Supplemental Privacy Notice for Brazil
This Supplemental Privacy Notice is intended to be read in conjunction with our global Privacy Policy (the “Policy”). The definitions found in the Policy apply to this Supplemental Privacy Notice.
If you are located in Brazil, pursuant to Article 3 of the Brazilian General Data Protection Law (“Law No. 13,709/2018” or “LGPD”), this section of the Policy (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.
Hormel Foods Corporation is the data controller for the purposes of Personal Data processed through this Website. If you have questions about the Policy or your rights, please contact us as indicated in our Policy, see Section 16, “Contact Details”.
Lawful Bases for Processing
We process the Personal Data of visitors to this Website who are located in Brazil for the purposes set out in the table under Section 6, “What is the legal basis for our data collection?,” of the Policy together with our legal basis. Where more than one purpose is listed, please contact us if you would like to know the specific legal basis, which applies in connection with your specific enquiry. We have provided further information on the legal bases we generally rely on below:
- Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.
- Legitimate interests – This means our general interest in conducting and managing our organization to enable us to provide you with the best products and give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Our specific legitimate interests include:
- Administering our operations;
- Providing high quality customer service;
- Developing our products and services, and what we charge for them;
- Defining types of customers for any new products or services;
- Understanding how our Website is being used;
- Developing and growing our operations;
- Ensuring cybersecurity;
- To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
- To meet our obligations and enforce our legal rights.
- Consent – In accordance with applicable law, we may seek your consent or explicit consent to process Personal Data collected on this Website or volunteered by you. For example, in relation to our marketing and promotional activities.
- Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Rights of Data Subjects
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of the rights set out below or learn more about such rights, please contact us, see Section 16, “Contact Details,” of the Policy.
LGPD provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the LGPD, and ensure that the third parties that also process your personal data will also comply with your requests, including the following:
- confirmation of whether your data are being processed;
- access to your data;
- correction of incomplete, inaccurate or outdated data;
- anonymization, blocking or erasure of data that is unnecessary, excessive or not processed according to LGPD’s provisions;
- erasure of data processed based on the consent of the data subject;
- portability of personal data to a third party;
- object to the processing of personal data, in case of violation of the law;
- information of public and private entities with which we shared data;
- information about the possibility to refuse providing consent to a personal data processing activity and the respective consequences, when applicable; and
- withdrawal of your consent.
Limitations to your rights
In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights, or when such disclosure is impossible or requires a disproportionate effort. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.
DPO
If you wish to reach the Company’s Data Protection Officer, contact us at: amkepper@hormel.com.
Access Logs
We keep your application access logs, under confidentiality, in a controlled and safe environment, for, at least, 12 months, in order to comply with legal obligations.
Language
The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.
International Data Transfer of Personal Data
When we transfer your Personal Data across Brazilian national borders to third parties, we will ensure that this international transfer occurs in compliance with LGPD’s provisions, especially with Article 33 of LGPD.
In order to comply with LGPD’s provisions regarding international data transfer, we may request the Data Subject’s express and specific consent to the international data transfer.