PRIVACY AND DATA PROTECTION POLICY

This Privacy and Data Protection Policy is exclusive to this website and is intended to help you understand our practices for processing your personal data.

By browsing our website and providing Personal Information, you are agreeing to the collection, processing and use of it in the manner described in this Privacy and Data Protection Policy.

If you do not agree with any condition described here, do not provide your personal data through this website. We emphasize that, in this case, you may encounter access restrictions to the website or our services.

This Privacy Policy was prepared in accordance with the General Data Protection Law – LGPD (Law 13,709/2018).

WHAT IS THE OBJECTIVE OF THIS POLICY?

This Policy aims to clarify how this website collects, processes and stores the personal data of its users.

Our work complies with Law No. 13,709/2018, commonly known as the General Data Protection Law – LGPD, and with good privacy governance practices suggested by regulatory bodies, such as the National Data Protection Authority – ANPD

WHO IS THE DATA COLLECTED FROM?

We collect and process personal data freely provided to us by the user who accesses the website and talks to our customer service representative via chat. It is important to emphasize that we only collect what is strictly necessary for the legitimate purpose of developing our advisory service.

The information collected on this website may occur in the following ways:

· Personal Identification: provided by the user, such as name, email address and telephone number. Personal information will only be collected if it is voluntarily provided by users and, once provided, it means that there is authorization for it to be used, in accordance with the terms of this Privacy Policy.


· Navigational information on the website:
when you visit the AGÊNCIA FLUMA website, a ‘cookie’ is inserted in your browser. We use cookies to improve the use and functionality of our website and to better understand how users use it, as well as the tools and services offered there. In this way, information is collected, such as IP address, geographic location, referral source, browser type, duration of visit and pages visited. All such information is collected automatically and linked to personally identifiable information provided by the user, and will be treated as personally identifiable information for the purposes of this privacy policy. Logs are also used to record the activities of any Users who use the website. If you do not agree to the use of Cookies and/or Logs in this way, the User may: (i) adjust their browser settings to not allow the use of Cookies/Logs or (ii) not access Our Digital Platforms. Please note that disabling the use of Cookies/Logs may impact the User’s experience when browsing Our Digital Platforms.


· Contact history:
AGÊNCIA FLUMA stores information relating to contacts already made by users, such as content downloaded from our pages and interactions via email.

WHAT ARE COOKIES? When you use the website, your browsing data may be saved on the hard drive of your device AGÊNCIA FLUMA uses cookies to save user preferences and optimize your Internet access navigation (for example, measuring the number of visits, computing new visits, etc.). Cookies contribute to a smoother browsing experience and make the website more user-friendly. In addition, we may use this information to send products that best suit your needs. APPLICABILITY – Cookies are transferred from the website server to your browser, allowing AGÊNCIA FLUMA to identify your device during its validity or registration period. Remembering that there are cookies that are configurable and you can agree to store them or not and there are others that are required for technical reasons, that is, for secure access to the AGÊNCIA FLUMA website.

HOW ARE THIRD PARTY COOKIES USED?

Some functions within our website use third-party providers, for example, when you visit a page with a video embedded or originating from YouTube, or even when browsing our pages, in which we use Google Analytics for navigation metrics.


COOKIES ARE USED.
At AGÊNCIA FLUMA, they are used for the following purposes:

• Help you with navigation;

• Assist with our event registration, login and your ability to provide feedback;

• Analyze your use of our services;

• Measure the use of the website;

• Location of units;

• Campaign Monitoring;

• Assist with our marketing and promotional efforts (including behavioral advertising) to provide content that is more relevant to the browser.


HOW TO ACTIVATE OR DISABLE COOKIES. If you do not wish to receive cookies from our website, you have several options, such as opting out of receiving them and deleting those that would have been installed on your device.

Browsers with default settings accept the installation of cookies. However, you have the option to adjust these settings by opting out by adjusting your device’s browser settings.


CHANGES TO THIS COOKIE POLICY. AGENCY FLUMA may change this cookie policy statement as necessary.

WHAT LEGAL BASIS DO WE USE TO PROCESS PERSONAL DATA?

Data is collected for the specific purposes of:

· AGENCY FLUMA the contracted services;

(item V of article 7 of Law nº 13,709/18)

· Legal obligation, such as, for example, for tax purposes or to respond to any legal request and guarantee the full execution and functionalities of the Services;

(item II of article 7 of Law nº 13,709/18)

· Defend the interests of AGÊNCIA FLUMA in judicial or administrative proceedings;

(item VI of article 7 of Law nº 13,709/18)

· Sending information requested through the “Contact Us” tab on our website or to send a resume.

(item I of article 7 and 14 of Law No. 13,709/18)

Personal data processing operations are recorded and can be consulted by competent public authorities or by the data subject himself.

WHAT IS AUTHORIZED WITH THE COLLECTION OF YOUR DATA?

· We may process data relating to the use of our websites, products, cloud services and applications and through the use of these (“Services”). Data Usage may include your IP address, geographic location, browser type and version, operating system, time of visit to our websites (“Usage of Data”), number of uses of the Services, date of visit, among others. The source of Data Usage is Google Analytics.

· To improve the website experience, we collect information through internet traffic analysis tools, which record information such as the number of times you access our platform, IP address, geographic location, referral source, browser type , duration of visit and pages visited;

· To contact the user, when we request to send data such as name, telephone and email.

· In all the cases mentioned above, we are committed to guaranteeing the security of your data and deleting it after the end of the processing, in accordance with the legal storage periods for the same.

HOW LONG DOES DATA PROCESSING TAKE?

The Personal Data collected will be stored in a secure and controlled environment for a minimum period that follows the table below:

Type of Data Collected

Digital identification data

Other data

Storage Term

06 months

As long as the relationship lasts and there is no request for deletion or revocation of consent

Legal Basis

Art. 15, Civil Rights Framework for the Internet

Art. 9, Section II of the General Personal Data Protection Law

If it is of interest to the data subject, he or she may request its deletion at any time through the xxxxxx option on the website.

Consent to maintain data for a period subsequent to that listed in the table above will only be authorized for:

· Compliance with legal or regulatory obligations

WITH WHOM DO WE SHARE THE PERSONAL DATA COLLECTED?

AGENCY FLUMA does not share any data with the aim of obtaining economic advantage. Personal information provided by users may be accessed by:

· We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our controllers and all their subsidiaries), to the extent reasonably necessary for the stated purposes and in accordance with applicable legislation, as well as subject to the legal bases of treatment informed in this policy.

· We may disclose your personal data to our professional advisors insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the initiation, exercise or defense of administrative, arbitration and/or legal claims. Furthermore, we may disclose your data to our suppliers to the extent reasonably necessary to provide you with our services and ensure the security of your use of our Services and the use of your personal data, such as suppliers, marketing and customer service providers, cloud networks and services.

· In addition to the specific disclosures of personal data set out in this Clause, we may disclose your personal data whenever such disclosure is necessary to comply with a legal and/or regulatory obligation to which AGÊNCIA FLUMA is subject, as well as to protect your vital interests or the vital interests of another data subject.

We will also share personal information with other entities as long as access, use, retention or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; comply with applicable Terms of Service, including investigation of potential violations; detect, prevent or otherwise address fraud, technical or security issues; and protect from harm to the rights, property or safety of AGÊNCIA FLUMA, our users or the public, as requested or permitted by law.


DUTIES FOR THE APPROPRIATE USE OF PERSONAL DATA

When carrying out the work and activities of AGÊNCIA FLUMA, all recipients of this Policy must exercise care and attention so that the use of personal data is carried out appropriately, in accordance with legislation, as well as the company’s internal rules.


SPECIFIC DUTIES OF PERSONAL DATA HOLDERS:

Communicate about any changes to your personal data that interfere with your relationship with AGÊNCIA FLUMA; (change of email address and telephone number, for example);


SPECIFIC DUTIES OF EMPLOYEES AND PARTNERS:

· Data sharing can only be done when its purpose and legal basis are respected, always observing the principle of necessity and the processing of personal data always being restricted to the objectives and related activities authorized by AGÊNCIA FLUMA;

· Do not share personal data with unauthorized people, even if they are members of AGÊNCIA FLUMA’s partner team;

· Obtain authorization for data processing, as well as the necessary documents that demonstrate the designation of your competence to carry out the lawful data processing operation;

· Comply with all standards, recommendations and guidelines that ensure information and prevent incidents.


DUTIES OF ALL RECIPIENTS OF THIS POLICY:

· Report any suspected use and processing of data that does not occur lawfully and in accordance with the guidelines of this Policy;

· Communication can occur directly on the AGÊNCIA FLUMA Ethics Channel, via the email address: contato@agenciafluma.com

RIGHTS OF DATA SUBJECTS

Given the context of data collection, AGÊNCIA FLUMA reinforces the rights of its holders, according to LGPD guidelines, which are:

· You can confirm the existence of personal data processing and obtain access to your data at any time;

· If your data is incomplete, inaccurate or out of date, you can request that it be corrected;

· You may also request the anonymization, blocking or deletion of unnecessary, excessive data, or data processed in non-compliance with the LGPD;

· You can request information about data sharing;

· Request the deletion of your data that is processed with your consent, if you fill in the “Contact Us” tab on our website;

· You have the option of portability of your data to another human resources company, upon formal request;

· You have the right to revoke consent, without affecting the legality of any processing carried out before withdrawal.

When consent is revoked, it may directly interfere with the provision of a service. In these cases, the holder will be informed.

CANCELLATION OF OUR COMMUNICATIONS AND REMOVAL OF PERSONAL INFORMATION

To no longer receive emails and/or text messages from AGÊNCIA FLUMA, as well as request the deletion of the data provided on the website, you can request their cancellation, through the tab on the website xxxxxxxxxxxxxxxxxxx. It is important to mention that, when filling out any form again, the user will reinsert their data into our list.

Therefore, the cancellation request must be made again, if it is in your interest.

FOLLOW-UP COMMITMENT

We are committed to periodically monitoring this Policy, reinforcing our commitment to good privacy and data protection practices. Therefore, this Policy may be modified to ensure updates and recommendations issued by the National Data Protection Authority – ANPD and other competent bodies.

 

CONTROLLER

AGÊNCIA FLUMA, legal entity under private law, registered with the CNPJ/MF under no. 47.784.924/0001-90, with headquarters at Av. Fernando Correa da Costa, no. 567, Areão neighborhood, in the city of Cuiabá/MT – ZIP code: 78.010-400.

PERSON IN CHARGE AND COMMUNICATION CHANNEL

For any additional information or to exercise your rights as holder of the data entrusted to us, please contact our Data Protection Officer:

In charge: Bruna Karina Dias Areco

Email: contato@agenciafluma.com