Corporate
Privacy Policy
This policy applies to all users of airport complexes managed by Aena Brasil, as well as users of our corporate website. Check out.
What is the objective of this Policy?
The purpose of this Policy is to inform you about the processing of your personal data, in accordance with the applicable legislation on privacy and data protection, including, but not limited to, the Federal Constitution, the Consumer Protection Code, the Civil Code, the European Data Protection Laws and Regulations, whenever applicable, the Civil Rights Framework for the Internet (Federal Law No. 12,965/14) and its regulatory decree (Decree No. 8,771/16), the General Data Protection Law Data (Law No. 13,709/18) and other sectoral norms or rules on the subject.
Who is the controller of personal data in the context of this Policy?
For the purposes of this Policy, AEROPORTOS DO NORDESTE DO BRASIL S/A (“AENA Brasil”), headquartered at Rua Barão de Souza Leão, 425, 19th floor, room 1901, Boa Viagem, Recife/PE, CEP 51.030-300, registered with CNPJ nº 33.919.741/0001-20, is accountable for decisions regarding the processing of personal data.
As controller, Aena Brasil is responsible for ensuring the security, privacy, and protection of personal data, and for adopting effective measures capable of proving compliance with and personal data protection rules and even the effectiveness of these measures as set out in this Policy. Aena Brasil is also responsible for guiding its employees and contractors who appear as operators regarding the practices to be adopted in relation to the protection of personal data.
As controller, Aena Brasil is responsible for ensuring the security, privacy, and protection of personal data, and for adopting effective measures capable of proving compliance with and personal data protection rules and even the effectiveness of these measures as set out in this Policy. Aena Brasil is also responsible for guiding its employees and contractors who appear as operators regarding the practices to be adopted in relation to the protection of personal data.
How does this Policy affect me if I am a user of airports managed by Aena Brasil?
Since 2020, Aena Brasil has been responsible for managing the airports of Campina Grande-Presidente João Suassuna, Juazeiro do Norte-Orlando Bezerra de Menezes, Maceió Zumbi dos Palmares, Aracaju-Santa Maria, João Pessoa-Presidente Castro Pinto, and from Recife/Guararapes-Gilberto Freyre.
If you are a user of any of these airport complexes, your personal data may be processed for specific purposes, as informed in the following topics.
If you are a user of any of these airport complexes, your personal data may be processed for specific purposes, as informed in the following topics.
What categories of personal data can be processed?
The following categories of personal data may be processed:
• Registration data (e.g., first name, last name, e-mail, address, RG, CPF);
• Professional life (e.g., curriculum, training, position);
• Personal life (e.g., parentage);
• Economic and financial data (e.g., related to means of payment);
• Location data (e.g., your flight details);
• Monitoring images (e.g., image, recording, voice);
• Data from loyalty cards with companies;
• Data related to complaints made; and/or
• Health data (e.g., tickets at airport medical stations, care for people with reduced mobility).
Remember that, occasionally, for the correct provision of the service, execution of the contract to which you are a party, compliance with a legal or regulatory obligation and/or in other cases in which the applicable legislation authorizes or requires, in addition to these categories, others may treated, under penalty of the respective service or contract not being able to be performed or signed, Aena Brasil not being able to comply with its legal and regulatory obligations or legitimate interests or regularly exercise its rights.
• Registration data (e.g., first name, last name, e-mail, address, RG, CPF);
• Professional life (e.g., curriculum, training, position);
• Personal life (e.g., parentage);
• Economic and financial data (e.g., related to means of payment);
• Location data (e.g., your flight details);
• Monitoring images (e.g., image, recording, voice);
• Data from loyalty cards with companies;
• Data related to complaints made; and/or
• Health data (e.g., tickets at airport medical stations, care for people with reduced mobility).
Remember that, occasionally, for the correct provision of the service, execution of the contract to which you are a party, compliance with a legal or regulatory obligation and/or in other cases in which the applicable legislation authorizes or requires, in addition to these categories, others may treated, under penalty of the respective service or contract not being able to be performed or signed, Aena Brasil not being able to comply with its legal and regulatory obligations or legitimate interests or regularly exercise its rights.
For what purposes do we process your personal data?
The personal data that you provide us directly or indirectly, at the beginning of your relationship with us or at a later time, and those that may be collected or generated during such relationship, will be treated for the purposes indicated below and, eventually, in newsletters, forms or by any other means that is made available to you, always in a clear, precise and easily accessible way.
In any case, Aena Brasil considers that the privacy and protection of personal data is extremely important and, for this reason, ensures that your personal data will only be collected and processed for legitimate, specific, explicit and previously informed purposes.
• Video surveillance: to guarantee the control, surveillance and security of airport operations, the protection of life or the physical safety of people and the protection of assets found in airport complexes, at our airports, your image may be captured by the video surveillance systems security monitoring through cameras, can also be treated with the purpose of promoting the security of the place.
Legal base: The processing of this personal data will be carried out to enable compliance with legal and regulatory obligations that fall on Aena Brasil (e.g., airport and operational security standards), to protect the life or physical safety of third parties or you and/or to serve our and/or your legitimate interests (e.g., ensuring the security of airport complexes).
Retention time: These data are kept for a maximum period of ninety days from their capture, unless otherwise determined by the competent authorities, legislation or applicable regulations, or if their storage for a longer period is necessary to legally protect Aena Brasil.
Sharing: This data may be shared with companies belonging to the Aena Group, as well as with service providers or partners, if authorized or required by applicable law and respecting legal limits. In addition, such information may also be shared with the competent authorities, including, but not limited to, public bodies, police authorities and/or armed forces, including to prevent real and serious dangers to public safety or for the repression of infractions. criminal offenses, as well as in other events provided for in the applicable legislation or regulation and/or in this Policy.
• Management and response to demands received through the different user service channels made available by Aena Brasil (e.g., User Service Center, Ombudsman Channel), should you decide to contact us to forward your questions, complaints, suggestions or demands, including to request information related to the protection of personal data.
Legal base: The processing of this personal data will be carried out to enable the fulfillment of the contracts signed with you and/or the applicable laws and regulations, to serve our and/or your legitimate interests or, even, with your consent, depending on the case. In this last hypothesis, you declare, from now on, to be aware that you may revoke the consent granted at any time, sending an email to privacidade@aenabrasil.com.br, indicating "Consent Revocation" + Type of Request + Airport, accompanying information that proves your identity.
Retention time: The data will be kept for the period necessary to achieve the specific purpose pursued, as well as for the period necessary to legally protect Aena Brasil, unless otherwise determined by the competent authorities, legislation or applicable regulations.
Sharing: This data may be shared with companies belonging to the Aena Group, as well as with service providers or partners, if authorized or required by applicable law and respecting legal limits. In addition, such information may also be shared with the competent authorities, including, but not limited to, public bodies, police authorities and/or armed forces, including to prevent real and serious dangers to public safety or for the repression of infractions. criminal offenses, as well as in other events provided for in the applicable legislation or regulation and/or in this Policy.
• If you are a public agent and/or public authority (“Authority”), your data will be processed for the management and control of services provided to public bodies to which you are linked, such as visits and rooms management, registration and maintenance of institutional contacts.
Legal basis: Compliance with legal and regulatory obligations.
Retention time: These data will be stored throughout your relationship with Aena Brasil, as well as during the period necessary to legally protect Aena Brasil, unless otherwise determined by the competent authorities, legislation or regulations.
applicable.
Sharing: This data may be communicated, if applicable, to the related airline, public security forces to comply with legal obligations and in other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Management of airport users: follow-up of visits made to airports and/or operations centers, temporary accreditation for visitors for different reasons (e.g., for operational or professional reasons), access control and security of airport facilities.
Legal basis: Compliance with legal and/or regulatory obligations (e.g., safety standards), protection of the life or physical safety of third parties or yours and/or in your and our legitimate interests (e.g., public interest in ensuring airport security).
Retention time: The data will be stored during accreditation and for a period of 5 (five) years, as well as during the period necessary to legally protect Aena Brasil.
Sharing: Your data may be communicated to public security forces in compliance with legal obligations, as well as in other cases in the applicable legislation or regulation and/or in this Policy.
• Management of requests for services directed at People with Reduced Mobility (PMR), as well as carrying out research to improve such services. The services are provided upon request at the properly identified airport points, or upon prior reservation through the Aena Brasil website or your airline. Your data may be communicated to Aena Brasil by airlines, if you made the reservation through the website of such company, or by other airport management companies, if your flight departed from an airport that is not managed by Aena Brasil. In this situation, in addition to identification, contact and flight number data, your health data will be processed (i.e., type of special need).
Legal base: These personal data will be processed for the correct performance of the contract signed with you, for compliance with legal and/or regulatory obligations, as well as to meet our legitimate interests in promoting activities and providing services that benefit you (except in the case of personal data sensitive, in which case this legal basis does not apply).
Retention time: Your data will be kept for the time necessary to meet the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing: No transfers of such data are foreseen, except those foreseen in the applicable legislation or regulation and/or in this Policy.
• Recording of phone calls, when appropriate, for certain sectors (e.g., operational, incident investigation, emergencies).
Legal basis: Depending on the type of call made, the data may be processed for the fulfillment of a legal or regulatory obligation, execution of a contract to which you are a party, protection of the life or physical safety of third parties or yours, fulfillment of our or your legitimate interests or , as appropriate, based on your consent.
Retention time: The period of conservation of the recordings will be necessary to achieve the specific purpose sought, which will vary according to the situation. In any case, it should be noted that when they are stored for evaluation of possible liabilities that may arise, they will only be made available to the competent authorities.
Sharing: No sharing or international transfers are foreseen, except those provided for in the applicable legislation or regulation and/or in this Policy.
• Security inspection, access to the boarding area and, if applicable, registration of occurrences. Under the terms of the regulations of the National Civil Aviation Agency (“ANAC”), to access airport departure lounges, you must present your boarding pass and documents and then go through the security inspection channels. Depending on the situation and in compliance with the applicable legislation, other procedures may be adopted and/or these procedures may be changed. In addition, Aena Brasil must record any incidents that deviate from the norm during such procedures.
Legal base: The purpose of processing your personal data is to comply with applicable legislation and/or regulations, including, but not limited to, those prepared by ANAC. In case you have contracted the “Fast Lane” service, which guarantees greater agility in the security inspection processes and access to the boarding area, eventually offered by any of the airports managed by Aena Brasil, your personal data will also be processed for the fulfillment of the contract to which you are a party.
Retention time: Your data will be kept for the time necessary to meet the specific purpose sought, to comply with applicable legislation or regulations, as well as for the period necessary to legally protect Aena Brasil.
Sharing: The data will be communicated to the airline, in order to expedite boarding for the scheduled flight and to verify the authenticity of the identification document, as well as to public security forces, with the aim of preventing a real and serious danger to public security or for the repression of criminal offenses, and in the other hypotheses provided for in the applicable legislation or regulation and/or in this Policy. In the case of Fast Lane, your data will be transferred to the airline for control purposes and, when applicable, for the airline to invoice you for the service provided, to execute the contract to which you are a party.
• Management of airport medical services, provided directly by Aena Brasil or by any contracted service provider, with a view to providing first aid services (i.e., emergency primary care and emergency medical transfer) and any other mandatory medical services in the airports’ complexes, under the terms of sectoral regulations, which may include, in this case, the processing of sensitive personal data related to health.
Legal base. Your data will be processed to comply with the applicable legislation and regulations, to protect the life or physical safety of third parties or yourself, to protect your health in a procedure carried out by health professionals, and/or based on your and/or our legitimate interest.
Retention time. Your data will be kept for the time necessary to achieve the specific purpose pursued, to determine the possible responsibilities that may arise therefrom, to comply with applicable regulations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Your data may be communicated to hospitals or other medical centers if necessary to achieve the purposes mentioned here. In any other case, no data will be communicated, except for legal or regulatory obligation, judicial requirement or the competent authorities and in the other cases provided for in this Policy.
• Legal defense and legal advice, in cases where you are an integral part of a process in which Aena Brasil and/or any of the companies belonging to the Aena Group have interests involved.
Legal base. Compliance with legal or regulatory obligations and/or regular exercise of rights in contracts and in judicial, administrative or arbitration proceedings.
Retention time. Your data will be kept for the time necessary to meet the specific purpose sought, to comply with applicable legislation or regulations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with companies belonging to the Aena Group, with service providers or partners, if authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Lost and found: in the event that you find a lost object, or if you are the owner of it, your identification and contact data and the documentation proving ownership of the object will be treated to enable the management of lost and found objects, the custody control in warehouse, the registration of entry and exit and returns and the identification of locators and applicants of lost objects.
Legal base. Compliance with legal and/or regulatory obligations and serving your and our legitimate interests.
Retention time. The data will be kept for 2 (two) years, unless otherwise determined by the competent authorities, legislation or applicable regulation, or if it is necessary to store it for a longer period to legally protect Aena Brasil.
Sharing. Your data may be communicated to the competent authorities, as determined by the applicable legislation and/or regulations (e.g., if an identity document or passport is found, it will be handed over to the police authorities; in the case of bank cards, your data may be communicated to the bank), as well as in the other hypotheses provided for in the applicable legislation or regulation and/or in this Policy.
• Entry/exit registration and archiving of various documents, to process your requests.
Legal base. Execution of a contract or preliminary procedures related to a contract to which you are a party, as well as to meet your and/or our legitimate interests in supporting and promoting our activities and providing services that benefit you.
Retention time. The data will be kept for the time necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Personal data may be communicated to the entities or individuals to whom the request is addressed, as well as in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Authorization to carry out air activities, if you request it to carry out certain activities in the airport complexes managed by Aena Brasil (e.g., remotely piloted aircraft (drones or RPAS) or other types of air activities), we may process your personal data (data identification and contact details, types of operations and details of the aircraft and operations to be carried out with the aircraft) to generate the authorization along with the entities involved.
Legal base. Compliance with legal and/or regulatory obligations based on the treatment of legal obligations (e.g., aviation safety standards).
Retention time. The data will be kept for the time necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. The data may be communicated to the competent authorities, to those responsible for air traffic services at the airports involved, as well as in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Collection of regulated fees for boarding and/or landing and/or stay related to Group II aircraft, if you request that this charge be made through your own credit/debit card or linked to the company you represent and offer consent for the processing of your personal data (information contained in credit cards, such as full name, expiration date, CVV, etc.). More information about the treatment is available in the Term of Consent for Performing Digital Sales, made available to the applicant/responsible for the authorization.
Legal base. Consent.
Retention time. The data will be kept for the time necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. No data will be transferred to third parties, except to comply with the obligations set forth in the applicable legislation or regulations and provided that the principles and guarantees established therein are respected.
• Free Wi-Fi service from Aena Brasil. To offer the Wi-Fi service at airports, Aena Brasil may obtain personal identification data (e.g., full name), contact (e.g., e-mail and telephone), connection (e.g., MAC address, IP address, IMEI), internet (e.g., cookies) and geolocation that were provided by the user during registration or access to the Wi-Fi portal, use of the service or internet browsing. If the access record is made through a social network, we may use the data provided by such platforms.
Legal base. The user's personal data are processed for the fulfillment of legal and/or regulatory obligations (e.g., Marco Civil da Internet) and for the execution of a contract or preliminary procedures related to a contract to which he is a party (including the contract for the provision of the service of Wi-Fi and the General Conditions of Use). At the same time, and in cases where Aena Brasil has a legitimate interest in supporting and promoting its activities or providing services that benefit the user, or if the user explicitly declares his consent by checking the aforementioned acceptance option on the Wi-Fi portal, Aena Brasil may also use the information provided during registration and/or obtained during navigation and geolocation to provide the user with a personalized experience, by electronically sending commercial and advertising communications, such as newsletters with information of interest to the user, promotions and coupons discount for products and services made available by Aena Brasil or third parties in the following areas or sectors: automobile and vehicle rental, leisure, travel agencies, tourism, transportation, airlines, restaurants, textiles, fashion, beauty and cosmetics, finance and insurance, press and magazines, games, betting.
Aena Brasil informs, from now on, that the user may revoke their consent at any time, simply by sending an email to privacidade@aenabrasil.com.br indicating in the subject “Revocation of Consent for the WiFi Portal”. If the user requests the revocation and/or cancellation of the sending of commercial and advertising communications and/or electronically indicated information, Aena Brasil informs that it will process the data associated with the device and the data of the user's registration credentials to enable the processing of the cancellation request.
The withdrawal of such consent will not make the use of the WiFi service unfeasible, but only the electronic sending of communications and/or commercial and advertising information indicated above and the prospective offer of products and services for commercial, advertising, informational, statistical and segmentation purposes.
Retention time. The data will be kept for the time necessary to achieve the specific purpose for which it was collected, as well as for the period established in the applicable legislation and/or regulations. The information will also be kept for the period necessary to legally protect Aena Brasil.
Sharing. No data will be transferred to third parties, except for the fulfillment of the obligations provided for in the applicable legislation or regulations, for the development of any activities of Aena Brasil, for the provision of the Wi-Fi service and in the other cases provided for in the applicable legislation or regulations and/ or in this Policy.
• Beneficiaries of Aena Brasil employees. If you are designated as a beneficiary of life and accident insurance or any other benefits by an employee of Aena Brasil, we inform you that we will process your personal data to enable your inclusion in such benefits (e.g., in the case of life insurance, to enable insurance management and communication to the insurance broker).
Legal base. Compliance with legal and regulatory obligations, for the execution of a contract or preliminary procedures to which the employee is a party and/or to meet our and your legitimate interests. When required by applicable law, we will process your personal data with your consent or the consent of at least one of your parents or legal representatives if you are a child or adolescent.
Retention time. Your data will be stored until verification that the purpose has been achieved or that the data is no longer necessary or relevant to achieve the specific purpose sought and may be retained for compliance with legal or regulatory obligations and/or for the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with service providers or partners, if authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Management and response to requests to exercise rights in terms of data protection.
Legal base. Compliance with a legal or regulatory obligation.
Retention time. The data will be stored until they are no longer necessary or relevant to achieve the specific purpose sought, under the terms of the applicable regulations, as well as during the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with companies belonging to the Aena Group, with service providers or partners, if authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
If there is a privacy policy or specific legal notice for a given service or activity, this Policy will apply, where appropriate, on a subsidiary basis.
In any case, Aena Brasil considers that the privacy and protection of personal data is extremely important and, for this reason, ensures that your personal data will only be collected and processed for legitimate, specific, explicit and previously informed purposes.
• Video surveillance: to guarantee the control, surveillance and security of airport operations, the protection of life or the physical safety of people and the protection of assets found in airport complexes, at our airports, your image may be captured by the video surveillance systems security monitoring through cameras, can also be treated with the purpose of promoting the security of the place.
Legal base: The processing of this personal data will be carried out to enable compliance with legal and regulatory obligations that fall on Aena Brasil (e.g., airport and operational security standards), to protect the life or physical safety of third parties or you and/or to serve our and/or your legitimate interests (e.g., ensuring the security of airport complexes).
Retention time: These data are kept for a maximum period of ninety days from their capture, unless otherwise determined by the competent authorities, legislation or applicable regulations, or if their storage for a longer period is necessary to legally protect Aena Brasil.
Sharing: This data may be shared with companies belonging to the Aena Group, as well as with service providers or partners, if authorized or required by applicable law and respecting legal limits. In addition, such information may also be shared with the competent authorities, including, but not limited to, public bodies, police authorities and/or armed forces, including to prevent real and serious dangers to public safety or for the repression of infractions. criminal offenses, as well as in other events provided for in the applicable legislation or regulation and/or in this Policy.
• Management and response to demands received through the different user service channels made available by Aena Brasil (e.g., User Service Center, Ombudsman Channel), should you decide to contact us to forward your questions, complaints, suggestions or demands, including to request information related to the protection of personal data.
Legal base: The processing of this personal data will be carried out to enable the fulfillment of the contracts signed with you and/or the applicable laws and regulations, to serve our and/or your legitimate interests or, even, with your consent, depending on the case. In this last hypothesis, you declare, from now on, to be aware that you may revoke the consent granted at any time, sending an email to privacidade@aenabrasil.com.br, indicating "Consent Revocation" + Type of Request + Airport, accompanying information that proves your identity.
Retention time: The data will be kept for the period necessary to achieve the specific purpose pursued, as well as for the period necessary to legally protect Aena Brasil, unless otherwise determined by the competent authorities, legislation or applicable regulations.
Sharing: This data may be shared with companies belonging to the Aena Group, as well as with service providers or partners, if authorized or required by applicable law and respecting legal limits. In addition, such information may also be shared with the competent authorities, including, but not limited to, public bodies, police authorities and/or armed forces, including to prevent real and serious dangers to public safety or for the repression of infractions. criminal offenses, as well as in other events provided for in the applicable legislation or regulation and/or in this Policy.
• If you are a public agent and/or public authority (“Authority”), your data will be processed for the management and control of services provided to public bodies to which you are linked, such as visits and rooms management, registration and maintenance of institutional contacts.
Legal basis: Compliance with legal and regulatory obligations.
Retention time: These data will be stored throughout your relationship with Aena Brasil, as well as during the period necessary to legally protect Aena Brasil, unless otherwise determined by the competent authorities, legislation or regulations.
applicable.
Sharing: This data may be communicated, if applicable, to the related airline, public security forces to comply with legal obligations and in other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Management of airport users: follow-up of visits made to airports and/or operations centers, temporary accreditation for visitors for different reasons (e.g., for operational or professional reasons), access control and security of airport facilities.
Legal basis: Compliance with legal and/or regulatory obligations (e.g., safety standards), protection of the life or physical safety of third parties or yours and/or in your and our legitimate interests (e.g., public interest in ensuring airport security).
Retention time: The data will be stored during accreditation and for a period of 5 (five) years, as well as during the period necessary to legally protect Aena Brasil.
Sharing: Your data may be communicated to public security forces in compliance with legal obligations, as well as in other cases in the applicable legislation or regulation and/or in this Policy.
• Management of requests for services directed at People with Reduced Mobility (PMR), as well as carrying out research to improve such services. The services are provided upon request at the properly identified airport points, or upon prior reservation through the Aena Brasil website or your airline. Your data may be communicated to Aena Brasil by airlines, if you made the reservation through the website of such company, or by other airport management companies, if your flight departed from an airport that is not managed by Aena Brasil. In this situation, in addition to identification, contact and flight number data, your health data will be processed (i.e., type of special need).
Legal base: These personal data will be processed for the correct performance of the contract signed with you, for compliance with legal and/or regulatory obligations, as well as to meet our legitimate interests in promoting activities and providing services that benefit you (except in the case of personal data sensitive, in which case this legal basis does not apply).
Retention time: Your data will be kept for the time necessary to meet the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing: No transfers of such data are foreseen, except those foreseen in the applicable legislation or regulation and/or in this Policy.
• Recording of phone calls, when appropriate, for certain sectors (e.g., operational, incident investigation, emergencies).
Legal basis: Depending on the type of call made, the data may be processed for the fulfillment of a legal or regulatory obligation, execution of a contract to which you are a party, protection of the life or physical safety of third parties or yours, fulfillment of our or your legitimate interests or , as appropriate, based on your consent.
Retention time: The period of conservation of the recordings will be necessary to achieve the specific purpose sought, which will vary according to the situation. In any case, it should be noted that when they are stored for evaluation of possible liabilities that may arise, they will only be made available to the competent authorities.
Sharing: No sharing or international transfers are foreseen, except those provided for in the applicable legislation or regulation and/or in this Policy.
• Security inspection, access to the boarding area and, if applicable, registration of occurrences. Under the terms of the regulations of the National Civil Aviation Agency (“ANAC”), to access airport departure lounges, you must present your boarding pass and documents and then go through the security inspection channels. Depending on the situation and in compliance with the applicable legislation, other procedures may be adopted and/or these procedures may be changed. In addition, Aena Brasil must record any incidents that deviate from the norm during such procedures.
Legal base: The purpose of processing your personal data is to comply with applicable legislation and/or regulations, including, but not limited to, those prepared by ANAC. In case you have contracted the “Fast Lane” service, which guarantees greater agility in the security inspection processes and access to the boarding area, eventually offered by any of the airports managed by Aena Brasil, your personal data will also be processed for the fulfillment of the contract to which you are a party.
Retention time: Your data will be kept for the time necessary to meet the specific purpose sought, to comply with applicable legislation or regulations, as well as for the period necessary to legally protect Aena Brasil.
Sharing: The data will be communicated to the airline, in order to expedite boarding for the scheduled flight and to verify the authenticity of the identification document, as well as to public security forces, with the aim of preventing a real and serious danger to public security or for the repression of criminal offenses, and in the other hypotheses provided for in the applicable legislation or regulation and/or in this Policy. In the case of Fast Lane, your data will be transferred to the airline for control purposes and, when applicable, for the airline to invoice you for the service provided, to execute the contract to which you are a party.
• Management of airport medical services, provided directly by Aena Brasil or by any contracted service provider, with a view to providing first aid services (i.e., emergency primary care and emergency medical transfer) and any other mandatory medical services in the airports’ complexes, under the terms of sectoral regulations, which may include, in this case, the processing of sensitive personal data related to health.
Legal base. Your data will be processed to comply with the applicable legislation and regulations, to protect the life or physical safety of third parties or yourself, to protect your health in a procedure carried out by health professionals, and/or based on your and/or our legitimate interest.
Retention time. Your data will be kept for the time necessary to achieve the specific purpose pursued, to determine the possible responsibilities that may arise therefrom, to comply with applicable regulations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Your data may be communicated to hospitals or other medical centers if necessary to achieve the purposes mentioned here. In any other case, no data will be communicated, except for legal or regulatory obligation, judicial requirement or the competent authorities and in the other cases provided for in this Policy.
• Legal defense and legal advice, in cases where you are an integral part of a process in which Aena Brasil and/or any of the companies belonging to the Aena Group have interests involved.
Legal base. Compliance with legal or regulatory obligations and/or regular exercise of rights in contracts and in judicial, administrative or arbitration proceedings.
Retention time. Your data will be kept for the time necessary to meet the specific purpose sought, to comply with applicable legislation or regulations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with companies belonging to the Aena Group, with service providers or partners, if authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Lost and found: in the event that you find a lost object, or if you are the owner of it, your identification and contact data and the documentation proving ownership of the object will be treated to enable the management of lost and found objects, the custody control in warehouse, the registration of entry and exit and returns and the identification of locators and applicants of lost objects.
Legal base. Compliance with legal and/or regulatory obligations and serving your and our legitimate interests.
Retention time. The data will be kept for 2 (two) years, unless otherwise determined by the competent authorities, legislation or applicable regulation, or if it is necessary to store it for a longer period to legally protect Aena Brasil.
Sharing. Your data may be communicated to the competent authorities, as determined by the applicable legislation and/or regulations (e.g., if an identity document or passport is found, it will be handed over to the police authorities; in the case of bank cards, your data may be communicated to the bank), as well as in the other hypotheses provided for in the applicable legislation or regulation and/or in this Policy.
• Entry/exit registration and archiving of various documents, to process your requests.
Legal base. Execution of a contract or preliminary procedures related to a contract to which you are a party, as well as to meet your and/or our legitimate interests in supporting and promoting our activities and providing services that benefit you.
Retention time. The data will be kept for the time necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Personal data may be communicated to the entities or individuals to whom the request is addressed, as well as in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Authorization to carry out air activities, if you request it to carry out certain activities in the airport complexes managed by Aena Brasil (e.g., remotely piloted aircraft (drones or RPAS) or other types of air activities), we may process your personal data (data identification and contact details, types of operations and details of the aircraft and operations to be carried out with the aircraft) to generate the authorization along with the entities involved.
Legal base. Compliance with legal and/or regulatory obligations based on the treatment of legal obligations (e.g., aviation safety standards).
Retention time. The data will be kept for the time necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. The data may be communicated to the competent authorities, to those responsible for air traffic services at the airports involved, as well as in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Collection of regulated fees for boarding and/or landing and/or stay related to Group II aircraft, if you request that this charge be made through your own credit/debit card or linked to the company you represent and offer consent for the processing of your personal data (information contained in credit cards, such as full name, expiration date, CVV, etc.). More information about the treatment is available in the Term of Consent for Performing Digital Sales, made available to the applicant/responsible for the authorization.
Legal base. Consent.
Retention time. The data will be kept for the time necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. No data will be transferred to third parties, except to comply with the obligations set forth in the applicable legislation or regulations and provided that the principles and guarantees established therein are respected.
• Free Wi-Fi service from Aena Brasil. To offer the Wi-Fi service at airports, Aena Brasil may obtain personal identification data (e.g., full name), contact (e.g., e-mail and telephone), connection (e.g., MAC address, IP address, IMEI), internet (e.g., cookies) and geolocation that were provided by the user during registration or access to the Wi-Fi portal, use of the service or internet browsing. If the access record is made through a social network, we may use the data provided by such platforms.
Legal base. The user's personal data are processed for the fulfillment of legal and/or regulatory obligations (e.g., Marco Civil da Internet) and for the execution of a contract or preliminary procedures related to a contract to which he is a party (including the contract for the provision of the service of Wi-Fi and the General Conditions of Use). At the same time, and in cases where Aena Brasil has a legitimate interest in supporting and promoting its activities or providing services that benefit the user, or if the user explicitly declares his consent by checking the aforementioned acceptance option on the Wi-Fi portal, Aena Brasil may also use the information provided during registration and/or obtained during navigation and geolocation to provide the user with a personalized experience, by electronically sending commercial and advertising communications, such as newsletters with information of interest to the user, promotions and coupons discount for products and services made available by Aena Brasil or third parties in the following areas or sectors: automobile and vehicle rental, leisure, travel agencies, tourism, transportation, airlines, restaurants, textiles, fashion, beauty and cosmetics, finance and insurance, press and magazines, games, betting.
Aena Brasil informs, from now on, that the user may revoke their consent at any time, simply by sending an email to privacidade@aenabrasil.com.br indicating in the subject “Revocation of Consent for the WiFi Portal”. If the user requests the revocation and/or cancellation of the sending of commercial and advertising communications and/or electronically indicated information, Aena Brasil informs that it will process the data associated with the device and the data of the user's registration credentials to enable the processing of the cancellation request.
The withdrawal of such consent will not make the use of the WiFi service unfeasible, but only the electronic sending of communications and/or commercial and advertising information indicated above and the prospective offer of products and services for commercial, advertising, informational, statistical and segmentation purposes.
Retention time. The data will be kept for the time necessary to achieve the specific purpose for which it was collected, as well as for the period established in the applicable legislation and/or regulations. The information will also be kept for the period necessary to legally protect Aena Brasil.
Sharing. No data will be transferred to third parties, except for the fulfillment of the obligations provided for in the applicable legislation or regulations, for the development of any activities of Aena Brasil, for the provision of the Wi-Fi service and in the other cases provided for in the applicable legislation or regulations and/ or in this Policy.
• Beneficiaries of Aena Brasil employees. If you are designated as a beneficiary of life and accident insurance or any other benefits by an employee of Aena Brasil, we inform you that we will process your personal data to enable your inclusion in such benefits (e.g., in the case of life insurance, to enable insurance management and communication to the insurance broker).
Legal base. Compliance with legal and regulatory obligations, for the execution of a contract or preliminary procedures to which the employee is a party and/or to meet our and your legitimate interests. When required by applicable law, we will process your personal data with your consent or the consent of at least one of your parents or legal representatives if you are a child or adolescent.
Retention time. Your data will be stored until verification that the purpose has been achieved or that the data is no longer necessary or relevant to achieve the specific purpose sought and may be retained for compliance with legal or regulatory obligations and/or for the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with service providers or partners, if authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Management and response to requests to exercise rights in terms of data protection.
Legal base. Compliance with a legal or regulatory obligation.
Retention time. The data will be stored until they are no longer necessary or relevant to achieve the specific purpose sought, under the terms of the applicable regulations, as well as during the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with companies belonging to the Aena Group, with service providers or partners, if authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
If there is a privacy policy or specific legal notice for a given service or activity, this Policy will apply, where appropriate, on a subsidiary basis.
How does this policy affect me if I am a user of the Aena Brasil website?
If you are a user of our website, we inform you that the following data processing activities may be carried out:
• Ombudsman. We will process your personal data to respond to your requests for contacts, services, information, questions, suggestions or complaints, of any nature, sent through the contact means available on the Aena Brasil website, always based on our legitimate interest, for compliance of legal or regulatory obligation, execution of contract and/or consent, depending on the specific case.
• Regarding the Work With Us section, operated through a third-party platform contracted by Aena Brasil, there may be two treatments:
"Talent bank" section: the data collected in the registration (e.g., full name, gender, date of birth, email address, education, professional experience, etc.) will be treated in order to keep you informed of future announcements of job.
Legal base. This treatment is based on your or our legitimate interest and/or on the consent given by you, depending on the specific case. You can cancel this treatment yourself by selecting the “delete my account” option in the “Preferences” section of the platform. Once deleted, your data will be erased, you will no longer be part of the talent pool and you will no longer receive emails. If you have any questions, please contact us at privacidade@aenabrasil.com.br.
Retention time. Once registered as interested, your e-mail will be stored during the period in which you are interested in being part of our talent bank. Once you are no longer interested and decide to delete your account, your data will be deleted from our database, except for those that are necessary to legally protect Aena Brasil. Once this is done, you will have to register again if you wish to participate in future selection processes. Eventually, if you do not take any action within the platform for a long time, we may contact you to find out if you are still interested in keeping your data with us.
Sharing. Your data may be communicated to Aena Group companies and to any recruitment and selection service providers, as well as in the other cases provided for in the applicable legislation or regulation and/or in this Policy. In addition, we hereby inform you that we have hired a platform developed by a third party to assist us with the operation of the “Work with us” section, which has contractually committed to providing strong and sufficient guarantees that it complies with data protection obligations. established in this Policy, in the applicable legislation and in the regulations issued by the competent authorities.
To manage the registrations and the information that you provide us (e.g., identification data, contact, resume, and information provided for the selection process) through the platform contracted by us, related to the selection processes that are being carried out by Aena Brasil.
Legal basis. This treatment is based on your or our legitimate interest and/or your consent, depending on the specific case. You can cancel this treatment by selecting the “delete my account” option in the “Preferences” section of the platform. Once deleted, your data will be erased, you will no longer participate in the selection process(es) and you will no longer receive emails. If you have any questions, please contact us at privacidade@aenabrasil.com.br.
Retention time. Data will be kept throughout the selection process. Once you are no longer interested in participating in the selection process(es) and decide to delete your account, your information will be deleted from our database, except for those that are necessary to legally protect the Aena Brasil. Eventually, if you do not take any action within the platform for a long time, we may contact you to find out if you are still interested in keeping your data with us.
Sharing. Your data relating to your job applications may be communicated to Aena Group companies and to any recruitment and selection service providers, as well as in the other situations provided for in the applicable legislation or regulations and/or in this Policy. In addition, as stated above, we have hired a platform developed by a third party to assist us with the operation of the “Work with Us” section, which has contractually undertaken to provide strong and sufficient guarantees that it complies with the personal data protection obligations established in this Policy, in the applicable legislation and in the regulations issued by the competent authorities.
• Parking Reservation. The management of parking reservations is carried out by a partner company through a sub-concession contract. For more information on how your personal data is treated by this third party, please access the privacy policy available on the sub-concessionaire company's website.
• Surveys on the quality of services provided. From time to time, Aena Brasil may carry out surveys on the quality of services provided.
Legal base. Searches can be carried out based on the legitimate interest of Aena Brasil.
Retention time. The data will be kept for the period necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with companies belonging to the Aena Group and with service providers or partners, as long as authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Prevention Report. This tool is used for the prevention of accidents and aeronautical incidents, in order to increase operational safety. Reports do not need to be identified and, if so, the reporter is subsequently informed about the measures adopted by Aena Brasil to solve risk situations.
Legal base. When you choose to identify yourself, keep in mind that Aena Brasil will process your personal data to comply with a legal or regulatory obligation and/or to meet its legitimate interest in ensuring operational security.
Retention time. Your personal data will be stored for the time necessary to assess the veracity of the reports and, if the case requires, to process the complaint and carry out the necessary investigations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Data sharing is not foreseen, unless necessary to assist criminal investigations (e.g., for judicial and administrative authorities), or in other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Reporting Portal. Aena Brasil's whistleblowing channel was created to enable safe communication of records, anonymously or not, of conduct considered unethical or that violates the principles and norms set forth in current legislation. The information will be handled by the Ethics Committee of Aena Brasil to prevent, detect, and correct violations of the rules in force and policies of the Aena Group or Aena Brasil.
Legal base. When you choose to identify yourself, keep in mind that Aena Brasil will process your personal data to comply with legal or regulatory obligations, for the regular exercise of rights in contracts and judicial, administrative or arbitration proceedings, and to meet your legitimate interests. .
Retention time. Your personal data will be stored for the time necessary to assess the veracity of the reports and, if the case requires, to process the complaint and carry out the necessary investigations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Data sharing is not foreseen, unless necessary to assist criminal investigations (e.g., for judicial and administrative authorities), or in other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Management of social networks. During the management of Aena Brasil's social networks (e.g., LinkedIn, Twitter), we may collect certain information about you, such as identification data from your profile on the social network, comments made, as well as the personal data you provide us for the resolution of the your incident (e.g., full name, phone, email, booking reference, etc.), as well as the content you generate or provide to us through private messages on our social networks.
The information collected on our social networks is used to manage and respond to questions and complaints communicated by you through social networks about the services offered by Aena Brasil, as well as to analyze the messages received and prepare anonymous reports. This helps us to get to know our customers better, what they like and how they react to our services, allowing us to improve our services as a whole.
Legal base. Execution of a contract or preliminary procedures to which you are a party and/or to serve our and your legitimate interests.
Retention time. Your data will be stored until the purpose for which they are intended is fulfilled, as well as during the period necessary to legally protect Aena Brasil. Subsequently, they will be kept properly blocked.
Sharing. Your data may be communicated to companies belonging to the Aena Brasil Group, with service providers, suppliers, partners or sub-concessionaires, in cases where such communication is necessary to fulfill your request or respond to your complaint, as well as in the other hypotheses foreseen. applicable law or regulation and/or this Policy.
• Ombudsman. We will process your personal data to respond to your requests for contacts, services, information, questions, suggestions or complaints, of any nature, sent through the contact means available on the Aena Brasil website, always based on our legitimate interest, for compliance of legal or regulatory obligation, execution of contract and/or consent, depending on the specific case.
• Regarding the Work With Us section, operated through a third-party platform contracted by Aena Brasil, there may be two treatments:
"Talent bank" section: the data collected in the registration (e.g., full name, gender, date of birth, email address, education, professional experience, etc.) will be treated in order to keep you informed of future announcements of job.
Legal base. This treatment is based on your or our legitimate interest and/or on the consent given by you, depending on the specific case. You can cancel this treatment yourself by selecting the “delete my account” option in the “Preferences” section of the platform. Once deleted, your data will be erased, you will no longer be part of the talent pool and you will no longer receive emails. If you have any questions, please contact us at privacidade@aenabrasil.com.br.
Retention time. Once registered as interested, your e-mail will be stored during the period in which you are interested in being part of our talent bank. Once you are no longer interested and decide to delete your account, your data will be deleted from our database, except for those that are necessary to legally protect Aena Brasil. Once this is done, you will have to register again if you wish to participate in future selection processes. Eventually, if you do not take any action within the platform for a long time, we may contact you to find out if you are still interested in keeping your data with us.
Sharing. Your data may be communicated to Aena Group companies and to any recruitment and selection service providers, as well as in the other cases provided for in the applicable legislation or regulation and/or in this Policy. In addition, we hereby inform you that we have hired a platform developed by a third party to assist us with the operation of the “Work with us” section, which has contractually committed to providing strong and sufficient guarantees that it complies with data protection obligations. established in this Policy, in the applicable legislation and in the regulations issued by the competent authorities.
To manage the registrations and the information that you provide us (e.g., identification data, contact, resume, and information provided for the selection process) through the platform contracted by us, related to the selection processes that are being carried out by Aena Brasil.
Legal basis. This treatment is based on your or our legitimate interest and/or your consent, depending on the specific case. You can cancel this treatment by selecting the “delete my account” option in the “Preferences” section of the platform. Once deleted, your data will be erased, you will no longer participate in the selection process(es) and you will no longer receive emails. If you have any questions, please contact us at privacidade@aenabrasil.com.br.
Retention time. Data will be kept throughout the selection process. Once you are no longer interested in participating in the selection process(es) and decide to delete your account, your information will be deleted from our database, except for those that are necessary to legally protect the Aena Brasil. Eventually, if you do not take any action within the platform for a long time, we may contact you to find out if you are still interested in keeping your data with us.
Sharing. Your data relating to your job applications may be communicated to Aena Group companies and to any recruitment and selection service providers, as well as in the other situations provided for in the applicable legislation or regulations and/or in this Policy. In addition, as stated above, we have hired a platform developed by a third party to assist us with the operation of the “Work with Us” section, which has contractually undertaken to provide strong and sufficient guarantees that it complies with the personal data protection obligations established in this Policy, in the applicable legislation and in the regulations issued by the competent authorities.
• Parking Reservation. The management of parking reservations is carried out by a partner company through a sub-concession contract. For more information on how your personal data is treated by this third party, please access the privacy policy available on the sub-concessionaire company's website.
• Surveys on the quality of services provided. From time to time, Aena Brasil may carry out surveys on the quality of services provided.
Legal base. Searches can be carried out based on the legitimate interest of Aena Brasil.
Retention time. The data will be kept for the period necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
Sharing. This data may be shared with companies belonging to the Aena Group and with service providers or partners, as long as authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Prevention Report. This tool is used for the prevention of accidents and aeronautical incidents, in order to increase operational safety. Reports do not need to be identified and, if so, the reporter is subsequently informed about the measures adopted by Aena Brasil to solve risk situations.
Legal base. When you choose to identify yourself, keep in mind that Aena Brasil will process your personal data to comply with a legal or regulatory obligation and/or to meet its legitimate interest in ensuring operational security.
Retention time. Your personal data will be stored for the time necessary to assess the veracity of the reports and, if the case requires, to process the complaint and carry out the necessary investigations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Data sharing is not foreseen, unless necessary to assist criminal investigations (e.g., for judicial and administrative authorities), or in other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Reporting Portal. Aena Brasil's whistleblowing channel was created to enable safe communication of records, anonymously or not, of conduct considered unethical or that violates the principles and norms set forth in current legislation. The information will be handled by the Ethics Committee of Aena Brasil to prevent, detect, and correct violations of the rules in force and policies of the Aena Group or Aena Brasil.
Legal base. When you choose to identify yourself, keep in mind that Aena Brasil will process your personal data to comply with legal or regulatory obligations, for the regular exercise of rights in contracts and judicial, administrative or arbitration proceedings, and to meet your legitimate interests. .
Retention time. Your personal data will be stored for the time necessary to assess the veracity of the reports and, if the case requires, to process the complaint and carry out the necessary investigations, as well as for the period necessary to legally protect Aena Brasil.
Sharing. Data sharing is not foreseen, unless necessary to assist criminal investigations (e.g., for judicial and administrative authorities), or in other cases provided for in the applicable legislation or regulation and/or in this Policy.
• Management of social networks. During the management of Aena Brasil's social networks (e.g., LinkedIn, Twitter), we may collect certain information about you, such as identification data from your profile on the social network, comments made, as well as the personal data you provide us for the resolution of the your incident (e.g., full name, phone, email, booking reference, etc.), as well as the content you generate or provide to us through private messages on our social networks.
The information collected on our social networks is used to manage and respond to questions and complaints communicated by you through social networks about the services offered by Aena Brasil, as well as to analyze the messages received and prepare anonymous reports. This helps us to get to know our customers better, what they like and how they react to our services, allowing us to improve our services as a whole.
Legal base. Execution of a contract or preliminary procedures to which you are a party and/or to serve our and your legitimate interests.
Retention time. Your data will be stored until the purpose for which they are intended is fulfilled, as well as during the period necessary to legally protect Aena Brasil. Subsequently, they will be kept properly blocked.
Sharing. Your data may be communicated to companies belonging to the Aena Brasil Group, with service providers, suppliers, partners or sub-concessionaires, in cases where such communication is necessary to fulfill your request or respond to your complaint, as well as in the other hypotheses foreseen. applicable law or regulation and/or this Policy.
How does this Policy affect me if I am an employee of a company that works at the airport, or work for a company that provides services to Aena Brasil?
If you are an employee of an external company, please consult the specific privacy policy by clicking here.
How does this Policy affect me if I am an individual entrepreneur, service provider or supplier to Aena Brasil?
In this case, Aena Brasil will treat your personal data as a representative of your company, as an individual entrepreneur or individual, in order to facilitate your participation or that of the company you represent in the bidding process(es) and the conclusion of contract(s). In addition, Aena Brasil may use such information to manage the services provided by its suppliers, service providers and/or customers (e.g., management of contracted services, use of contact data to communicate matters related to the services provided, management of compliance with tax obligations, monitoring of labor and social security obligations arising from the provision of services, billing, and collection management).
We point out, right away, that the personal data to be requested are essential for the development of the contract and/or for the fulfillment of the corresponding legal and regulatory obligations, so that the refusal to supply would make its execution or signature unfeasible, or would make compliance unfeasible of the legal obligations that fall on Aena Brasil.
The data of the successful bidder (i.e., winner of the competition), of the bidding companies (i.e., participants of the competition) and of the representatives of said companies will be processed by Aena Brasil for the execution of the contract or preliminary procedures related to the contract, when necessary to comply with the legitimate interests of both parties and/or, as the case may be, in the express consent of the representative of the bidding company by signing the forms and annexes necessary for participation in the bidding. Likewise, the professional contact data provided may be used to establish relationships with your company, with said treatment being based on the legitimate interest of Aena Brasil.
The data will be kept for the period necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
This data may be shared with companies belonging to the Aena Group and with service providers or partners, as long as authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
We point out, right away, that the personal data to be requested are essential for the development of the contract and/or for the fulfillment of the corresponding legal and regulatory obligations, so that the refusal to supply would make its execution or signature unfeasible, or would make compliance unfeasible of the legal obligations that fall on Aena Brasil.
The data of the successful bidder (i.e., winner of the competition), of the bidding companies (i.e., participants of the competition) and of the representatives of said companies will be processed by Aena Brasil for the execution of the contract or preliminary procedures related to the contract, when necessary to comply with the legitimate interests of both parties and/or, as the case may be, in the express consent of the representative of the bidding company by signing the forms and annexes necessary for participation in the bidding. Likewise, the professional contact data provided may be used to establish relationships with your company, with said treatment being based on the legitimate interest of Aena Brasil.
The data will be kept for the period necessary to achieve the specific purpose sought, as well as for the period necessary to legally protect Aena Brasil.
This data may be shared with companies belonging to the Aena Group and with service providers or partners, as long as authorized or required by the applicable legislation and respecting the legal limits, and in the other cases provided for in the applicable legislation or regulation and/or in this Policy.
From what sources can we receive your personal data?
In general, Aena Brasil collects personal data directly from the holder through the forms available or the records of the various services it provides, as reported in this Policy.
Personal data may sometimes come from third parties, such as airlines, customers and partners, when necessary for the conclusion of a contract to which the interested party or his company is a party, when there is a legal obligation to do so, or in other hypotheses provided for in the applicable legislation or regulation and/or in this Policy.
Personal data may sometimes come from third parties, such as airlines, customers and partners, when necessary for the conclusion of a contract to which the interested party or his company is a party, when there is a legal obligation to do so, or in other hypotheses provided for in the applicable legislation or regulation and/or in this Policy.
How long do we store your personal data?
Except as provided in this Policy, your data will be kept for the time necessary to fulfill the purpose for which it was collected, under the terms of the applicable legislation.
Subsequently, they will be kept for the period necessary to legally protect Aena Brasil from any liability.
Subsequently, they will be kept for the period necessary to legally protect Aena Brasil from any liability.
With whom may your personal data be shared?
In addition to the specific situations listed above, Aena Brasil reserves the right to share or transfer personal data in other cases authorized or required by applicable law, including, but not limited to, the following:
• Judiciary bodies and other public and supervisory bodies, for compliance with legal or regulatory obligations and/or regular exercise of rights in judicial, administrative or arbitration proceedings.
• To the customs authorities, for compliance with a legal or regulatory obligation.
• To the public security forces, to protect the life or physical safety of the holder or third parties and/or to comply with legal or regulatory obligations.
• To financial institutions, for payment for services provided by you or the company you represent.
• The National Civil Aviation Agency (ANAC), for the regular exercise of rights in judicial, administrative or arbitration proceedings, and/or for compliance with legal or regulatory obligations (eg, regulatory inspection procedures).
• Your airline or company, if we provide you with a service.
• For other entities involved in your complaints or demands of any nature through the Ombudsman Channel.
• To companies belonging to the Aena Group, including its controlling, controlled and affiliated companies, to comply with contractual, legal or regulatory obligations, provide the services requested or authorized by you, guarantee our exercise of rights in judicial, administrative or arbitration proceedings or in other hypotheses strictly necessary.
• To credit bureaus and collection companies, in case of non-payment of a product or service within the established period, within the limits of the applicable legislation.
• To the authorities that require it based on the applicable legislation.
• Service providers contracted by Aena Brasil to assist it in complying with its legal, regulatory or contractual obligations or in carrying out its commercial activities. As an operator, such companies must process personal data according to the instructions provided by Aena Brasil, which will contractually require strong and sufficient guarantees that operators comply with the personal data protection obligations established in this Policy, in the Governance Program in Privacy of Aena Brasil, in the applicable legislation and in the guides, guidelines and instructions published by the competent authorities.
Aena Brasil declares, however, that any sharing or transfer will be carried out in compliance with the personal data protection requirements provided for in the applicable legislation and regulations.
In addition, considering that the Aena group has operations in several countries, as well as that Aena Brasil may store personal data in a “cloud”, a technology that allows the storage of information on servers located in Brazil or abroad, it is noteworthy that the personal data controlled by Aena Brasil may be processed in foreign countries, always adopting effective guarantees and security measures.
In any case, Aena Brasil clarifies that it will only carry out international data transfers in accordance with the applicable legislation and adopting appropriate technical and contractual standards and security measures.
• Judiciary bodies and other public and supervisory bodies, for compliance with legal or regulatory obligations and/or regular exercise of rights in judicial, administrative or arbitration proceedings.
• To the customs authorities, for compliance with a legal or regulatory obligation.
• To the public security forces, to protect the life or physical safety of the holder or third parties and/or to comply with legal or regulatory obligations.
• To financial institutions, for payment for services provided by you or the company you represent.
• The National Civil Aviation Agency (ANAC), for the regular exercise of rights in judicial, administrative or arbitration proceedings, and/or for compliance with legal or regulatory obligations (eg, regulatory inspection procedures).
• Your airline or company, if we provide you with a service.
• For other entities involved in your complaints or demands of any nature through the Ombudsman Channel.
• To companies belonging to the Aena Group, including its controlling, controlled and affiliated companies, to comply with contractual, legal or regulatory obligations, provide the services requested or authorized by you, guarantee our exercise of rights in judicial, administrative or arbitration proceedings or in other hypotheses strictly necessary.
• To credit bureaus and collection companies, in case of non-payment of a product or service within the established period, within the limits of the applicable legislation.
• To the authorities that require it based on the applicable legislation.
• Service providers contracted by Aena Brasil to assist it in complying with its legal, regulatory or contractual obligations or in carrying out its commercial activities. As an operator, such companies must process personal data according to the instructions provided by Aena Brasil, which will contractually require strong and sufficient guarantees that operators comply with the personal data protection obligations established in this Policy, in the Governance Program in Privacy of Aena Brasil, in the applicable legislation and in the guides, guidelines and instructions published by the competent authorities.
Aena Brasil declares, however, that any sharing or transfer will be carried out in compliance with the personal data protection requirements provided for in the applicable legislation and regulations.
In addition, considering that the Aena group has operations in several countries, as well as that Aena Brasil may store personal data in a “cloud”, a technology that allows the storage of information on servers located in Brazil or abroad, it is noteworthy that the personal data controlled by Aena Brasil may be processed in foreign countries, always adopting effective guarantees and security measures.
In any case, Aena Brasil clarifies that it will only carry out international data transfers in accordance with the applicable legislation and adopting appropriate technical and contractual standards and security measures.
What security measures are adopted during the processing of your data?
Aena Brasil, as the controller of the personal data referred to in this Policy, adopts, from conception and by default, security, technical and administrative measures capable of protecting personal data from unauthorized access and accidental or illegal situations of destruction, loss, alteration, communication or any form of inappropriate or unlawful treatment.
Among the security measures implemented, it is included the control and tracking of user access to its internal systems (e.g., upon user and password request and collection of access logs), the protection of its systems and servers through the use of specific tools (e.g., antivirus and firewalls), and the backup of your databases.
Nevertheless, all Aena Brasil employees who need access to personal data have been properly instructed and are subject to confidentiality commitments, in order to ensure that such access will only occur in essential situations for achieving the desired purposes and provided that the necessary precautions.
In addition, Aena Brasil only hires a third party to assist in the provision of its services involving the processing of personal data if sufficient guarantees are presented that it adopts the necessary measures to meet the requirements set forth in this Policy and in the applicable legislation.
Among the security measures implemented, it is included the control and tracking of user access to its internal systems (e.g., upon user and password request and collection of access logs), the protection of its systems and servers through the use of specific tools (e.g., antivirus and firewalls), and the backup of your databases.
Nevertheless, all Aena Brasil employees who need access to personal data have been properly instructed and are subject to confidentiality commitments, in order to ensure that such access will only occur in essential situations for achieving the desired purposes and provided that the necessary precautions.
In addition, Aena Brasil only hires a third party to assist in the provision of its services involving the processing of personal data if sufficient guarantees are presented that it adopts the necessary measures to meet the requirements set forth in this Policy and in the applicable legislation.
How can you exercise your rights?
Pursuant to article 18 of the General Law for the Protection of Personal Data (Federal Law No. 13,709/2018), the holder of personal data has the right to obtain from Aena Brasil, in relation to the data processed by it, at any time and upon request:
• Confirmation of the existence of treatment
• Access to data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking or elimination of unnecessary data, excessive or treated in violation of applicable law
• Data portability to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets
• Elimination of personal data processed with the consent of the holder, observing the legal limits
• Information from public and private entities with which Aena Brasil shared data;
• Information on the possibility of not providing consent and on the consequences of refusal
• Revocation of consent
• Petition regarding your data against Aena Brasil before the national authority, and
• Review of decisions taken solely based on automated processing of personal data that affect your interests.
You can exercise these and other rights related to privacy and protection of personal data provided for in the applicable laws and regulations in front of Aena Brasil through the following email address: : privacidade@aenabrasil.com.br
• Confirmation of the existence of treatment
• Access to data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking or elimination of unnecessary data, excessive or treated in violation of applicable law
• Data portability to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets
• Elimination of personal data processed with the consent of the holder, observing the legal limits
• Information from public and private entities with which Aena Brasil shared data;
• Information on the possibility of not providing consent and on the consequences of refusal
• Revocation of consent
• Petition regarding your data against Aena Brasil before the national authority, and
• Review of decisions taken solely based on automated processing of personal data that affect your interests.
You can exercise these and other rights related to privacy and protection of personal data provided for in the applicable laws and regulations in front of Aena Brasil through the following email address: : privacidade@aenabrasil.com.br
How can you contact our Personal Data Controller?
To clarify any doubts related to this Policy or the privacy and protection of personal data, you can contact our Person in Charge for the Processing of Personal Data through the following e-mail address: privacidade@aenabrasil.com.br.
Finally, we emphasize that this Policy may be revised at any time to reflect changes in our activities or in the applicable legislation. Therefore, we recommend that you check this page periodically.
Updated on September 15th, 2021.
Finally, we emphasize that this Policy may be revised at any time to reflect changes in our activities or in the applicable legislation. Therefore, we recommend that you check this page periodically.
Updated on September 15th, 2021.