1. Purpose of this privacy policy

We are committed to protecting your privacy online. We appreciate that you do not want the personal information you provide us to be distributed indiscriminately. This policy sets out when and how we use your personal information that you or others have provided to us

We can only provide you with a great service, consult you and/or transact with you if you provide us with your personal and business data. That's why we ask for your consent to use your data when you use our websites and we ask for your consent to this privacy policy when you engage with our website as described in this document. For the described business purposes, we collect data about you, such as the name and address of your company or employer, the type of company, your language preference, your personal name, address, date of birth, email address, telephone numbers , CNPJ or similar tax numbers, bank account information and other similar data. We also require this information to ensure that we do not conduct business with minors or end consumers and to meet our compliance requirements.

We will use the information you provide for the purposes described in this privacy policy. Your personal data will be used by Elebbre SA to provide you with the information, products and services offered through our websites, as well as for sales dialogue, email communication, contracts, billing, compliance, identity verification and carrying out transactions.

This privacy policy does not apply to other linked sites.

2. The information we collect

We will only collect and process personal data about you when we have a legal basis to do so. The two types of legal basis are "consent" and "legitimate interest"

• Consent : We ask for your consent before we collect information from you through our websites.
• Legitimate Interest : We may process your information for the purposes of our legitimate interests or the legitimate interests of third parties. For example, to process your order, protect you, us or others from threats (data breach or fraud), comply with laws and embargoes, or respond to your inquiries.

When we rely on your consent, you have the right to withdraw or refuse it at any time. Regarding legitimate interests, you have the right to object. In both cases, you can contact us by sending an email to privacy@elebbre.com .

We collect information from 5 sources:

• When you register as an Elebbre connection:  We collect personal information whenever you interact with our website. For example, when you create an account with us, participate in one of our programs, download one of our guides, request information or a quote on one of our products, order one of our products, initiate a chat with us, or sign up for our Newsletter. We may also collect personal information through our customer service department via phone, chat or email to respond to your requests and follow up if necessary .
• When you contact us : When you contact us by phone, email, on our portal or via the contact page of our website with general inquiries, we generally collect your name and contact details, as it is in our legitimate interest to ensure that we can adequately respond to your query.
• When you have expressed interest in our services or platform : We will handle your personal information (such as your name, email address, postal address, telephone number and industry preferences) to provide you with our news updates in accordance with preferences you have given us.

When we send you our news updates, because you opted in to receive them, we rely on your consent to contact you. If you have not opted in and we send you our emails with news updates, we do so because of our legitimate interest in promoting our business.

You can unsubscribe from our updates at any time by clicking the unsubscribe link at the bottom of any of our emails, sending an email to  privacy@elebbre.com  , or logging into your account and updating your subscriptions.

• Technical information when using our website : When you agree, we collect information about how you use our website. We use this information to improve our website and better understand how people use it. More details about what information we collect and how we do it are set out in our cookie policy.
• If our business is sold : We process your personal information for this purpose because we have a legitimate interest in ensuring that our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.

We may request and store confidential documents, such as identification documents and extracts from your business register, to verify your identity. This data is encrypted and we use it for transaction purposes only.

Cookies : A cookie is a small text file that we store on your device when you start visiting our website or in specific events such as user registration. Our websites use different types of cookies, beacons and other tracking and personalization methods (abbreviated as cookies) that distinguish you from other users. Cookies also provide us with information about how our website is used so that we can keep it as up-to-date, relevant and error-free as possible. Cookies also allow us to store your browsing preferences and settings so, for example, you don't have to repeat the login process each time you visit our website. That way we can offer you a friendlier experience.

You are always in control to use your browser settings to block all cookies. However, you may not be able to access all or part of our website when doing so. For more information about changing your browser settings and about cookies in general, you can visit www.allaboutcookies.org .

from third parties

We allow certain third-party companies, such as analytics partners and network advertisers such as Google™ and Facebook, to use cookies, web beacons and other storage technologies to collect or receive information from our website and elsewhere on the Internet and use them in training to provide measurement services and targeted advertisements. We use web analytics services such as Google Analytics to help us analyze how users use our website.

The data these third parties collect will be subject to their own privacy policies. You can always opt out of collecting and using information for ad targeting on any of these websites: www.aboutads.info/choices and www.youronlinechoices.eu . Opt-out of any of these networks only means that they will no longer provide targeted content or advertisements to you. This does not mean that you will no longer receive any targeted content or generic advertisements from us on our website or other websites.

The data these third parties collect will be subject to their own privacy policies. You can always opt out of collecting and using information for ad targeting on any of these websites: www.aboutads.info/choices and www.youronlinechoices.eu .

Opt-out of any of these networks only means that they will no longer provide targeted content or advertisements to you. This does not mean that you will no longer receive any targeted content or generic advertisements from us on our website or other websites.

Cookie Policy : As described above, we use first-party cookies to enable the functionality of our own websites, as well as third-party cookies provided by our service providers. You can find more information about the cookies used on our websites on the websites of our most important providers: Google Analytics, Google Adwords and Single Sign-On, Facebook, Hubspot, Hotjar, RD Station and Trusted Shops.

Classifieds Sites: We use different third-party sites, such as classifieds pages or online marketplaces, to advertise our products. Whenever you make a request for information on any of these sites, we receive your data by email containing details such as your email address, telephone number, name and company name.

You have the right to request information from us, whether or not we have made such requests for information and created a financial file. You may also obtain a copy of your financial file by providing us with a written request and proof of your identity to our postal address below.

3. How We Use Your Information

The information we collect and store is primarily used to enable us to best provide our services to you. We may use your information for the following purposes:

• To communicate and interact with you.
• To contact you with marketing information and commercial offers (including our newsletter) about products we think may be of interest to you, through any available channels.
• To personalize content, products and offers on our website and in our communication with you.
• To provide you with targeted advertising, including the use of remarketing technology via third-party websites (more on this in the Remarketing section below).
• Fulfill and track transactions and requests for products and information.
• To verify your level of engagement with our website and products, for which we may use Automated Profiling technologies (more on this in the Automated Profiling and Programs section below).
• To understand more about user behavior on our website, allowing us to improve the layout and/or content of our pages, personalize them for users, track which product pages have been accessed and use them for marketing purposes and sales.
• To process it at our company using services such as Gmail, Google Cloud Storage, Google Apps, RD Station and Dropbox, which may include servers in other countries, including the United States, under data processing agreements with our service providers to ensure a high standard of Data Protection.
• To comply with legal requirements.
• To detect and prevent fraud and other prohibited or illegal activities.
• With your consent, publish your testimonial along with your name on our website or in our advertisements (you can always withdraw your consent by contacting us).
• To verify your identity.

We retain your personal data for as long as your account exists or as necessary to fulfill the above business purposes. If you terminate your account by notifying us by email, we will delete your personal data after two years. However, we may retain some of your data after your account is closed as necessary to comply with our legal obligations, meet regulatory requirements, maintain security, prevent fraud or fulfill your request to “opt out” of other messages from us.

remarketing

Our network advertising partners (including Google and Facebook) collect information about your web activities on this and other websites through cookies, web beacons and other storage technologies (abbreviated as cookies) to provide you with targeted advertising on different websites across the internet. , based on your interests.

If you do not wish this information to be used to serve you targeted advertisements, you can disable Google's use of cookies by visiting Google's Ad Settings. Alternatively, you may opt out of a third party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page. Please note that this does not exclude you from receiving advertising. You will continue to receive generic ads.

Profile and Automatic Programs

To know your level of engagement with our website, we have automatic scoring rules that give points for certain actions performed on our website. For example, we assign high scores to people who have ordered one of our products. This data helps us to understand your interaction with our website and to provide, develop and promote only those products and services that are relevant to you.

We also have automatic programs that send emails that are triggered by your behavior on our website and different criteria, such as the time since you last visited our website or requested a quote. These programs help us deliver relevant marketing content to you at the right time so that you can get the most out of our products and services.

You may opt-out of receiving personal marketing communications from us by changing your communications preferences or using the opt-out link included in the footer of such marketing emails or by sending an email to privacy@elebbre.com

4. How we share and protect your information

We will not sell your contact information or email address without your permission and will protect your data with all reasonable efforts, for example with data encryption technology, secure data storage and proper operating procedures.

Disclosure of personal data

We may disclose your personal data:

• to our agents and IT service providers (eg web hosting providers or maintenance services)
• for any purpose necessary in connection with a business transaction we may have with you (eg customs authorities or logistics providers)
• to other companies in our group
• if we sell our business to a third party
• to business partners, such as our accounting service providers, where we have a legitimate business interest in doing so
• in any other case where we are required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the website or the rights, property or personal safety of any person.7. to Facebook and Google for the purpose of targeting you with ads
• for Trusted Stores in case you choose to use Buyer Protection when placing an order

We may also release aggregated statistics about visitors to our websites when describing our services to potential customers or partners and other reputable third parties and for other lawful purposes, but these statistics will not include personally identifiable information.

International transfer of personal data

In certain circumstances, it may be necessary to transfer your personal data to our service providers outside Brazil, including to countries that do not offer equivalent adequate protection for personal data. Where this is the case, we will take reasonable steps to ensure that your personal data is adequately protected.

5. Data Security

We attach great importance to the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. Documents uploaded by you are stored in a securely encrypted location. You can request the deletion of these documents at any time pursuant to clause 7.

We will use technical and organizational measures to protect your personal data, for example using personal password and username, secure servers and SSL encryption.

You should keep in mind that sending information over the Internet is never completely secure. We cannot guarantee the security of information while in transit over the internet.internet and such submission is at your own risk. All we can do is use all our reasonable efforts to protect your data and ensure that we maintain a safe and secure environment in which to use your data.

It is advisable to close your browser when you are finished with your user session to help ensure that others do not access your personal information if you use a shared computer or a computer in a public place.

6. Protection of Children's Privacy

Our Sites are only intended for use by professional users and individuals acting in a professional capacity who have reached the age of eighteen (18) and our Sites and Marketplaces are not intended for use by consumers. Our website may not be used by children of any age. We do not intentionally target or collect personal data from children of any age. We encourage parents and guardians to take an active role in their children's online activity.

7. Customer rights

If you are concerned about your data, you have the right to request access to the personal data we may hold or process about you and request corrections, if applicable, by providing us with a written request and proof of your identity to our postal address below. You can contact us with any questions or concerns about your data via email or telephone. We will respond to your request within 30 business days.

You have the right to withdraw any authorizations, permissions or consent you have provided to us by notifying us. You have the right to request free disclosure of the data we hold about you in a structured or machine-readable format and to request that we do not transfer your data to third parties with whom we work. You can request that we block your data or that we delete any data we hold about you (right to be forgotten). In that case, we may no longer be able to provide you with access to our sites or services and we will terminate our relationship with you as applicable and considering the circumstances on a case-by-case basis of your requests and the situation.

Subject to the General Law for the Protection of Personal Data (LGPD), you have the right to object to the use of your personal information by Elebbre SA. You can also consult the supervisory authority to help enforce your rights or file a complaint.

8. Changes to the Privacy Policys

We may modify sections of our Privacy Policy or add new ones to reflect changes in our practices. If this happens, we will always inform you by email indicating the changes and on which date it was updated. We also encourage you to review our Privacy Policy from time to time to learn about new changes.

9. Our contact details

We welcome your comments and questions. If you wish to contact us, please send an email to privacy@elebbre.com or write to Elebbre SA, Avenida Queiroz Filho, 1700, Vila Hamburguesa, 05319-000 São Paulo, Brazil or call +55 11 2925-764341 .