Privacy Policy
Personal Data Privacy Policy
1. PURPOSE
The Data Privacy Policy (“Policy”) of CRT ADJUSTERS sets forth the fundamental principles and guidelines for the Processing of Personal Data, in compliance with current legislation, especially the Brazilian General Data Protection Law (LGPD) – Law No. 13.709/2018.
The purpose of this Policy is to clarify how the collection, use, storage, sharing, and protection of information related to an identified or identifiable natural person (“Personal Data”) occur, ensuring transparency, security, and respect for the rights of the data subjects.
This Policy applies to all personal data processing activities carried out by CRT ADJUSTERS.
2. SCOPE OF APPLICATION
This Policy applies to all natural and legal persons who, in some way, have a social, commercial, or legal relationship with CRT ADJUSTERS, including, but not limited to: customers, policyholders, suppliers, service providers, business partners, job applicants, employees, legal representatives, and other interested parties (“You”).
By using any official electronic pages (“Website”), social networks, applications, or digital platforms maintained by CRT ADJUSTERS, as well as by entering into contracts, signing physical or electronic documents, interacting at events, trade shows, or institutional communications promoted by CRT ADJUSTERS, or by applying for a job, You are deemed to have read, understood, and fully accepted this Policy.
For the purposes of this Privacy Policy, when we mention Website, we refer to the following address(es):www.crtadjusters.com.br , www.crtgroup.com.br .
This Policy supplements other internal regulations of CRT ADJUSTERS related to privacy and data protection, in addition to observing applicable legislation, including the Brazilian General Data Protection Law (LGPD) – Law No. 13.709/2018.
3. DEFINITIONS
Data Controller: means the natural or legal person to whom the decisions regarding the processing of personal data are incumbent;
Data Operator (or Processor): means the Party that processes Personal Data on behalf of the Data Controller and under the Controller’s guidance;
Personal Data or Data: means any information related to an identified or identifiable natural person, such as: RG, CPF, address, date of birth, email, telephone number, image, voice sound are some examples of personal data, but information like consumption habits, travel habits, profile, and preferences, and other similar information, when related to an identified or identifiable natural person, are considered “personal data”. Likewise, information about internet browsing, such as IP number, browser, device used for navigation, among others, are generally considered “personal data” whenever it is possible to identify the person related to this information;
Sensitive Personal Data: is personal data concerning racial or ethnic origin, religious conviction, political opinion, union membership or membership in a religious, philosophical, or political organization, data related to health or sexual life, genetic or biometric data, when linked to a natural person. The law introduces additional requirements and imposes certain restrictions on the processing of sensitive data;
Anonymized Data and Identifiable Person: is data that cannot be associated with an individual, meaning it makes the data effectively anonymous and not susceptible to identification. It is data that does not permit reverse engineering, meaning it cannot be used to turn anonymized data into identifiable data. It is important to note that even if data is not directly and explicitly associated with an identified person, it can be considered personal data (and not anonymous) whenever it is possible to associate it with an individual using the technical means available at the time;
Data Protection Officer (“DPO”): a person appointed by a processing agent to act as a communication channel between the Parties, the data subjects, and the National Data Protection Authority (“ANPD”);
Applicable Data Protection Laws: means all laws related to data protection and privacy that are periodically applicable, including, without limitation, Law No. 13.709/2018 – General Data Protection Law (“LGPD”) and the Marco Civil da Internet, in each case, as periodically amended, replaced, or updated;
Data Subject: means any natural person to whom the Personal Data refers and who, as a consequence, can be identified directly or indirectly;
Data Processing (or Processing): any operation carried out with Personal Data, including mere storage. The LGPD expressly mentions several other non-exhaustive examples: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination/deletion, evaluation or control of information, modification, communication, transfer, diffusion, or extraction;
Security and Prevention: means the use of technical and administrative measures suitable for protecting Personal Data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication, diffusion, or use in a manner different from the purpose for which the personal data was or is being processed;
Personal Data Breach: any act or omission that compromises the security, confidentiality, or integrity of the Personal Data or the physical, technical, administrative, or organizational safeguards implemented to protect them. The loss or unauthorized access, disclosure, or acquisition of Personal Data constitutes a Security Breach, regardless of whether the incident meets the level of a security breach according to the Privacy and Data Protection Requirements.
4. MAIN SOURCES OF PERSONAL DATA
CRT ADJUSTERS may collect or receive your Personal Data from the following sources:
i) Use of services: When You access, purchase, or interact with any products, services, or platforms offered by CRT ADJUSTERS.
ii) Commercial or legal relationship: When You establish a commercial or legal relationship with CRT ADJUSTERS, whether through signing contracts, terms of service, commercial/technical proposals, or any other document.
iii) Corporate relationship: When the company for which You work enters into a contract with CRT ADJUSTERS, and the Processing of your Personal Data is necessary for the execution of that contract.
iv) Direct communications: When You contact CRT ADJUSTERS, whether in person, by postal mail, telephone, email, instant messaging applications, or any other means of communication.
v) Forms and registrations: When You provide your data directly through electronic or physical forms, platform registrations, social media interactions, acquisition of products and/or services, among other activities conducted by CRT ADJUSTERS or its network of business partners.
vi) Access to digital platforms: When You access the official websites, applications, and other digital platforms of CRT ADJUSTERS.
vii) Access to Physical Facilities: When You access or visit any premises of CRT ADJUSTERS, which may require registrations and access records, as well as the collection of images by video surveillance systems for security purposes.
viii) Selection processes: When You submit your curriculum vitae (CV) or resume by any means, including email, recruitment platforms, or physical delivery at one of CRT ADJUSTERS‘ units.
ix) Online navigation: When You access our official electronic pages (“Website”) or use functionalities available on the Website, where certain technical information may be collected automatically, such as: device type, operating system, browser type and settings, IP address, among other navigation data.
This collection occurs in accordance with the specific purpose of each processing activity and always in compliance with current legislation, ensuring the protection of your privacy, under the terms of the Applicable Laws.
CRT ADJUSTERS does not collect or process your Sensitive Personal Data, except when:
The Processing is required or permitted by the Applicable Laws;
The Processing is necessary to establish, exercise, or defend legal claims;
CRT ADJUSTERS has obtained your explicit prior consent before processing your Sensitive Personal Data; or
Any other legal basis for the Processing of Sensitive Personal Data.
5. MAIN PURPOSES FOR THE PROCESSING OF PERSONAL DATA
CRT ADJUSTERS may process your Personal Data for the following purposes:
Contract Execution and Service Provision
To execute contracts/proposals and/or any documents to which You are a party, or preliminary steps necessary for their formalization;
To provide, manage, and improve general services, expert assessments, inspections, and products offered by CRT ADJUSTERS and/or its network of business partners; and
To enable your registration and participation in loyalty programs offered by CRT ADJUSTERS.
Communication and Relationship
To contact You regarding services provided such as support, answering questions, complaints, or requests;
To deliver correspondence, documents, newsletters, and/or institutional communications; and
To measure the quality and satisfaction level of services and products offered, thereby personalizing your experience.
Compliance with Legal and Regulatory Obligations
To comply with applicable legislation and meet the requirements of competent authorities, including court orders and requests from supervisory bodies;
To protect the legal rights of CRT ADJUSTERS by establishing or exercising defenses in legal claims;
To ensure the security and integrity of CRT ADJUSTERS’ physical and digital facilities, including access control and video monitoring; and
To collaborate in investigations of illegal activities and complaints, fraud prevention, and mitigation of financial or operational risks.
Health and Safety
To ensure the protection of the health and safety of all individuals accessing CRT ADJUSTERS’ physical premises, including monitoring and entry control.
Service Development and Improvement
To develop new features and improve services, products, and benefits available to clients/users;
To offer advertising and marketing actions when there is the explicit consent of the data subject; and
To reuse content published by You on social media, respecting the permissions granted.
Handling Specific Situations
To the extent necessary to
Establish, exercise, or defend legal claims;
Comply with applicable legal or regulatory requirements;
Prevent physical harm or significant financial loss to any person or entity;
Assist investigations into unlawful activities or complaints; and
Serve the legitimate justified interest of CRT ADJUSTERS.
WE DO NOT COLLECT MORE DATA THAN IS STRICTLY NECESSARY FOR THE ACTIVITIES DESCRIBED IN THIS POLICY.
6. CATEGORIES OF PERSONAL DATA PROCESSED BY OR ON BEHALF OF CRT ADJUSTERS
The categories of Personal Data that may be processed by or on behalf of CRT ADJUSTERS, to fulfill the purposes described in this Policy, may include the following types of personal data, which vary according to the activity:
Identification, qualification, and contact information: full name; marital status; nationality; residential or business address; date of birth; Identity Card Number (RG) or Individual Taxpayer Registry Number (CPF); email address; phone number; membership registration number; photo, vehicle license plate, among other related data.
Digital identification information: IP address, browser and device information; browsing history; stored cookie data; social media profile; demographic data; recording data, among other related data.
Financial information: bank details; transaction history; credit card number, cardholder name, and expiration date, among other related data.
Miscellaneous information such as: images from internal surveillance recordings for security monitoring, among other related data.
Other information that may be collected:
Social login information, if You register using a social media account such as Facebook or Google and authorize such collection.
Information about You that has become public by You or is publicly available.
Information voluntarily provided by You.
Copies of documents sent by You such as proof of residence or a copy of an identity document, occasionally used to verify your registration or validate your identity.
CRT ADJUSTERS may collect this information in various ways. This Personal Data may be collected directly from the Data Subject or obtained from third parties or someone related to the Data Subject. Regardless of the data source, the processing will be governed by this Privacy Policy and Applicable Laws.
Whenever Sensitive Personal Data is processed, it will be done in the best interests of these individuals and with explicit, specific, and highlighted consent given by one of the parents or legal guardians of the minor.
7. USE OF COOKIES
Cookies are small data files stored on your device or computer to provide a personalized experience when accessing the CRT ADJUSTERS Website. These files allow continuous improvement of navigation and the quality of services offered.
CRT ADJUSTERS may use cookies and other tracking technologies to:
Improve your browsing experience and personalize content;
Analyze the performance and usability of the Website;
Enable essential functionalities for the platform’s operation;
Conduct marketing and/or commercial campaigns.
Most browsers are configured to accept cookies automatically. However, You can manage your preferences directly in your browser settings, choosing to be notified before accepting or to completely refuse the use of cookies. It is important to note that disabling cookies may impact the functionality and browsing experience on the Website.
If You do not want your Personal Data to be used for marketing purposes or commercial actions through cookies, You may request the exclusion of such processing by contacting the Data Protection Officer (DPO) of CRT ADJUSTERS.
8. LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA
CRT ADJUSTERS may, depending on the circumstances, base its processing activities on any of the following legal grounds:
We have obtained your explicit consent prior to processing;
We have a legitimate interest in carrying out the processing, and there is no undue risk to your rights, freedoms, or interests;
The processing is necessary for the execution of a contract entered into with You or for Your benefit, or for preliminary steps related to this contract;
The processing is required by Applicable Laws; or
Any other legal basis available under the Applicable Law.
9. DISCLOSURE OF PERSONAL DATA
CRT ADJUSTERS will not assign, transfer, or sell your Personal Data without your consent. However, we may share or disclose your Personal Data to third parties under the following circumstances:
With employees, service providers, suppliers, and business partners: To the extent necessary for the execution of the activities described in this Policy and other CRT ADJUSTERS regulations, aiming to ensure the proper provision of services, supply of products, benefits, and facilities offered.
With technology and infrastructure providers: Including software vendors, cloud hosting services, management platforms, and other Information Technology (IT) services used to manage your relationship with CRT ADJUSTERS, carry out registrations, documentation, and other processes necessary for the operation of our services.
With third parties involved in contract execution: When sharing is necessary for the execution of contracts or preliminary steps in which You are a party, ensuring the fulfillment of obligations assumed between the parties.
With competent authorities: Including judicial, administrative, or governmental authorities, whenever there is a legal requirement, formal request, or court order, as well as to protect the legitimate interests of CRT ADJUSTERS, as permitted by Applicable Law.
CRT ADJUSTERS ensures that any sharing of Personal Data will be conducted securely, respecting the principles of necessity, adequacy, and transparency, in compliance with the LGPD and other applicable regulations.
10.RIGHTS OF PERSONAL DATA SUBJECTS
Under the terms of the General Data Protection Law (LGPD), You, as a personal data subject, have the following rights regarding the processing of your information by CRT ADJUSTERS:
Right of Confirmation and Access: To confirm the existence of processing and access your Personal Data processed by CRT ADJUSTERS.
Right of Rectification: To request the correction or update of your Personal Data if it is incomplete, inaccurate, or outdated.
Right to Anonymization or Deletion: To request the anonymization or deletion of your Personal Data that is excessive, unnecessary, or processed in non-compliance with the legislation, except in cases where storage is legally permitted or mandatory.
Right to Data Portability: To request the portability of your Personal Data to another entity, in a structured format.
Right to Information on Sharing: To obtain information about public and private entities with which CRT ADJUSTERShas shared your Personal Data.
Right to Object: To object to the processing of your Personal Data when there is non-compliance with the LGPD or legitimate grounds.
Right to Revoke Consent: If the processing of your Personal Data is based on consent, You may revoke it at any time, without compromising the legality of the processing carried out before the revocation.
Right to File Complaints: Should You believe that your Personal Data is not being processed in accordance with current legislation, You have the right to file a complaint with the National Data Protection Authority (ANPD).
If You wish to exercise any of the rights mentioned above or have questions about how your Personal Data is being used, please contact our Data Protection Officer (DPO).
All requests will be handled free of charge and within the deadlines established by law. For your security, before we process your request, we may ask for additional information to confirm your identity.
11.STORAGE AND INTERNATIONAL DATA TRANSFER
CRT ADJUSTERS may securely store your Personal Data in third-party data centers (cloud service provider servers) located in Brazil and in countries that have specific data protection legislation and within legal determinations.
12.DATA PROCESSING TERMINATION
CRT ADJUSTERS shall terminate the processing of your Personal Data in the following circumstances:
a) When the purpose is achieved or the data becomes unnecessary for the purposes set forth in this Policy;
b) When the retention period is met, as determined by applicable legal, regulatory, or contractual obligations;
c) When You request the deletion of your Personal Data, under the terms of current legislation, unless there is another legal basis that justifies its retention; or
d) By determination of the National Data Protection Authority (ANPD) or another legally competent authority.
We only retain your Personal Data as long as we need such Personal Data to fulfill the objectives set out in this Privacy Policy. We may also retain your Personal Data for additional periods, when required under Applicable Laws.
13.THIRD-PARTY WEBSITES AND SERVICES
While browsing the CRT ADJUSTERS Website, we may provide links to other sites on the Internet. This Privacy Policy does not apply to and/or assume responsibility for content available on third-party websites, nor do we share, endorse, monitor, validate, or accept the way these sites or content storage tools handle your personal and private information. We recommend that You consult the respective privacy policies of such sites to be adequately informed about the use of your personal information by other websites.
14.MARKETING
As established in this Policy, CRT ADJUSTERS may contact You periodically by email, text message (SMS), instant messaging applications, or other electronic means of communication to provide information about products, services, benefits, and updates that may be of interest to You.
If you wish to unsubscribe from these communications, we include detailed cancellation instructions in every message sent. Additionally, You may manage your preferences through the following options:
Using the cancellation functions available on our Websites and Applications; or
Requesting directly from our Data Protection Officer (DPO), using the contact information provided in the “Contact Information” section of this Policy.
It is important to note that even if You choose to cancel marketing and advertising communications, CRT ADJUSTERSmay keep your Personal Data stored in its databases for the purpose of complying with legal, regulatory, contractual obligations, or other legitimate purposes provided for in this Privacy Policy.
15.POLICY AMENDMENTS
CRT ADJUSTERS may amend, revise, or update this Policy at any time, without providing any prior and/or specific notice. We recommend that You consult this Policy periodically to ensure You are aware of the most recent version.
16. CONTACT
If You have any questions or concerns about this Privacy Policy, our Personal Data collection and use practices, please contact our Officer.
The Personal Data Protection Officer, also known as the “DPO”, is the person responsible for assisting CRT ADJUSTERS with the fulfillment of its legal obligations regarding privacy.
The Personal Data Officer is responsible for the following activities:
Accepting complaints and communications from data subjects, providing clarification, and taking necessary actions;
Receiving communications from the national authority and taking necessary actions;
Guiding the entity’s employees and contractors regarding the practices to be adopted in relation to personal data protection;
Executing other duties determined by the controller or established in supplementary regulations;
Providing guidance on the procedure to be followed regarding any Personal Data or privacy breach.
If your request falls under the Officer’s responsibility, please contact us through the link “Exercise Data Subject Rights” available on the official websites.
17.ACCEPTANCE OF THIS POLICY
By using any CRT ADJUSTERS Website, Application, or Device, signing contracts or documents, registering for any Relationship Program, or applying for a job, You are deemed to have read, understood, and fully agreed to the terms of this Privacy Policy.
November/2025