This section clarifies how FACILITE manages your personal information obtained and used in its operations and services.

We cover the main topics in the following categories:

1. What Personal Information Do We Collect?

   When interacting with and/or using our services, FACILITE may process certain information provided, acquired or associated with you, such as:

   • Initial registration information, such as name, telephone contact and e-mail address, as well as details about your company, such as the nature of the activity and where the organization is registered;
   • Additional identification details, such as home address, telephone number, social security number, password, when you register and use the services, report an incident, participate in opinion polls or promotions, including to confirm discounts and special offers from partnerships and campaigns;
   • Company financial information entered into the platform by the CLIENT (via OFX or other methods);
   • Personal information found in articles of association and power of attorney documents;
   • Entity or company with which you are associated and related information;
   • Technical data collected from the device used to access our Platform (such as IP, Mac Address, IMEI, Location, Browsers and other possible data);
   • Information about you received from third parties, including public databases and information you have made publicly available (such as profile, posts or social media data);
   • Information about you generated from your use of the Services and other data acquired; and
   • Communications, whether oral, video or written, between you and FACILITE.

   Please note that in certain contexts, such as in the pursuit of a relationship with the User or in compliance with good practices and anti-corruption regulations, FACILITE may also obtain your personal data from other sources, such as public databases or background check providers, always in strict compliance with data protection laws and relevant regulations.

   According to the legal definition, sensitive personal information is information related to racial or ethnic origin, religious belief, political opinion, membership of trade unions or organizations of a religious, philosophical or political nature, information about health or sex life, genetic or biometric data (“Sensitive Data”). FACILITE only collects employees’ ethnicity, as this is mandatory information for the Human Resources Department to submit to e-Social. This information is not shared with any other system.

   Information from Minors
   – In general, FACILITE does not knowingly collect Personal Information from individuals under the age of 18.

2. For What Purposes Do We Process Your Personal Data?

   We use your personal information for the following purposes:

   • Offering, providing and maintaining our services;
   • Registration and other initial contracting procedures;
   • Fulfillment of contractual obligations between you and FACILITE;
   • Facilitate communication between you and FACILITE, including to ensure that commitments are met;
   • Allow the provision of additional support and services related to the contracts signed with the User, including by third-party commercial partners of FACILITE;
   • Manage the relationship with the User, including communication by available means, direct marketing, advertising and promotions;
   • Preventing and combating fraud at any stage of the offer of products and services by FACILITE;
   • To ensure your safety when using our Services;
   • Attend to and respond to requests made by you in relation to our Services;
   • Produce analyses and statistical reports on the performance and operation of our services and platform, for the benefit of FACILITE and its commercial partners;
   • Customize, improve and develop our Platform and its functionalities by combining and using the information and profile we have about you, such as your interaction with the Platform, frequency of use of our Services and your preferences in general;
   • Conducting internal and external audits and quality control, with a view to improving service provision and identifying operational faults;
   • Carrying out satisfaction surveys on our services or those of our partners;
   • Detect, identify, prevent and defend against possible abusive or illegal practices;
   • Comply with legal and regulatory obligations to collect, retain and/or share data, including with government authorities, in accordance with applicable laws and regulations;
   • For the defense of FACILITE’s rights in administrative, arbitration or judicial proceedings, in accordance with the law, and for the protection of FACILITE, its rights, property and legitimate interests.
3. Who do we share your personal data with?

   FACILITE can share your information with:

   • Business partners, to fulfill the purposes set out in this Privacy Policy, support activities or in the confirmation of special commercial conditions – if applicable;
   • FACILITE’s service providers who act on behalf of FACILITE and for its benefit in carrying out the purposes of this Privacy Policy. These service providers will have no autonomous right to use your information;
   • In situations where you request or authorize the division;
   • With entities, agencies, authorities and other bodies of the administration and/or public power, as well as with private entities, in compliance with a legal obligation or court order;
   • For the protection and defense of any rights of FACILITE, at its discretion, including in judicial, arbitration or administrative proceedings;
   • In situations of change in ownership or control of FACILITE, due to merger, acquisition, division or sale of assets, in which your information may be transferred to a new owner.
   • FACILITE does not sell or make available Users’ personal data to companies, organizations.

* This Privacy Policy does not apply to the processing of personal data carried out by other companies or individuals, websites or other third parties, including any partners of FACILITE.