Privacy and Personal Data Protection Policy (LGPD)

1.Introduction

Agência Firma values the privacy, security and protection of the personal data of everyone who visits its website, uses its services or contacts it through its communication channels.

This Privacy Policy explains how personal data may be collected, used, stored, shared and protected, in compliance with Brazilian Law No. 13,709/2018, known as the General Personal Data Protection Law (Lei Geral de Proteção de Dados Pessoais, LGPD).

By browsing the website or providing personal information, users can consult in this policy the data processing practices and the rights guaranteed to them by law.

2.Collection of personal data

Agência Firma may collect personal data provided directly by the user or obtained automatically during browsing, according to the features available on the website.

The data that may be collected, when applicable, includes:

• Full name;
• Email address;
• Phone number;
• Information provided in contact, registration or service request forms;
• Browsing data, such as IP address, device type, browser and pages visited;
• Other information necessary to handle requests or to provide the services offered.

Collection and processing will be carried out for specific, legitimate purposes disclosed to the user, in accordance with the applicable legal grounds.

3.Purpose of data processing

Personal data collected may be used, according to the nature of the interaction and applicable law, to:

• Respond to requests, questions and contacts made by users;
• Enable customer service and the provision of products or services;
• Send information and communications related to the requests received;
• Share informational, institutional or promotional content, when permitted by law;
• Improve the browsing experience and the operation of the website;
• Carry out statistical analyses and performance evaluations;
• Comply with legal, regulatory or contractual obligations;
• Ensure the security of operations and prevent improper activities.

The processing of personal data shall observe the legal bases provided for in the LGPD, including, when applicable, the data subject’s consent, the performance of a contract, compliance with legal obligations and legitimate interest, subject to the requirements established by law.

4.Sharing of personal data

When necessary and in accordance with the stated purposes, personal data may be shared with suppliers, service providers, technology platforms and partners involved in the company’s activities.

Such sharing may involve, when applicable, hosting, customer service, communication, performance analysis, relationship management and other tools used in the operation.

Data may also be shared to comply with legal obligations or to respond to requests from competent authorities, under the terms of the law.

Agência Firma will seek to ensure that sharing takes place appropriately, observing the principles of necessity, security and personal data protection.

5.Cookies and browsing technologies

The website may use cookies and similar technologies to enable features, understand how users browse, analyze page performance and, when applicable, personalize content or communication actions.

Cookies may include categories such as:

• Necessary: used for the proper functioning of the website;
• Analytics: used to understand browsing patterns and performance;
• Functional: used to store certain user preferences;
• Marketing: used, when applicable, to measure campaigns and personalize advertising communications.

Users can manage cookies through their browser settings and, when available, through the website’s own privacy preference tools.

The use of cookies and similar technologies will comply with the applicable legal requirements.

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6.Data storage and security

Personal data will be stored for the period necessary to fulfill the purposes for which it was collected, subject to legal and regulatory obligations and the other retention cases provided for by law.

Agência Firma will adopt appropriate technical and administrative measures to protect personal data from unauthorized access and from accidental or unlawful destruction, loss, alteration, communication or improper processing.

Although protective measures are adopted, no digital environment is completely free of risk.

7.Data subject rights

Under the LGPD, data subjects may exercise, as applicable, the following rights:

• Confirm the existence of processing of their personal data;
• Request access to the data processed;
• Request the correction of incomplete, inaccurate or outdated information;
• Request the anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the law;
• Request data portability, subject to the applicable rules;
• Request the deletion of data processed on the basis of consent, except for the legal retention cases;
• Obtain information about the public and private entities with which the data has been shared;
• Obtain information about the possibility of not giving consent and the consequences of refusal;
• Revoke consent, when that is the legal basis used for processing;
• Request the review of decisions made solely on the basis of automated processing of personal data that affect their interests, under the terms of the law.

Requests may be made through the contact channel indicated in this policy and will be reviewed according to the deadlines and conditions set out in the applicable law.

8.Links to third-party websites

The website may contain links that direct users to third-party pages, platforms or services.

Agência Firma is not responsible for the privacy practices adopted by these external environments, and users are advised to consult their respective policies before providing personal information.

9.Changes to this Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in data processing practices, in the website’s features or in the applicable law.

The current version will be available on this page, together with the date of its last update.

10.Contact and LGPD-related requests

To clarify questions about this Privacy Policy, obtain information about the processing of personal data or exercise the rights provided for in the LGPD, please contact us through the channels below:

• Company: Agência Firma
• CNPJ (Brazilian company ID): 20.431.153/0001-09
• Privacy contact email: [email protected]
• Service channel: +55 11 99185-2903

Requests will be received and handled in accordance with the provisions of the law in force.