Privacy Policy

1. INTRODUCTION AND PURPOSE

This Privacy Policy ("Policy") aims to demonstrate Vericode Tecnologia Ltda.'s ("Vericode" or "We") commitment to the privacy and data protection of our users ("Data Subject," "you," or "your"), and to establish the rules for the processing of your Personal Data in our environments ("Our Environments"). Vericode is located at Rua Haddock Lobo, No. 337, 8th floor, suites 81A and 81B, Cerqueira Cesar, São Paulo/SP, ZIP 01414-901, CNPJ No. 05.490.788/0001-85.

This Policy describes in a simple, transparent, and objective manner how Vericode collects, maintains, processes, protects, and uses your Personal Data, as well as the rights you have under applicable laws, especially Law No. 13.709/2018 ("General Data Protection Law" or "LGPD").

As a condition for accessing and using the exclusive functionalities of Our Environments, you declare that you have read this Policy thoroughly and carefully, and that you are aware of its content.

Furthermore, we ask that children and adolescents under 16 years of age do not register in Our Environments. Parents should always supervise their minor children's online activities and oversee the activities of adolescents aged 16 to 18.

2. DATA WE COLLECT

Data, including Personal Data, may be collected when the Data Subject provides it, such as by sending a message or interacting in Our Environments. This data includes:

• Full name
• Email
• Phone number
• Company
• Job title
• Profession
• Professional history
• Educational history
• Social media addresses

In addition to the data provided above, we also automatically collect information such as IP address and Port of Origin, device information (operating system version), timestamps of each action you take, which screens you accessed, and cookies.

We use only the Data that is relevant and necessary for each purpose on a case-by-case basis. If you choose not to provide some of the Data mentioned above, we may be unable to fully or partially provide our services, as many of our services require the Data mentioned above.

Vericode emphasizes that it does not process, for the general purposes set out here, Data considered sensitive by the LGPD, particularly those related to racial or ethnic origin, religious beliefs, political opinions, union membership, or affiliation to religious, philosophical, or political organizations, as well as data concerning health, sexual life, genetic or biometric data, when linked to a natural person. In specific and rare cases where we process such data, the processing is based on specific terms previously provided to the Data Subjects, with specific consent or based on express legal authorization.

3. PURPOSE OF THE DATA WE COLLECT

We collect data to:

(I) Present personalized ads to the Data Subject based on the data provided.

(II) Inform the Data Subject about updates, content, features, news, and events that we consider relevant to you, as well as to enhance our relationship and enrich your experience with us.

(III) Improve our services and products.

(IV) Measure user satisfaction with our services and/or products or the effectiveness of our advertising campaigns.

(V) Establish contractual relationships and manage, provide, administer, improve, and/or expand the services provided to the Data Subject, including adapting to the preferences and tastes of the Data Subject. (VI) Fulfill obligations arising from the use of our services and products.

(VII) Ensure the portability of registration data to another service or product provider if requested by the Data Subject, complying with Article 18 of the LGPD.

(VIII) Identify the professional profile of the Data Subject.

(IX) Conduct recruitment of employees if the Data Subject wishes to work with us.

4. DATABASE

The database created through data collection is owned by Vericode and is under our responsibility. Access, use, and sharing, when necessary, will be carried out within the limits and purposes described in this Policy.

It is also important to note that some data collected by Vericode may be stored in databases located in foreign countries, always aiming at greater security and ease of management. Therefore, international data transfers will be required, always with the utmost security and care, considering the best interests of the Data Subject. By agreeing to this Policy, the Data Subject consents to such data sharing.

5. DATA ACCURACY AND UPDATES

The Data Subject is solely responsible for the accuracy and correctness of the Data provided and collected. In case of any changes, the Data Subject must inform us so that we can keep the registration updated.

Additionally, the Data Subject can access, update, and complete their data, or request the deletion of their data, among other rights, by contacting us via our email privacidade@vericode.com.br. We will make every effort to respond as quickly as possible.

6. RETENTION AND STORAGE OF PERSONAL DATA

The Personal Data collected is stored in a controlled and secure environment for the following minimum periods:

(I) Registration data – 5 years after the end of the relationship, as provided in Article 43, §1 of the Consumer Defense Code (CDC).

(II) Records of access to internet applications – 6 months, as provided in Article 15 of Law No. 12.965/2014 (Marco Civil da Internet).

(III) Other data – as long as the relationship between Vericode and the Data Subject lasts, and there is no request for data deletion or consent revocation, as provided in Article 9, item II of the LGPD.

In cases where applicable law or regulatory standards authorize and provide for, as well as to preserve rights, the Data Subject's registration history may remain stored for periods longer than those mentioned above for security, credit protection, fraud control, and auditing purposes.

Finally, we clarify that the collected data will be stored on our servers located in Brazil, as well as in the cloud, which may require data transfer and/or processing outside Brazil.

7. DATA SHARING

The data collected by Vericode may be shared:

(I) With judicial, administrative, or governmental authorities, provided there is a legal and/or judicial determination.

(II) With companies responsible for analyzing and processing complaints related to violations of Vericode's Code of Ethics, which will always act in accordance with the terms set forth herein and applicable legislation.

(III) With companies hired for the recruitment and selection of new employees, which will always act in accordance with the terms set forth herein and applicable legislation.

(IV) Automatically, in the event of corporate transactions by Vericode, such as mergers, acquisitions, splits, or acquisitions.

The data provided by the Data Subject will be anonymized (making it impossible to identify the Data Subject) when shared for market intelligence research, advertising development, and press data dissemination.

It is important to note that some of the companies mentioned above may be located or have facilities in foreign countries. Therefore, international data transfers will be required, always with the utmost security and care, considering the best interests of the Data Subject.

8. DATA PROTECTION AND SECURITY

Vericode adopts technical, physical, electronic, and institutional measures to ensure the protection of Data Subjects' data.

Measures adopted by Vericode include access to data by authorized and necessary personnel only, signing confidentiality agreements by those with access to the data, and using reputable and secure environments for data storage.

Despite Vericode's best efforts to protect data and privacy, no information transmission is completely secure, and Vericode cannot guarantee that the information it receives and/or sends will not be accessed by unauthorized third parties due to cyber-attacks or errors by the Data Subject.

Therefore, Vericode encourages Data Subjects to take all necessary measures to protect and preserve their data and privacy, such as not sharing their data with third parties, including usernames and passwords.

9. DATA SUBJECT'S RIGHTS

In accordance with applicable legislation, Vericode clarifies that the Data Subject has the following rights:

(I) Confirmation of the existence of data processing.

(II) Access to data.

(III) Correction of outdated, inaccurate, or incomplete data.

(IV) Portability of data to another service or product provider if requested by the Data Subject.

(V) Information and the possibility of not providing consent, with information about the consequences if not provided.

(VI) Revocation of consent.

(VII) Deletion of data if requested by the Data Subject.

(VIII) Knowledge of which public or private entities Vericode has shared your data with.

To exercise your rights, simply contact us via our email privacidade@vericode.com.br. We will make every effort to respond as quickly as possible.

10. USE OF COOKIES

Vericode may use cookies on Our Platforms to enhance the User's experience by storing information when the User accesses Our Platforms, such as preferred language, location, date and time of access, among other variables we consider relevant, to tailor content according to their interests and needs.

On Our Platforms, we use necessary cookies, which are essential for the functioning of the services and features of Our Platforms, performance cookies, which collect information from the page accessed by the User to understand, for example, how and for how long they interact with our page or if it encountered errors, functionality cookies, which store your preferences to provide a more personalized experience, and advertising cookies, which direct ads and promotions related to your interests.

In this context, we use cookies and other measurement technologies to improve your browsing experience on our site, display personalized content, targeted ads, analyze site traffic, and understand where visitors come from.

We also clarify that the User can revoke their consent regarding cookies at any time, simply by deleting Vericode's cookies through their preferred browser settings. Below we outline the steps to manage cookies in some browsers:

Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Safari: https://support.apple.com/en-us/guide/safari/sfri11471/mac

Microsoft Edge / Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

We emphasize that if the User refuses all or some of the cookies from our pages, certain services may not function properly.

11. CHANGES TO THIS PRIVACY POLICY

We clarify that this Policy may undergo updates. Thus, it is the User's responsibility to periodically visit this page to be aware of the changes.

Furthermore, we stress the importance of the User carefully reading all communications sent regarding updates to this Policy.

Last updated on: July 13, 2023.

12. DATA PROTECTION OFFICER

For additional clarifications or new requests, please contact our Data Protection Officer via email: privacidade@vericode.com.br.

13. APPLICABLE LAW AND JURISDICTION

This Policy will be interpreted according to Brazilian law, in the Portuguese language, with the jurisdiction of your domicile elected to resolve any disputes arising from this Policy, unless otherwise provided by applicable law.

If you do not have a domicile in Brazil, given that the products and services are offered by us in national territory, you submit to Brazilian law and agree that any disputes arising from this Policy will be resolved in the Central Civil Court of the District of São Paulo/SP.

If any term of this Policy is deemed unenforceable by judicial or data authority, the remaining terms shall not be affected and will remain in full force and effect.

14. DEFINED TERMS

For the purposes of this Policy, the terms below will have the following meanings:

(I) Personal Data: information related to an identified or identifiable natural person;

(II) Sensitive Personal Data: personal data on racial or ethnic origin, religious belief, political opinion, membership in a trade union or religious, philosophical, or political organization, data concerning health or sexual life, genetic or biometric data, when linked to a natural person;

(III) Anonymized Data: data related to a subject who cannot be identified, considering the use of reasonable and available technical means at the time of its processing;

(IV) Database: structured set of personal data, established in one or several locations, in electronic or physical support;

(V) User: natural person to whom the personal data processed pertains;

(VI) Data Protection Officer: person appointed by the controller and operator to act as a communication channel between the controller, data subjects, and the National Data Protection Authority (ANPD);

(VII) Processing: any operation carried out with Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction;

(VIII) Anonymization: use of reasonable and available technical means at the time of processing, whereby data loses the possibility of association, directly or indirectly, with an individual;

(IX) Consent: free, informed, and unequivocal manifestation by which the data subject agrees to the processing of their personal data for a specific purpose;

(X) IP: Abbreviation for “Internet Protocol,” a numerical representation that identifies users' devices on the Internet or local networks;

(XI) Deletion: removal of data or set of data stored in a database, regardless of the procedure used;

(XII) International Data Transfer: transfer of personal data to a foreign country or international organization to which the country is a member.o