1.Who does this privacy notice apply to?

This privacy notice applies to anyone who has, in any way, their personal data processed by PINE DATA OFFICER. According to item X, of article 5, of the LGPD, processing of personal data consists of "every operation carried out with personal data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission , distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.”

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2.What is the purpose for the processing of personal data?

For managing requests for the exercise of rights of holder provided for in the LGPD.

For guidance and training of our customers on organizational and administrative practices and measures necessary to comply with the rules provided for in the LGPD. For hiring employees and associates to carry out the activities of the parent company, service providers, such as, but not limited to, experts, accountants, lawyers and other professionals and companies that can assist us in defending the interests of our clients and holders of Dice;

For contacts with customers, suppliers, service providers and others, whenever necessary to defend the interests of our customers.

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3.What personal data do we use?

We use registration data for the exercise of our core business, which consists of providing advisory services for the provision of services in charge of processing personal data.

As an example, so that we can respond to a request for the exercise of rights of the holder provided for by the LGPD, it is essential that the holder identify himself unequivocally, providing his name, identity, CPF, address and other registration data that may exist in the relationship with the controller.

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4.Use security measures to protect your personal data

Personal data processed by PINE DATA OFFICER are constantly monitored and supervised, and we adopt the following measures to promote information security:

We store personal data on servers with access control by personal and confidential passwords. The place where our physical server is located has physical security against unauthorized access.

We train and train our team constantly, and carry out a comprehensive program to adapt our activity to the LGPD.

We do not pass on any personal data of our customers or third parties to unauthorized persons and members of the parent company's core business, unless there is a court order, legal or regulatory obligation that requires us to do so.

We do not have commercial partners with direct and unrestricted access to our database and we do not, under any circumstances, commercialize the personal data of our customers.

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COMMUNICATIONS: E-MAILS AND OTHER MESSAGES SENT AND OUR ANTI-SPAM POLICY:

We only send any type of communication, whether by whatsapp, email, letter or other means, when necessary to defend the interests of our customers, or to charge for our services, due under contracts entered into.

We do not send spam of any kind, do not offer our services without solicitation, and have no targeted marketing policy or practice.

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5.Who do we share your personal data with?

In order to exercise our management activities for the exercise of rights of the holder provided for in the LGPD, as an external DPO, we will receive from our customers your request containing your personal data and any existing data, provided that it is strictly necessary for the management of the respective requests.

Personal data processed by PINE DATA OFFICER may be shared with external service providers, such as, but not limited to, experts, accountants, translators, reviewers, reviewers, lawyers and offices that act in partnership, always for the purpose of the exercise of our main activity, namely, the provision of services in charge of the processing of personal data.

Prior to receiving personal information and data, these third parties will have received guidance on the need to fully adhere to the parent company's privacy and data protection policy.

6.What are the rights of the holder of personal data?

Holders of personal data may request the exercise of their rights provided for in the LGPD, especially those included in its article 18.

However, it is important to point out that, eventually, some of these rights may have their exercise limited or impossible, due to any contractual, legal or regulatory obligation that may exist and that affects the legal relationship between the parties.

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7.What is the storage period of the collected information?

Personal data subject to processing may be stored and preserved for the purpose of complying with legal or regulatory obligations that affect the legal relationship between the parties.

We also take into account, for the conservation of personal data in our databases, the statute of limitations for the exercise of any right by data subjects against our company, such as, and not limited to, demand for accountability , civil liability action, damages repair, among others, as well as the rights of this parent company against contractors or third parties.

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8.How to exercise your rights under the LGPD?

For any request regarding the exercise of rights provided for in the LGPD, we provide the contact channel through this email - dpo@pinedataofficer.com.br . It is essential and essential that in your email there is an unequivocal identification of the applicant, as well as an objective description of your claim, so that we can respond to your request.