Protecting your personal data is of utmost importance to us. Therefore, we process your data exclusively pursuant to the legal provisions. In this Data Protection Policy, we provide information on how ALDORO treats its personal data.

WHAT DATA IS PROVIDED TO US?

When registering with ALDORO, even in our online form available on the website, the following Personal Data are requested:

• Full name, email address, company name and phone number.

Whenever a registration is made in our systems, we understand that the interested party is civilly capable and that the data provided are personal and true, assuming the commitment to update them if there is any change.

Also, in order to ensure the security of our operations, we may use all valid means to confirm your identity, and if necessary we may request additional data, as well as copies of identification documents.

WHAT PERSONAL DATA DO WE COLLECT?

The foregoing information is provided directly by you, but there are other data that we may automatically collect when you use our services. Even so, you should know what they are:

• The IP address;
• Data from mobile devices from which access to the digital platform was given and other information such as the type and version of the browser used;
• Log data;
• There is the possibility of anonymously browsing and managing the cookies of the website. Simply change the configuration of your browser, making sure that certain cookies are kept so that our platforms may function. You can learn more about this in our Cookie Policy;
• Images captured by our security cameras, in case you visit us in any of our units.

WHAT WE PROCESS YOUR PERSONAL DATA FOR

 We will use your personal data when necessary to achieve any of the following purposes:

• Satisfactory performance of ALDORO’s business;
• Creating, amending and maintaining ALDORO’s user records;
• Obtaining generic statistics to identify the profile of our customers and develop our campaigns;
• Service and relationship with users as well as the continuous improvement of the service provided by ALDORO;
• Complying with legal obligations or requirement of the applicable law; in response to legal proceedings; in response to a request from the relevant legal authority; to protect our rights, privacy, safety or property; to enforce the terms of any necessary agreement or contracts or our terms;
• Protecting the rights of users, third parties (especially those related to intellectual property) and ALDORO itself;
• Making advertisements and publicity and promotional contacts.

DO WE SHARE YOUR PERSONAL DATA?

ALDORO may share your Personal Data to provide and operate our services, which will be done to achieve a legitimate and specific purpose. We may, for example, share your data with:

• Partnering companies and suppliers, for activities focused exclusively on the relationship that ALDORO has with you;
• Professional consultancy firms for banking, insurance, accounting or other technical consultancy services;
• Advertising companies, to select and produce advertisement consistent with your profile, as authorized;
• Government agencies, tax authorities, the Judiciary and/or other relevant authority to comply with existing obligations in the legislation. This processing may include your full qualification data, for example.

It is important that you know that we make every effort to ensure that your Personal Data does not need to be shared beyond an actual necessity, and we undertake to update this Policy whenever we notice that we need to include or exclude any sharing activity.

Thus, we wish you remain aware that when Personal Data is shared with a third party, it will occur only to achieve some legitimate and specific purpose previously informed to you.

Cookies

Cookies, tags, pixels or similar technologies (“Cookies“) are small text files stored on devices (computer, smartphone etc.) that keep information about the User’s navigation, such as the pages they visited, the objects of searches, purchase intentions, the website that originated the access, Internet Protocol (IP), the browser version, which ads they clicked on, their location, among other information from their internet browsing routine.

The most common purposes are to enable and personalize navigation, marketing targeting, conducting informative and statistical surveys to guide the market strategy at companies. Cookies, in general, can be classified as follows:

• Strictly necessary cookies: they guarantee the that our website will function properly and correctly. They do not identify an user and cannot be deactivated without harming or even making the operation of our website impossible;
• Performance cookies: they store anonymous information, such as number of visits, most accessed websites, among other statistical information regarding the management of operations and improvement of our website. These cookies do not identify an user and can be disabled; however, their deactivation may affect the proper functioning of our website;
• Functionality cookies: they enable the website to offer improved and customized features to users. Disabling these cookies may hinder some features of our website. These cookies collect information that can identify an user and be disabled;

• Advertising cookies: they use some information and direct personalized content to users, as per their own browsing preferences. These cookies collect information that can identify users be disabled; and

• Third-party cookies: these are the cookies placed by partners such as Facebook and Google, which collect information from users when they visit our website, so that these partners disclose our advertising materials on their platforms when users utilize them. These cookies collect information that can identify users and be disabled.

COOKIE MANAGEMENT

Cookies that can be found on the website can be disabled through the cookie management tool available on the homepage or in the settings of the internet browser utilized by users. To this end, we provide the cookie management link of the most popular browsers in the market (addresses may vary depending on the browser version):

• Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Google Chrome
• Safari
• Opera

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep the data with us only for as long as it is necessary to achieve some specific purpose, to comply with legal or regulatory requirements during the legal limitation period of possible contractual (including audit) or legal liabilities.

Aside from that, if the Data Controller requests, ALDORO will anonymize or delete the data from our servers, unless for some legitimate or mandatory reason, we have to retain the data for a longer time.

HOW DO WE KEEP PERSONAL DATA SECURE?

The security of personal data is a serious matter and the right of all holders. Thus, zealing and information security practices are strict standards of action, and must follow the legal provisions with regard to deploying and updating technological resources to ensure that all information and Personal Data collected are not subject to destruction, loss, amendment, communication or dissemination.

WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL DATA?

In compliance with the current legislation, ALDORO informs you of your rights regarding your Personal Data, guaranteeing the possibility of submitting requests based on the following rights:

The Holder of Personal Data may contact us to exercise their rights, which are:

• Knowing what Personal Data is processed by ALDORO;
• Requesting the deletion of their data;
• Request the change or correction of their data;
• Asking for information about the sharing of their data;
• Requesting a copy of their data in a legal and appropriate format and conveying them so as to use them in other services;
• Revoking the consent given to ALDORO for processing their data;
• Requesting the interruption of the submission of any marketing communication;
• Requesting the portability of their Personal Data to another service or product provider upon their express request, subject to commercial and industrial secrets, in accordance with future regulations of the National Data Protection Authority (ANPD).

You may still exercise any other right provided by law, even if not listed herein. As an exception, your request may not be met, but if it does, we’ll explain why. Yet, we anticipate that this will only occur if there is some legal basis for that.

WHO CAN I CONTACT ABOUT THIS SUBJECT?

If you have any questions, concerns or wish to exercise any of your rights regarding the processing of your Personal Data, or further wishes to make any complaint or request, please do not hesitate to contact our Person in Charge of Processing Personal Data, Ariza Otta Martendal, via [email protected].