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Privacy Policy

1 - Background

This Privacy Policy establishes a commitment by each of the companies listed, henceforth
referred to as “Sonae Indústria”, with its stakeholders (e.g. clients, employees, suppliers,
shareholders and investors) as regarding the protection of the personal data it is responsible for,
with the aim of strengthening and consolidating a trustworthy and close relationship, through
clear and transparent communication about the use of these data, the rights of the respective
owners and how they can exercise such rights.

Companies covered by the Privacy Policy:
- Sonae Indústria, SGPS, SA
- Sonae‐Indústria de Revestimentos, SA
- Movelpartes‐Componentes para a Indústria do Mobiliário, SA
- Sonae Indústria‐Management Services, SA
- Maiequipa‐Gestão Florestal, SA
- Parcelas e Narrativas – Imobiliária, SA
- Frases e Frações – Imobiliária e Serviços, SA

Sonae Indústria strictly complies with the principles described in this policy, Regulation (UE)
2016/679 (General Data Protection Regulation) and the applicable data protection legislation in
all activities that involve the processing of personal data under its responsibility.

The Privacy Policy is included in the personal data protection’s framework of Sonae Indústria,
which outlines the rules and procedures for the management of the safety and privacy of the
personal data.

Sonae Indústria processes the personal data through the use of multiple operational and
technical means to support its business activities.

a. Goals

The Privacy Policy, as a communication tool, has the following goals:
- Strengthen and consolidate a trustworthy and close relationship between Sonae
Indústria and all its stakeholders;
- Show transparency regarding the purposes and processing activities of personal data
performed by Sonae Indústria, as well as the retention period of the personal data
involved;
- Inform the owners of the personal data about their rights regarding the protection of
these data and how to exercise such rights;
- Inform the owners of the personal data who to contact at Sonae Indústria, in order to
exercise their rights or clarify how their personal data is processed.


b. Scope of application

The Privacy Policy applies exclusively to the personal data processed by Sonae Indústria, within
the defined purposes. For the purposes of this policy, personal data is defined as any information
relative to an individual who is identified or identifiable (owner of the data). The owner of the
data is deemed identifiable if he/she can be identified directly or indirectly, namely through an
identification number or through specific characteristics of his/her physical, physiological,
genetic, mental, economic, cultural or social identity.

c. Maintenance, communication and application of the policy

The Privacy Policy must be reviewed annually, when circumstances change and whenever
legislative changes occur, to ensure it is updated and suitable to the applicable laws and
regulations. The proposals to revise the policy and supervision of its application and compliance
are under the responsibility of Sonae Indústria’s competent governing body.

This policy must be acknowledged by all Sonae Indústria’s employees and should be disclosed
to its stakeholders, in any situation involving the processing of their personal data, through the
appropriate channels, namely Sonae Indústria’s website.

 

2 - Contents of the Privacy Policy


a. Our Privacy Commitment

Sonae Indústria carries out its business based on trust and transparency. This commitment is
reflected in the daily relationship with our clients, employees and suppliers and other
stakeholders. The privacy and safety of the data entrusted to us is a priority for us.

We undertake to collect, store, process, transmit or eliminate personal data with transparency
and only use the data which are essential to maintain the commercial relationship. We shall
inform you how we use your personal data and for what purposes, ensuring that we collect,
share and store your personal data in accordance with the best practices as regards the safety
and protection of the personal data.

When your personal data are collected, stored, processed, transmitted or eliminated by other
entities, we demand the same level of privacy and safety.

We want you to feel confident that your personal data are safe with us, as we are constantly
committed to protect your privacy and we take our responsibility to protect your personal data
extremely seriously.

Whenever you have any doubt about how we use your personal data, we are available to help
through the following e‐mail address: dataprotection@sonaeindustria.com.

b. Who is Responsible for Your Personal Data

The above‐mentioned company, to which you provided your personal data, is responsible for
processing your personal data under the terms of the General Data Protection Regulations and
the complementary legislation concerning protection of personal data in countries where it
operates.

Each of the above‐mentioned companies belongs to Sonae Indústria Group, meaning that your
personal data may be transmitted and processed by any of the Group’s companies.
Occasionally, personal data may be jointly processed by Sonae Arauco Group and Sonae
Indústria Group companies, which will inform the data subject whenever such occurs.

c. Personal Data that We May Collect

In this Privacy Policy, the term “Personal Data” means all the information related to you and
which allows us to identify you directly or indirectly. Your personal data may include, for
example, your name, fiscal number and contact details (physical and/or electronic).

We may also receive your personal data from other companies, namely when they collect,
process or store these data in fulfilment of a service provision contract.


d. How and Why Do We Use Your Personal Data?

We use your personal data only when strictly necessary for our relationship.

e. How Long Do We Retain Your Personal Data?

We retain your personal data only for the time needed to fulfil the aims defined in our
relationship and to comply with law.

Once the maximum retain period is reached, your personal data will be anonymised or securely
destroyed/deleted.

f. Who May We Share Your Personal Data With?

In some cases we may disclose your personal data to other entities, as part of the services such
entities provide. In these cases, we demand that appropriate security measures are in place to
protect your personal data.

Your personal data may be shared with companies belonging to Sonae Indústria Group and,
eventually, with companies belonging to Sonae Arauco Group, which will inform the data subject
whenever this occurs .
When required by law, we may have to disclose your personal data to the authorities or third
parties.

In the case of transfer of or access to your personal data by the Sonae Indústria Group, suppliers
or service providers based outside the European Union, we guarantee that your personal data
will be processed in accordance with the appropriate security and protection measures,
compatible with the ones we implement.

g. How Can You Exercise Your Personal Data Protection Rights?

In certain circumstances, you are entitled to access or request:

  1. Additional information about how we use your personal data;
  2. Your personal data;
  3. That we transmit the personal data you supplied to us to another entity;
  4. An update of your personal data;
  5. Deletion of your personal data;
  6. The non‐processing of your personal data;
  7. Restricting how we use your personal data as we correct or clarify possible doubts
    about its content or about how we use the data;
  8. The provision of a channel to dispute automated decisions made based on your
    personal data profiling.


You are also entitled to withdraw or change, at any time, the permission you gave us to use your
personal data.

An exception to exercising these rights occurs when your personal data are used to safeguard
the public interest, namely in cases of detection and prevention of crimes, or when they are
subject to professional confidentiality.

To exercise your personal data protection rights or whenever you have a question about how
we use your personal data, please contact us using the e‐mail address:
dataprotection@sonaeindustria.com
If you are not satisfied with how we use your personal data or with our response to your request
to exercise your rights, you can make a complaint to the competent regulatory authority.

h. How Do We Protect Your Personal Data?

We have a range of information security measures, in line with the best national and
international practices, to protect your personal data, including technological checks,
administrative, technical and physical measures and procedures that guarantee the protection
of your personal data, preventing them from improper use, and non‐authorised access and
disclosure, loss and improper or inadvertent alteration, or their non‐authorised destruction.
With regard to information security, we make the same commitment to continuous
improvement as we do in our day‐to‐day business.

Among others measures, we highlight the following:

  1. Access to your personal data is restricted to those who need them for the specific
    purposes outlined above;
  2. Storage and transfer of personal data using safe means only;
  3. Protection of the information systems using devices that prevent non‐authorised access
    to your personal data;
  4. Implementation of mechanisms that ensure the complete safety and quality of your
    personal data;
  5. Permanent monitoring of the information systems, to prevent, detect and avoid the
    improper use of your personal data;
  6. Redundancy in the storage equipment, processing and communication of personal data,
    to avoid unavailability.

When required by law, we may have to disclose your personal data to the authorities or third
parties, and in these cases our control over how your personal data is protected is limited.

i. Updates to this Privacy Policy
This Privacy Policy may be updated whenever necessary, being the information released through
the appropriate channels, namely Sonae Indústria’s website.