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Data Privacy Policy

Fugini is concerned with the privacy and security of your data and is committed to respect it. With this thought we created the data privacy policy, to clearly establish all the treatment that your information will receive during the processes.

This policy clarifies to the owners and other interested parties the types of data collected, the form, the treatment, the storage and the reason for its collection, as well as informing how the owner can manage or delete their personal data. For this reason, we recommend that you read our policy completely.

This policy covers all units and companies of the Fugini group, all customers, employees and partners.

1. Reference

General Law for the Protection of Personal Data or LGPD, Law No. 13,709, dated August 14, 2018.

2. Consent

By using our websites and/or our digital services, you acknowledge and accept the entirety of the terms and conditions of this policy, and agree to be bound by it, freely and spontaneously. Likewise, you consent to the collection and use of your personal data by Fugini, which may be stored/collected by us.

3. Definitions

To establish this data privacy policy, the terms set forth and used herein shall have the meanings ascribed to them below:

  • Policy: Designation given to this Privacy Policy;

  • Consent: Free manifestation by which the holder agrees to the processing of his/her personal data for a specific purpose;

  • You or Data Subject: Natural person browsing Fugini's websites, holder of the personal data subject to processing;

  • Websites: Fugini websites to which this policy is applicable, including their respective subdomains and hotsites;

  • Controller: Designation granted by law to the natural or legal person, of public or private law (Fugini), to whom the decisions concerning the processing of personal data are made;

  • Children and Adolescents: Definition provided in art. 2 of Law No. 8,069, of July 13, 1990, namely: "A child is considered, for the purposes of this Law, a person up to twelve years of age incomplete, and an adolescent between twelve and eighteen years of age."

  • Anonymized Data: Data related to the holder that cannot be identified, considering the use of reasonable and available technical means at the time of the data processing, which assist the controller in creating better experiences to the holder when navigating the websites;

  • Personal Data(s): Means information relating to an identified or identifiable natural person, including information that identifies and describes him/her, that is linked and/or can be reasonably linked, directly or indirectly, to the data subject, alone and/or in combination with other information provided to and/or collected by us.

  • Sensitive Personal Data(s): Personal data about racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data concerning health or sexual orientation, genetic or biometric data, when linked to a natural person;

  • Information: Anonymized data that shows the behavior of the holders on the websites, that is, the pages displayed and browsed by the holder on the websites, their dwell time and the path traveled;

  • IP or Internet Protocol: Internet Protocol, being an address assigned to each device (cell phone, personal computer, tablet, among others), in order to identify it on the world wide web;

  • General Law on Personal Data Protection or LGPD: Law No. 13,709 of August 14, 2018, known as the General Law on Personal Data Protection;

  • Operator: Natural or legal person, of public or private law, who performs the processing of personal data on behalf of the controller;

  • Contact Us: Fugini's Customer Service;

  • Processing: Any operation carried out with personal data, such as those related to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of the information, modification, communication, transfer, dissemination or extraction;

4. Data Privacy Policy Guidelines

4.1. Rights and Preferences of the Data Subject

In accordance with the legislation in force, Fugini guarantees the holder rights regarding the treatment of his/her personal data, namely:

  • The confirmation of the existence of processing of their personal data;

  • Access to the data collected through the websites;

  • The correction of his/her data, in case they are incomplete, inaccurate or outdated;

  • The portability of your personal data, through express request by the holder, as provided for in the applicable legislation;

  • The information about the possibility of not providing your consent, as well as to be informed about the consequences in case of denial;

  • The information about the public and private entities with whom your data has been shared;

  • The possibility to revoke consent for the processing of certain personal data, as well as to request the deletion of data processed on the basis of consent.

Should the data subject request the deletion of data or the revocation of their consent, access to their websites and functionality may be compromised or become unavailable.

4.2 What Information We Collect

Fugini may collect personal data including, but not limited to, your name, e-mail address, marital status, credit card number, address and geolocation, personal document data and numbers (ID, CPF, CTPS, functional ID number, etc.), the IP address of your personal device/equipment, Information on the pages viewed, dwell time and the path taken by you on our websites.

Eventually, Fugini will collect sensitive personal data of the holder, especially those necessary for the creation of marketing campaigns, such as your personal preferences, among others, on which occasion we will inform you in advance, as well as collect your specific authorization, at your sole discretion to do so.

4.3. Personal Data of Children and Adolescents

Fugini does not recommend that the websites be accessed or used by children or teenagers. Thus, if any personal data of a child or adolescent is:

(i)    Accidentally collected by Fugini;

(ii)   Provided voluntarily by the holder under age and/or Fugini is induced to an error in the collection of personal data by the child or adolescent, as soon as the situation and age of the holder are confirmed, such personal data will be immediately deleted from our databases.

Exceptionally, and under the terms of §3 of article 14 of LGPD, the personal data of children or adolescents may be stored when they voluntarily provide it to Fugini, or when Fugini is induced to error by them in the treatment of their personal data, so that, when Fugini judges necessary and at its sole discretion, the data of the parents or legal guardian of the child or adolescent are contacted to report the situation and when it is possible to identify them (their parents or legal guardian).

If such identification is not possible or after the situation has been reported to the parents or legal guardian of the child or adolescent, their respective personal data will be deleted from our databases on an ongoing basis.

If we learn that we have collected personal data from a child, we will take reasonable steps to delete the personal data in question.

This may include deleting the child's or teenager's account.

4.4. How We Collect Your Information and Personal Data

We collect your information from you when you voluntarily provide it to us:

  • When the holder subscribes on our website or uses the services provided by us, or when the holder uses the services provided in our online store, the following personal data will be collected: email, name, CPF number, telephones, date of birth and address;

  • When you use our electronic platforms, we collect personal data about your use of the platform automatically or semi-automatically;

  • When you fill out forms on our website;

  • When you contact our Contact Us by telephone, communication applications, third-party social networks and/or e-mail;

  • When contacted by email, telephone or communication applications (WhatsApp, Telegram, Zoom, MS-Teams and other official Fugini channels);

  • When contacted personally, to perform specific themes or registrations, marketing campaigns and/or opinion polls, upon obtaining consent for collection of personal data, obtained physically or digitally;

  • When using our application intended for smartphones, tablets or desktop / laptop;

  • And finally when using third party platforms and social networks.

4.5. Use Of Cookies

To optimize your experience while browsing, we make use of cookies.

In addition to the personal data voluntarily submitted by you, we use other technologies to collect information and personal data, such as cookies.

What are "Cookies"?

Cookies are small files or information that a Web site can send to a browser, which may be stored on your hard drive so that we can recognize you when you return to the Web site. Cookies can enhance your online experience by saving your personal preferences while visiting our Website.

They do not contain any Personally Identifiable Information.

You can set your computer to notify you when you receive a cookie, or to disable cookies altogether. You can also delete your cookies once you leave the Website. For more information on how to do this, please refer to the "help" section of your browser or visit:

Although you are not required to accept cookies when you access our Website, if you set your browser to reject cookies, you may not be able to use all of their features and functionality.

What cookies do we use?

  • Essential Cookies - These are essential to access specific areas of our website. They allow you to navigate the site and use its applications, such as accessing secure areas of the site through login. Without these cookies, services that require it cannot be provided.

  • Analytical Cookies - Used to analyze how users use the site and monitor its performance. This allows us to provide a high quality experience by customizing our offering and quickly identifying and fixing any problems that arise. For example, we use performance cookies to learn which pages are most popular, which method of linking pages is most effective, or to determine why some pages are receiving error messages.

Based on site usage, we may also use these cookies to highlight articles or services on the site that we think will be of interest to users.

These cookies are used only for statistical creation and analysis purposes, and never collect personal information.

  • Functionality Cookies -These cookies allow us to remember user preferences. For example, cookies avoid typing the user's name each time the user accesses the site. We also use functionality cookies to provide enhanced services to the user, such as commenting on an article. In short, functionality cookies store the user's preferences regarding the use of the site so that they don't have to re-configure the site each time they visit.

  • Third Party Cookies - Used to measure the success of applications and the effectiveness of third party advertising on our site.

  • Advertising Cookies - Used to target advertising based on each user's interests and the number of visits they have made, allowing you to limit the number of times the ad is displayed. These cookies help measure the effectiveness of advertising.

4.6. How We Use Your Information and Personal Data

Your information and your personal data collected, will be used by Fugini for the following purposes:

  • To provide a personalized experience when you use our website;

  • Display personalized advertisements when you visit our Website;

  • To conduct marketing campaigns;

  • Better understand your interests and needs;

  • Improving our products and services;

  • Provide you with the products, information and services you request;

  • For security, credit, or fraud prevention purposes;

  • Provide you with efficient customer service;

  • Contact you regarding matters that we believe may be of interest to you;

  • Invite you to participate in surveys that provide us with feedback;

  • Improve the content, functionality and usability of our Web sites;

  • Periodically send you newsletters on subjects of interest to you, related to Fugini;

  • Improve our marketing and promotional efforts;

  • Customer Service through Contact Us or other own or third party contact channels (including social networks);

  • To meet contractual and/or legal obligations;

  • For any other purpose identified in an applicable Privacy Notice or other agreement between Fugini and You.

4.7. Sharing Data with Third Parties

Fugini will not disclose and/or assign your personal data and/or sensitive personal data to third parties that do not have a legal relationship with Fugini (contract, for example). However, we may share your personal data and/or sensitive personal data with third parties performing functions for Fugini, such as data storage and processing servers, companies contracted to perform marketing services, among others, who will act on behalf of Fugini as operators, who have secrecy, confidentiality and Personal Data protection obligations. In the same way, if requested by a competent authority in the fulfillment of its legal attributions, or by order, decree, regulation or government rule, or in case of violations or suspected violations of this or the Law, Fugini may be required to make available the information and personal data stored in our power. Fugini, however, undertakes to strictly disclose the Information and personal data requested in order to achieve the required purposes.

Anonymized data, such as statistical reports on Website usage access (and other Information) and market trends, which do not reveal the identity of the data subjects, may also be shared with subcontractors or business partners of Fugini.

As Fugini develops and grows, which may be through, but not limited to, a corporate transaction, such as an acquisition, merger, consolidation, spin-off, or through the sale or purchase of companies, products and/or assets, a data subject's personal data may be transferred.

In such transactions, information and personal data about customers and data subjects is generally one of the transferable assets of the business.

4.8. Retention of personal data and/or sensitive personal data

Fugini will keep personal data and/or sensitive personal data for the period necessary to fulfill the purposes set out in this policy or until eventually requested by the holder to delete such data, when so possible and applicable. In this case, even after the request for exclusion, Fugini may keep the Personal Data stored for the statute of limitations established by law.

4.9. Security

Fugini is committed to protecting the personal data of our data subjects. To this end, technical and organizational measures are implemented to help protect the security of your personal data. However, it is important to note that no system is completely secure. Therefore, please be advised that we use the following tools and mechanisms for digital security:

  • We employ technological mechanisms to protect against unauthorized access to the systems, and these are considered a controlled and secure environment;

  • We provide access to personal data storage locations only to previously authorized persons;

  • We apply mechanisms for authenticating access to systems that hold personal data;

  • Technical protection measures such as firewall and endpoint.

The password protects the user account, so we encourage users to use strong passwords on their accounts (using uppercase and lowercase letters, numbers and special characters where possible, and avoiding using words or dates), to limit access to the computer and browser, not to access our Platform on public or shared computers, and to log out by clicking "Logout" after using the Platform.

4.10. Contacts and Requests

For any questions or clarifications about this policy and our privacy practices, suggestions, complaints, requests for access, removal or correction of personal data, please contact us through the following communication channels attaching proof of your identity (such as ID, CPF or similar):

Personal Data Handling Officer e-mail: seginf@fugini.com.br

Phone: (16) 3242 5566 - extension 5729

Mail: Av. Fugita, 1000 - Jardim Paraiso, Monte Alto - SP, 15610-000, to the attention of the Information Security Sector.

Any request will be attended to within the legal timeframe and complaints will be investigated with due impartiality. If the request is made by a person other than you, without providing evidence or proof that the request is legitimate on your behalf, it will be rejected.

4.11. Law

This policy shall be governed and interpreted in accordance with the Laws of the Federative Republic of Brazil, especially the General Law of Protection of Personal Data, regardless of the laws in force in other countries and territories.

5. VALIDITY AND UPDATING

The holder declares that he/she is aware and irrevocably accepts that Fugini may, without prior notice and at our sole discretion, modify, add or remove any terms or conditions of this Policy.

Any modifications to this Policy will be immediately For this reason, we recommend that you revisit this Policy frequently.

This Policy is now fully effective.

Any updates to the way we treat your personal data will be made in this Privacy Policy, which may be changed at any time with the express permission of the Board of Directors.

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