Privacy and Personal Data Protection Policy - Ecominas

1. INTRODUCTION

Ecominas Meio Ambiente e Urbanismo Ltda, registered under CNPJ No. 05.957.237/0001-89, with headquarters at Avenida Prudente de Morais, 901, Rooms 210 to 212, Santo Antônio, Belo Horizonte, MG - CEP 30.350-143, operates in socio-environmental consulting, studies and advisory services in environmental licensing, participatory diagnostics, socio-environmental perception and mobility research, environmental education programs, ESG consulting and institutional communication.

These activities involve, to a greater or lesser degree, the processing of personal data — of residents of researched communities, of representatives of clients and suppliers, of job applicants, and of visitors to our digital channels.

This Policy explains what data we process, for what purpose, on what legal basis, with whom we share it, and how the data subject can exercise their rights, in accordance with Law No. 13.709/2018 (General Data Protection Law — LGPD).

Applies to: Institutional website (ecominas.com) and Insights blog, social media profiles, field or online research forms, in-person community activities, relationships with clients, suppliers, and stakeholders (stakeholders) or third parties, selection processes and institutional communications.


2. DEFINITIONS

  • Personal information: Information relating to an identified or identifiable natural person.
  • Sensitive personal data: Data concerning racial or ethnic origin, religious beliefs, political opinions, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data.
  • Holder: natural person to whom the data refers.
  • Treatment: any operation involving personal data (collection, use, storage, sharing, deletion, etc.).
  • Controller: Who is responsible for decisions regarding treatment?
  • Operator: who processes data on behalf of the controller.
  • Anonymization: The process by which a piece of data loses the possibility of being associated with an individual.
  • Data Protection Officer (DPO): person designated to act as a communication channel between Ecominas, data subjects, and the National Data Protection Authority (ANPD).


3. OUR ROLE: CONTROLLER AND OPERATOR

Ecominas operates under two distinct conditions, depending on the context:

As a controllerwhen deciding on the purposes and means of processing — for example: website and social media management, institutional communications, recruitment processes, and relationships with clients and suppliers.

As an operatorWhen processing personal data on behalf of and under the instructions of a contracting client—for example: conducting socio-environmental perception surveys, mobility surveys, and environmental education programs linked to a specific project—Ecominas is the data controller. In these cases, the contracting entrepreneur is the data controller, and Ecominas processes the data within the limits of the contract, applying the same security and confidentiality standards described in this Policy to this activity.

Whenever the data subject is contacted in the field or via a form, the data collection instrument itself will indicate who is controlling that data processing.


4. DATA WE PROCESS AND PURPOSES

4.1. Visitors to the Insights website and blog

Data: IP address, browsing data, device and origin of access, cookie data; and, when the visitor fills out forms, name, email, phone number, company and message content.
Purposes: To operate and protect the website, measure audience and content performance, and respond to commercial and institutional inquiries.

4.2. Subscribers to institutional newsletters and mailing lists

Data: Name, corporate email, company, job title, and history of interaction with messages.
Purposes: Sending out newsletters, technical content, invitations, and institutional communications.

4.3. Social networks and advertising

Data: Profile identifiers, public interactions (comments, messages, likes), and aggregated metrics provided by the platforms themselves.
Purposes: Relationship management with the public, addressing requests received through these channels, and measuring communication performance.
Observation: The platforms (Meta, LinkedIn, Google/YouTube) act as controllers of the data collected in their environments, according to their own policies.

4.4. Participants in socio-environmental perception surveys, mobility studies, and related studies.

Data: depending on the instrument used — identification and contact information (when necessary for sample validation), age range, gender, education level, occupation, income bracket, length and place of residence, household composition, commuting habits, opinions and perceptions about the project and the territory.
Purposes: To compile socio-environmental diagnoses, impact studies, EIVs (Environmental Impact Assessments), plans and programs required for environmental or urban planning licensing; to support participatory diagnoses and socio-environmental management actions of the developer; to meet the Terms of Reference of public bodies.
Treatment rule: the results are presented in a way aggregate and statisticalData that allows for the direct identification of the respondent is not published in the reports, except when indispensable for compliance with legal requirements or Terms of Reference, in which case the data subject is informed beforehand.
Participation: Participation in surveys is voluntary. Participants may choose not to answer any question or discontinue their participation at any time.

4.5. Participants in environmental education programs and community activities

Data: Name, contact information, affiliated institution or community, attendance list, and participation records. Purposes: Organization of activities, proof of execution to the entrepreneur and environmental agencies, and evaluation of the programs.

4.6. Image, voice and testimony recording

Data: Photographs, videos, audio recordings, and testimonies captured in the field, workshops, meetings, and events. Purposes: Technical documentation of activities in reports and licensing processes; and, when specifically authorized, institutional and communication use, including the Ecominas image bank.
Treatment rule: The use of images for institutional communication purposes depends on image usage authorization Signed by the holder or, in the case of children and adolescents, by their legal guardian.

4.7. Customers, suppliers, partners and service providers

Data: Name, position, email, phone number, and other information necessary for hiring, invoicing, and fulfilling tax and contractual obligations of the parties' representatives.
Purposes: Contract execution, commercial management, issuance of tax documents, participation in public and private procurement processes, and compliance with legal obligations.

4.8. Job applicants

Data: Curriculum vitae, identification and contact information, education, professional experience, salary expectations, and records of the selection process.
Purposes: Conducting the selection process, creating a talent pool (with consent), and taking preliminary steps towards hiring.


5. LEGAL BASIS

TreatmentLegal basis (Law No. 13.709/2018)
Contract execution with clients, suppliers, and partners.Article 7, V — execution of contract
Studies, reports and programs required for environmental and urban planning licensing.Article 7, II — compliance with a legal or regulatory obligation
Issuance of tax documents, record keeping, and assistance to regulatory bodies.Article 7, II — compliance with a legal or regulatory obligation
Perception surveys, participatory diagnostics, and socio-environmental studies.Article 7, II and IX; and, when applicable, Article 7, IV — conducting studies by a research body, with anonymization whenever possible.
Sending newsletters and institutional communications to professional contacts.Article 7, IX — legitimate interest
Audience measurement, security, and improvement of the website and digital channels.Article 7, IX — legitimate interest
Non-essential cookiesArticle 7, I — consent
Use of images and testimonials in institutional communication.Article 7, I — consent (authorization for use of image)
Selection processesArticle 7, V — preliminary steps for hiring; talent pool, Article 7, I
Regular exercise of rights in judicial, administrative or arbitration proceedings.Art. 7, VI
Protection of life or physical safety in the field.Art. 7, VII and VIII


Regarding legitimate interest:
When this is the basis used, Ecominas only processes the data strictly necessary for the purpose, previously assesses the impact on the data subject's rights, and guarantees the right to object, in accordance with Article 10 of the LGPD (Brazilian General Data Protection Law).


6. Sensitive Personal Data

Ecominas does not routinely collect sensitive data. When a study requires such information—for example, health or ethnic origin data in diagnoses of traditional communities or in specific programs—the processing will comply with Article 11 of the LGPD (Brazilian General Data Protection Law), will be limited to the minimum necessary, will be informed to the data subject at the time of collection, and will be based on specific and explicit consent or on another applicable legal basis.


7. CHILDREN AND ADOLESCENTS

Some of Ecominas' activities reach children and adolescents, such as mobility research in the school environment and environmental education programs.

In these cases:

  • The processing is carried out in the best interests of the child and adolescent, in accordance with Article 14 of the LGPD (Brazilian General Data Protection Law) and the Statute of Children and Adolescents;
  • The collection of children's data depends on specific and prominent consent from at least one parent or legal guardian;
  • We do not make participation in activities conditional on providing more data than is necessary;
  • The dissemination of images, voices, or testimonies of children or adolescents depends on the express, specific, and written authorization of at least one parent or legal guardian, indicating the purposes and means of dissemination authorized;
  • In the absence of such authorization, or if it is revoked, the material will only be released after irreversible disfigurement applied to the file intended for publication — blurring, obscuring, or cropping the face and any other elements that allow direct or indirect identification, such as name, badge, uniform, school sign, house number, or visible address;
  • The original files, without any alteration, remain in a restricted access environment and are used only for technical verification of the activity before the entrepreneur and environmental agencies, never for institutional communication;
  • The authorization may be revoked at any time by the legal representative. Upon receiving the revocation, Ecominas will cease further use and remove the material from the channels under its control within [10] business days, except for records already incorporated into administrative processes or necessary for compliance with legal obligations;
  • Under no circumstances will images of children or adolescents be published in conjunction with information that exposes their vulnerability, health, conduct, or family life.


8. DATA SHARING

The data can be shared with:

  • Contracting clients (entrepreneurs), when Ecominas acts as the operator, within the limits of the contract and the purpose of the study;
  • Public bodies and regulatory entities — such as environmental secretariats and councils, municipalities, licensing and control bodies — to prepare licensing processes, comply with Terms of Reference, conditions and legal requirements. Documents filed in administrative processes may become public, in accordance with access to information legislation;
  • Service providers and technology suppliers who act as operators for Ecominas (hosting, email and productivity, electronic forms, cloud storage, email marketing tools and audience analytics), under contractual obligations of security and confidentiality;
  • Judicial, administrative and police authorities, by legal request;
  • Consultants and advisors (legal, accounting and auditing), when necessary for the regular exercise of rights.

Ecominas never It sells personal data.


9. INTERNATIONAL TRANSFER

Some of the tools used (cloud services, productivity tools, electronic forms, social networks, and audience analytics) are operated by companies with infrastructure outside of Brazil. In these cases, the transfer occurs based on the provisions of Article 33 of the LGPD (Brazilian General Data Protection Law) and through suppliers that adopt contractual clauses and protection standards compatible with Brazilian legislation.


10. COOKIES

The website uses cookies and similar technologies to:

  • Essentials: Functioning and security of navigation (do not depend on consent);
  • Performance and analysis: Audience metrics and browsing behavior;
  • Advertising and remarketing: ad measurement and targeting.

Non-essential cookies are only activated with consent, collected via the banner displayed on the first visit. The user can review their choice at any time in the banner settings or their browser settings. Disabling non-essential cookies does not prevent the use of the website.


11. STORAGE PERIOD

The data is kept for the time necessary to fulfill the purposes, observing:

Data typeReference deadline
Data from studies and technical reports delivered to clients and regulatory bodies.For the duration of the licensing process and conditions, and for the contractual retention period — a minimum of [5] years after delivery.
Contractual, tax and accounting dataFor the applicable legal periods (generally 5 to 10 years)
Mailing and communication contactsAs long as there is a relationship and no cancellation has occurred.
Resumes and selection processes[12] months after the end of the process, unless consent is given for a talent pool
Website access logs6 months, at a minimum, according to article 15 of Law No. 12.965/2014 (Brazilian Internet Bill of Rights).

Once the deadline has passed, the data is deleted or anonymized, except in the cases provided for in Article 16 of the LGPD (Brazilian General Data Protection Law).


12. INFORMATION SECURITY

Ecominas adopts technical and administrative protection measures, including: access control by profile and individual credentials, multifactor authentication in corporate environments, storage in a controlled corporate environment, backups, confidentiality agreements with employees and suppliers, and periodic training for field teams on the collection and storage of forms.

Physical forms used in the field are digitized and kept in a restricted access environment; the originals are stored or disposed of securely.

In the event of a security incident that poses a significant risk to data subjects, Ecominas will notify the ANPD (National Data Protection Authority) and the affected data subjects, in accordance with Article 48 of the LGPD (Brazilian General Data Protection Law).


13. RIGHTS OF THE HOLDER

According to Article 18 of the LGPD (Brazilian General Data Protection Law), the data subject may request:

  • confirmation of the existence of processing and access to the data;
  • Correction of incomplete, inaccurate, or outdated data;
  • Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
  • Portability to another service or product provider;
  • deletion of data processed based on consent;
  • Information about the entities with which we share data;
  • Information about the possibility of not providing consent and its consequences;
  • revocation of consent;
  • opposition to treatment based on legitimate interest.

How to practice: send the request to comunicacao@ecominas.comWe will respond within [15] days, and may request additional information to confirm your identity and prevent the improper disclosure of data to third parties.

When Ecominas acts as the operator, the request will be forwarded to the controlling client, and the account holder will be informed of this forwarding.

The data subject can also file a complaint directly with the ANPD (www.gov.br/anpd).


14. DEREGISTRATION OF COMMUNICATIONS

All communications sent by Ecominas contain a link or instruction to unsubscribe. The request is processed within [5] business days. Even after unsubscribing, we may retain the minimum record necessary to verify that the request was fulfilled and to prevent further mailings.


15. Data Protection Officer (DPO)

Name: Lais Rosa Leite Nogueira
E-mail: comunicacao@ecominas.com
Address: Av Prudente de Morais, 901, Rooms 210 to 212, Santo Antônio, Belo Horizonte, MG - Postal Code 30.350-143


16. CHANGES TO THIS POLICY

This Policy may be updated at any time. The current version will always be available at ecominas.com, indicating the date of the last update. Significant changes will be communicated through the usual communication channels.


17. APPLICABLE LEGISLATION

This Policy is governed by Brazilian law, in particular Law No. 13.709/2018 (LGPD), Law No. 12.965/2014 (Marco Civil da Internet), Law No. 12.527/2011 (Access to Information Law), Law No. 8.078/1990 (Consumer Protection Code) and Law No. 8.069/1990 (ECA), as applicable. The jurisdiction of the district of Belo Horizonte/MG is chosen to resolve any disputes.


Version: 01 | Validity: 20/03/2025 | Last updated: 26/08/2026

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