PRIVACY POLICY

IT BROKER SERVICOS OPERACIONAIS LTDA., Limited, liability company headquartered in the city of São Paulo, State of São Paulo, at Alameda Vicente Pinzon, n. 54 - 7 floor, Vila Olimpia - SP. Zip Code: 04547-130, registered in the National Register of Legal Persons of the Ministry of Finance (“CNPJ / MF”) under No. 18.901.359 / 0001-03 (“ITB360”), creator of the ITB360 platform (“ITB360 System”) for the ITB Databroker, ITB Databuilder, ITB Data Analyzer, ITB Infinity and ITB Salesbot solutions that can be contracted through its website (“Platform”). Through this Privacy Policy (“Policy”),  ITB360 presents its Users with the conditions and essential information about the data to be received.This Privacy Policy is an integral part of the Terms and Conditions of Use.

1.Definitions
1.1. For the purposes of this document, the following definitions and descriptions should be considered for your better understanding: Platform: Designates the digital platform, made available by ITB360, which enables and makes ITB360 services available to Users. User: Any and all natural or legal persons able to seek and enjoy the services provided by ITB360.

2.Information Privacy

2.1. The information we collect includes, but is not limited to:
a)Company name;
b)CNPJ / Company registration number;
c)Email address;
d)Telephone for contact;
e)Information about the device's browser and operating system;
f)IP address;
g)Web pages / application sessions visited;
h)Clicked links and buttons;
i)Data and information on commercial transactions carried out between Users and Partners.

2.2. We are not responsible for the veracity or lack of it in the information provided by Users, as well as for its outdating when it is your responsibility to provide it accurately or update it.

2.3. The collected data will be used for the following purposes:
a) Properly identify them on the Platform;
b) Manage, provide services and fulfill obligations arising from the use of our services and products;
c) Properly attend to your requests and doubts;
d) Keep your records updated for purposes of contact by phone, instant communication applications, electronic mail, SMS, direct mail or other means of communication;
e) Improve the use and navigation experience of our Platforms;
f) Perform statistics, studies, research, and surveys relevant to the activities of their behavior when using the Platform;
g) Promote our services and products, inform about news, features, content, news and other relevant events;
h) Protect us from rights and obligations related to the use of our Platform;
i) Collaborate and / or comply with a court order or request by an administrative authority;
j) Share the data collected with our partners to maintain and improve our Platform, products, and services;
k) Share the data collected using cookie technology and tools for personalization and recommendation of products and offers, to allow business partners to have access, in addition to offering a more appropriate experience with users;
l) Collect and analyze anonymous data from third-party software including, without limitation, Google Analytics, KISSmetrics, Linkedin, MixPanel, for parameterization and creation of metrics; and
m) Share and transfer the data collected to business partners, provided that for the specific purpose of enriching its database and preventing the occurrence of fraud and associated risks.
n) The use of data may eventually cover purposes other than those provided above, provided that it is duly authorized with the express consent of the User.

2.4. The database formed through data collection on the Platform is our property and responsibility, and its use, access, and sharing, when necessary, will be made within the limits and purposes of the ITB360 business and can be made available for consultation and assigned to our business partners, suppliers and authorities, provided that they comply with the provisions of this Privacy Policy.

2.5. From now on, the User is aware that we can enrich our database, adding information from other legitimate sources - including those derived from databases of other companies that relate to ITB360, and expressly express consent when agreeing with the terms of this Privacy Policy.

2.6. Internally, our Users' data are accessed only by professionals duly authorized by ITB360, respecting the principles of proportionality, necessity, and relevance to the objectives of ITB360 and the ITB360 Payment System, in addition to the commitment to confidentiality and preservation of privacy under this terms of this Privacy Policy.

2.7. ITB360 uses technological resources in order to guarantee the inviolability of the data. These techniques include (i) encryption techniques; (ii) regular monitoring of the system; (iii) periodic security tests and (iv) installation of barriers against improper access to the database (firewalls).

2.8. ITB360 recommends that Users keep their access data on the Platform in total confidentiality, avoiding its disclosure to third parties. We do not ask for your password outside the website, by phone, email, or any other means of communication.

2.9. ITB360 has a procedure in place to deal with any suspected violation of its database. In such cases, ITB360 undertakes to notify Users under the terms of this Privacy Policy.

2.10. We have business partners who can offer services through features or websites accessed from our Platforms. The data provided by the Users to these partners will be their responsibility, being thus subject to their own data collection and use practices, without any burden being placed on ITB360 for the treatment of such information.

2.11. The activities of Users on the Platform, will create, when possible and applicable, logs with the following information:

a) User IP address;
b) Access and actions performed by the User on the Platform;
c) Pages and screens accessed by the User on the ITB360 Platform;
d) Dates and times of each User action on the ITB360 Platform, in addition to the access he makes to the pages and screens of the tools and features he uses;
e) Information about the device used by the User, such as version of the operating system, device location, browser, among other installed applications and software;
f) Session and User ID, when available.

2.12. We may use other technologies to collect our Users' browsing data, which includes, but is not limited to, cookies, Web beacons, and JavaScript resources. However, such technologies will always respect the terms of this Privacy Policy.

3. Two Rights of Data Subjects
3.1. The User may exercise his rights known as ARCO (Access, Rectification, Cancellation, and Opposition) in relation to the data collected directly by ITB360 and at any time by contacting by e-mail:  juridico@itb360.com.br. Only identifiable data is liable to exercise such rights.

3.2. User ARCO rights include the following definitions:
a) Right of access: allows the User to know and obtain information about the personal data subject to processing.
b) Right of rectification or exclusion: allows the correction of errors and the modification of inaccurate and incomplete data.
c) Right of cancellation: allows the exclusion of inappropriate or excessive data.
d) Right of opposition: the User's right to prevent the processing of their personal data or to stop processing in progress.
e) The right to restrict processing: involves marking personal data stored to restrict its future processing.
f) Data portability: providing User data that is subject to processing so that it can be transferred to another controller without hindrance.
g) Right not to be subject to individual automated decisions for which the User has not given his consent (including profile).
h) Right not to be subject to a decision based on automated processing that has legal or similarly significant effects.
i) The right to withdraw the consent given at any time.

3.3. ITB360 reserves the right to use all legal means necessary to verify the identity of those who request the exercise of ARCO rights in order to prove that they are, in fact, the respective data subjects.

4. Retention and Exclusion of Personal Data
4.1. ITB360 will keep the collected data for a minimum of six months to meet the purposes for which ITB360 collects it, including for legal and tax purposes. This deadline is essential to ensure the collection of statistics on access and customer governance. After this period, they will be discarded through data destruction techniques, through the ITB360 server.

4.2. ITB360 follows the security standards commonly used to ensure the safety of Users. However, considering that no security system is infallible, ITB360 disclaims any liability for any damages and / or losses arising from failures, viruses, or invasions of the ITB360 database, except in cases where the sole fault of the ITB360.

4.3. The data obtained from our Users may be stored on our own servers or from a third party hired for this purpose, allocated in Brazil and / or in another country, and may also be stored by means of cloud computing technology and / or others that may arise in the future, always aiming at improving and perfecting our activities. The security of this cloud is achieved, above all, by maintaining its integrity,
confidentiality, authenticity, availability, and privacy. In addition, this data is accessed only by authorized professionals.

4.4. Our Users can request the display, rectification, or ratification of their personal data, through the service tools provided by us.

4.5. Using the same service tools, our User can request the deletion of his personal data collected and recorded by ITB360, provided that the contract between the User and ITB360 has ended and the minimum legal term has elapsed. ITB360 clarifies that in some situations it will not be possible to perform the complete deletion of data.

4.6. We may, for the purposes of auditing and preservation of rights, remain with the history of recording our Users' data for a longer period of time in the event that the law or regulatory rule so establishes or for the preservation of rights. However, we have the option of permanently excluding them at their convenience in a shorter period.

4.7. All of our promotional emails are sent through marketing@itb360.com.br and their links lead directly to the ITB360 website.

4.8. Costumer relationship emails will be sent to Users who choose to receive them. And if at any time, the User wishes to cancel the receipt of these correspondences, his order will be promptly fulfilled.

5. Changes and / or Modifications to this Policy

5.1 We may change the content of this Privacy Policy at any time, according to the purpose or need, such as for the adequacy and legal compliance of a provision of law or rule that has equivalent legal force.

5.2. The new Policy will come into force 1 (one) day after being published on the Platform. Within 15 (fifteen) days from the publication of the changes, the User must inform, by email, if he does not agree with the amended terms. In this case, the contractual link will cease to exist, as long as there are no open accounts or debts. If there is no manifestation within the stipulated period, it will be understood that the
User has tacitly accepted the new Data Privacy Policy and the contract will continue binding the parties.

6. Of the Forum

6.1. All items in this Policy are governed by the laws in force in the Federative Republic of Brazil. For all matters relating to the interpretation, compliance, or any other question related to this Policy, the parties expressly agree and elect the Central Forum of the District of São Paulo. The User declares to have read, understood, and accepted all the rules, conditions, and obligations established in this Privacy Policy.

TERMS OF ADHESION, USE AND CONDITIONS
Read the terms and conditions carefully.
When purchasing the products of ITBROKER SERVIÇOS OPERACIONAIS LTDA, registered with the CNPJ under number 18.901.359 / 0001-03, headquartered in the Municipality of São
Paulo, State of São Paulo, at Alameda Vicente Pinzon, n ° 54 - 7th floor, Vila Olimpia - SP - Brazil. Zip Code: 04547-130 ("ITBROKER"), according to the user license agreement, you AGREE AND, FROM NOW ON, ACCEPT ALL THE CONDITIONS AND TERMS contained in this instrument, and the refusal of these Terms will prevent you from using the services and benefits arising from the products now contracted.
1. SERVICES OFFERED
1.1. This TERMS applies to regulate the use of the services offered by ITBROKER to USERS, including their applications within the platform.
1.2. It is immediately clear to the USER - who declares himself to be aware and accepts - that the services offered by ITBROKER consist exclusively of providing digital platforms for limited access and use to ITBROKER and / or its suppliers' products / content packages, exempting the ITBROKER of any responsibility for the actions proposed and carried out, or for the benefits eventually offered, by partner companies or by third parties.
1.3. The USER is aware and agrees that the services are provided as they are made available, as described in thelicense agreement for use.
1.4. The USER is immediately informed and agrees that the services now hired will be available 24 (twenty-four) hours a day, 7 (seven) days a week, but for reasons beyond the control of ITBROKER, including, but not limited to, the incident or the case of force, force majeure, and maintenance of servers, they may be temporarily unavailable for consultation by the USER.
1.5. The USER is aware and agrees that the amount / volume of content made available through the use of ITBROKER platforms may vary according to the research undertaken by the USER and that the amount / volume of the content corresponding to each survey depends only on the quantity / volume content made available by each of the sources providing this researched content.
2. REGISTRATION
2.1. The USER, in order to use the services described above, must have legal capacity for civil acts and must necessarily provide the information required in the REGISTRATION, assuming full responsibility (including civil and criminal) for the accuracyand veracity of the information provided in the REGISTRATION, which can be verified at any time by ITBROKER.
2.1.1. In case of incorrect, untrue or unconfirmed information, as well as in theevent of refusal to correct them or send documentation proving the correction, ITBROKER reserves the right not to complete the registration in progress or, even, to block the registration already existing, preventing the USER from using the services now hired until, at the discretion of ITBROKER, the anomaly situation is resolved. ITBROKER reserves the right to prevent, at its discretion, new REGISTRATIONS, or to cancel those already made, in case an anomaly is detected that, in its analysis, is seriousor demonstratesa deliberate attempt to circumvent the mandatory rules described here. for all USERS. ITBROKER will also act in such a way if the USER fails to comply with any obligation provided for in this TERM.
2.2. Once the REGISTRATION has been successfully completed, the USER will have access to the services now contracted by means of login and password, data which are personal, non-transferable, undertakes not to disclose to third parties, being under his exclusive responsibility any service request that is made using your login and password.
3. OBLIGATIONS OF THE USER
3.1. Upon successful completion of the USER REGISTRATION, the user is obliged not to  disclose to third parties login and access password, nor to allow the use of such information by third parties, being responsible for the consequences and possible damages caused by the improper use of their login and password ownership.
3.2. It is the USER's obligation to provide registration information that is completely true and accurate, is exclusively and fully responsible (in all legal fields) forall the content informed by him in the REGISTRATION item, keeping it always up to date.
3.3. The USER who is under 18 (eighteen) years of age is aware that he cannot behave inappropriately to his age group, being responsible for the correct information of his age in the REGISTRATION item, personally assuming his legal obligations in any case, or through your legal guardian.
3.4. The USER declares, recognizes, and accepts that it is his / her responsibility and risk to operate the system and use the services now contracted. The USER certifies that he uses his own free and unimpeded choice to participate voluntarily in this activity. The USER undertakes to take due care during the sharing, participation, use, and / or operation of the services. The USER recognizes, understands, and is aware of all the risks related to the use of the services.
3.5. ITBROKER will not be responsible, under any circumstances, for any crimes possibly practiced by the USER due to the use of the services now contracted, nor for any losses or damages relatedto the use of the services.
3.6. The USER is aware and accepts the prohibition to publish, modify, translate, distribute, redistribute, commercialize, lease, rent, sell, dispose of, make available, share, extract withdraw, alter, even partially, transfer, forward, decompile, practice reverse engineering, in any way to copy content and information to which it may have access through the use of ITBROKER platforms. In the event of a breach of the clause in question, the USER will pay ITBROKER a non-indemnity fine in the amount of R$ 1,000,000.00 (one million reais), updated by IGPM / FGV, or, in its absence, by another index that will replace it, in addition to the losses and damages, to be determined amicably or judicially.
4. OBLIGATIONS OF ITBROKER
4.1. Provide virtual space that allows the USER duly registered to access and exercise options for using content packages, under the terms of the license agreement for use. Products and services may be included and excluded from the platforms, as well as altered prices, at the discretion of ITBROKER, without the need forprior notification.
4.2. Protect, by means of storage on servers or any other high-securitymagnetic means, the confidentiality of all information and records related to USERS, as well as values related to financial operations arising from the operationalization of the services provided for in this TERM. However, it will not be responsible for repairing losses that may be derived from the seizure and co-optation of data by third parties that, breaking the security systems, are able to access this information.
4.3. ITBROKER may provide USER information to third parties in the following cases: I - by ourt order; II - in response to a request from the Public Ministry or Police; III - to guarantee the non-violation of the rights of third parties; IV - to ensure compliance by the USERS of this Term of Adhesion, Use and Conditions.
5. MODIFICATIONS TO THIS TERM
5.1. This TERMS OF USE may, at any time, have its content, or part of it, modified for adjustments andinsertions, all with a view to improving the services provided.
5.2. The new conditions will come into force as soon as they are posted on the ITBROKER platforms, and it is possible for the USER to express opposition to any of the modified terms, provided he does so in writing and forwards it to ITBROKER through the electronic address contained in clause6.1. below, which will automatically cancel your REGISTRATION.
6. COMMUNICATION CHANNEL
6.1. In order to establish contact between ITBROKER and the USER, the electronic address suporte@itb360.com.br is made available, be certain that the USER is obliged, equally, to keep in his register current electronic address through which communications will be made to him, directed by ITBROKER, immediately lending legal validity and effectiveness to this electronic meansof exchanging reciprocal information.
7. LINKS
7.1. The USER acknowledges and agrees that ITBROKER will not be responsible for the content, advertising, products, services, or other materials contained or made available by advertisers, through links contained in websites, applications, or where the services are being made available.
8. RESPONSIBILITY
8.1. ITBROKER cannot be held responsible for any failure or non-functioning of services provided bythird parties or resulting from unforeseeable circumstances or forcemajeure.
8.2. The USER is aware of and is responsible for the proper use of the services now contracted, exempting ITBROKER from all liability, in any way, for any damages, such as material, personal, moral, aesthetic
damages, which it may cause to itself or to third parties. , or who will suffer due to any events that occurred or related to the use of the services now contracted.
9. DATA PROTECTION
9.1. ITBROKER will process and use the USER data obtained and necessary for the provision of services. The protection of data of USERS will apply the rules of the privacy policy of ITBROKER.
9.2. ITBROKER will take all possible measures to maintain confidentiality for the security of USERS data obtained and necessary for the provision of services, but will not be liable for any loss that may be caused by the breach of these measures by third parties using public networks or internet to access USERS information.
10. GENERAL PROVISIONS
10.1. Any copy or improper use of ITBROKER platforms by the USER will be considered as an unauthorized copy and its mere existence will be considered a violation of the Computer Program copyright, leading to the necessary acts for its repair and indemnities that may be necessary, is authorized by the provisions of this contract and the legislation in force, especially under the terms of art. 102 of Law 9610/98. The determination of the infraction will be substantiated and dimensioned in accordance with the Sole Paragraph of art. 103 of Law 9,610 / 98.
10.2. In the event that any of the provisions of this Term will be considered contrary to Brazilian law, by any governmental authority or judicial decision, the remaining unaffected provisions will remain in force and the parties must amend this instrument in order to adapt it to that law or the court decision.
10.3. The USER is aware that the content made available on the ITBROKER platforms is the exclusive property of ITBROKER or its supplier sources, according to the rules of Intellectual Property and Copyright.
11. ACCEPTANCE OF TERMS OF USE
11.1. The USER declares to have read, understood, and accepts all the rules, conditions, and obligations established in this TERM.
12. COURT OF JURISDICTION
12.1. The parties elect as competent to settle any disputes that may arise from the interpretation and compliance with this TERM the jurisdiction of the District of the Capital of the State of São Paulo, with the waiver of any other, however privileged it may be.
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Data removal request form

For privacy reasons, you may have the right to request that certain information be removed.

The User can request the deletion of his personal data collected and recorded by ITB360, provided that the contract between the User and ITB360 has ended and the minimum legal term has elapsed. ITB360 clarifies that in some situations it will not be possible to perform the complete deletion of data, as specified in our Privacy Policy.

After your request, we will review it.

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