Privacy and Personal Data Protection Policy

Please read this Privacy and Personal Data Protection Policy carefully to understand our policies and practices regarding your Personal Data and how the processing of this data is carried out. This Policy applies to individuals (natural persons) who interact with AllStrategy services as consumers. This Policy explains how your Personal Data is collected, used, and disclosed by AllStrategy. It also informs you how you can access and update your Personal Data and make certain decisions about how your Personal Data is used.

This Policy covers our data collection activities both online and offline, covering the Personal Data we collect through our multiple channels, including - but not limited to - Websites, Apps, third-party Social Networks, Surveys and Events. Please note that we may aggregate Personal Data combined from different sources (e.g. our website and offline events).

As part of this, we combine Personal Data that was originally collected by different entities. You can refer to the section "About your rights regarding Personal Data" for more information on how to object to this. In some specific cases, if you decide not to provide us with your Personal Data that we have identified as necessary (We will indicate when this is the case, for example by explicitly placing this information on our registration forms), we may not be able to provide you with our products and/or services.

We collect your Personal Data through the following sources:

AllStrategy Websites

All of our websites may be used to collect Personal Data. This includes both websites that we operate directly through our domains and IP addresses, and websites or pages that we establish on third-party services, such as Facebook, Linkedin, and other third parties that offer these services.

Electronic mail and instant messaging systems

Services used to maintain electronic communications between you and AllStrategy, including those made available directly by us, or third-party services such as WhatsApp, Linkedin, SMS (short message service) and the like.

Plan mobile apps

Mobile apps provided directly by AllStrategy or through third-party services such as Google or Apple.

Offline registrations

Records completed offline, distributed during events and other interactions with AllStrategy.

Data received from third parties

Including, but not limited to, third-party social networks and websites such as Facebook, Instagram, Linkedin, and others, data aggregator services, AllStrategy's partners, public sources, and data received during acquisitions of other companies.

What Personal Data we collect and how it is collected

During your interaction with AllStrategy, using one of the previously mentioned collection sources, we may collect various types of personal data about you, as set forth below:

Contact Information

Includes any type of information that may facilitate our contact with you, telephone numbers, e-mail addresses, websites and social media profiles.

Technical information about your computer equipment or mobile devices

Details about your computer or other portable device that was used to access one of our websites, services or applications, including a record of the public IP address used to connect your computer or device to the internet, including your geographical location, web browser version.

Information about how you use our websites and services

During your interaction with our websites and services, we use automatic data collection technologies to capture information about the actions you have taken. This may include details such as which links you click, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as response times to content, download errors, and length of visits to certain pages. This information is captured through automated technologies such as Cookies (Browser Cookies, Flash Cookies and similar) and also via third party tracking. You are free to object to the use of such technologies, please refer to the details in the Section "About your rights regarding Personal Data".

Information from third party social networks

This is any data that you share publicly on a third party social network or information that is part of your profile on a third party social network (such as Facebook, Instagram, Linkedin and similar) and that you allow the third party social network to share with us.

This data may include details such as your basic account information (name, email address, date of birth, current city, profile picture, user ID, friends list, and similar information) and any other additional information or activities that you allow the third-party social network to share with us.

We receive your third-party social network profile information (or parts thereof) whenever you download an item or interact with an AllStrategy application or web service on a third-party social network, whenever you use a social network feature that is integrated with an AllStrategy website, or whenever you interact.

With us through a third-party social network. To learn more about how your information from a third-party social network is obtained by AllStrategy or to opt-out of sharing this social network information, please visit the specific third-party social network's website.

Sensitive Personal Data

AllStrategy does not normally handle Personal Data that is considered sensitive under applicable law, so we do not intend to collect or process sensitive personal data in the normal course of your interactions with our products or services.

Where we have a legitimate interest or need to process your sensitive personal data for any reason, we will obtain your prior, express and formal consent for any processing that is voluntary (e.g. for marketing purposes).

If we process your sensitive personal data for other purposes, we rely on the following legal bases: (l) detection and prevention of crime; and (ll) compliance with applicable law.

About Personal Data of Children and Adolescents

AllStrategy does not knowingly request, collect, process, store, or share personal data from underage children and adolescents. If we discover any unintentional handling of such data, we will remove that child's or teen's personal data from our records promptly.

About the use of Cookies, log files and similar files:

Cookies are small text files that may be placed on your computer or portable device by websites or web services that you use. They are used to ensure the proper functioning of websites and other online services, as well as to provide information to the owners of the website or online service.

Cookies are used to improve the use and functionality of AllStrategy's websites and other supported web services and to better understand how our visitors use our websites and online services and the tools and services they offer. Cookies make it easier for us to adapt AllStrategy's websites to your personal needs, making it easier for you to use them whenever possible, and to receive feedback on our users' satisfaction.

AllStrategy uses the following types of Cookies on its websites and supported services:

Session cookies

These are temporary cookies, which are deleted the moment you close your browser. When you restart your browser and return to the website that created the cookie, that website treats you as a new visitor.

Persistent cookies

These are Cookies that remain in your browser until you delete them manually or until your browser deletes them according to the duration period established by the cookie. These Cookies will recognize your return as a visitor to an AllStrategy website or service.

Necessary Cookies

These are Cookies that are strictly necessary for the operation of a compatible AllStrategy website or service. They allow you to navigate the site and use our features.

AllStrategy websites and compatible services may also use other tracking technologies similar to Cookies, which may collect information such as IP addresses, log files, and web browser beacons, among others. This data is also used to help us customize AllStrategy's websites and other compatible services to meet your personal needs.

IP addresses

An IP address is a number used on the Internet or on a network to identify your computer. Every time you connect to the internet your computer is assigned an IP address by your internet service provider. We may record IP Addresses for the following purposes.

Handling technical problems;

Maintaining the safety and security of our websites and other online services;

Gaining a better understanding of how our websites and other online services are used;

About our use of your Personal Data

The following describes the purposes for which AllStrategy collects your Personal Data, and the different types of Personal Data we collect for each purpose. Please note that not all of the uses below will be relevant to all individuals and may only apply to specific situations.

Conducting contests, promotions and other marketing actions

With your consent (where required under applicable law), AllStrategy uses your Personal Data to provide you with information about products or services, such as marketing communications and advertising campaigns. This may be done through different means of communication, including email, advertisements, phone calls and postal mailings (as permitted by applicable law), as well as our own websites and/or third party websites and social networks. In this situation, the use of your Personal Data is completely voluntary, which means that you can object, or even withdraw your consent at any time, to the processing of your Personal Data for these purposes. For more details on how to change your preferences about marketing communications, please see the section "About your rights regarding Personal Data" in this policy.

Social networks and third-party websites

We use your Personal Data when you interact with third-party social networking functions and websites, such as "liking", to provide advertisements and interact with you on third-party social networks. How these interactions work, the profile data AllStrategy obtains about you, and how to opt-out of them can be understood by reviewing the privacy policies directly on the respective social networks and third-party websites.

Legal reasons or merger/acquisition

If AllStrategy or its assets are acquired by or merged with another company, including by reason of bankruptcy, we will share your Personal Data with our legal successors, subject to the requirements of applicable law. We will also disclose your Personal Data to third parties (i) when required to do so by applicable law; (ii) in response to legal process; (iii) in response to a request by a competent legal authority; (iv) to protect our rights, privacy, safety or property; or (v) to enforce the terms of any agreement or the terms of our website, products and services, as required by applicable law.

About Disclosure of Your Personal Data

In addition to the entities that are part of AllStrategy, we may share your Personal Data with the following types of third-party organizations:

Third-party companies that use Personal Data for their own marketing purposes

Except in situations where you have given specific consent, AllStrategy does not license or sell your Personal Data to third parties for their own marketing purposes. In cases where this type of sharing occurs, the identity of these third parties will be disclosed prior to obtaining your consent.

About retention and ending the processing of your Personal Data

In accordance with applicable law, AllStrategy uses your Personal Data for as long as necessary to fulfill the purposes for which your Personal Data was collected, as described in this policy, or to comply with applicable legal requirements.

Personal Data used to provide a personalized experience to You will be kept only for as long as permitted under applicable law.

You can obtain further details about the retention of Your Personal Data through the communication channels detailed in this policy.

When the processing of your Personal Data ends, it will be deleted within the scope and technical limits of the activities, with retention authorized in the situations provided for in current legislation.

About the disclosure, storage or transfer of your Personal Data

AllStrategy takes appropriate measures to ensure that your Personal Data is kept confidential and secure. However, these protections do not apply to information that you have chosen to share in public areas, such as third-party social networks.

Users who may access your Personal Data

Your Personal Data will be processed by our employees or authorized agents as long as they need access to such information, depending on the specific purposes for which your Personal Data has been collected.

Measures taken in operational environments

We store your Personal Data in operating environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data.

About your rights regarding Personal Data

You have the right to confirm the existence of, access, review, modify and/or request an electronic copy of the information about your Personal Data that is processed by AllStrategy.

You also have the right to request details about the origin of your Personal Data or the sharing of this data with third parties.

At any time, you may also limit the use and disclosure, or revoke consent to any of our processing activities of your Personal Data, except in situations provided for in current legislation.

These rights can be exercised through the communication channels detailed in this policy, being necessary to validate your identity by providing a copy of your ID or equivalent means of identification, in accordance with current legislation.

Whenever a request is submitted without providing the necessary evidence to prove the legitimacy of the data subject, the request will be automatically rejected. We emphasize that any identifying information provided to AllStrategy will only be processed in accordance with, and to the extent permitted by, applicable laws.

AllStrategy is committed to doing its very best to address any questions you may have about how we process your Personal Data. However, if you have unresolved concerns, you have the right to complain to the relevant data protection authorities.

What are your choices about how we use and disclose your Personal Data?

AllStrategy makes every effort to give you freedom of choice over the Personal Data you provide to us. The following mechanisms give you control over the processing of your Personal Data:

Cookies/Similar Technologies

You can manage your consent by using your browser settings to refuse some or all Cookies and similar technologies, or to alert you when they are being used.

Advertising, Marketing and Promotions

You may consent to your Personal Data being used by AllStrategy to promote our products or services through checkboxes located on registration forms or by answering questions submitted by our representatives.

If You decide that You no longer wish to receive such communications, You may unsubscribe from receiving marketing-related communications at any time by following the instructions provided in such communications.

To unsubscribe from marketing communications sent by any means, including third-party social networks, You may opt out at any time by unsubscribing, by the links available in our communications, by logging into our websites, applications, compatible online services or third-party social networks, and by adjusting Your user preferences.

Changes to our Privacy Policy

Whenever AllStrategy decides to change the way we treat your Personal Data, this Policy will be updated. We reserve the right to make changes to our practices and this Policy at any time, provided that we remain in compliance with applicable law.

We encourage you to check back often, or whenever you have questions, to see any updates or changes to our Privacy Policy.

How to get in touch

You can contact us to:

Ask questions or make comments about this Policy and our privacy and Personal Data protection practices;

Make a complaint;

Confirm whether we are processing your Personal Data;

Obtain information on how to access your Personal Data;

Correct incomplete, inaccurate or outdated Personal Data;

Obtain information about the portability of your personal data to another service or product provider, upon express request, in accordance with current legislation;

Request the deletion of personal data processed with your consent, except in the cases provided for in current legislation;

Request details of the public and private entities with which we share your Personal Data;

Obtain information about the possibility of not providing consent and the consequences of such refusal;

Revoke consent for the processing of your Personal Data, except in the cases provided for in current legislation;

Other rights of the holder of personal data, according to current legislation.

For this, we ask you to contact us using the following channels:

Person in Charge of Personal Data Processing:

Lucio Vicente de Faria

dpo@allstrategy.com.br

Privacy Portal:

www.allstrategy.com.br/politica-privacidade

By phone:

+55 41 3013-2254

Personally or by regular mail:

General Mário Tourinho st, 1746 | 11th floor 80740-000, Bigorrilho - Curitiba/PR.

AllStrategy will receive, investigate, and reply to, within a reasonable time, any request or complaint about the way we handle your Personal Data, including complaints about non-compliance with your rights under applicable privacy and Personal Data protection laws.

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Contact

+55 41 3013-2254

+55 41 99254-9529

Mario Tourinho st, 1746,
postal code 80740-000, Curitiba-Brazil
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