Data Disposal Policy
Updated on December 15, 2024
CG TECH DESENVOLVIMENTO DE SOFTWARE LTDA, a private legal entity registered under CNPJ No. 50.856.893/0001-40, headquartered at Rua Riachuelo, No. 1200, São José, Aracaju/SE, ZIP code 49015-160, Brazil, herein represented in accordance with its articles of incorporation by its Legal Representative Clovijan Bispo Rocha, Brazilian citizen, CPF No. 036.779.995-29, e-mail address cg.tech.ltda@gmail.com, is responsible for ensuring compliance with the Brazilian General Personal Data Protection Law (LGPD) and its requirements regarding the collection, storage, retrieval, and destruction of records of personal data and/or sensitive data ("Personal Data").
CGTECH maintains sets of stored Personal Data ("Records") in compliance with contractual and regulatory requirements and other legal bases applicable to the forms of Personal Data processing it carries out. It is essential that these Records be protected against loss, destruction, falsification, unauthorized access, and unauthorized disclosure. To that end, a variety of controls are used, such as backups, access control, and encryption.
This control applies to all operations, people, and processes that make up the CGTECH information system, including employees, board members, officers, suppliers, customers, and third parties who have access to the data processed by CGTECH.
Retention Period
All Personal Data will be retained for as long as necessary to fulfill the purpose for which it was collected, for lawful, specific, and disclosed purposes.
There are various forms of Personal Data processing whose retention period is not set by law — for example, how long the Personal Data of a sales prospect is kept. For such data, CGTECH sets a retention period consistent with market practice and with the nature of the processing, for as long as no specific determination is issued by the regulatory authority.
For other Records, including those of a tax, labor, and social security nature, CGTECH reserves the right to keep them stored until the end of the statute of limitations established by law.
All documents stored at CGTECH, whether physical or electronic, have a retention period set out in the Retention Schedule, which may be consulted at any time.
This Policy must always observe those periods, as well as the other documents that make up the LGPD compliance program.
Disposal by CGTech
Once the period expires, and provided there is no valid reason to keep it, Personal Data in physical form will be destroyed as confidential waste, and data kept electronically will be deleted from the systems of CGTECH and of its contracted third parties.
Where physical documents are destroyed, this may be done by incinerating or burning the document, so that no trace of personal data remains that could compromise the procedure.
All disposal actions, whether physical or electronic, must be recorded in the "Disposal Minutes", signed by the company's Legal Representative, the Data Protection Officer, and the manager of the department responsible for the disposal (for example: if the sales department needs to delete e-mails of inactive customers, the sales manager must sign the minutes).
Ongoing investigations and administrative or judicial proceedings are valid reasons to retain Records and, regardless of consent, the storage periods indicated in the Retention Schedule may be extended in such cases. Except in the cases indicated above, if CGTECH wishes to extend the storage period, the Personal Data subjects must be notified in writing a reasonable time before the end of the retention period.
Should the subject of the Records choose to exercise their right to have this information deleted, the Personal Data will be disposed of immediately by CGTECH, except where required to comply with a legal or regulatory obligation.
Simplified Contact
Requests received from the subject of the Records to exercise their rights, throughout the entire processing period, will be answered in the manner and within the timeframes required by applicable regulations.
Unless specifically stated otherwise, the data subject may submit requests by e-mail to contato@gerefrotas.com.br.
The data subject may also submit a request through the CGTECH website.
Updates to This Policy
CGTECH reserves the right to amend or update this Policy. The most recent version is dated December 15, 2024.