico Europeu, esta Política de Privacidade Europeia Online aplica-se a si.
  • Verordnung (EU) 2016/679 des Europäischen Parlaments und des Rates vom 27. April 2016 zum Schutz natürlicher Personen bei der Verarbeitung personenbezogener Daten, zum freien Datenverkehr und zur Aufhebung der Richtlinie 95/46/EG (Datenschutz-Grundverordnung)
  • Regulation (EU) 2016/679 of the European Parliament and of the Council  of 27 April 2016 on the protection of natural persons with regard to the  processing of personal data and on the free movement of such data, and  repealing Directive 95/46/EC (General Data Protection Regulation)
  • Règlement (UE) 2016/679 du Parlement européen et du Conseil du 27 avril  2016 relatif à la protection des personnes physiques à l'égard du  traitement des données à caractère personnel et à la libre circulation  de ces données, et abrogeant la directive 95/46/CE (règlement général  sur la protection des données)
  • Regolamento (UE) 2016/679 del Parlamento europeo e del Consiglio, del 27  aprile 2016, relativo alla protezione delle persone fisiche con  riguardo al trattamento dei dati personali, nonché alla libera  circolazione di tali dati e che abroga la direttiva 95/46/CE  (regolamento generale sulla protezione dei dati)
  • Reglamento (UE) 2016/679 del Parlamento Europeo y del Consejo, de 27 de  abril de 2016, relativo a la protección de las personas físicas en lo  que respecta al tratamiento de datos personales y a la libre circulación  de estos datos y por el que se deroga la Directiva 95/46/CE (Reglamento  general de protección de datos)
  • Verordening (EU) 2016/679 van het Europees Parlement en de Raad van 27  april 2016 betreffende de bescherming van natuurlijke personen in  verband met de verwerking van persoonsgegevens en betreffende het vrije  verkeer van die gegevens en tot intrekking van Richtlijn 95/46/EG  (algemene verordening gegevensbescherming)
  • Europa-Parlamentets og Rådets forordning (EU) 2016/679 af 27. april 2016  om beskyttelse af fysiske personer i forbindelse med behandling af  personoplysninger og om fri udveksling af sådanne oplysninger og om  ophævelse af direktiv 95/46/EF (generel forordning om databeskyttelse)
  • Rozporządzenie Parlamentu Europejskiego i Rady (UE) 2016/679 z dnia 27  kwietnia 2016 r. w sprawie ochrony osób fizycznych w związku z  przetwarzaniem danych osobowych i w sprawie swobodnego przepływu takich  danych oraz uchylenia dyrektywy 95/46/WE (ogólne rozporządzenie o  ochronie danych)
https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=celex%3A32016R0679