Syngenta is committed to transparency in its operations, especially when they involve personal data, and to keeping our trustworthy relationship by adopting the best security, technical, and administrative measures available and able to assure the protection of your privacy and the security of your personal data.
The current Policy covers our online and offline data collection activities, including the personal data we collect through our many channels, including websites, applications, third-party social media, printed forms, customer services, and events, among others. Please, observe that we may aggregate personal data from different sources, and that we crosscheck the personal data originally collected by any of the abovementioned companies and/or from other sources.
You will accept our Policy when you agree, in our Platform or in one of our partners’ platforms, with the use of your Personal Data for each one of the herein described purposes. That will indicate that you are aware and fully agrees with how we might use your information and your personal data. In case you do not agree with the current Policy, please, do not use our services, and inform us on the reasons of your disagreement so we may improve it.
- Information that you need to know before you read the current Policy
- What is personal data?
It is all the information that enables us to identify you, such as your name, Individual Taxpayer Registration Number, e-mail, telephone number, address, as well as information that may indirectly identify an individual, such as his/her geolocation, IP address, among others.
- What is sensitive personal data?
It is personal data related to the racial or ethnic origin, religious belief, political opinion, affiliation to a workers’ union or to an organization of a religious, philosophical, or political nature, data related to an individual’s health or sexual life, and genetic or biometric data, when such data pertains personally to you.
- What does data processing mean?
Any operation, such as the collection, production, receipt, classification, utilization, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, and modification, communication, transfer, dissemination or extraction, performed using personal data.
2. How and where do we collect your data?
In order to build and maintain a trustworthy relationship, it is important that you are aware on how we process your Personal Data, and especially how and where we collect your Data. It will all basically depend on how you interact with the Group (online, offline, or in any other mean). We collect many types of information about you, as described below:
- Syngenta Group’s websites/mobile applications. Websites dedicated to farmers, seed managers, and agricultural input distributors and retailers owned or managed by the Syngenta Group companies that we operate in our own domains, such as the institutional website www.syngenta.com.br or other websites used to access relevant content, such as www.portalsyngenta.com.br, which offers many benefit programs to those who interact in any way with the Syngenta Group companies, with contents and benefits for the processing of industrial seeds, or www.acessaagro.com.br, which is one of Syngenta Group’s customer benefit platforms that gathers solutions so farmers can produce more and better, among other things, or website www.nucofee.com, which connects coffee farmers to roasters and importers from all over the world, in addition to offering qualification and market access, or also website www.syngentappm.com.br, which provides relevant information on the solutions developed by Syngenta to control pests in urban areas, such as commercial, industrial, and residential spaces, and on public health issues, among other things, including other commercial platforms and webpages we keep in third-party social media, such as Facebook and Instagram, in addition to many different applications related to our products and services.
- We collect your information whenever you access the Syngenta Group’s websites or applications using your computer or mobile device, such as IP address, operating system type, and the type and version of your web browser, the exclusive device ID of your telephone number, advertising ID, geographic location, and other similar data found in your mobile device.
- We collect your information whenever you access your specific account profile, such as username, password in non-recoverable format, and/or questions and answers about security.
- By e-mail, text messages, and other electronic messages. Interactions we hold with you, such as electronic communications sent by the Syngenta Group companies by e-mail, for example.
- When we receive a request from you through our Customer Service (C.A.S.A), and when you take part in fairs or events organized by the Group’s companies or sponsored by third parties. We are legally required to process some information, for example regarding certain purchases, and sometimes we ask you to provide certain information so we can enter into and sign a contract with you.
- When we process your orders we may collect personal data related to a transaction, in order to conclude the same and manage our commercial relationship. We may also receive information from our retailers, distributors, suppliers, business partners, and other third parties based on our legitimate interests.
- Information is also collected through printed or digital forms, and similar means, through which we request your Personal Data, such as, for example, through a Technical Sales Representative for inclusion in any program dedicated to clients or in specific training offered by the Syngenta Group companies to their clients, among others.
- Interactions with ads in our own or in third-party websites;
- In case you have registered to use services that enable uploading information from your device into one of our portals or applications, we collect data from your equipment or device. We may also receive location data from your smartphone or from any other device having geographical recognition, provided the equipment is linked to an application that you have downloaded and to which you have granted data sharing permission.
- Through the Customer Score Programs implemented together with our commercial partners and distributors that sell Syngenta products or use Syngenta’s applications. Your personal data is shared with us so we can fulfill your order or execute a signed contract.
- When you enjoy the benefits offered in our Client Portal for the commercial and financial management of your orders and billing, as well as in case you utilize webagil (www.webagil.com.br), a third-party tool made available for free by the Syngenta Group, which offers you full product inventory management.
- We may collect your data through third-party social media (such as Facebook, Instagram, Twitter, and Google), when you create or share photos, videos, personal stories, or any other similar content and media with the Syngenta Group. We also collect your data when you download an item from or interact with a Syngenta Group web application in a third-party social media, or whenever you use a social media feature that is integrated into a Syngenta Group website. For further information on how the Syngenta Group acquires information about you from a third-party social media, or to opt not to share such social media information, please visit the specific social media website.
- We may collect data through market surveys (if information is not returned in anonymized form), third-party data aggregators, public sources, and data received when we acquire other companies.
- We may collect personal data when you act as a supplier, to be able to sign contracts and manage our relationship with suppliers.
- If data is necessary to invoice an order, or to make a purchase. In these cases the Syngenta Group, or our payment processing service providers, will collect financial and payment information in conformity with the applicable laws, norms, and security standards.
- We also collect Information on products and transactions to understand how you interact with us, and with our retailers and business partners, including purchases, consultations and client accounts, purchase history, products and their quantity, culture and preferences;
- Calls to our Customer Service (“CASA”) may be recorded or listened to, according to the applicable laws, for local operational needs (for example, for reasons of quality assurance or training). When required by law, you will be informed on such recording at the start of your call.
- Information on relationship that helps us understand who you are and what you wish, in order to offer you products, technologies and services that might be of your interest, such as property and commercial information, your overall location, and other demographic information, according to the applicable laws. We collect this information when you interact with us or have kept a previous relationship with any Group company.
- Information on recruitment to helps us determine your availability for a function in any of the Syngenta Group companies to which you may apply, such as general contact information, résumé, information on your level of education, competencies and skills, career and professional experiences, and other information, such as photo, Individual Taxpayer Registration Number, professional certificates, labor history, working references, other relevant information.
- Sensitive Personal Data. We always strive to process the least possible number of Sensitive Personal Data. When it is necessary to process your Sensitive Personal Data, we will inform you on the intended purpose, and will count on your previous and express consent, when so required by law.
- Data on children and adolescents: The Syngenta Group does not acknowledge the collection of Personal Data pertaining to minors less than eighteen years of age. If you are less than eighteen years old, please do not provide any Personal Data. If you are aware that a child or adolescent has provided his/her Personal Data to us, please contact any of our customer service channels indicated at the end of the current Policy, and we will proceed to delete such Personal Data from our database.
3. How do we use your personal data?
We mainly process your Personal Data to facilitate our commercial relationship, to fulfill some contractual and legal obligations, as well as to engage our brand. In addition to that we may utilize your personal data for the following purposes:
- Direct and indirect customer service. We use your Personal Data to provide services to our direct or indirect clients, including answering to their questions, complaints and requests.
- To provide the requested functionalities, products, technologies and services, and other services related to your order, such as delivery, recommendations and product maintenance.
- To send the products you have ordered (including those you order through our distributors).
- To provide financial, commercial and logistic management services deemed relevant to you and related to your business activities, with the purpose of improving your productivity, quality and profitability.
- To grant points based on your purchase history, which may be exchanged for gifts and products, or discounts in other Syngenta Group products or services when you join one of our loyalty programs that generate points.
- Send administrative information, such as changes in our terms and policies.
- The Syngenta Group uses your Personal Data to process, invoice and send your orders, inform you on the status of your orders, correct addresses, verify your identity, and perform other activities to fight frauds.
- To provide support, including updates and communications related to our product enhancement program, and for diagnostic, repair, product safety, and recall purposes;
- To provide other forms of technical assistance, such as installation and maintenance assistance, and to deal with defects, in addition to promoting adequate product disposal;
- To provide information on products or services (for example, marketing communications or promotional campaigns) through e-mails, ads, SMS, telephone calls, and by mail, as allowed by the applicable laws. Some of our campaigns and promotions are executed in third-party websites and/or social media.
- To provide communications, information and direct marketing on the products, technologies and services offered by the Syngenta Group, including the creation of a profile we will then use to offer targeted marketing solutions, newsletters, information about products, magazines published by the company, catalogues, ads or invitations to events, etc., which we believe might be of your interest.
· We also use your personal data to administer and manage surveys, polls, loyalty programs and other promotional events, and to enable our clients to take part in polls and surveys, so that we may improve our service offers.
· We also process personal data to exercise our legitimate interest of providing our clients with personalized marketing materials, using information associated to their purchase history, preferences, behavior and other related information, so we may better understand their business challenges and needs.
· In addition to that, we segment and use personal data to perform analyses, in order to improve and offer relevant products, communications and services, and increase our agronomic knowledge. We also use segmentation and the creation of profiles to determine if potential clients (leads) are interested in our specific products or communications.
· To enable the publication of your comments and testimonies in our websites and mobile applications.
· When required by the legislation in force, we must obtain your consent for such marketing actions and surveys. You may, at any time, oppose the receipt of marketing offers via electronic communication by following the instructions contained in those messages, or by contacting us sending a message to email@example.com
· In addition to that, the Syngenta Group captures your Personal Data when you interact with third-party social media functions, such “liking” a post, in order to display ads and generate an interaction.
· To recruit new collaborators for the Syngenta Group, in case you have registered your résumé through our websites, to be evaluated by the Syngenta Group or, in any other way, if you have filled a job application to work with us. We use the information you have provided to determine your qualification for the function to which you have applied. In this specific case, we will keep your information in our CV database for any eventual function that may become available within a period of up to 2 years after the date on which you have forwarded it to us, when it will then be deleted;
· For legal or merger/acquisition purposes. In case the Syngenta Group or its assets are acquired by, or merged with, another company, including due to bankruptcy, we will share your Personal Data with our legal successors.
· To promote direct contact between Brazilian farmers and foreign purchasers in order to stimulate and undertake the exportation of some commodities.
4. What are the legal bases the Syngenta Group employs to process your data?
- Contract Execution
When we enter into a sale, purchase, or product or service delivery contract, or when we establish a relationship with you at the time you have accepted the regulations of our loyalty or client relationship programs, our legal basis for data processing is the execution of a contract or the adoption of previous measures before signing the same.
This legal foundation applies to any and every data processing deemed necessary to manage and execute such contract, and to any and every data processing deemed necessary to enter into such a contract. It may include, for example, customer services (such as in the form of a loyalty program), client relationship management and billing, relationship programs, in addition to other processes deemed necessary to provide the requested functionality, products, and services.
When we request personal data to fulfill our legal or contractual obligations, the provision of such data will be mandatory: if such data is not provided, we will not be able to manage our contractual relation, nor to fulfill the obligations imposed on us.
- Legal Obligation
In some cases, we process your personal data because we are obliged by law to do so (for example, in order to fulfill accounting and regulatory obligations).
- Legitimate Interests
We also process your data when we have a legitimate interest to do so, and when such interests do not invalidate your data protection rights. Such interests usually regard improving our products, technologies and services, with the purpose of enhancing client satisfaction and adapting our services to your specific needs and preferences, or to provide direct assistance to farmers and clients and help them sell their products in the country and abroad.
We also process your data based on our legitimate interests when processing your order, when you fill one of our printed or digital forms, and to enable our clients to comply with their applicable legal obligations. In addition to that, we process clients’ personal data when deemed necessary to exercise our legitimate interest when executing contracts with distributors in order to furnish the products and services ordered by a client.
Sometimes (for example, when we create profiles), our legal basis for processing data is the need to do so for purposes related to our legitimate business or marketing interests, in addition to the creation of a profile of our clients in order to adapt our offers and services to your needs, provided this interest is not in conflict with the rights of a client or third party that asks for personal data protection.
When we already maintain a relationship with a client, we sometimes forward digital marketing materials about products and/or services related to those contemplated in the current relationship program held with a client, and we rely on our legitimate interest to do so. In case you do not want to receive our materials, you will be able to opt not to receive such materials.
For the purposes of segmentation and analysis, our legal foundation is based on our legitimate interest in improving our products and services and offering products, communications, and services deemed relevant to our clients/potential clients (leads), and expanding our agronomic knowledge.
When we receive personal data from our commercial partners or distributors, for example, through a Budget Request or Loyalty Program, our legal basis to process that data is the legitimate interest in fulfilling your order, and in executing a contract signed with you or between the Syngenta Group and such partners.
We also rely on our legitimate interests as the legal basis to achieve some of our commercial objectives, such as acquiring market intelligence, improving our products, for governance and auditing purposes, for commercial transactions, and to protect the Syngenta Group’s assets.
At times, we process your data based on your own consent (for example, when you wish to receive newsletters or other marketing materials from the Syngenta Group, and has not established yet a relationship with us). In such cases, you are free to withdraw your consent at any time, by following the registration cancellation instructions provided in the received marketing message.
The cancellation of your consent will not affect the legality of processing data according to a consent granted previously to such cancellation.
5. How is your data shared with third parties?
The Syngenta Group may share your personal data with the companies mentioned in the preamble to the current document. In addition to that, as in the case of any other company, the Group operates in partnership with many other companies in order to offer its services and products. Thus, we may share your Personal Data with those companies, protecting however your privacy as much as we can and, whenever possible, by anonymously sharing such data. Here we will describe those situations in which we will share Personal Data and for what purposes.
- Providers, partners and service providers - Any Syngenta Group company may share Personal Data collected from third parties, such as service provider companies, data processing companies, credit rating/debt collection agencies, advertising agencies, attorneys’ and accounting offices, among other providers that, on behalf of any Syngenta Group company, may help us launch our products and/or to provide our services, and/or that may help us execute any legal obligation on our behalf. These companies may need to have access to information related to your so they are able to perform their functions, and are not authorized to use the Personal Data we may share with them for any other purpose except as defined by us and specified in the current Policy;
- In addition to that, your Personal Data may be used to comply with the obligations established by law, the regulations set by government entities, tax authorities, and the Judicial Power, such as sentences and agreements, and/or any other competent authority. Such data processing may include your data and personal identification documents.
- For any other purpose, when so required by the applicable laws and regulations.
If appropriate, before sharing Personal Data with a third party, Syngenta will contractually require that that third party adopts all the precautions deemed necessary to protect such Personal Data against any unauthorized use or sharing.
In case you have any doubt regarding our providers, please contact us through the channels indicated in item 11 of the current policy.
7. Can my data be transferred to a foreign country?
Yes. Although the headquarters of the abovementioned companies are located in Brazil and the data we collect are ruled by the Brazilian laws, the Syngenta Group operates in a global business environment, and some of its companies manage facilities and databases in many different countries and may transfer Personal Data collected in Brazil to European Union countries and to the US. Such transfers will only involve those Syngenta Group partner companies that have proven to be striving to conform or are already conforming to the applicable laws and complying with the purposes described in the current Policy.
In such cases, we ensure you that, when any personal data is transferred to countries holding different data protection standards, adequate safeguards will be implemented to protect any personal data to make sure such data transfers are in conformity with the applicable data protection laws.
8. How does the Syngenta Group ensure the security and integrity of your personal data?
Syngenta will adopt all the commercially pertinent measures to keep the reliability and accuracy of any Personal Data information stored in our databases, by making sure we use secure databases.
We only store your Personal Data for the time deemed necessary to fulfill the initial purpose intended for such collected data, or in conformity with any legal obligation or order to withhold documents. The criteria used to determine our data retention periods include:
(i) The period of time during which we maintain a continuous relationship with you and provide the requested products/services (for example, during the time you keep an account with us or continue to use our services/mobile applications), or to enable you to perform your activities, and to fulfill your retention requirements;
(ii) In case there is a legal obligation we may be subject to (for example, certain laws may oblige us to keep records of your transactions for a certain period of time before we can delete them), and
(iii) In case such retention is advisable in relation to our legal standing (such as regarding the applicable statutes of limitation, disputes, or regulatory investigations).
Our servers and databases are protected by standard security technologies, such as firewalls and password protection. Those collaborators who have access to Personal Data are trained to appropriately manage such data and in conformity with our security protocols. Although we cannot fully guarantee against any loss, misuse, unauthorized sharing, data switching or destruction, we thoroughly try to avoid that such events might occur.
9. Understand what are your rights as a data subject, and how to exercise them.
Your personal data will always belong to you, and the Brazilian laws guarantee that you have certain rights in that regard. We are committed to fulfilling such rights, and in this section we will explain how you may exercise them before SYNGENTA. The Brazilian Laws guarantee the following rights:
- To access, revise, and know if we have processed your Personal Data in any way whatsoever, and ask for an electronic copy of the information we store about you;
(ii) To correct or request the correction of incomplete, inaccurate or outdated Personal Data;
- To request the anonymization, blocking or deletion of unnecessary and excessive Personal Data;
Please, observe that, in certain circumstances, we may not be able to delete your Personal Data without also excluding your user account. It may be necessary to retain some of your Personal Data after you have asked us to delete it, in order to comply with our legal or contractual obligations, or also to fulfill our corporate needs.
- To request Personal Data portability to another provider of similar products or services;
(v) To request the deletion of any Personal Data collected and used based on your own consent;
(vi) To obtain information about the public or private entities with which we may share your Personal Data;
(vii) When the data processing activity requires your consent, you may deny such consent. In such case, we will inform you about the consequences of not performing such activity;
(viii) When the data processing activity requires your consent, you may revoke it at any time.
Whenever you exercise your rights we may request some complimentary information for the purpose of confirming your identity so we can prevent frauds. We will do that to ensure your security and the privacy of our clients, distributors, and etc. Also, we commit ourselves to answering to any and every request within a reasonable time, and always in conformity with the applicable legislation.
In case you have any doubt on these issues, or on how you may exercise such rights, please contact us through the channels mentioned in item 11 of the current Policy.
10. How do we keep your personal data safe?
Our responsibility is to care for your Personal Data, and to only use it for the purposes described in the current Policy. And to ensure your privacy and the protection of your Personal Data, we have adopted all the security practices deemed adequate in our market, by using extremely efficient information security techniques and systems.
We strive to protect your account’s privacy, but unfortunately we cannot guarantee full and complete security. Unauthorized access to or use of an account, any hardware or software failure, and other factors may compromise your Personal Data’s security at any time, and so please help us to keep a safe environment for all of us. In addition to adopting good security practices in relation to your account and data (such as, for example, not sharing your password with third parties), in case you identify or become aware of anything that might compromise your data’s security, please, immediately contact us.
Your Personal Data will be processed by our authorized collaborators or agents, provided they need to have access to such information, depending on the specific purposes for which your Personal Data may have been collected (ex.: our collaborators responsible for customer service matters will have access to your product acquisition records).
We store your Personal Data in operational environments that employ reasonable security measures to prevent any unauthorized access. We follow reasonable protocols to protect your Personal Data. But information transmission through the Internet, unfortunately, is not completely safe and, although we do our best to protect your Personal Data, we cannot guarantee data security during transmission using our websites/applications.
You play a fundamental role in keeping your Personal Data safe. When you create an online account or perform online registration, please, make sure to choose a difficult password so that other people are not able to try and guess it. You are responsible for keeping that password confidential to any other use in your account. If you use a shared or public computer, never select the login ID, e-mail address or password memory saving options, and make sure you have logged out from your account whenever you leave such a computer.
We adopt strict policies and procedures to establish how any Personal Data must be processed at the Syngenta Group. Such norms have as their purpose to assure an adequate and lawful processing of your Personal Data. Our security measures are being continuously monitored and revised according to the most up to date technological advancements and organizational resources.
11. How can you contact Syngenta?
- Syngenta’s Customer Service – C.A.S.A – toll-free at: 0800 7044 304
- Send an e-mail to firstname.lastname@example.org