Privacy Policy
PLEASE READ THIS PRIVACY AND DATA PROTECTION POLICY CAREFULLY. BY ACCESSING OR USING THIS WEBSITE, YOU ACCEPT THIS POLICY. IF YOU DISAGREE WITH THE TERMS OF THIS POLICY, DO NOT USE THIS WEBSITE
Privacy and Data Protection Policy applicable to Empresas CMPC S.A.’s Investor Relations Website
- Background information
In order to provide information to its investors and comply with its legal obligations, Empresas CMPC S.A. and its subsidiaries, hereinafter "CMPC", through this website implemented to inform and interact with its investors or Investor Relations (IR), hereinafter the "CMPC IR Website", collects, controls, processes and stores certain personal data of investors, analysts and users who access the CMPC IR Website from anywhere in the world.
Below we provide information about the type of personal data collected, processed and stored by CMPC through the CMPC IR Website, and for what purposes they are used. We will also provide information on how you can exercise your rights as the owner of that personal data.
CMPC declares that it respects the privacy and the right to informational self-determination of every person and that it is responsible for the processing of personal data that is collected, processed and stored on the CMPC IR Website in accordance with the Political Constitution and the laws of the Republic of Chile.
When accessing or using the CMPC IR Website, the user will be asked to expressly agree, through the option “Accept”, to this Privacy and Data Protection Policy. Regardless of the country in which the user resides, accesses the CMPC IR Website or provides information, the user expressly authorizes CMPC to use the their information in accordance with the provisions of this Privacy and Data Protection Policy.
The user knows, understands and accepts that any changes to this Declaration of Privacy and Personal Data Protection will be published on the CMPC IR Website. This will allow the user to be informed at any time about what personal data is being collected, processed and/or stored, and for what purpose.
The user knows, understands and accepts that by using the CMPC IR Website, they may access third-party websites through hyperlinks, and that this Declaration of Privacy and Data Protection Policy does not apply to websites accessible through those hyperlinks or links.
- Collection and storage of personal data of the CMPC IR Website users
Controller Name: Empresas CMPC S.A. (CMPC).
Controller Address: 1343 Agustinas St, Santiago, Chile.
Tax ID number: 90.222.000 - 3
Contact Email Address: ir_cmpc@cmpc.cl
CMPC collects, processes and stores only the personal data that is strictly necessary for the proper functioning of the CMPC IR Website and to improve the user experience on it. Any additional processing of personal data is only performed in accordance with other legal bases, or if the respective user has given express consent to CMPC.
CMPC collects, processes and stores personal data in the manner detailed below:
- Automatic collection and storage of personal data when visiting the CMPC IR Website:
When visiting the CMPC IR Website, certain personal data is automatically collected and stored, such as:
- The IP address of the user of the CMPC IR Website. Through the IP information and other similar data, the physical location where the CMPC IR Website user is located can be determined, with a high degree of accuracy.
- The user’s activity on the CMPC IR Website, including the number of clicks and attempts to use the site, as well as the pages which the user accesses on the CMPC IR Website.
- The respective type of final device used to access the CMPC IR Website.
- ID Code (IMEI) of the mobile device through which the user accesses the CMPC IR Website.
- The type of search engine that was used, as well as the operating system and Internet supplier.
- The date, time, and duration of the session on the CMPC IR Website.
- Non-automatic collection and storage of personal data voluntarily supplied by the user:
When visiting the CMPC IR Website, users may provide their personal data for certain specific purposes. The supplied data could include one or more of the following:
- Full name of the user
- Company to which the user belongs to and position or role within that company
- User’s e-mail address
- User’s phone number
- User’s domicile
- Information about WhatsApp account or other digital communication media
- User’s geolocation
- User’s digital calendar data
- User’s preferences on various topics
- Any personal data that is necessary to carry out the activity that the user intends to execute on the CMPC IR Website according to their preferences and interests
The aforementioned personal data are collected through the CMPC IR Website when the user enters the information in any of the fields set out for such purpose. The aforesaid data can also be collected in other sites of CMPC subsidiaries to which the user accesses through hyperlinks or links. These fields are duly signaled and do not collect any personal data unless the user expressly consents to such submission, processing and storage.
The user must bear in mind that the combination of the personal data gathered in the CMPC IR Website could allow CMPC to obtain a highly accurate profile of the user, including his/her physical location, interests and preferences, reflected in their browsing within the CMPC IR Website.
In order to prevent the collection of personal data, the user of the CMPC IR Website may always change the setup of their browser.
- Use and processing of the personal data of CMPC IR Website users
The personal data that were collected and stored, may be used for the following purposes, depending on the specific scenario in which they are supplied or collected, and the consent that has been granted, as per this Declaration of Privacy and Data Protection Policy:
- To allow users or investors to contact CMPC, in order to answer their concerns or queries.
- To answer queries from users or investors, information requests, comments or suggestions. Personal data will be treated so as to manage the queries that the user submits via the channels established for such purposes on the CMPC IR Website.
- To send information about CMPC to users or investors, such as information pertaining to investments, stock market data, financial statements, statistics, stocks, investment opportunities, news about sustainability policies and corporate governance, notices about corporate developments and material disclosures regarding CMPC and its subsidiaries, notices regarding new events in which the IR team from CMPC will participate, and corporate presentations updated for the CMPC IR Website, as well as invitations to participate in events for investors (for example, Investor Day).
- To allow the user to employ tools of the CMPC IR Website, that will facilitate the user to submit queries or comments about the performance of the company; participate in the periodical interactive conferences provided by the CMPC IR Website; visualize corporate videos and presentations; download financial statements, annual reports, balance sheets, material disclosures, press releases and other documents recording CMPC’s financial, legal and compliance status; download CMPC’s financial information using the Interactive Analyst CenterTM technology; inquiring to be forward to the Shareholders Departament about his/her shares, certificates, dividends, transfers, and proxies; update his/her personal information, or that of his/her companies; register for corporate seminars or events; schedule appointments for corporate activities in digital calendars; subscribe to news alerts, newsletters, financial reports, news, events, presentations and end of day stock quotes; subscribe to and use the Really Simple Syndication (RSS) technology in order to stay updated about any developments to the contents of the CMPC IR Website; and share or receive information about the CMPC IR Website in social networks or media.
- To maintain records, such as mailing lists or lists about user types, classified per preferences or characteristics, with the purpose of maintaining the user duly informed about CMPC’s corporate governance for business purposes. CMPC may create profiles based on marketing studies and statistical and segmenting techniques and procedures that will enable the personalization of information offerings that adjust to the characteristics and needs of the user who visits the CMPC IR Website. Eventually, in this context, profiles could be created using automated technological means, in order to make predictions about the user of the CMPC IR Website.
- To help in the establishment and verification of the user’s identity, and maintaining the systems’ security, speed and integrity.
- To analyze the user’s behavior on the CMPC IR Website and his/her preferences.
- Legal standing for the treatment of personal data on the CMPC IR Website
The processing of personal data is based on the legal provisions that justify such operations, based on the assumption that the processing and use is legitimate, due to the following reasons:
- Processing is necessary in order to provide the CMPC IR Website as an instrument and means for the performance of the legal and contractual obligations of CMPC with its investors.
- CMPC has a legitimate interest in guaranteeing and improving the functionality of the CMPC IR Website. Specifically, said legitimate interests are comprised by business interests, the ability to provide a functional and safe CMPC IR Website, the security of personal data, and compliance with court mandates and legal requirements in general.
- CMPC must protect the interests of users, investors, third parties or any public interest that could be affected as a consequence of issues with the CMPC IR Website, as provided under applicable law.
- User or investor consent (see following section).
CMPC may share and transfer the collected information to any member of its business group, whether in Chile or abroad, provided that this is reasonably necessary in order to fulfill the purposes – and based on the legal grounds – set forth in this Privacy and Data Protection Policy.
CMPC may not sell, nor deliver this information to other non-related parties, without prejudice to the terms contained in this Privacy and Personal Data Protection Policy.
The collected personal data will be added to a database or registry kept by CMPC’s IR team. The personal data will be stored until the objective for which they have been gathered has been fulfilled, or until the user exercises his/her right to rectify, cancel, limit and challenge the same. The foregoing shall be complied with insofar as no conflict exists with the need to continue storing the data, based on legal grounds.
CMPC has established and maintains in place the security, administrative, technical and physical measures enabling it to protect the personal data against damage, loss, tampering, destruction, or any unauthorized use, access or handling, in compliance with the applicable legislation. Nevertheless, the user should be aware that communication over the internet is not 100% safe.
In particular, the CMPC IR Website has instituted the following tools and practices for processing and storing the users’ personal data in a secure manner:
- SSL Certificate
- Encryption with SSL protocol
- No sensitive data is stored.
- Layers of the security model from supplier Q4 Inc.
- Consent
The main legal justification for the handling of personal data is the explicit acceptance for their collection, processing, treatment and storage, pursuant to this Personal Privacy and Personal Data Protection Policy.
When entering, browsing on, and using the CMPC IR Website, the user accepts and consents to this Privacy and Personal Data Protection Policy.
If the user disagrees with this Privacy and Personal Data Protection Policy, he/she should not deliver, nor enter his/her data on the CMPC IR Website.
The user of the CMPC IR Website declares that he/she is older than 18 years of age.
- Use of the sensitive personal data belonging to CMPC IR Website users
The CMPC IR Website does not gather sensitive data. However, it is possible that the user, when employing some tools on the CMPC IR Website, provides some data related to his/her private life or personal habits, even though the site does not request them. Said data could be provided in the blank fields of tools such as contact forms or other similar ones.
Likewise, in the case of contact forms (such as “Contact Us” or “Request a Meeting” forms) and other forms with open fields for observations, the user assures accuracy of the information that he/she provides in these open fields, whose content the user is aware that, understands and accepts has not been requested by CMPC and, therefore, is beyond CMPC’s control.
- Rights of the user of the CMPC IR Website regarding his/her personal data
At any time, and provided that the respective requirements are fulfilled, the user can exercise the following rights in connection with his/her personal data that have been delivered to the CMPC IR Website:
- Right of access: the user can access his/her personal data in order to know which of his/her personal data are being processed and how they are being processed.
- Right to request the rectification of personal data: the user has the right to correct any personal data which he/she believes are inaccurate.
- Right to request the cancellation, erasure, or elimination of personal data: the user is entitled to request the elimination of his/her personal data.
- Right to request the limitation or restriction of the processing of personal data: the user is entitled to request the limitation of the handling of his/her personal data, for example, in order for said data to only be used for certain purposes.
- Right to challenge or object to the processing of personal data: the user will be entitled to challenge said processing at any time, for specific reasons.
CMPC will cease the processing of the personal data, unless it can prove legitimate reasons to continue doing so or otherwise when such processing is necessary to enforce, exercise, or address a legal claim.
- Right to the portability of personal data: the user will be entitled to receive any personal data which pertain to him/her, in a structured format of common use that allows for machine reading, and to deliver said data to a third party – or request CMPC to do so, if technically feasible.
- Right to retract any given consent, without it affecting the lawfulness of the treatment based on the consent granted prior to said retraction. This right can be exercised by sending a written request addressed to Empresas CMPC S.A., domiciled at 1343 Agustinas St, Santiago, Chile; or to the contact e-mail address ir_cmpc@cmpc.cl.
- Right to object to the sending of advertisements via electronic means, by sending a written request addressed to Empresas CMPC S.A., domiciled at 1343 Agustinas St, Santiago, Chile; or to the contact e-mail address ir_cmpc@cmpc.cl.
The rights to request rectification, cancellation, limitation, and objection of the stored personal data shall not operate retroactively. It is likely that the user who requests these actions may not be able to use the CMPC IR Website again with all of the site’s functionalities.
- Supervisor of personal data protection
Any query or requirements that users of the CMPC IR Website may have with respect to the aspects mentioned in this Privacy and Data Protection Policy will be channeled through the person appointed by CMPC as the supervisor of personal data protection, sending an email to: ir_cmpc@cmpc.cl.
- Cookies
Please refer to our Cookie Policy.
- Web tracking
The CMPC IR Website does not perform web tracking of its users.
Notwithstanding the foregoing, external sources that are implanted automatically when accessing the CMPC IR Website, or third-party websites that the user may access through the CMPC IR Website – hyperlinks or links – could perform web tracking. Please refer to this topic in our Cookie Policy.
- Other personal data
The CMPC IR Website is an instrument and means to comply with CMPC’s legal and contractual obligations in favor of its investors, particularly the obligations of information and transparency.
Based on this legitimation for personal data treatment, in parallel to the collection, processing and storage of data that takes place by accessing the CMPC IR Website, the CMPC IR Website also contains personal data belonging to people who advise or work for CMPC or are shareholders of CMPC.
In particular, the CMPC IR Website may include personal data such as names, titles, and business addresses of CMPC executives, professionals, commercial agents, shareholders, employees and authorities. It is possible for certain contact information (email and telephone contacts), professional profile, job function, employment history and academic training to be included as well. It could also include shareholdings of investors who are natural persons (with their full name, personal identification number and date of birth) and records of meetings, including notes and images relating to such meetings, photos, comments and opinions expressed by investors and executives, topics discussed or the nature of questions asked in such meetings. The names and contact details of analysts and executives of credit rating agencies and financial institutions not related to CMPC could also be included.
The owners of the personal data mentioned above may exercise the rights indicated under article number 7 of this policy in accordance with Chilean law, to the extent that this exercise does not infringe upon the legal obligations of CMPC in favor of its investors or the contractual obligations of those people with CMPC or their employers.
- Other channels
CMPC may also collect and process personal data belonging to users in other communication channels, such as telephones, emails, applications or social networks, in which case the user will be informed of the objectives of the personal data handling and will be asked for the explicit and prior consent. This Policy will also apply to those channels.
Last updated September 24, 2019.