PRIVACY POLICY

At LUBRIGAZ, we understand that the use of your personal data requires your trust. We adhere to the highest privacy standards and will only use your personal data for clearly identified purposes and in accordance with your data protection rights.

The confidentiality and integrity of your personal data is one of our top priorities.

This Privacy Policy sets out how LUBRIGAZ uses the personal data of its customers and potential customers.

1. GENERAL PART

1.1. COLLECTION AND PROCESSING OF USER DATA

Depending on how the Customer interacts with LUBRIGAZ (online, offline, by phone, and/or in person), we collect various types of information about them, as described below:

Personal contact information: This includes information that the Customer provides to us and that allows us to contact them, such as their name, postal address, email address, social media details, or phone number.

Demographic information: any information describing your demographic or behavioral characteristics. Some examples include your date of birth, age or age group, geographic location (e.g., postal code), favorite products, hobbies and interests, as well as information about your household or lifestyle.

Technical information about the computer/mobile device: any information regarding the computer system or other technological device you use to access one of our websites or apps, such as the Internet Protocol (IP) address used to connect your computer or device to the Internet, the operating system type, and the web browser type and version. If you access the LUBRIGAZ website or app via a mobile device, such as a smartphone, the information collected will also include-where permitted-your mobile phone's unique identification number, advertising identifier, geolocation, and other similar data related to mobile devices.

Website usage/communications information: When you browse and interact with our websites or newsletters, we use automatic data collection technologies to gather specific information about your activity. This includes information such as the links you click, the pages or content you view and the duration of such views, as well as other similar information and statistics regarding your interactions-such as content response times, download errors, and the duration of visits to specific pages. This information is captured via automated technologies, such as cookies (browser cookies, Flash cookies) and web beacons, and is also collected through third-party tracking services (such as DoubleClick, Google Analytics, Adobe Dynamic Tag Management, and/or Omniture). Consumers have the right to object to the use of such technologies.

Customer Feedback: this includes information you voluntarily share with us about your experience using our products and services.

Customer-generated content: this refers to any content you create and subsequently share with us on social media or by uploading it to one of our websites or apps, including the use of social media apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, we collect and publish customer-generated content related to a variety of activities, including contests and other promotions, community website features, consumer engagement, and third-party social media activities.

Social media information: this refers to any information that the consumer shares publicly on a social network, or information that is part of their profile on a third-party social network (such as Facebook) and which the consumer allows that third-party social network to share with us. Some examples include basic account information (e.g., name, email address, gender, date of birth, city of residence, profile picture, username, friend list, etc.) and any additional information or activities that the consumer permits to be shared by that third-party social network. We receive your social network profile information (or parts thereof) whenever you download or interact with a LUBRIGAZ web application on a social network (such as Facebook), whenever you use a social network feature integrated into a LUBRIGAZ website (such as Facebook Connect), or whenever you interact with us via a social network. For more information on how LUBRIGAZ obtains your information from a third-party social network, or to opt out of sharing such social network information, please visit the website of the social network in question.

Calls to the Customer Service Center. Communications with the Customer Service Center may be recorded in accordance with applicable law for local operational reasons (e.g., for quality and satisfaction purposes, as proof of commercial transactions, and, in certain cases, to record proof of consent to direct marketing and profiling).

The Client will be informed of such recording at the beginning of the respective call and will have the right to object to it.

For the purposes of this Privacy Policy, a contractual relationship is defined as any contract established between LUBRIGAZ and the entities with which it interacts, regardless of the subject matter of said contract.

1.2. SUBCONTRACTED ENTITIES

In the course of processing User Data, LUBRIGAZ engages or may engage third-party entities—acting as its subcontractors—to process User Data on LUBRIGAZ’s behalf and in accordance with its instructions, in compliance with the law and this Privacy Policy.

These subcontracted entities may not transmit User Data to other entities without LUBRIGAZ’s prior written authorization, and they are also prohibited from engaging other entities without LUBRIGAZ’s prior authorization.

LUBRIGAZ commits to subcontracting only entities that offer maximum security in the implementation of appropriate technical and organizational measures, so as to ensure the protection of the User's rights. All entities subcontracted by LUBRIGAZ are bound to the latter by a written contract governing, in particular, the subject matter and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data subjects, and the rights and obligations of the parties.

Following the collection of personal data, LUBRIGAZ provides the User with information regarding the categories of subcontracted entities that, in the specific case, may process data on behalf of LUBRIGAZ.

1.3. DATA COLLECTION CHANNELS

LUBRIGAZ may collect data directly (i.e., directly from the User) or indirectly (i.e., through partner entities or third parties). Collection may take place via the following channels:

• Direct collection: in person, by phone, by email, and through the website;
• Indirect collection: through partners, group companies, and official entities.

1.4. SHARING OF PERSONAL DATA

We share your data, specifically with SIVA – SOCIEDADE DE IMPORTAÇÃO DE VEÍCULOS AUTOMÓVEIS, S.A., headquartered at Rua do Comércio nº 2, 2050-541 Vila Nova da Rainha, holding corporate tax ID number 500.301.522 and registered with the Commercial Registry Office under the same number, in its capacity as the importer in Portugal of the brands we market.

2. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA

Regarding general principles concerning the processing of personal data, LUBRIGAZ undertakes to ensure that the User Data it processes are:

• Subject to processing that is lawful, fair, and transparent in relation to the User;
• Collected for specific, objective, and legitimate purposes, and not subsequently processed in a manner incompatible with those purposes;
• Adequate, justified, and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and kept up to date whenever necessary, with all necessary measures taken to ensure that inaccurate data—having regard to the purposes for which they are processed—are erased or corrected without delay;
• Retained in a manner that allows for the identification of the User only for the period necessary for the purposes for which the data are processed;
• Retained in a manner that allows for the identification of the User only for the period necessary for the purposes for which the data is processed;
• Data processing operations carried out by LUBRIGAZ are permitted and lawful when at least one of the following situations applies:
  • The User has unequivocally given their consent to the processing of the User's Data for one or more specific purposes;
  • The processing is necessary for the performance of a contract to which the User is a party, or for pre-contractual procedures at the User's request;
  • The processing is necessary for compliance with a legal obligation to which LUBRIGAZ is subject;
  • The processing is necessary to protect the vital interests of the User or of another natural person;
  • The processing is necessary for the purposes of the legitimate interests pursued by LUBRIGAZ or by third parties (except where such interests or the fundamental rights and freedoms of the User requiring the protection of personal data prevail).

LUBRIGAZ commits to ensuring that the processing of User Data is carried out only under the conditions listed above and in compliance with the principles mentioned above.

When the processing of User Data is carried out by LUBRIGAZ based on the User's consent, the User has the right to withdraw their consent at any time. However, the withdrawal of consent does not affect the lawfulness of the processing carried out by LUBRIGAZ based on the consent previously given by the User.

The period of time during which data is stored and retained varies according to the purpose for which the information is processed.

Indeed, there are legal requirements mandating the retention of data for a minimum period. Accordingly, in the absence of a specific legal obligation, data will be stored and retained only for the minimum period necessary for the purposes for which they were collected or subsequently processed, after which they will be deleted.

3. USE AND PURPOSES OF USER DATA PROCESSING

In general terms, LUBRIGAZ uses User Data for the following purposes:

• Management of user contacts;
• To inform the User—upon their request—of new products and services made available on the Site, special offers and campaigns, and updated information regarding LUBRIGAZ’s activities; and, more generally, for LUBRIGAZ marketing purposes via any communication channel, including electronic media;
• Ensuring that the Site meets User needs by developing and publishing content tailored as closely as possible to User requests and profiles, improving the Site’s search capabilities and functionalities, and obtaining information or statistics regarding the typical User profile (analysis of consumption profiles);
• Provision of services, and other services such as newsletters, opinion surveys, or other information or products requested or purchased by the User;
• Sending satisfaction surveys;
• LUBRIGAZ may combine Usability Information with anonymous demographic information for research purposes, and may use the result of this combination to provide more relevant content on the Site.

User Data collected by LUBRIGAZ is not shared with third parties without the User's consent, except in the situations referred to in the following paragraph. However, if the User contracts services from LUBRIGAZ that are provided by other entities responsible for processing personal data, such entities may consult or access the User Data to the extent necessary for the provision of said services, and the User will be informed accordingly.

In accordance with applicable law, LUBRIGAZ may transfer or disclose User Data to other entities if such transfer or disclosure is necessary for the performance of the contract between the User and LUBRIGAZ, or for pre-contractual measures at the User's request; if necessary to comply with a legal obligation to which LUBRIGAZ is subject; or if necessary to pursue the legitimate interests of LUBRIGAZ or a third party. In the event of a transfer of User Data to third parties, reasonable efforts will be made to ensure that the recipient uses the transferred User Data in a manner consistent with this Privacy Policy.

4. TECHNICAL, ORGANIZATIONAL, AND SECURITY MEASURES IMPLEMENTED

To ensure the security of User Data and maximum confidentiality, LUBRIGAZ treats the information you have provided with absolute confidentiality, in accordance with its internal security and confidentiality policies and procedures—which are periodically updated as needed—as well as applicable legal terms and conditions.

Taking into account the nature, scope, context, and purposes of the data processing, as well as the risks to the User's rights and freedoms arising from such processing, LUBRIGAZ undertakes to implement—both at the time of determining the means of processing and at the time of the processing itself—the technical and organizational measures necessary and appropriate to protect User Data and ensure compliance with legal requirements.

It further undertakes to ensure that, by default, only data necessary for each specific processing purpose are processed and that such data are not made available to an indeterminate number of persons without human intervention.

Communication between the user's device and LUBRIGAZ takes place via secure channels using the HTTPS protocol and the SSL security standard.

Nevertheless, in terms of general measures, LUBRIGAZ adopts the following:

• Regular audits aimed at assessing the adequacy of the technical and organizational measures implemented;
• Raising awareness and training of personnel involved in data processing operations;
• Pseudonymization and coding of personal data;
• Mechanisms capable of ensuring the permanent confidentiality, availability, and resilience of information systems;
• Mechanisms that ensure the restoration of information systems and access to personal data in a timely manner in the event of a physical or technical incident.

5. DATA TRANSFER OUTSIDE THE EUROPEAN UNION

The Site does not transfer your personal data to recipients located in countries outside the European Union.

6. USE OF COOKIES

When you visit our website, a small text file (cookie) is created and saved on your computer's hard drive; consequently, by browsing the site, you agree to the installation of this text file on your device. This file enables faster and easier access to the site, as well as customization based on your preferences.

If you wish to delete them or automatically block them, you can find instructions on how to configure these settings in your browser's "Help" menu. However, if you do not allow the use of cookies, there may be some features of the Site that you will be unable to use.

By browsing our Site, you consent to the collection and storage of small text files known as cookies; these contain information and are downloaded to users' computers or other devices via a server. These text files enable a more personalized and efficient browsing experience. Each time you visit the Site, your web browser sends these cookies back to the Site, allowing for the recognition and retention of users' identities and usage preferences.

For more information, please consult our cookie policy here.

LUBRIGAZ uses cookies to:

• To get to know our visitors and thereby improve their browsing experience;
• Customize the information on the web pages they visit;
• Segment our offering and make campaigns available based on the interests of each of our visitors.

Device Data

The device data that our sites collect includes:

• Technical information, your Internet domain name (this could be your Internet Service Provider—e.g., NOS, MEO, Vodafone—or your workplace) and the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version (e.g., Google Chrome, Microsoft Edge, Mozilla Firefox), your device type, time zone setting, browser plug-in types and versions, operating system (e.g., Windows 10 or macOS), and platform;
• Information about your visit, including the full clickstream of Uniform Resource Locators (URLs) to, through, and from our websites (including date and time); products you viewed or searched for; page response times; download errors; the duration of visits to certain pages, the number and identity of pages visited during a session on our site, and the time spent on the site; as well as page interaction information (such as scrolling, clicks, and mouse-overs).
• We may receive information about you if you use any other websites operated by us or services we provide. We work with third parties (including, for example, business partners; subcontractors in technical, payment, and delivery services; authentication and fraud support service providers; advertising networks; analytics providers; search information providers; and credit reference agencies) and may receive information about you from these third parties.

This site uses the following types of cookies:

Functional Cookies:

They allow us to remember the user's browsing preferences on our website. This means you do not need to reconfigure or personalize it each time you visit. This type of cookie does not collect information that could be used for marketing purposes.

Performance and Analytics Cookies:

Our website uses Google Analytics, a web analytics service provided by Google. This service uses cookies to collect and analyze information about user behavior on the LUBRIGAZ website, including IP addresses. The information collected by Google Analytics is processed to generate statistical reports on users' browsing activities.

For more information about Google Analytics cookies, visit: https://goo.gl/UTajdR.

Cookies related to social media usage:

These cookies are linked to services provided by third parties, such as “Like” or “Share” buttons. They are used to provide you with sharing services for various social networks.

We recommend that you consult the privacy policies of these social networks to learn about the browsing information they may collect through these application buttons and the purposes for which it is used.

We analyze and collect data made available by our users on our social media channels via the forms we provide during communication campaigns hosted on each platform. This data is processed in accordance with each platform's regulations and the user's prior consent.

Types of Cookies

Manage cookies – Disable, enable, and delete cookies

You can choose to accept or decline cookies by changing your browser settings. However, you may not be able to use all the interactive features of the site if cookies are disabled. To find out if cookies are enabled, follow the instructions below.

How to configure and customize your cookie settings for the browser you are using

• How to manage cookies in Internet Explorer: In most versions of Internet Explorer, you can access cookie settings by clicking the Tools option and then the Privacy tab.
• How to manage cookies in Microsoft Edge: In Microsoft Edge, you can access cookie settings by clicking the More option and then the Settings icon.
• How to manage cookies in Firefox: In Firefox, cookie settings are managed in the Privacy panel of the Options window. See the Options window – Privacy panel for more information about these settings.
• How to manage cookies in Chrome: Click the wrench icon on the toolbar, select Settings, click the tab at the top, then click Content settings in the Privacy section.
• How to manage cookies in Opera: In Opera, click Settings, Preferences, Advanced, and finally Cookies to manage cookies.
• How to manage cookies in Safari: Select Safari, followed by Preferences, and finally click Security. You can then specify whether and when Safari should accept cookies.
• To manage cookies on your mobile phone: Consult your manual or guide.

Delete cookies

You can easily delete any cookies installed in your browser's cookie folder. For example, if you are using Microsoft Windows Explorer:

1. Open Windows Explorer.
2. Click the “Search” button on the toolbar.
3. Type “cookie” in the search box for “Folders and files”
4. Select “My Computer” in the “Look in” box.
5. Click “Search now”
6. Double-click the folders you find.
7. Select all cookie files
8. Press "Delete" on the keyboard.

If you are not using Microsoft Windows Explorer, you should select “cookies” in the “Help” function to find out where the cookies folder is located.

You can obtain more general information about cookies on this page: http://ec.europa.eu/ipg/basics/legal/cookies/.

If you have any questions or concerns regarding LUBRIGAZ's Cookie Policy, please contact us via email at: protecaodedados@lubrigaz.pt.

Consumer Arbitration

For the resolution of disputes related to sales and service contracts, the competent body is the Arbitration Center for the Automotive Sector, to which this company is a member, with a website at www.arbitragemauto.pt

Electronic Complaints Book

The Complaints Book is now available online https://www.livroreclamacoes.pt, while continuing to use the previously available complaint channels, such as email or telephone.

LUBRIGAZ WHISTLEBLOWING SYSTEM

Law No. 93/2021 of December 20 approved the general regime for the protection of whistleblowers (hereinafter the “General Whistleblower Protection Regime”), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019, on the protection of persons who report breaches of Union law (the “Whistleblowing Directive”).

Under this regime, which entered into force on June 18, 2022, Lubrigaz, S.A.’s policy on reporting infringements may be consulted here. Reports of infringements may be submitted via the Lubrigaz, S.A. Ethics Channel at the email address denuncias@lubrigaz.pt.

Anti-Corruption Policy

LUBRIGAZ, S.A. conducts its activities based on high standards of professional responsibility and ethics, guided by the principles of integrity, transparency, honesty, loyalty, rigor, and good faith.

Lubrigaz, S.A. has adopted a compliance program aimed at preventing, detecting, and sanctioning acts of corruption and related offenses. You can view our Corruption Prevention Policy here.