WP8 AGÊNCIA DIGITAL LTDA, the company responsible for the development of the CLICK GARAGE system, a private legal entity, with headquarters and jurisdiction in the city of Santa Maria, at Rua São Vicente Paloti, 70, Noal District, ZIP 97020-680, registered with CNPJ under No. 15.663.145/0001-40, hereby presents to its user ("Data Subject") through this Privacy Policy ("Policy"), the essential information about how their data will be used and processed.

This Privacy Policy details how WP8, through the Click Garage system, collects, stores, uses, shares and discloses the Data Subject's personal data, and clearly indicates the measures taken to ensure the protection of collected data.

When accessing the website or application, the Data Subject must read this Policy, expressing their agreement with its provisions. Through such act, the Data Subject demonstrates their free, express and informed acceptance, without any reservations, regarding all the content of this document.

Definitions

Legal bases: These are the legal justifications provided in the LGPD that authorize us to process Personal Data. These may be your consent, the need to fulfill a contract or compliance with a legal obligation, for example.

Personal data controller: Natural or legal person, under public or private law, responsible for decisions regarding the processing of personal data.

Cookies: These are small files that we transfer to your browser or device (such as a mobile phone or tablet) that allow us to recognize you, know how and when our website is visited, as well as how many people access it. They can be useful for better understanding your preferences and offering you more efficient products, services and experiences.

Personal data: Information related to an identified or identifiable natural person.

Sensitive personal data: Personal data about racial or ethnic origin, religious belief, political opinion, membership in a union or an organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person.

Data protection officer: Natural or legal person appointed by the Processing Agent to act as a communication channel between the Controller, data subjects and the ANPD, being responsible for implementing personal data protection techniques and conducting activities related to personal data protection.

General Data Protection Law: Law No. 13,709 of August 14, 2018, which regulates the processing of personal data, including in digital media, by natural persons or legal entities under public or private law, with the objective of protecting the fundamental rights of freedom and privacy and the free development of the personality of the natural person.

Personal Data Processor: Natural or legal person, under public or private law, that processes personal data on behalf of the Controller.

Data Subject: Natural person to whom the personal data refers, such as former, current or potential customers, employees, contractors, business partners and third parties ("You").

Processing: Any operation performed with personal data, such as those referring to: collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

What data will be collected?

On our website, the Data Subject can browse without sending any type of personal data. However, it is important to know that when contacting us, whether through communication apps (WhatsApp, Telegram, Messenger,...), telephone, email or even through our websites, we may request the following data:

Registration data: full name, telephone number, email, address, CPF or CNPJ number, date of birth, place of birth, profession, among others that may be requested including in registration fields;

Contact data for advertising: telephone numbers, mailing address, email and social media profiles;

Location data: geolocation, device data, date and time of access to the Solution and/or Platforms, obtained through technologies such as GPS, Wi-Fi networks and telephony;

Browsing data: Browsing data, such as cookies and device IDs; Internet Protocol address (IP Address) used to connect your computer to the internet; date and time of access; browser type; visit duration; pages visited; data about the access device, such as model, manufacturer, operating system, unique identifier, telephone operator, screen resolution, browser type and connection speed.

By providing their personal data, the Data Subject declares that they are legally capable, that the data provided is personal and true, and expressly authorizes, freely and spontaneously, that their data be processed for that specific purpose.

What are the legal bases and purposes for collecting the provided data?

All Personal Data collected is Processed ethically and according to the most reliable standards of security and confidentiality, in accordance with applicable legislation and regulation.

Below we detail the main Legal Bases for Processing the Personal Data indicated above, in scenarios where WP8 is the Controller of your Personal Data:

To fulfill our legal and regulatory obligations: We will process your data for the purpose of complying with legal and regulatory requirements provided for, including, in the Civil Code, the Internet Civil Rights Framework, the Bank Secrecy Law, the Money Laundering Law, among other applicable Standards;

When necessary for the execution of your contract and/or preliminary procedures related to it: We will process your data to fulfill the contract we have entered into with the Data Subject or for the feasibility analysis of a potential relationship;

Based on legitimate interest: We will process your data based on the legitimate interest of WP8, yours and your clients', our Partners and Affiliates, in accordance with the legal requirements and limits for this type of Processing;

For the defense of rights in judicial, administrative or arbitration proceedings: We will process your data for the eventual defense of our rights and interests in any types of conflicts, especially lawsuits and administrative or arbitration demands, including in the handling of complaints made through our ombudsman channels;

For credit analysis and protection: We will process your data whenever necessary for our Affiliates and/or Partners to perform analysis for possible credit granting, in Solutions and Platforms that require such Processing;

To ensure fraud prevention and Data Subject security: We will process your data in the processes of identification, validation and authentication of registration and/or access to Solutions and Platforms for fraud prevention purposes, observing, including, applicable regulations;

Through consent collection: WP8 may, in specific cases, require consent for the Processing of Personal Data.

Whenever WP8 requests your consent to collect any type of Personal Data, under the terms of the LGPD, the Data Subject may or may not provide it, being informed by WP8 of the consequences of their refusal, if requested.

Browsing data is captured through automated technologies, such as Cookies (browser Cookies, Flash Cookies and similar) and web beacons, and also via third-party tracking.

The Data Subject can configure cookies in the "options" or "preferences" menu of their browser. Note that by disabling cookies, the Data Subject may prevent some services on our websites from functioning correctly, affecting, partially or totally, their experience in these environments.

In addition to the legal basis for processing, the Data Subject's data will be used for the following purposes: properly identify them on the website and app; adequately respond to requests and questions to fulfill the Data Subject's rights; inform the Data Subject about news, features, content, news and other relevant events for maintaining this relationship; maintain analytical and statistical data about interaction with content; maintenance and improvement of website and app resources and functionalities, and; observation of browsing habits for service customization

With whom do we share your data?

When necessary, we may share your Personal Data with:

Partners and suppliers, in the development of our activities, and to enable the delivery of our products and provision of services;

Marketing and advertising companies, to select and produce ads consistent with your profile, as authorized;

Outsourced companies for the development of internal processes and website maintenance;

Financial companies, so that you can make payments through our website;

Public and government authorities to comply with court orders or requests from administrative authorities that have legal competence to make such requirements.

Our partners and service providers must comply with the LGPD and use the data exclusively for the purposes for which they were contracted. It is essential that they be cautious about the security and confidentiality of this data.

How long will your data be stored?

We keep your personal data until the purpose for which it was collected is achieved. In addition, we may keep it to comply with legal or regulatory requirements during the legal statute of limitations for possible contractual or legal liabilities.

What security measures do we adopt?

We invest in the implementation and updating of our technology resources. We adopt technical and administrative measures capable of protecting personal data from unauthorized access or situations of destruction, loss, alteration, communication or dissemination of such data, in addition to good information security practices transformed into strict standards of conduct, following legal provisions and market best practices.

WP8 is not responsible for illegal interceptions or violations of its systems or databases by unauthorized persons, nor will it be responsible for the improper use of information obtained by these means.

What are your rights regarding your personal data?

You can contact WP8 to exercise your rights whenever you want. They are:

Confirmation and Access: Allows you to verify whether WP8 processes your Personal Data and, if so, request a copy of the Personal Data we have about the Data Subject.

Correction and Cancellation: Allows you to request the correction of your incomplete, inaccurate or outdated Personal Data, as well as deletion of inadequate or excessive data.

Anonymization, blocking or elimination: Allows you to ask us to: (a) anonymize your data, so that it can no longer be related to you and, therefore, cease to be Personal Data; (b) block your data, temporarily suspending our ability to process it; and (c) delete your data, in which case we will erase all of it without possibility of reversal, except in cases provided for by law.

Portability: Request the portability of your Personal Data to another service or product provider upon your express request, observing commercial and industrial secrets, in accordance with future regulation by the National Data Protection Authority (ANPD).

Information about sharing: Know the public and private entities with which WP8 shares data, as provided in this Policy.

Withdraw consent given at any time: Clear and complete information about the possibility and consequences of not providing consent, as well as withdrawing your consent in relation to Processing activities that are based on this Legal Basis.

Opposition: We may process personal data even without your consent or a contract. In this case, it is necessary to demonstrate that there are legitimate reasons to process your data, such as, for example, preventing fraud or improving our communication. If the Data Subject does not agree with this processing, they may oppose it, requesting its interruption.

It is essential that, for your security, you know that we will need to confirm your identity before responding to your request. In addition, we will present a justification if it is not possible to fulfill your request.

If you have any complaints about how we use your personal information, we prefer that you contact us first. However, you also have the right to petition the National Data Protection Authority.

Revocation and Consent

The User who wishes to revoke their consent will proceed by requesting revocation of consent, as provided in paragraph 5 of article 8 of Law No. 13,709, of August 14, 2018, except for the cases provided for in article 16 of the same law. If this occurs, WP8 will use its best efforts to respond to all legitimate requests for revocation of consent, acting within up to 15 (fifteen) days. If it takes longer than expected, we will notify you.

Contact

If you have other questions about data protection and how we use your personal data, the Data Subject may contact our Data Protection Officer at any time through the email [email protected].

Privacy Notice Amendment

This Privacy Notice is subject to possible changes and updates, at any time, to allow the continuous improvement of our Solutions and Platforms and provide the Data Subject with increasing transparency.

In case of relevant changes, the Data Subject will be notified, however, we recommend that you regularly consult this Privacy Notice to stay updated regarding the Processing of Your Personal Data by WP8.