SENSEDIA'S PRIVACY POLICY

Introduction

Privacy laws establish the duty of Controllers and Operators to formulate rules for good practice and governance that establish, in general, conditions for data processing, including: technical standards, security regulations, risk mitigation measures, professionals responsible for receiving complaints and requests from holders, in addition to monitoring the due compliance with this policy, etc.
Therefore, we request that this policy be read carefully to understand our policies regarding your Personal Data and how it is handled. This policy applies to our online and offline data collection activities, covering Personal Data that Sensedia may collect by digital or physical ways, including, but not limited to, websites, social media, apps, emails, telephone service, third-party social media, search and events, or sales channels.
In some cases, if you choose not to provide us your Personal Data identified as necessary (we will indicate when this is the case), Sensedia may not be able to provide you our products/services.

● User: All individuals who will use or visit the website(s) and/or app(s), over 18 (eighteen) years old or emancipated, and fully capable of practicing the acts of civil life. Here in this policy referred to as "You".

● Sensedia: Legal Entity under Private Law, Controller or Operator of the data collected, depending on the destination given to the data. Mentioned in this policy as "Sensedia", "We" or "With Us".

● Controller: The person responsible for making decisions regarding the personal data processing.

● Operator: The person who performs the personal data processing on behalf of the controller.

● Personal Data: Any information collected by Sensedia or its affiliates, directly or indirectly, capable of making the user identified or identifiable.

● Sensitive Personal Data: Personal data about racial or ethnic origin, religious belief, political opinion, union membership, or organization of a religious, philosophical or political nature, data related to health or sexual life, genetic or biometric data, when linked to an individual.

● Purposes: The purpose that Sensedia wants to achieve from each act of processing personal information.

●  Consent: Free, informed, and unambiguous statement by which the holder agrees to the processing of their personal data for a specific purpose.

2. What Personal Data we collect and how it is collected

During your interaction with Sensedia, your personal data may be collected as mentioned above and as shown below:

Contact Information: Includes any type of information that may facilitate our contact with You, including: your mailing address; your electronic address (email); phone numbers; company and position; websites and profiles on social media.

Demographic Information and Your Interests: Any information that can describe your demographic data, habits or characteristics, including: birthday; age or age group; genre; geographic location; hobbies; family information or other interests.

Information about how You use our websites and services: During your interaction with our websites and services, we use automatic data collection technologies to capture which links you click on, what types of content, for how long and other statistical information. This information is captured using automated technology, such as Cookies or third-party tracking. You have complete freedom to oppose the use of such technologies. For this, see details in the Section “About your rights regarding Personal Data”.

Market Research and Consumer Feedback: These are data that You voluntarily share with Sensedia about your experiences using our products and/or services.

Content generated by consumers: Any information You create and share with Sensedia on social media (Instagram, Facebook, YouTube, LinkedIn, Twitter or similar). These data include texts, comments, articles, photos, videos, personal stories or other similar content and media.

Third Party Social Media Information: Any data you share publicly on social media (Instagram, Facebook, YouTube, LinkedIn, Twitter or similar) and allow this network to share with Sensedia. These data may include details such as your basic account information (name, email address, gender, date of birth, current city, profile picture, user ID, friends list and similar information.). Thus, whenever you use a social media feature that is integrated with a Sensedia website or whenever You interact with us through a third-party social media, data collection may occur.

● Contacts with our Customer Service Department: Your interactions with our Customer Service Department can be recorded or heard, in accordance with applicable laws, for Sensedia's operational needs. When required by law, you will be informed about it at the beginning of your call.

Sensitive Personal Data: Sensedia does not normally deal with Sensitive Data, so we do not intend to collect or process such types of data. When there is a legitimate interest or it is necessary to process your sensitive data, Sensedia will obtain prior, express, and free consent. Sensedia, however, may process your sensitive personal data according to the following legal bases: (i) crime detection and prevention; and (ii) compliance with applicable law.

3. Children and Teenagers Personal Data

Sensedia does not request, collect, process, store or share personal data of teenagers and children. If we discover the occurrence of any type of processing of these data, unintentionally, we will remove that child's or teenager's personal data from our records promptly.However, Sensedia may collect personal data from children and teenagers directly from their parents or legal guardians, with explicit consent and in accordance with current legislation.

4. About the Use of Personal Data

The items listed below describe the purposes for which Sensedia collects Personal Data and the different types of Personal Data we collect for each purpose. We kindly ask you to note that not all uses below will be relevant to all individuals and may only apply in specific situations.

Consumer Services: Your Personal Data is used for providing services to the consumer, including answering calls, doubts, questions, suggestions, technical assistance, or any relevant and consumer-related act. This usually requires personal contact information and information about the reason of your contact, for example, what your order was, the technical problem, question, product complaint or general question.

▪ Motivations for using your personal data in this situation:
- Comply with contractual obligations
- Comply with legal obligations
- Our Legitimate Interests

▪ Our legitimate interests in this situation:
- Continuously improve Sensedia products and services
- Continuously improve the effectiveness of our customer service.

Promotions and Other Marketing Actions: With your consent (when necessary), Sensedia will use your Personal Data to provide information about products or services, such as marketing communications, advertising campaigns, event disclosures or any promotion performed by marketing. This can happen via emails, SMS, phone calls, forms and questionnaires, mail or via a message on social media. In this situation, the use of your Personal Data is completely voluntary, which means that You can oppose, or even withdraw your consent at any time, to the processing of your Personal Data for these purposes. For more details on how to change your preferences on marketing communications, see the “About your rights regarding Personal Data” section in this policy. Sensedia may share such data with logistical partners for delivering kits, gifts, souvenirs, etc

▪ Motivations for using your personal data in this situation:
- Comply with contractual obligations
- Our legitimate interests
- We obtained your consent, when necessary

▪ Our legitimate interests in this situation:
- Understand which of our products and services may interest You and provide information about them
- Define consumers for new products or services.

Social Media and Third-Party Sites: Sensedia uses your Personal Data when you interact with third-party social media and website features, such as “like”, to provide advertisements and interact with you on these channels. The way these interactions work, the profile data that Sensedia obtains about you, and how to opt-out can be understood by reviewing the privacy policies directly on the respective social media and third-party websites.

▪ Motivations for using personal data in this situation:
- Our legitimate interests
- We obtained your consent, when necessary

▪ Our legitimate interests in this situation:
- Understand which of our products and services may interest you and provide information about them.

Processing of your orders: Sensedia uses your Personal Data to process your orders, whether for products or services, in addition to inform you about their status, correct addresses and conduct identity verification and other fraud verification activities. Certain situations involve the use of payment data, such as bank account details and amounts.

▪ Motivations for using personal data in this situation:
- Comply with contractual obligations
- Legal obligations
- Our legitimate interests
- We obtained your consent, when necessary

▪ Our legitimate interests in this situation:
- Improve and develop new products and services
- Be more efficient in meeting your requests
- Protect our systems, networks, and employees
- Fully comply with legal obligations.

In case of legal reasons or merger/acquisition: If Sensedia or its assets are acquired by, or merged with, another company, including bankruptcy reasons, we will share your Personal Data with our legal successors, respecting the legal requirements for this situation. We will also disclose your Personal Data to third parties (I) when required by applicable law; (II) in response to legal proceedings; (III) in response to a request from the competent legal authority; (IV) to protect our rights, privacy, security or property; or (V) to enforce the terms of any agreement or the terms of our website, products and services, in accordance with current legislation.

▪ Motivations for using personal data in this situation:
- Legal obligations
- Our legitimate interests

▪ Our legitimate interests in this situation:
- Fully comply with legal obligations
- Protect our systems, assets, and employees 

Other Purposes and Situations in General: In accordance with current legislation, Sensedia uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research, measuring satisfaction with the use of our services or products, or the effectiveness of our advertising campaigns. We reserve the right, if you have Sensedia accounts, to integrate these accounts into a single account. We also use your Personal Data to manage and operate our communications, IT, and security and data protection systems.

▪ Motivations for using your personal data in this situation:
- Comply with contractual obligations
- Legal obligations
- Our legitimate interests
- We obtained your consent, when necessary

Our legitimate interests in this situation:
- Improve and develop new products or services
- To be more efficient in service
- Protect our systems, networks, and employees
- Fully comply with legal obligations

5. Sharing Your Personal Data

Sensedia may share your Personal Data with the following third-party organizations: 

Service Providers: External companies that are necessarily used by Sensedia to assist in their service or product operations. Selected service providers and employees are only authorized to access your Personal Data on behalf of Sensedia for specific tasks, which are requested from them based on our direct instructions. Our service providers are contractually obliged to keep your Personal Data confidential and safe, and in cases of violation, respond in accordance with current legislation. 

Financial Services Agencies: If you are a Sensedia employee, your Personal Data is shared with payroll, lending, and financial agencies, with your consent or in accordance with the privacy policy of these financial companies. 

Third parties that use Personal Data for their own marketing purposes: Except for situations where You have given your specific consent, Sensedia does not license or sell your Personal Data to third parties for their own marketing purposes. In cases where it happens, the identity of these third parties will be revealed before obtaining your consent.

6. Processing, Retention and Elimination of your Personal Data

In accordance with current legislation, Sensedia uses your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected, as described in this policy, or to comply with applicable legal requirements. Personal data used to provide you with a personalized experience will be kept exclusively for the time allowed, in accordance with current legislation.You can obtain more details about the retention of your Personal Data through the communication channels detailed in this policy. At the end of the processing of your Personal Data, these will be eliminated within the scope and technical limits of the activities, and conservation of this data is authorized in the situations explained in the current legislation.

7. About the Disclosure, Storage or Transfer of your Personal Data

Sensedia takes appropriate measures to ensure that your Personal Data is kept confidential and secure. However, these protections do not apply to information that You have chosen to share in public spaces, such as third-party social media.

People who can access your Personal Data: Your Personal Data will be processed by our employees or authorized agents, as long as they need access to such information, depending on the specific purposes for which your Personal Data has been collected.

Measures taken in operational environments: We store your Personal Data in operating environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data.

Measures that Sensedia expects you to take: It is important that You also have a role in keeping your Personal Data safe. When creating an online account, please, ensure to choose a password that is strong to prevent unauthorized parties from guessing it. We recommend that You never reveal or share your password with others. You are solely responsible for keeping this password confidential and for any action taken through your account on Sensedia's compatible sites and services. If you use a shared or public computer, never choose the option to remember your login name, email address or password, and make sure that You log out of your account whenever you leave the computer. You must also use any privacy settings or controls that Sensedia provides on its website, services, or applications, including those considered optional.

Transfer of your Personal Data: Given the nature of Sensedia's services and products, we may need to transfer your Personal Data to third parties, in accordance with the purpose set out in this Privacy Policy. For this reason, we may transfer your Personal Data to other countries, as long as they have laws and regulations compatible with those in force in Brazil.

8. Your Rights Regarding Personal Data

You have the right to confirm the existence, access, review, modify and/or request an electronic copy of the information from your Personal Data that is processed by Sensedia. You are also entitled to request details about the origin of your Personal Data or the sharing of this data with third parties. At any time, You may also limit the use and disclosure, or revoke consent to any of our activities for processing your Personal Data, except in situations provided for in current legislation. These rights can be asked through the communication channels detailed in this policy, and it is necessary to validate your identity by providing a copy of a document, in accordance with current legislation. Whenever an application is submitted without providing the necessary evidence to prove the legitimacy of the data owner, the application will be automatically rejected. We emphasize that any identity information provided to Sensedia will only be processed in accordance with the applicable laws. We emphasize that, in certain cases, we cannot delete your Personal Data without also deleting your user account. In addition, some situations require the retention of your Personal Data after you request its exclusion, in order to follow legal or contractual obligations.

9. What are your choices about how we use and disclose your Personal Data

What are your choices about how we use and disclose your Personal Data Sensedia respects your privacy and autonomy as much as possible, so you have the freedom over your Personal Data that You provide to us. The following mechanisms give you control over the treatment of your Personal Data:

▪ Cookies/Similar Technologies: You can manage your consent using:
▫ Your browser settings to refuse some or all cookies and similar technologies, or to alert you when they are being used.

▪ Advertising, marketing, and promotions: you can consent to your Personal Data being used by Sensedia to promote our products or services through checkboxes located on registration forms or by answering questions presented by our representatives. If you decide that you no longer wish to receive such communications, you may cancel your subscription at any time by following the instructions provided in these communications or by sending a request to marketing@sensedia.com.

▪ Targeted Advertising: Sensedia may partner with ad services or ad providers, which display advertisements on our behalf.

10. Changes to our Privacy Policy

Whenever Sensedia decides to change the way we process your Personal Data, this Policy will be updated. We reserve the right to make changes to our practices and this Policy at any time, as long as compliance with current legislation is maintained. Considering it, we recommend that you log in frequently, or whenever you have questions, to see any updates or changes to our Privacy Policy.

11. How to contact Sensedia:

You can contact Sensedia to: 
·  Ask questions or make comments about this Policy and our personal data protection and privacy practices;
·  Complain;
·  Confirmation of the existence of Personal Data processing;
·  Obtain information on how to access your Personal Data;
·  Adjust incomplete, inaccurate or outdated personal data;
· Obtain information on the anonymization, blocking or elimination of unnecessary, excessive or processed data in non-compliance with the provisions of the current legislation;
· Obtain information about the portability of your personal data to another service or product provider, upon request, in accordance with current legislation;
· Request details of public and private entities with which we share your Personal Data;
· Obtain information about the possibility of not providing consent and the consequences of this denial;
· Ask the revocation of consent for the processing of your Personal Data, except for the cases provided for in the current legislation;
· Other rights of the holder of personal data, according to current legislation. For this, we request that you contact us using the following communication channels: 

Responsible for Personal Data Processing: Compliance Team
Email: privacy@sensedia.com
Phone Number: +55 19 3500.8265
▪ In person or by mail:
Rua Doutor Ricardo Benetton Martins, nº1.000, Prédio 3, Piso 01, Loteamento Parque II do Polo de Tecnologia, Campinas, São Paulo, Brazil Code: 13086-902.

Sensedia will receive, investigate, and respond, within a reasonable time, to any request or complaint about the way we process your Personal Data, including complaints about breaches of your rights under the current Personal Data protection and privacy laws.