B2B Scope ELEVA operates exclusively in the Business to Business segment, providing heavy port equipment rental services to legal entities. We collect only business data and data of business representatives: we do not keep databases of private individuals for personal purposes.

1. Our Commitment

GV COMERCIO LOCACOES REPRESENTACOES E TRANSPORTES ESPECIAIS LTDA. ("ELEVA", "we" or "our company"), registered under CNPJ (Brazilian company tax ID) no. 09.592.071/0001-03, headquartered at Av. Alcântara Machado, 1025, Brás, São Paulo/SP, Brazil, is committed to transparency and security in the processing of the business data of our clients and business partners.

Legal compliance

Law no. 13,709/2018 (LGPD, Brazilian General Data Protection Law), where applicable to data of representatives of legal entities
Law no. 12,846/2013, Brazilian Clean Company (Anti-corruption) Act
Marco Civil da Internet (Brazilian Internet Civil Framework): Law no. 12,965/2014
Brazilian Civil Code, business relationships
ISO 27001:2013 Standard, Information Security
Law no. 8,078/1990 (CDC, Brazilian Consumer Protection Code), where applicable to legal entities

2. Business Data Collected

2.1. Information we collect

A) Client Company Data

Legal name and trade name
CNPJ and state/municipal registration
Business address
Line of business and company size

B) Business Contact Data

Name of the business representative
Position/role in the company
Corporate e-mail
Business phone and business WhatsApp

C) Business Communication Data

Quote requests
Messages sent through the contact form
WhatsApp Business history
Specific operational needs

D) Contractual and Commercial Data

Rental contracts
Service orders
Billing data
Rental history and preferences

2.2. What we do NOT collect

CPF (Brazilian individual taxpayer ID), except for MEI when necessary
Personal bank details
Health or biometric information
Sensitive data as defined in Art. 5, II of the LGPD
Personal information unrelated to business activities

3. Purposes of Processing

We use the business data collected exclusively for:

Service Delivery

Preparing commercial proposals, managing rental contracts, equipment delivery/pickup, preventive and corrective maintenance, technical and operational support.

Commercial Management

Communication about services and availability, sending quotes, commercial negotiation and management of the B2B relationship.

Legal Obligations

Issuing invoices, meeting tax obligations, responding to inspections, mandatory accounting records and port authority requirements.

Security and Quality

Access control to port areas, ensuring operational safety, continuous improvement of services and prevention of commercial fraud.

4. Legal Basis for Processing

Legal Basis	Application	Examples
Performance of Contract (Art. 7, V, LGPD)	Data required to provide the services	Contact details, CNPJ, delivery address
Legal Obligation (Art. 7, II, LGPD)	Compliance with laws and regulations	Invoicing, tax records
Legitimate Interest (Art. 7, IX, LGPD)	Operational improvements and security	Quality analyses, fraud prevention
Regular Exercise of Rights (Art. 7, VI, LGPD)	Defense in legal proceedings	Contract documentation

5. Information Sharing

5.1. Business partners

Carriers: equipment delivery/pickup
Partner workshops: specialized maintenance
Insurers: claims
Financial institutions: payment processing
Accounting and law firms: legal compliance

5.2. Authorities, when legally required

Receita Federal (Brazilian Federal Revenue Service) · State Finance Departments · Port Authorities · Regulatory bodies

No sale of data: ELEVA does NOT sell, rent or trade its clients' business data.

6. Information Security

Technical Safeguards

SSL certificate on the website
Corporate firewall
Antivirus and anti-malware
Periodic backups
Access control to systems

Administrative Safeguards

Restricted access to information
Confidentiality agreements
Clean desk policy
Secure disposal of documents

Physical Safeguards

Files kept in a secure location
Access control to facilities
Security cameras

7. Retention and Disposal

Document Type	Period	Legal Basis
Commercial contracts	5 years after termination	Art. 206, §5, I, Brazilian Civil Code
Invoices	5 years	Tax legislation
Business communications	2 years	CDC limitation period
Quotes not accepted	6 months	Commercial management
WhatsApp messages	1 year	Commercial history

8. Company Rights

Client companies have the right to:

Access: request information about their data
Correction: update outdated business data
Deletion: request deletion once legal obligations have been met
Information: know with whom we share the data
Objection: object to certain processing

How to exercise them: e-mail contacto@elevalog.com · phone +55 (11) 3277-2028 · mail to Av. Alcântara Machado, 1025, Brás, São Paulo/SP, Brazil. Response time: up to 15 business days.

9. Cookies and Browsing

Our website uses only essential cookies (basic operation), session cookies (temporary) and Google Analytics (anonymized statistics). You can disable them in your browser settings, but this may affect the website's functionality.

10. Business Communications

We may contact you about active contracts, scheduled maintenance, safety notices, service updates and administrative communications. B2B marketing communications are sent only to business contacts, always with an unsubscribe option.

11. LGPD and the B2B Context

The LGPD applies to our processes when we handle data of representatives who are natural persons, process data of MEIs, or when a natural person is identified in the business context. When we collect the name and e-mail of representatives, we process them only within the context of the business relationship and always link them to the company represented.

12. Responsibilities and Contact

Data Controller
GV Comercio Locacoes Representacoes e Transportes Especiais Ltda.
CNPJ: 09.592.071/0001-03
Address: Av. Alcântara Machado, 1025, Brás, São Paulo/SP, Brazil
Phone: +55 (11) 3277-2028
E-mail: contacto@elevalog.com

14. Anti-corruption and Compliance Program

ELEVA is fully committed to ethical and transparent business practices and rejects any form of corruption, bribery or misconduct in business relationships. We act in accordance with Law no. 12,846/2013, Law no. 8,429/1992, Decree no. 11,129/2022 and the Brazilian Penal Code (Arts. 317, 333 and 337-B).

14.2. Prohibited practices

Offering or paying bribes, kickbacks or undue advantages
Facilitation payments to public officials
Excessive gifts or hospitality
Contracts with intermediaries for unlawful practices
Donations intended to influence decisions
Falsification of tax or accounting documents
Fraud in public tenders or procurement processes
Undeclared conflicts of interest

14.3. Whistleblowing channel

E-mail: contacto@elevalog.com
Web form: etica.gvlogistica.com.br
Mail: Ethics Committee: Av. Alcântara Machado, 1025, São Paulo/SP, Brazil

Whistleblower guarantees: absolute confidentiality, option to report anonymously, protection against retaliation, response within 30 days and case follow-up.

17. Compliance and Audit

We maintain a robust compliance program covering Data Protection and Anti-corruption: process documentation, processing records, periodic assessments (semiannual internal audit, quarterly review, monthly tests and annual assessment) and continuous improvement through the PDCA cycle.

17.4. Unified Compliance Channel

Privacy: contacto@elevalog.com
Anti-corruption and Ethics: contacto@elevalog.com
General: contacto@elevalog.com · +55 (11) 3277-2028

Annex I: Definitions

B2B: Commercial transactions between companies (Business to Business)
CEIS: Brazilian Register of Ineligible and Suspended Companies
CNEP: Brazilian National Register of Sanctioned Companies
CNPJ: Brazilian National Register of Legal Entities
Compliance: Conformity with laws and regulations
Due Diligence: Prior investigation and verification process
LGPD: Brazilian General Data Protection Law (Law 13,709/2018)
MEI: Individual Microentrepreneur (Brazilian legal form)

Privacy and Data Protection Policy