PRIVACY POLICY
We take your privacy seriously.

Summary

We take privacy seriously. Therefore, in this Privacy Policy we explain the ways in which we use, store, share and protect personal data collected from the use of our services and solutions (collectively "Services") and from visiting our website and as the data subjects may exercise their rights under applicable law.

The personal data we collect depends on the context of your interactions with us. To facilitate your understanding, we explain in this Policy how we treat the data of Customers ("Consumers") and users of our website ("Users"), collectively ("Owners" or "you").

Specific Privacy Policies may apply for some of our products and services. For more information about our privacy practices relating to a specific product or service, please visit the website for that product or service.

1. Important definitions

General Data Protection Law (LGPD). Federal Law No. 13.709 published on August 14, 2018, which regulates Personal Data Processing activities, including in digital media, by a natural person or by a legal entity governed by public or private law, in order to protect the fundamental rights of freedom and of privacy and the free development of the natural person's personality.

Treatment Agents. are those responsible for the Processing of Personal Data and are separated into two categories: the Controller and the Operator. The Controller is the person or company responsible for decisions regarding the Processing of Personal Data. The Operator, in turn, is the person or company that carries out the Processing of Personal Data on behalf of the Controller, following its instructions.

Personal data. information relating to the identified or identifiable natural person Treatment. any operation carried out with Personal Data, whether automated or not, that is, it is the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

2. Customers

2.1 Data We Collect

Generally speaking, when a Customer (or for the purposes of this section, "you") or your company engages, uses or interacts with the Services, we collect your personal data, which can be divided into three broad categories:

(i) Data You Provide Us: When you contract, use or interact with the Services or communicate with us in any way, you (or your company) may provide us with some data. These data include:

• Professional contact details such as your name, title, company, location, telephone number and email address;
• Marketing preferences;
• Account credentials such as your email address, username and password;
• Payment information such as credit card details, bank details and billing address;
• Data related to technical support and troubleshooting. This data includes call opening data, such as the type of product or service related to your help request, contact or authentication data, and the content of your communications with us, including telephone recordings.

(ii) Data We Collect Automatically: When you use our services, we may automatically collect and store data. These data include:

• Device data you use to access the Services, such as your IP address, operating system, geolocation information and device identifier.
• Log data such as the IP address and your activities on the Services (such as the date and time associated with your use, the pages and files viewed, searches and other actions you take (such as which features you used).
• Browsing data, ie data about how you use and interact with our Services, which may include the dates you used the Services and your browsing activities. We also collect information about the performance of the Services, including metrics related to the sending of emails and other communications you send through the Services.

(iii) Data We Collect From Other Sources: We may collect data from other sources, such as public databases, public profile data on social media and credit bureaus.

2.2 How we use this data

We use the data collected or received from using the Services for the following purposes:

• Comply with our contractual obligations to you or your company. This includes creating and managing the accounts you may have with us, verifying your identity, charging you dues, providing, customizing and improving our services;
• Notify you of any changes to our products and services;
• Strengthen our safety and security procedures, aiming to provide a safer and more effective service;
• Perform internal operations, including support, troubleshooting, data analysis, testing, research and statistics;
• Provide information about other services and/or products we offer, similar to those already contracted by you;
• Evaluate or understand the effectiveness of the advertising we serve to provide you with relevant advertising;
• Manage risks and detect, prevent and/or remedy fraud or other potentially illegal or prohibited activities, and violations of applicable policies, contracts or terms of use;
• As necessary, to establish, exercise and defend rights in judicial, administrative or arbitration proceedings;
• Comply with legal or regulatory obligations, or as required in a court proceeding, by any law enforcement or government agency with jurisdiction, or claiming to have jurisdiction, over us.
• For other purposes for which we provide a specific notice at the time of collection, or otherwise as authorized or required by law.

3. Consumers

This section applies to our Customers' personal Consumer data (or for the purposes of this section, "you"), when we act as Controllers. Note that in most of the products and services we offer, companies/business units that may be part of us, they act as Operators of personal data, according to the instructions of our Clients. We are not responsible for our Customers' privacy or security practices. To understand how your data is treated by our Clients, it is important to consult the respective privacy policies of each one.

3.1 Data We Collect

(i) Data we receive from our Customers: Customers from our companies/business units may provide us with their personal data through the Services. When, for example, a Customer uploads their contact base to use our email marketing services, when you sign up for a Customer newsletter, or when you make a purchase on the Customer's webshop, the Customer may provide us with certain information such as your name, email address, telephone number or payment details.

(ii) Data We Collect Automatically: When you interact with the Services purchased by the Customer, such as when you interact with a marketing communication, browse the Customer's website or make a purchase from the Customer's webshop, we may collect information about your device and its activities. This information includes:

• Device data you use to access the Services, such as your IP address, operating system, geolocation information and unique device identifiers.
• Browsing data, ie data about how you use and interact with our Services, which may include the dates you used the Services and your browsing activities, such as the pages you viewed, if you opened an email or added a product to the cart. We also collect information about the performance of the Services, including metrics related to the sending of emails or other forms of communication sent by our Customers through the Services.

(iii) Data we collect from other sources: we may collect data from other sources, such as public databases, public profile data on social networks, credit protection entities, especially when you make a purchase on a website that uses our payment intermediation services.

3.2 How we use this data

We may use the data collected or received from the use of the Services by our Clients for the following purposes:

• Provide, customize and improve our Services;
• Perform internal operations, including support to our customers, troubleshooting, data analysis, testing, research and statistics;
• Develop marketing strategies for our Clients, so that they can offer you relevant advertising.
• Proceed with payment requests made by you, in payment intermediation operations.
• Manage risks and detect, prevent and/or remedy fraud or other potentially illegal or prohibited activities, and violations of applicable policies or terms of use;
• Establish, exercise and defend rights in judicial, administrative or arbitration proceedings;
• Comply with legal or regulatory obligations, or as required in a court proceeding, by any law enforcement or government agency with jurisdiction, or claiming to have jurisdiction, over us.
• For other purposes for which we provide a specific notice at the time of collection, or otherwise as authorized or required by law.

4. Users

This section applies to the personal data we collect when Users (or for the purposes of this section, "you") visit our website.

4.1 Data we collect

(i) Data you provide us: our website has several ways in which you can almost contact us. You can provide us with personal data, for example, when you express an interest in obtaining more information about our products and services, participate in surveys, subscribe to our newsletter, download informational content or otherwise contact us. These data include:

• Professional contact details such as your name, title, company, location, telephone number and email address;
• Area of expertise and interests;
• Nature of your communication with us;
• Marketing preferences;
• Any other information you choose to provide us.

(ii) Data We Collect Automatically: When you use our website, we may automatically collect and store data. These data include:

• Device data that you use to access the Services, such as your IP address, operating system, browser information, geolocation information, and device unique identifiers.
• Browsing data, ie data about how you use and interact with our Services, which may include the dates you used the Services and your browsing activities, including for example your interaction with our informational materials. We also collect information about the performance of the Services, including metrics related to the sending of emails and other communications you send through the Services.

4.2 How we use this data

We may use the data collected or received from using the websites for the following purposes:

• Provide, customize and improve our website;
• Strengthen our safety and security procedures, aiming to provide a safer and more effective service;
• Perform internal operations, troubleshooting, data analysis, testing, research and statistics;
• Process transactions and manage your accounts online;
• Send marketing communications and recommendations for products or services offered by our companies, based on your marketing preferences.
• Evaluate or understand the effectiveness of the advertising we serve to provide you with relevant advertising;
• Manage risks and detect, prevent and/or remedy fraud or other potentially illegal or prohibited activities, and violations of applicable policies or terms of use;
• As necessary, to establish, exercise and defend rights in judicial, administrative or arbitration proceedings;
• Comply with legal or regulatory obligations, or as required in a court proceeding, by any law enforcement or government agency with jurisdiction, or claiming to have jurisdiction, over us.
• For other purposes for which we provide a specific notice at the time of collection, or otherwise as authorized or required by law.

5. How we share personal data

We may share the personal data collected with other companies in your economic group, with third parties and business partners, which are relevant for the purpose of enabling the provision of the Services. Such sharing takes place based on the following criteria and for the purposes described below.

• Our Companies: Our companies may share with each other the personal data collected from the provision of the Services in order to operate, execute, improve, understand, customize, support, advertise our Services and prevent fraud.
• Third Party Service Providers: We work with third party service providers to help us operate, execute, improve, understand, customize, support and advertise our Services. When we share data with third-party service providers, we require them to use your data in accordance with our instructions and terms or with your express consent, where applicable.
• Credit Protection Entities: We may share your registration data with entities dedicated to reducing credit risk and protecting companies and individuals against fraud, in order to validate the information you provide.
• Regulatory bodies, judicial or administrative authorities: we may share your personal information in order to provide the competent authorities with any information that may be requested in relation to the Owner and operations performed by him on the Sites. Furthermore, we may share your personal data with public authorities or private entities to combat fraud and abuse in the use of the Services, to investigate suspected violations of the law, or to combat any other suspicion of non-compliance with our policies and contracts.
• Transfer of Assets: If a company or business unit that is part of us is reorganized or sold and all or substantially all assets are transferred to a new owner, your personal information may be transferred to the buyer regardless of your authorization to ensure continuity of services;
• With your authorization: In other cases not provided for above, having the purpose of sharing personal data and information, we will send you a notification with information regarding such sharing to request your consent, for a specified purpose.

6. Cookies and Tracking Technologies

We and our partners may use a variety of technologies to automatically collect and store data about the use of the Services. These technologies include cookies, pixels, web beacons and SDKs. We use the information collected through these technologies to optimize and customize your browsing experience, target advertising campaigns, develop and apply security features and fraud prevention procedures, among other possible uses. For more information, visit our Cookies Policy.

7. Transfers of personal data outside Brazil

We may transfer some of your personal data to service providers located abroad, including cloud service providers. When your personal data is transferred outside Brazil, we will take appropriate measures to ensure adequate protection of your personal data in accordance with the requirements of applicable data protection legislation, including by entering into appropriate data transfer agreements with third parties of your personal data when required.

8. Interactions with Third Party Sites

We may provide links to other websites on the Internet. WE ARE NOT RESPONSIBLE FOR THESE SITES AND CONTENT AND FURTHER DOES NOT SHARING, SUBSCRIBE, MONITORS, VALIDATE OR ACCEPT HOW SUCH SITES OR CONTENT STORAGE TOOLS COLLECT, PROCESS AND TRANSFER YOUR PERSONAL INFORMATION. We encourage you to consult the respective privacy policies of such websites to properly inform you about the use of your personal information by other websites or other tools. We may log your access to third party websites in order to measure the relevance of those websites to our users.

9. Security

Personal Data processed by us are protected by physical, technical and organizational security measures to reduce the risk of loss, misuse and unauthorized access, disclosure and alteration, such as firewalls and data encryption, physical access controls to data centers, in addition to information access authorization controls.

10. Rights of the Holder

Subjects of personal data have certain rights regarding their personal data and can exercise them by contacting us through our service channels.

• Confirmation of the existence of personal data processing;
• Access to personal data, pursuant to applicable law;
• Correction of incomplete, inaccurate or outdated data;
• Data portability;
• Deletion of data, when it is processed based on the Owner's consent or when the data is unnecessary, excessive or processed in disagreement with the applicable legislation;
• Request for information about shared use of data. Please note that this Privacy Policy describes our personal data sharing activities. To receive more information about how we share your data, please contact us;
• Revocation of consent, where applicable. For security reasons, we will only be able to fulfill your request if we are sure of your identity. Therefore, we may request additional data or information to confirm the Cardholder's identity and authenticity. Please note that, as mentioned above, in most of the products and services we offer, we act as the operator of personal data, in accordance with the instructions of our Clients. If you are a Consumer and wish to exercise your rights in relation to the personal data that we process as an operator, you must contact the Customer who is using the Services.

11. End of Treatment

This Privacy Policy applies to the circumstances mentioned above throughout the period in which we store personal data. We store and maintain your information:

(i) for the time required by law;

(ii) until the end of the processing of personal data, as mentioned below; or

(iii) for as long as necessary to preserve our legitimate interest. Thus, we will treat your data, for example, during the applicable statute of limitations or as necessary to comply with a legal or regulatory obligation.

The termination of the processing of personal data will occur in the following cases:

(i) when the purpose for which the personal data was collected is achieved, and/or the collected personal data is no longer necessary or relevant to the achievement of such purpose;

(ii) when the Owner requests the deletion of their data; and (iii) when there is a legal determination in this regard. In the event of termination of the processing of personal data, except in the cases established by applicable law or by this Privacy Policy, the personal data will be deleted and this Policy will no longer apply to your relationship with us.

12. Change in Privacy Policy

With the constant evolution of the business model, We reserve the right to change this privacy policy at any time, by publishing the updated version on your website. If there is a material change in the treatment of personal data, you will be informed and given the opportunity to review the revised policy before deciding to continue using our Services.