PRIVACY POLICY - ESTAMPO TEC INDÚSTRIA E COMÉRCIO LTDA

1. Introduction
1.1. ESTAMPO TEC INDÚSTRIA E COMÉRCIO LTDA ("ESTAMPO TEC") is a Brazilian limited liability company operating in the market since 1990, specializing in the development of projects and solutions for progressive precision stamping tools and stamping of metallic components, construction of tools and supply of stamped components for the national and international market of auto parts, home appliances and other sectors.

1.2. The Terms of Use and Privacy Policy of the "ESTAMPO TEC" website are based on the commitment to transparency and respect for the privacy and security of all its visitors.

1.3. When visiting or using this website or any of its pages, it is assumed that you have read and agreed to all the terms set forth herein.

1.4. Due to the daily operations and activities of "ESTAMPO TEC", it is necessary to collect personal data from customers and/or potential customers in order to provide and/or offer products and services in accordance with the profile of each one, their values and interests.

1.5. "ESTAMPO TEC" respects the privacy of all holders of personal data and is therefore committed to taking all possible measures to reasonably ensure the protection of personal data collected. applicable data protection laws and regulations. Thus, this Privacy Policy stipulates how "ESTAMPO TEC", its subsidiaries and affiliates, carry out the processing of personal data, in accordance with current legislation and regulations.

1.6. This Privacy Policy is regularly reviewed with the aim of ensuring its compliance with the national legislation, regulations and also with any new technologies, reflecting possible adjustments or changes in the operations and business practices of "ESTAMPO TEC", therefore, it is important that you regularly access this policy, carefully observing the informed update date.

1.7. This Privacy Policy applies to "ESTAMPO TEC" and to all Members who have access to any personal data held by "ESTAMPO TEC" or on its behalf, as well as to all its activities involving the processing of personal customer data, potential customers, partners, collaborators, employees in general, candidates for job openings, visitors to the office(s) and/or factory of "ESTAMPO TEC", visitors and users of its website(s)( s), application(s) and/or program(s), if applicable.

1.8. "ESTAMPO TEC" guarantees that the personal data processing activities it employs observe good faith and the following principles: (i) purpose; (ii) suitability; (iii) need; (iv) free access; (v) data quality; (vi) transparency; (vii) security; (viii) prevention; (ix) non-discrimination; and, (x) accountability and accountability.

2. General Considerations

2.1. "ESTAMPO TEC" guarantees the commitment to take all possible measures to reasonably ensure the protection of the personal data collected and to treat the information in accordance with the applicable data protection laws and regulations.

2.2. Technical and organizational procedures are in place to ensure that your information and data are safe and, as part of these procedures, regular training and awareness of all our employees about the importance of maintaining, safeguarding and respecting your personal information.

2.3. The possible violation of the privacy of personal data is considered very serious, which is why there is constant monitoring, as well as appropriate disciplinary measures for possible non-compliance with technical and organizational procedures.

2.4. Definitions, pursuant to the General Data Protection Law ("LGPD") - Law 13,709, of August 14, 2018:

(i) Personal Data: information related to an identified or identifiable natural person;
(ii) Sensitive Personal Data: personal data about racial or ethnic origin, religious conviction, political opinion, union membership or organization of a religious, philosophical or political nature, data referring to health or sex life, genetic or biometric data, when linked to a natural person;
(iii) Anonymized Data: data relating to the holder who cannot be identified, considering the use of reasonable technical means available at the time of processing;
(iv) Database: structured set of personal data, established in one or several places, in electronic or physical support;
(v) Holder: natural person to whom the personal data that are subject to processing refer;
(vi) Controller: natural or legal person, public or private, who is responsible for decisions regarding the processing of personal data;
(vii) Operator: natural or legal person, public or private, that processes personal data on behalf of the controller;
(viii) Processing Agents: the controller and the operator;
(ix) Treatment: all operations carried out with personal data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;
(x) Consent: free, informed and unequivocal statement by which the holder agrees with the processing of his personal data for a specific purpose;
(xi) Blocking: temporary suspension of any treatment operation, through custody of personal data or the database;
(xii) Deletion: deletion of data or a set of data stored in a database, regardless of the procedure used.

3. Data Collection

3.1. "ESTAMPO TEC" may collect, store, process, process and use the following information, among others, regarding User or Visitor access to the website and/or application, in order to develop and improve its functionalities, analyze the website and/or application performance, check User or Visitor browsing habits and experiences and security analysis:

(i) Geographic location;

(ii) Operating system used;

(iii) Browser and its versions;

(iv) Date, time and amount of time (hours, minutes and seconds) of use of the website and/or application by the User or Visitor, from a given IP Address (Internet Protocol);

3.2. "ESTAMPO TEC" may use different ways to collect personal data, such as:

(i) When they are provided by filling in requests, requests, forms, questionnaires, emails, websites, mail, applications, social networks, landlines or mobile phones, SMS (Short Message Service), contracts or even, through the delivery or forwarding of personal documents or their copies/scans/photos/reprographs, in situations that include, by way of example and not exhaustively: a) Having an interest or intention to have any working relationship with "ESTAMPO TEC";

b) Maintain any working relationship with "ESTAMPO TEC";
c) Provide or have an interest or claim to provide products and/or services to "ESTAMPO TEC";
d) Request products or services from "ESTAMPO TEC";
e) Create an account on the website(s) or application(s) of "ESTAMPO TEC";
f) Hire services from "ESTAMPO TEC";
g) Request the sending of marketing or institutional materials from "ESTAMPO TEC";
h) Participate in promotions, surveys or surveys;
i) Contact "ESTAMPO TEC" to transmit some feedback and/or make any complaints and/or any other type of record or communication.
(ii) Through access data to the websites, applications or social networks of "ESTAMPO TEC";
(iii) When authorized and enabled by the User, for authentication and/or alteration of data, the collection of biometrics for the preparation or maintenance of an efficient biometric survey (if applicable); telephone; and, email. The biometrics (if applicable) used or that will be used for authentication will be collected and stored by method(s) corresponding to the specific technology of each device, not being replicated to other environments;
(iv) Through public or publicly available sources.
These collected data are and/or will be used for the purposes presented in topic 4, below, of this document.

4. Purposes of collecting personal data and information:

Your personal data and information may be used for the following purposes:

4.1. Account creation on our platform(s)

Verifying and confirming your identity in order to validate you as a customer, which may include credit and/or identity checks by third parties so the use of your personal information is necessary for us to identify who you are and comply with all regulatory obligations .

4.2. Execution of contracted services and/or purchase of products and/or services

Subsequent to opening an account on our platform(s), it will be necessary to use your personal data to perform our activities, perform services, products, process orders, requests and fulfill our contractual obligations.

4.3. Compliance with legal obligation

In view of the need to comply with legal obligations arising from the laws and regulations to which "ESTAMPO TEC" is subject, as well as other laws of the national order and compliance with related court orders.

4.4. Forwarding communications and satisfaction surveys

For opening and closing account(s), registration or updating processes, transactional and/or supporting communications regarding operations, relationships and contractual obligations, in addition to satisfaction surveys to ensure the level of excellence with which "ESTAMPO TEC" commits.

4.5. Behavioral analytics on our website(s) and apps

Our website(s) and applications may contain data and behavioral analysis tools to ensure the maintenance of their quality and/or improvement, in order to provide the best experience to the User or Visitor and, under the terms of the General Law of Data Protection ("LGPD") - Law 13.709, of August 14, 2018, the information collected is not considered personal, as it is used in such a way as not to be linked to any User or Visitor, being considered anonymized.

4.6. Advertising

Personal data can be used so that data holders are always well informed about matters relating to their interests and related to the activities of "ESTAMPO TEC", provided that these holders choose to receive this information, including those related to products and services offered, during the account opening process, or at any time, upon express request, and the sending may be done by E-mail, SMS, WhatsApp or another previously agreed channel and based on consent. 4.7. Assurance of property security and physical integrity

In cases of attendance/visits to the physical facilities of "ESTAMPO TEC", images of the visitor/customer may be recorded through the monitoring system for security reasons, personal information may also be collected to arrange for the entry of the visitor/customer into the premises of "ESTAMPO TEC", through access credentials, applicable practice in compliance with the norms internal security.

4.8. Internal accreditation

All of our employees need to have their personal data collected so that the procedures for accreditation and internal control of entry and exit can be carried out, as well as other validations required by current legislation and regulatory bodies.

4.9. Guarantee of fraud prevention and maintenance of cardholder security

Personal data may be processed for the purpose of analyzing and preventing fraud, crimes, anti-intrusion measures and maintaining the security of data subjects' assets.

4.10. Safeguarding legitimate interests of "ESTAMPO TEC"

By way of example, not exhaustive, the following legitimate interests are included: (i) legal claims; (ii) defenses in cases of litigation; (iii) analysis of financial transactions to prepare strategic reports; (iv) establishment of monitoring systems for security reasons; (v) business management; (vi) platform(s) and application(s) performance optimization; (vii) development and improvement of products and services; (viii) legal control, including the fight against money laundering and terrorist financing.

5. Consent

5.1. If your consent is required for any processing of personal data, it will be requested and provided through our website(s) and/or application(s).

5.2. If you want to revoke the consent given, so that "ESTAMPO TEC" no longer sends communications and marketing/advertising emails for products and services, you can do so using the cancellation option present at the bottom of the e-mails. -mails.

6. Sharing of personal data

6.1. In compliance with the criteria defined in this Privacy Policy, "ESTAMPO TEC" will not disclose personal data of its customers to third parties, except:

(i) to comply with the necessary measure, stipulated within the terms of the current legislation, rules or applicable regulations;
(ii) before the legal obligation of disclosure;
(iii) in the face of legitimate interest that requires disclosure; or
(iv) at the request of the customer, with his consent.
6.2. The third parties to which personal information is shared in order to comply with the charges and contracted services, must carry out their processing in order to guarantee compliance with all legal obligations.

6.2.1 These third parties, who handle or obtain this personal data, are required to do the following: (i) recognition of the criticality of this information; (ii) respect for all individual privacy rights; and, (iii) compliance with all data protection legislation, in particular the General Data Protection Law ("LGPD") - Law 13,709, of August 14, 2018.

6.3. For the aforementioned purposes, your personal data may eventually be disclosed to:
(i) Other companies belonging to "ESTAMPO TEC", within the limits of the purposes established in this policy;
(ii) Third parties related to the activities of "ESTAMPO TEC" such as service providers, specialized consultants, hired for administrative, financial, legal, security, research and other services;
(iii) Third parties performing an audit;
(iv) Business parties, credit providers;
(v) Courts, controlling bodies and regulatory authorities;
(vi) Payment service providers and/or banking institutions, for generating and controlling payments;
(vii) Any natural or legal person, provided with the consent of the data subject.
7. International data transfer
Considering the legal definition of transferring personal data to a foreign country or international organization of which the country is a member, "ESTAMPO TEC" treats your personal information in national territory, as well as in countries that have similar and equivalent legislation, maintaining specific clauses that ensure the correct treatment and alignment with the laws and regulations of the country.

8. Security and privacy of personal data

8.1. "ESTAMPO TEC" is committed to safeguarding and processing the information of its customers and other data holders using technical and administrative measures capable of protecting personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or diffusion;

8.2. "ESTAMPO TEC" still uses measures that aim to guarantee the protection, maintenance of privacy, integrity, availability and confidentiality of personal data processed in its environment, seeking to continuously implement measures for prevention, detection and reduction of vulnerability to incidents in its technological environments.

9. Storage of personal information and retention period

9.1. "ESTAMPO TEC" will keep your personal information for as long as necessary to comply with the purposes for which the information is processed or for other valid and legitimate reasons legals for retention of this personal information.

9.2. If you wish that "ESTAMPO TEC" no longer uses your personal data, contact us through our website, in "CONTATO" or send an e-mail to: lgpd@estampotec.com.br; with the title: "PERSONAL DATA – STORAGE", with your request. After processing the information, your report will be sent directly to the email that is registered in our system.

10. Consult your Personal Data

If you want to consult about your personal data that are processed in our environment, send an email to: lgpd@estampotec.com.br with the title: "PERSONAL DATA – CONSULTATION", with your request. After processing the information, your report will be sent directly to the email that is registered in our system.

11. Change your Personal Data

If you want to change or update your personal data, you can do so by logging into the website with your login and password, accessing your registration area and proceeding with the change or update.

12. Request the cancellation of the processing of your personal data and its disposal

If you no longer want us to process your personal information, you can do so as follows: (i) observing the contractual stipulations, if you are our client, as well as the full item 9. and sub-items 9.1. and 9.2. of this Policy; (ii) if you are not our client, observe the full provisions of item 9. and sub-items 9.1. and 9.2. of this Policy.

13. Contacts

"ESTAMPO TEC" has a Data Protection Officer, who is responsible for data protection and issues related to this Privacy Policy. If you have any questions about how to consult your data and/or exercise your rights as a holder, please contact us by e-mail: lgpd@estampotec.com.br

14. Legal Notice

"ESTAMPO TEC" is not responsible for: (i) the misuse or loss of data and/or personal information over which it has no access or control; and, (ii) for the illegal and unauthorized use of such data and/or information, due to the misuse and/or misuse of access credentials due to negligent and/or malicious conduct; as a result of acts or omissions by the data subject and/or someone authorized on their behalf.

15. Policy Review

This Privacy Policy will be subject to review every 2 (two) years or in periods shorter than this, whenever necessary, in order to preserve the conditions of security and legality, due to the current economic situation or legal change.