Privacy policy

Why is your data important to Tramontina de Panama S.A.?

Tramontina de Panama S.A., committed to the best experience for its consumers and users, through an ongoing effort to improve people's lives, considers its data to be extremely important for the fulfillment of these objectives.

With the purpose of reaffirming our commitment to the security and privacy of the personal information collected in our business, respecting your privacy and complying with the legal standards of Ecuadorian legislation, especially Law No. 81 of 2019, regulated by Executive Decree No. 285 of 2021.

This "Policy" is integral to all Tramontina de Panamá S.A. companies and applies to personal information collected from all those with whom Tramontina de Panama S.A. interacts. There may be specific "Privacy Policies" for interactive applications or services, in which case the user at the time of access.

What are the objectives of Tramontina de Panama S.A.'s Privacy Policy?

The purpose of this "Policy" is to transparently demonstrate our commitment to protecting your data by setting out how to:

• we collect;
• we use;
• we disseminate;
• we share;
• We store; and
• we ensure the security of your data, in accordance with legal guidelines.

All your rights will be duly explained in this "Policy", with the indication of the channels to contact us.

Tramontina de Panama S.A.'s Privacy Policy may be modified at any time, in order to comply with the applicable regulations. It is recommended that reading periodic, accessing to the sites web.

What data do we collect and how do we use it?

The following are the main ways in which Tramontina de Panama S.A. collects personal data, with the respective details of the purposes of use, legal bases and any exchange we make:

PURCHASES AT E-COMMERCE OR TRAMONTINA DE PANAMA S.A.

Data categories and places of pickup:

• Name
• Last Name
• Recipient's name
• Full delivery and billing address
• Address Type
• Email
• Date of birth
• Payment Details
• No. of Cédula or RUC
• Phone
• Consumption profile

What purpose?

• Comply with the obligation to deliver the product to consumer
• Issue of invoice
• Promotional campaigns
• Validation of purchases such as anti-fraud protection
• Consumer protection compliance

What is the legal basis?

• Execution of contracts
• Compliance with legal obligation
• With your consent
• Regular exercise of rights

Who do we share it with?

• Other units of Tramontina del Ecuador S.A.
• Companies hired to guarantee the operation of the website
• Database management companies
• Companies hired to carry out promotional campaigns
• Anti-fraud companies
• Courier companies
• Logistics companies
• Technology companies
• Marketing companies
• Public agencies and/or inspection entities

Tramontina de Panamá S.A. does not sell, disclose and/or share the data of the data holders mentioned in this "Policy" for purposes other than those detailed above.

The veracity of the data provided by the interested parties to Tramontina de Panama S.A. is its sole responsibility, and the deficiency or failure to fill them out may harm the very purpose for which they will be registered, except for the possibility of correcting and updating the information through the channels available in this "Policy".

Where do we store your data?

The collected data will be stored in data centers, on physical servers located in Brazil, and in virtual clouds located abroad.

Is there an international transfer of your data?

Yes, there will be international data transfer for the purpose of storing information in a cloud environment.

ATF manages providers who access member information, ensuring that they adopt appropriate information security measures. In addition, these providers are evaluated to verify that they have an adequate level of protection for personal data.

Tramontina de Panamá S.A. also establishes mechanisms to guarantee the legality of the international transfer of personal data, following the guidelines of the Organic Law on the Protection of Personal Data and its regulations.

What are your rights?

• Confirm the existence of your data
• Have access to your data
• Request the correction of incomplete, inaccurate or outdated data
• Request anonymization, blocking, or deletion of unnecessary data
• Request portability of your data from another provider
• Request the deletion or anonymization of your data after use
• Be informed about the use of shared data
• Be informed about the consequences of not providing their data
• Request the revocation of your consent

To exercise any of these rights, you may contact Tramontina de Panama through the channels available in this Policy.

What precautions do we take with information security?

Tramontina de Panama S.A. adopts good security practices for the information, based on nationally and internationally recognized guidelines.

We also strive to ensure that our partners and suppliers follow equivalent standards, ensuring adequate protection of the data under their responsibility.

How long does Tramontina de Panama S.A. use and store its data?

Your personal data will remain stored in Tramontina de Panama S.A. for legitimate and essential purposes, such as:

• The existence of a specific law or regulation that requires a specific period of time for data retention; and
• for security, fraud control and rights preservation purposes

We will keep the data registration history of the interested parties, ensuring the exclusive use of Tramontina de Panamá S.A. and the companies hired by it to fulfill the purposes described in this "Policy", in addition to preserving the security of such information and other legitimate interests.

You may request anonymization or revocation of your consent through the channels informed in this "Policy".

When consent is requested or revoked, the data subject will be disqualified from receiving advertising and marketing information.

What about children's data?

Tramontina de Panama S.A.'s websites are directed to and intended for use only by persons over 18 years of age.

We do not target advertising to children and we do not knowingly collect personal data from anyone under the age of 18.

Tramontina de Panamá S.A. may have internal processes where process the children's data, which will always be carried out respecting the best interests of the minor, in an ethical manner, observing the Code of Childhood and Adolescence and with the consent of at least one of the parents or legal guardians.

Does Tramontina de Panama S.A. use cookies?

What are cookies?

They are small text files, such as a data packet, recorded and sent from a web server (website) to browser programs (browsers). The browsers used store this information to set preferences based on user access.

What are the types of cookies?

a) First-party cookies: these are cookies set directly by the website or application that the owner visits. First-party cookies generally cannot be used to track activity on a website other than the original website on which they were placed. These types of cookies may include information such as login credentials, shopping cart items, or preferred language

b) Third-party cookies: these are cookies created by a domain other than the one the owner is visiting. They are the result of functionalities of other domains that are incorporated into an electronic page, such as the display of advertisements.

c) Necessary cookies: these are those that are used for the website or application to perform basic functions and function properly. Therefore, the collection of information is essential to ensure the operation of the website or for the correct provision of the service. Thus, the activities covered as strictly necessary include those related to the specific functionality of the service, i.e., without them the user would not be able to perform the main activities of the website or application. This category is restricted to what is essential to provide the service requested by the owner, not contemplating non-essential purposes, which satisfy other interests of the responsible party.

d) Analytical or performance cookies: allow us to collect data and information about how users use the website, which pages they visit most often on that website, the occurrence of errors, or information about the performance of the website or application itself.

e) Functionality cookies: these are used to provide the basic services requested by the user and allow us to remember preferences of the website or application, such as username, region or language. Functionality cookies may include first-party, third-party, persistent or session cookies.

f) Advertising cookies: these are used to collect information from the owner in order to display advertisements. More specifically, by collecting information relating to the user's browsing habits, advertising cookies make it possible to identify the user, create profiles and display advertisements tailored to their interests.

What data do we collect through cookies?

First-party and third-party cookies such as "Rockin Tags" and Google is used to collect browsing information such as: site activities/visits, most frequented categories, clicks, among others. The data is collected automatically, and the examples are described in the table below:

• Click here to learn more about the "Rockin Tags" and access the privacy policy at: https://blog.pmweb.com.br/pmweb-rockin-tags/.
• Click here to learn more about "Criteo" and access the privacy policy at: www.criteo.com/privacy/.
• Please also see Google's privacy policy available at: https://policies.google.com/privacy.
  

Facebook Pixel: We use Facebook pixel tracking to enable more robust campaign reporting and to track social media users who visit our websites, using a tagging mechanism provided by those social networks. These cookies may also be used to track events and for marketing and remarketing purposes. All data collected will be used in accordance with the cookie policy of TRAMONTINA DE PANAMÁ S.A. and the privacy policies of the social network. Tramontina de Panama
S.A. will not store personally identifiable information of the user.

You can also set preferences directly on the Facebook platform: Facebook ad settings and refresh preferences.

Who uses our cookies?

The data collected through cookies will be used by companies contracted by Tramontina de Panamá S.A. and Tramontina de Panamá S.A. to improve your access and offer a more personalized experience.

Tramontina de Panamá S.A. has no control over the use of cookies collected by third parties.

How can I set cookies?

TRAMONTINA DE PANAMA S.A. uses third-party tools to facilitate the configuration of the cookie options allowed by the user, according to their preferences. When you access the TRAMONTINA DE PANAMA S.A. websites and Intranet for the first time, a banner will be available of "CONFIGURE COOKIES" with the possibility of configuring your preferences.

You can modify your options at any time by clicking on the
"Cookie Preferences" buttons located at the bottom of each Tramontina de Panama S.A. website and intranet.

It is important to inform you that if you choose to set your browser to disable,
By refusing or blocking cookies, there may be restrictions on the operation of the pages of the website and personalization according to your preferences as well as session information will not be recorded, which may have a negative impact on the usability and experience on our website.

What is the contact channel for Tramontina de Panamá S.A.?

The interested party may clarify any doubts regarding this "Policy", as well as request any of your rights, through the communication channels listed below:

Company Name:
TRAMONTINA DE PANAMA S.A.

RUC No.:
2185559-1-770972

Address:
Las Mañanitas, Tocumen Office Storage, Bodega 24, ubicado en Carretera Panamericana, frente a Plaza Las Americas

Petitions/complaints channel:
Contact: +507 309 9507 / 08 / 09