Document Number: POL-00384
Revision: 4
Published Document: 10/Mar/2026
PRIVACY AND PERSONAL DATA PROTECTION POLICY
I. INTRODUCTION
The companies Zilia Technologies Indústria de Componentes Semicondutores Ltda., a private legal entity registered with the CNPJ under number 06.103.827/0001-07, and Zilia Technologies Indústria e Comércio de Componentes Eletrônicos Ltda., a private legal entity registered with the CNPJ under number 11.576.445/00001-30, are committed to protect privacy and personal data of all stakeholders, including their customers, suppliers, service providers, business partners, and employees.
From now on, for a better understanding of the terms of this Policy, the companies will be referred as ZILIA.
Privacy and protection of the stakeholders personal data is very important to ZILIA. To achieve this goal, this Policy, in a simple, transparent and objective manner, clarifies and describes how ZILIA collects, uses, transfers, stores and protects the stakeholders personal data.
II. DEFINITIONS
For the purposes of this Policy, the following definitions shall apply, in accordance with the provisions of the Brazilian General Data Protection Law (“LGPD”) nº 13.709/2018:
a. Anonymization or anonymized data: the use of reasonable and available technique when Processing, ensuring Data loses the possibility to identify an individual directly or indirectly;
b. Personal Data(s) or Data(s): information relating to an identified or identifiable natural person and, where applicable, may include Sensitive Personal Data, which refers to 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, when linked to a natural person;
c. Interested Parties: means clients, Business Partners, employees or any other Data Subjects who have any connection with ZILIA;
d. Business Partner(s): means agents, contracted companies, suppliers, partners, joint ventures or similar entities/persons, distributors, manufacturers, sales representatives, consultants, intermediaries or any third parties who act or will act for or on behalf of ZILIA;
e. Data Subject(s): natural person whose personal data is under Processing;
f. Processing: any operation performed on the Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Any terms used hereafter that have not been specifically defined will be interpreted in accordance with the LGPD (Brazilian General Data Protection Law), as well as those whose definition the LGPD may modify or update, or that have been or may be interpreted and clarified by the National Authority for Personal Data Protection (“ANDP”).
III. APPLICATION
If you are a Data Subject who interacts in any way with ZILIA as an Interested Party or Business Partner, or if you use our website ziliatech.com, this Privacy Policy applies to you (“YOU”).
It is important to clarify that if YOU are an employee of ZILIA, in addition to this Policy, the other internal policies of ZILIA apply to the Processing of your Personal Data, especially the EMPLOYEE MANUAL. Therefore, if you do not find the information you are looking for in this Policy, please check the EMPLOYEE MANUAL.
If YOU are a user of the ZILIA website, the COOKIES AND NAVIGATION LOG POLICY available on the website itself also applies.
If YOU, in any way, interact with ZILIA because you are a representative of a Business Partner, and need to access and use any tool, application or software made available by ZILIA to perform your activities on behalf of the Business Partner, the respective policies and terms of consent will also apply in a complementary manner.
ZILIA decided to draft this Policy in the simplest and most accessible way possible, using examples so that YOU can have a pleasant reading experience and understand how your Data is Processed. If YOU have any questions about how ZILIA processes your Data or about this Policy, please contact ZILIA’s Data Protection Officer, Daniela Borges, by email at dpo.brasil@ziliatech.com.
IV. WHICH PERSONAL DATA IS PROCESSED BY ZILIA?
Depending on the purpose, ZILIA may process different Personal Data, the most common being: i) name, ii) email address, iii) telephone number, iv) position and company you represent, and v) business address.
It is also possible that, depending on the purpose, other Data may be processed, such as nationality, personal and/or professional documents number, marital status, health data, vehicle license plate, financial data, and credit bureau scores. ZILIA may also process Personal Data automatically when YOU access its website, applications, or other web tools, such as device and browser information, Internet Protocol (IP, with date, time, and origin).
V. HOW AND WHY ZILIA PROCESSES YOUR PERSONAL DATA
In order for ZILIA to ensure the excellent and high-quality supply of its products and services to the market, it is necessary to process different types of Data about YOU.
ZILIA may process your Data: i) when in preliminary negotiations to supply its products and/or provide its services to a potential client with whom YOU have a direct and necessary relationship in such negotiations; ii) when supplying its products and/or providing services to a client whom YOU represent or, in some way, have a direct relationship with the business under discussion; iii) when you intend to have, or are in, a business relationship with a Business Partner whom YOU represent or who, in some way, has a direct relationship with the business in question; iv) to comply with applicable legislation; iv) to fulfill a contract/commitment entered into with YOU or with a client/Business Partner whom YOU represent; v) when YOU are voluntarily interacting with ZILIA through any of its digital channels (e.g., LinkedIn, Facebook, website, WhatsApp, Business Partner platforms); vi) when YOU voluntarily provide your Personal Data or such data is publicly available.
To ensure transparency with YOU, ZILIA has listed below some of the legitimate purposes and their respective legal bases that justify the Processing of your Personal Data.
|
PURPOSE
|
LAWFULNESS OF PROCESSING
|
|---|---|
|
Managing the contract with YOU or with a client or Business Partner YOU represent.
|
It is necessary to execute the contract involving YOU, a client, or a Business Partner that YOU represent.
|
|
Relationship with a customer or Business Partner.
|
Processing is needed to perform the contract with the customer or Business Partner. Depending on the case, ZILIA may act as a data controller or data processor.
|
|
Recruitment
|
ZILIA has legitimate interest in recruiting suitable candidates who meet company requirements. The Personal Data collected is also needed to prepare a future employment contract with the selected candidate.
|
|
Facilitating communication with YOU (including emergencies and providing YOU the requested information).
|
ZILIA has a legitimate interest in maintaining clear communication and effectively managing emergency situations.
|
|
Operating and managing ZILIA's business.
|
ZILIA has a legitimate interest in ensuring its operations run properly, meeting contracts, legal obligations, and certification requirements.
|
|
Complying with legal requirements or government orders.
|
Processing is necessary to comply with laws, regulations, or valid orders issued by government authorities.
|
|
Monitoring your use of our systems (websites, programs, applications and tools).
|
ZILIA has legitimate interest in preventing non-compliance, protecting its reputation, and ensuring the security of its business and employees.
|
|
Internal processes and procedures
|
Processing helps prevent fraud and ensure security for YOU. It is also supported by ZILIA's legitimate interest in business continuity, and by legal requirements in some cases.
|
|
Defending ZILIA's rights
|
Processing is necessary for ZILIA to exercise its rights in judicial, administrative, or arbitration proceedings.
|
VI. SHARING PERSONAL DATA WITH THIRD PARTIES
ZILIA does not share, sell, or transfer your Personal Data to any company or individual, except when necessary to achieve the purposes indicated in item V and, especially, to comply with its legal obligations. The use of the data will be limited to business purposes and its use restricted to the Interested Parties responsible for delivering the contracted services and products.
The Data may be processed both, inside and outside Brazil. Whenever the Data is transferred to a location abroad or to other companies in the ZILIA group, the transfer will follow all applicable legal and regulatory requirements, as well as the company’s internal rules, ensuring the highest level of care and confidentiality. However, because of the nature of the internet, it is not possible to fully guarantee that malicious third parties will never improperly access the information stored by ZILIA. If this happens, ZILIA will promptly adopt the necessary technical and legal actions, including notifying the ANPD (Brazilian National Data Protection Authority) and/or the Data Subjects, when required.
Therefore, ZILIA may share your data with:
Public authorities or other companies belonging to the business group to which ZILIA belongs, only and to the exact extent necessary;
Business Partners who carry out operations for ZILIA and who are involved in the processing of Personal Data, such as: digital signature platforms, recruitment platforms, operational and communication applications. To protect ZILIA, Business Partners must commit to protecting the Data shared with them, regardless of their position as controller or processor of Personal Data.
ZILIA adopts technical measures to protect Personal Data, among which the following stand out:
Access limitation to Data by defining the responsibilities of who will have access and giving minimum permissionsthey need;
The useof authentication mechanisms to control access to records;
Establishing a password policy that requires strong passwords, regular passwords changes, prevents reuse of old passwords, and blocks access after repeated failed attemps;
Monitoring all environments where Data is processed, keeping a detailed log of access to connectionsand applications;
• Using record management tools that protect Data integrity, such as encryption;
• Using security measures to protect stored Data;
• Implementing secure methods to permanently delete Data, making recovery impossible.
VII. STORAGE AND DELETION
Data will be stored for the minimum time necessary, in line with legal and regulatory requirements.
Data will be permanently deleted within the period determined by ZILIA, as long as legal and regulatory requirements are followed and, in general, data will be kept only as needed to protect the company’s rights.
To decide how long Personal Data should be retained, ZILIA considers the amount, nature, and sensitivity of the Personal Data, the potential risks of possible security incidents; the purpose for which the Personal Data is processed and whether that purpose can be achieved in another way, and the legal requirements that apply.
VIII. WHAT ARE YOUR RIGHTS UNDER THE LGPD (Brazilian General Data Protection Law)?
YOU have several rights related to privacy and the protection of your Data, and ZILIA is committed not only to keeping your data secure but also to ensuring that YOU understand and can exercise these rights.
Below is a simplified summary of the main rights that YOU have when interacting with ZILIA:
• Access to your Data
You can request confirmation that ZILIA is processing your Personal Data and receive a copy of the Data we hold about you.
• Correction
At any time, while ZILIA processes your Data, you can request the correction of your Personal Data if you find incorrect or incomplete information. However, ZILIA may need to verify the new information before updating it.
• Deletion
You can request the deletion of your Data from our systems. All processed Data will be deleted from our internal system environments when you request it or when it is no longer necessary, unless there is any other reason to keep it, such as a possible legal obligation to retain Data or the need to preserve it to safeguard ZILIA’s rights.
• Objection to processing
You also have the right to object to where and how ZILIA is processing your Personal Data for different purposes. In certain situations, ZILIA may demonstrate that it has legitimate reasons to continue processing your Data, which may override your request.
• Anonymization, blocking, or deletion of unnecessary Data
YOU can request that ZILIA stop processing your Personal Data or request that it be anonymized. As with objections, ZILIA will also evaluate your request and, may deny it when there is a legal basis to do so.
Identity Verification
ZILIA may request additional information to confirm your identity before allowing access to your Personal Data. This security measure ensures your information is not shared with unauthorized third parties.
If you have any questions about these issues and how YOU can exercise these rights, feel free to contact us directly by email at dpo.brasil@ziliatech.com.
IX. CHANGES TO THE PRIVACY POLICY.
This Policy may undergo updates and revisions so that ZILIA can always adapt to the best standards of Privacy and Personal Data Protection. Therefore, ZILIA may, at any time, include, modify or delete provisions contained in this Policy, without prior notice and by publishing the updated version on its website or other available means.
X. APPLICABLE LAW AND JURISDICTION
This Policy shall be governed, interpreted and executed in accordance with the laws of the Federative Republic of Brazil, regardless of any conflict of these laws with the laws of other States or countries, and the Court of the District of Atibaia/SP shall have exclusive jurisdiction to resolve any dispute arising from this instrument.
XI. CONTACT
If you have any questions, comments or complaints about this Policy, you can contact ZILIA’s data protection officer, Daniela Borges, directly by email: dpo.brasil@ziliatech.com.
PRIVACY AND PERSONAL DATA PROTECTION POLICY
I. INTRODUCTION
The companies Zilia Technologies Indústria de Componentes Semicondutores Ltda., a private legal entity registered with the CNPJ under number 06.103.827/0001-07, and Zilia Technologies Indústria e Comércio de Componentes Eletrônicos Ltda., a private legal entity registered with the CNPJ under number 11.576.445/00001-30, are committed to protect privacy and personal data of all stakeholders, including their customers, suppliers, service providers, business partners, and employees.
From now on, for a better understanding of the terms of this Policy, the companies will be referred as ZILIA.
Privacy and protection of the stakeholders personal data is very important to ZILIA. To achieve this goal, this Policy, in a simple, transparent and objective manner, clarifies and describes how ZILIA collects, uses, transfers, stores and protects the stakeholders personal data.
II. DEFINITIONS
For the purposes of this Policy, the following definitions shall apply, in accordance with the provisions of the Brazilian General Data Protection Law (“LGPD”) nº 13.709/2018:
a. Anonymization or anonymized data: the use of reasonable and available technique when Processing, ensuring Data loses the possibility to identify an individual directly or indirectly;
b. Personal Data(s) or Data(s): information relating to an identified or identifiable natural person and, where applicable, may include Sensitive Personal Data, which refers to 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, when linked to a natural person;
c. Interested Parties: means clients, Business Partners, employees or any other Data Subjects who have any connection with ZILIA;
d. Business Partner(s): means agents, contracted companies, suppliers, partners, joint ventures or similar entities/persons, distributors, manufacturers, sales representatives, consultants, intermediaries or any third parties who act or will act for or on behalf of ZILIA;
e. Data Subject(s): natural person whose personal data is under Processing;
f. Processing: any operation performed on the Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Any terms used hereafter that have not been specifically defined will be interpreted in accordance with the LGPD (Brazilian General Data Protection Law), as well as those whose definition the LGPD may modify or update, or that have been or may be interpreted and clarified by the National Authority for Personal Data Protection (“ANDP”).
III. APPLICATION
If you are a Data Subject who interacts in any way with ZILIA as an Interested Party or Business Partner, or if you use our website ziliatech.com, this Privacy Policy applies to you (“YOU”).
It is important to clarify that if YOU are an employee of ZILIA, in addition to this Policy, the other internal policies of ZILIA apply to the Processing of your Personal Data, especially the EMPLOYEE MANUAL. Therefore, if you do not find the information you are looking for in this Policy, please check the EMPLOYEE MANUAL.
If YOU are a user of the ZILIA website, the COOKIES AND NAVIGATION LOG POLICY available on the website itself also applies.
If YOU, in any way, interact with ZILIA because you are a representative of a Business Partner, and need to access and use any tool, application or software made available by ZILIA to perform your activities on behalf of the Business Partner, the respective policies and terms of consent will also apply in a complementary manner.
ZILIA decided to draft this Policy in the simplest and most accessible way possible, using examples so that YOU can have a pleasant reading experience and understand how your Data is Processed. If YOU have any questions about how ZILIA processes your Data or about this Policy, please contact ZILIA’s Data Protection Officer, Daniela Borges, by email at dpo.brasil@ziliatech.com.
IV. WHICH PERSONAL DATA IS PROCESSED BY ZILIA?
Depending on the purpose, ZILIA may process different Personal Data, the most common being: i) name, ii) email address, iii) telephone number, iv) position and company you represent, and v) business address.
It is also possible that, depending on the purpose, other Data may be processed, such as nationality, personal and/or professional documents number, marital status, health data, vehicle license plate, financial data, and credit bureau scores. ZILIA may also process Personal Data automatically when YOU access its website, applications, or other web tools, such as device and browser information, Internet Protocol (IP, with date, time, and origin).
V. HOW AND WHY ZILIA PROCESSES YOUR PERSONAL DATA
In order for ZILIA to ensure the excellent and high-quality supply of its products and services to the market, it is necessary to process different types of Data about YOU.
ZILIA may process your Data: i) when in preliminary negotiations to supply its products and/or provide its services to a potential client with whom YOU have a direct and necessary relationship in such negotiations; ii) when supplying its products and/or providing services to a client whom YOU represent or, in some way, have a direct relationship with the business under discussion; iii) when you intend to have, or are in, a business relationship with a Business Partner whom YOU represent or who, in some way, has a direct relationship with the business in question; iv) to comply with applicable legislation; iv) to fulfill a contract/commitment entered into with YOU or with a client/Business Partner whom YOU represent; v) when YOU are voluntarily interacting with ZILIA through any of its digital channels (e.g., LinkedIn, Facebook, website, WhatsApp, Business Partner platforms); vi) when YOU voluntarily provide your Personal Data or such data is publicly available.
To ensure transparency with YOU, ZILIA has listed below some of the legitimate purposes and their respective legal bases that justify the Processing of your Personal Data.
|
PURPOSE
|
LAWFULNESS OF PROCESSING
|
|---|---|
|
Managing the contract with YOU or with a client or Business Partner YOU represent.
|
It is necessary to execute the contract involving YOU, a client, or a Business Partner that YOU represent.
|
|
Relationship with a customer or Business Partner.
|
Processing is needed to perform the contract with the customer or Business Partner. Depending on the case, ZILIA may act as a data controller or data processor.
|
|
Recruitment
|
ZILIA has legitimate interest in recruiting suitable candidates who meet company requirements. The Personal Data collected is also needed to prepare a future employment contract with the selected candidate.
|
|
Facilitating communication with YOU (including emergencies and providing YOU the requested information).
|
ZILIA has a legitimate interest in maintaining clear communication and effectively managing emergency situations.
|
|
Operating and managing ZILIA's business.
|
ZILIA has a legitimate interest in ensuring its operations run properly, meeting contracts, legal obligations, and certification requirements.
|
|
Complying with legal requirements or government orders.
|
Processing is necessary to comply with laws, regulations, or valid orders issued by government authorities.
|
|
Monitoring your use of our systems (websites, programs, applications and tools).
|
ZILIA has legitimate interest in preventing non-compliance, protecting its reputation, and ensuring the security of its business and employees.
|
|
Internal processes and procedures
|
Processing helps prevent fraud and ensure security for YOU. It is also supported by ZILIA's legitimate interest in business continuity, and by legal requirements in some cases.
|
|
Defending ZILIA's rights
|
Processing is necessary for ZILIA to exercise its rights in judicial, administrative, or arbitration proceedings.
|
VI. SHARING PERSONAL DATA WITH THIRD PARTIES
ZILIA does not share, sell, or transfer your Personal Data to any company or individual, except when necessary to achieve the purposes indicated in item V and, especially, to comply with its legal obligations. The use of the data will be limited to business purposes and its use restricted to the Interested Parties responsible for delivering the contracted services and products.
The Data may be processed both, inside and outside Brazil. Whenever the Data is transferred to a location abroad or to other companies in the ZILIA group, the transfer will follow all applicable legal and regulatory requirements, as well as the company’s internal rules, ensuring the highest level of care and confidentiality. However, because of the nature of the internet, it is not possible to fully guarantee that malicious third parties will never improperly access the information stored by ZILIA. If this happens, ZILIA will promptly adopt the necessary technical and legal actions, including notifying the ANPD (Brazilian National Data Protection Authority) and/or the Data Subjects, when required.
Therefore, ZILIA may share your data with:
Public authorities or other companies belonging to the business group to which ZILIA belongs, only and to the exact extent necessary;
Business Partners who carry out operations for ZILIA and who are involved in the processing of Personal Data, such as: digital signature platforms, recruitment platforms, operational and communication applications. To protect ZILIA, Business Partners must commit to protecting the Data shared with them, regardless of their position as controller or processor of Personal Data.
ZILIA adopts technical measures to protect Personal Data, among which the following stand out:
Access limitation to Data by defining the responsibilities of who will have access and giving minimum permissionsthey need;
The useof authentication mechanisms to control access to records;
Establishing a password policy that requires strong passwords, regular passwords changes, prevents reuse of old passwords, and blocks access after repeated failed attemps;
Monitoring all environments where Data is processed, keeping a detailed log of access to connectionsand applications;
• Using record management tools that protect Data integrity, such as encryption;
• Using security measures to protect stored Data;
• Implementing secure methods to permanently delete Data, making recovery impossible.
VII. STORAGE AND DELETION
Data will be stored for the minimum time necessary, in line with legal and regulatory requirements.
Data will be permanently deleted within the period determined by ZILIA, as long as legal and regulatory requirements are followed and, in general, data will be kept only as needed to protect the company’s rights.
To decide how long Personal Data should be retained, ZILIA considers the amount, nature, and sensitivity of the Personal Data, the potential risks of possible security incidents; the purpose for which the Personal Data is processed and whether that purpose can be achieved in another way, and the legal requirements that apply.
VIII. WHAT ARE YOUR RIGHTS UNDER THE LGPD (Brazilian General Data Protection Law)?
YOU have several rights related to privacy and the protection of your Data, and ZILIA is committed not only to keeping your data secure but also to ensuring that YOU understand and can exercise these rights.
Below is a simplified summary of the main rights that YOU have when interacting with ZILIA:
• Access to your Data
You can request confirmation that ZILIA is processing your Personal Data and receive a copy of the Data we hold about you.
• Correction
At any time, while ZILIA processes your Data, you can request the correction of your Personal Data if you find incorrect or incomplete information. However, ZILIA may need to verify the new information before updating it.
• Deletion
You can request the deletion of your Data from our systems. All processed Data will be deleted from our internal system environments when you request it or when it is no longer necessary, unless there is any other reason to keep it, such as a possible legal obligation to retain Data or the need to preserve it to safeguard ZILIA’s rights.
• Objection to processing
You also have the right to object to where and how ZILIA is processing your Personal Data for different purposes. In certain situations, ZILIA may demonstrate that it has legitimate reasons to continue processing your Data, which may override your request.
• Anonymization, blocking, or deletion of unnecessary Data
YOU can request that ZILIA stop processing your Personal Data or request that it be anonymized. As with objections, ZILIA will also evaluate your request and, may deny it when there is a legal basis to do so.
Identity Verification
ZILIA may request additional information to confirm your identity before allowing access to your Personal Data. This security measure ensures your information is not shared with unauthorized third parties.
If you have any questions about these issues and how YOU can exercise these rights, feel free to contact us directly by email at dpo.brasil@ziliatech.com.
IX. CHANGES TO THE PRIVACY POLICY.
This Policy may undergo updates and revisions so that ZILIA can always adapt to the best standards of Privacy and Personal Data Protection. Therefore, ZILIA may, at any time, include, modify or delete provisions contained in this Policy, without prior notice and by publishing the updated version on its website or other available means.
X. APPLICABLE LAW AND JURISDICTION
This Policy shall be governed, interpreted and executed in accordance with the laws of the Federative Republic of Brazil, regardless of any conflict of these laws with the laws of other States or countries, and the Court of the District of Atibaia/SP shall have exclusive jurisdiction to resolve any dispute arising from this instrument.
XI. CONTACT
If you have any questions, comments or complaints about this Policy, you can contact ZILIA’s data protection officer, Daniela Borges, directly by email: dpo.brasil@ziliatech.com.
