PRIVACY POLICY

Golfleet Tecnologia Ltda (the “Golfleet” or “We”) is a company specialized in
technologies for managing light fleets, which develops technological solutions that help
to optimize resources, reduce operating costs and take care of driver safety.

We maintain the website www.golfleet.com.br, where you will find the presentation of
solutions we offer, as well as you can consume the free content therein
available. If you are interested in receiving other information, such as
our newsletter and news, there will be a specific and voluntary field to fill in.
Still on our website, without prejudice to other information, you will find reports of
face-to-face and remote events via the web, free and paid, online and offline, on the most
various topics within fleet management.

To offer all these services, We collect various data and information, aiming,
above all, to provide an increasingly better experience for You. So, for example,
when You use our services, consume our content, browse our website,
participate in events and answer questionnaires, entrust us with data and information about you.

This Privacy Policy (“Policy”) is intended to inform which
information is collected when you use any of our services and describes
the conduct and procedures adopted by Golfleet for the collection, storage, use,
treatment, sharing and elimination of information obtained from Users.

This Policy applies when You use our Services that involve data collection.
online and offline data, including Personal Data collected through our various
services and channels, including website, social networks, events, surveys, among others.

How may Personal Data be collected (source of collection)?

1. When browsing our website: when you browse and interact on our website, we automatically collect access, usage, communication and Cookies data.

2. When You show interest in the services: when You interact with, access or request our content or materials through the Website, Landing Pages, forms, email, telephone, social networks or any other communication channel of Golfleet.

3. At the time of contracting the services: when contracting solutions offered by Golfleet, enrolling in courses and events via the website, Landing Pages, e-mail or filling out forms.

4. Ad interaction: interactions with our advertisements (for example, if You interact with one or more of our advertisements on a third-party website, we may receive information about that interaction).

5. Data created by Us: during our interactions with You, we may create Personal Data about You (for example, but not limited to records of your purchases (eg events) on our websites, and records of your interactions with our content and emails).

6. Third party platforms: We may hire outsourced services from partners, such as marketing automation and Leads management and collection, whose consent to share your personal data with us was granted by You to these third parties. In this case, we always respect the purpose determined by our partner, as well as the provisions of this Policy, remembering that You can always request the retention, deletion, anonymization and elimination of your personal data, as provided in this document.

What Personal and Non-Personal Data may be collected?

1. Registration Personal Data (information to enable enrollment in courses, events, commercial proposal, access to systems, drafting of contracts, request for contact through “talk to us”, when you want to become a partner): full name, e-mail, number of phone, full address, date of birth, CPF, RG, CNH, professional information, marital status, city, state, position held, name of the company you work for and economic segment;

2. Payment Personal Data (when you use a paid service, this is information to make financial transactions viable, to analyze and prevent fraud or to issue an invoice): full name, CPF, date of birth, financial data (card, bank, agency, account current), full address, e-mail;

3. Personal Data for sending material, newsletter, communications, recommendations and advertising (information necessary for sending rich materials - ebooks, infographics, etc -, important announcements, newsletter, advertisements and recommendations): full name, e-mail, full address, telephone;

4. Data collected automatically when You use our website:

4. 1. Access logs: information including the IP address, with date and time, used to access our website;

4. 2. Usage data: information about your interactions on our website, such as your navigation, the pages or other content you access or create, your searches, participation in surveys or forums and other actions;

4. 3. Communication with our Platform: when you communicate with our Website, we collect information about your communication, including metadata such as date, IP and time of communications and all their content, as well as any information you choose to provide;

4. 4. Cookies and similar technologies: We use cookies, which are text files generated and stored on your browser or device by websites, apps and online advertisements. Cookies may be used to improve and personalize the user's experience on the Website.

5. Leads: if you interact with our materials and content, we collect, in addition to your navigation data mentioned above, your visit data to our pages, and other information that you choose to share with us, through your interactions with our forms, Landing Pages and emails, for example.

6. Non-Personal Data (information that does not identify a person): size of the fleet, type of fleet, registration information of the Legal Entity.

How can this data be used?
When You interact with the website, use one of our services or purchase one of our products, we use various technologies to process the Personal Data collected. Below, we describe how your Personal Data may be used.

1. Personal Data will be used with the aim of providing, developing, enabling and improving the services provided or products offered, including those to be created. In addition, we will use your data to offer you our services and establish a communication flow.

2. Personal Data may be used in the following ways:

2. 1. So that We can communicate with You, including to offer our services or products;

2. 2. In order to offer content and materials of interest to you, it is often necessary to cross-reference the data we collect from you, so that our marketing actions are directed to what you expect to receive from us. We guarantee that this crossing is not done in a discriminatory way, not injuring any of your individual rights or freedoms. Considering all these points, some possibilities for using your data may occur. For example:

2. 2. 1. Recommend events and send advertising, as well as other promotional materials aimed at marketing our services and news to Users, which includes digital campaigns such as targeted marketing on social networks and notifications;

2. 2. 2. For sending Newsletters, always related to themes of the Fleet universe, and, also, communication of the launching of new materials or of new products, services of Golfleet and partners;

2. 2. 3. Our commercial team may contact you via email and telephone (message and calls) to carry out research or present products and services, including for commercial purposes;

2. 2. 4. Send You messages regarding support or service, such as alerts, notifications and updates;

2. 2. 5. Communicate with you about products, services, promotions, news, updates, events and other matters that You may be interested in;

2. 2. 6. Carry out targeted advertising according to your tastes, interests and other information collected.

2. 3. Your e-mail data, collected at our events, will be shared with our Marketing team, in order to send you content and news regarding topics related to the event proposal or Fleet management. You can request changes to these preferences or the cancellation of the shipment, at any time, through the e-mail itself;

2. 4. The User's image and voice may be collected, through recordings of the services provided (for example, an event) for the dissemination and publicity of our services;

2. 5. Internal and managerial purposes, such as auditing, data analysis and research to improve products, services and communications with users, and generating statistical analysis regarding the use of our services, including consumption trends;

2. 6. Comply with legal obligations and requirements, protect your rights, the rights of other users or our rights;

2. 7. Formalize any contractual relationship between You and Golfleet;

2. 8. To register or register for participation, enabling access to services, as well as issuing certificates, allowing access control to the event, content or system, enabling payments and issuing Invoices.

3. The processing of personal data will be carried out based on the following legal hypotheses: compliance with a legal obligation, execution of a contract, regular exercise of rights and fulfillment of legitimate interests. The legal basis for processing may vary depending on the activity carried out.

4. Eventually, we may use data for purposes not foreseen in this privacy policy, but these will be within your legitimate expectations. The eventual use of your data for purposes that do not comply with this prerogative will be done with your prior authorization.

Will personal information be shared?

1. We do not market our Users' Personal Data to third parties, but there are situations in which we may disclose, transfer or share Personal Data with third parties, as provided in this document and in Brazilian legislation, especially in accordance with the LGPD.

2. We may share your Personal Data with contractors and service providers who process such data on our behalf, in order to perform certain functions related to their activities, such as, but not limited to, marketing agencies, marketing automation tools , sales automation and lead collection tools, database service providers, recovery and backup service providers, email service providers, payment processors, educational service providers, and others.

3. The data collected will be treated and stored on third-party servers, which operate in accordance with the security and confidentiality policies and mechanisms stipulated in this instrument.

4. We employ other companies to carry out work on our behalf and need to share your Personal Data with them in order to provide products and services to You. For example, we use data hosting services to store our database, we also use payment services to be able to process billing data for our products purchased by you, we use marketing automation tools where we focus our communication strategies . Our Partners are only authorized to use Personal Data for the specific purposes for which they were contracted, therefore, they will not use your Personal Data for purposes other than the provision of contractually provided services.

5. In the event of a sale, merger, reorganization or other similar corporate transaction, Personal Data may form part of the shared or transferred intangible assets.

6. The sharing of Personal Data may be carried out with affiliated companies or maintainers, with the following purposes: (i) the development of new products and services; (ii) offering products and services that best serve the interests of Service Users; (iii) generation of statistical and aggregated data about the use of products and services and user profiles; (iv) commercial activation.

7. We reserve the right to provide your data and information about you, including your interactions, if legally required to do so, act necessary for the company to comply with national laws, or if you expressly authorize it.

How is the data stored?

1. The personal information collected will be stored in reliable services, provided by partners that may be located in Brazil or in other countries, which meet the security standards established in this policy.

2. When contracting these services, Golfleet will look for companies that employ a high level of security in the storage of your information, establishing contracts that do not violate the privacy definitions set forth in this Policy.

3. Golfleet stores users' information only for the period necessary for the purposes presented, including for the purposes of complying with any legal, contractual obligations, or requests from competent authorities, always respecting the data retention period determined by the applicable legislation.

4. We do not store financial information and data.

Retention and Disposal of Data.

1. The personal data collected is retained for an indefinite period of time, as long as You maintain active authorization or are under a contractual relationship with us (subscribing to a solution, answering forms, taking a course, participating in an event, subscribing to Our newsletter etc.). As long as the relationship exists or for as long as necessary to provide the Services, this data will be retained.

2. When you wish, free of charge and easily, you can request the deletion of your personal data or, even, that they are made anonymous, through the [email protected].

3. If you request the deletion of your Personal Data, we may initiate the procedure within 30 days of your request. However, please note the following: (1) there may be some latency between deleting information from our servers and the backup; and (2) we may retain this information as necessary to comply with our legal obligations, resolve disputes or enforce our agreements. In the event of termination of the contract or revocation of authorization, personal data will be deleted or anonymised.

4. When You sign up for or contract one of our Services, we will periodically send you information, updates, marketing and advertising material, and we may contact You to communicate and offer products and/or services. If You do not wish to receive a specific type of marketing material from us, please click the “Unsubscribe” link in a corresponding email You receive. In other cases, request unsubscription via email [email protected].

5. It is important for you to understand that when you click on the “Unsubscribe” link, our system will automatically stop sending you emails, however, your Personal Data may remain in our database. If you want deletion or anonymization, you must make the specific request via email [email protected].

6. We reserve the right not to proceed with the deletion or anonymization of Personal Data in cases where we are authorized or required by law, and your consent to this procedure is automatic and expressed upon acceptance of this Policy.

7. We reserve the right to anonymize Personal Data through the use of a robust and sufficient technique that will not allow the identification of a specific individual, nor records that may, in some way, make some connection with the data subject.

Is there international data transfer?

1. We may carry out international transfers of data to other countries in order to carry out some of the activities involved in the services provided to users, as well as to be able to obtain information that may contribute to the improvement and security of our services.

2. In the event of sharing with partners located in other countries, we contractually establish that the partner has a data protection and information security standard compatible with this Privacy Policy, so that data is always protected under these terms.

Is there international data transfer?

1. We may carry out international transfers of data to other countries in order to carry out some of the activities involved in the services provided to users, as well as to be able to obtain information that may contribute to the improvement and security of our services.

Confirmation of the existence of processing of personal data;
Access to personal data;
the correction of incomplete, inaccurate or outdated data;
Anonymization, blocking or deletion of unnecessary or excessive data;
Data portability, within legal limits.

Changes to the Privacy Policy.

1. This Privacy Policy may be updated periodically, and the current version will always be the most recent.

2. We recommend that You periodically visit our website so that you are aware of the changes. If relevant changes are made that lead to a new consent from you, we will publish this update and request a new consent from you.

Version 1.0 of February 2022.

How can you talk to us?

1. We have appointed a representative responsible for supervising all matters relating to this Privacy Policy and the subject of data protection.

2. If you believe that your personal information has been used in a manner that is incompatible with the Privacy Policy or your choices, or if you have other questions, comments or suggestions regarding this Privacy Policy, you may contact us via email : [email protected].

Legislation and Forum.

1. This Policy will be governed, interpreted and enforced in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13.709/2018, regardless of the Laws of other states or countries, the User's domicile being competent to settle any doubts arising from this document.

12. Acceptance of this Policy.

This document was prepared in a simple and accessible way, precisely so that you can read and understand how we use your data to offer you a safe and comfortable experience in the use of the services we offer you. Therefore, it is necessary that you carefully read the terms contained herein before making the decision to start using the services offered.

As a condition for using our services, you declare that you have read the rules in this document in full and carefully, being fully aware and in agreement.

PRIVACY POLICY

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