AQUARELA PRIVACY POLICY

This privacy policy describes how your personal data is handled by AQUARELA INOVAÇÃO TECNOLÓGICA DO BRASIL S.A. (“AQUARELA” or “we”). We are a Brazilian company that is a benchmark in the use of artificial intelligence in industry and in large, national and global companies. From the conception to the commercialization and distribution of products and services on a large scale, we assist organizations in optimizing processes and operations, creating new businesses, and increasing analytical maturity.

AQUARELA offers services, projects, solutions and products, which can be accessed through the website – https://www.aquare.la/ (“Website”) – and respective products and solutions, including, but not limited to, Smart Pricing, Smart Assortment, Smart Maintenance, Smart Stock – OTIF, Geo Expansion, Smart Product Development, Vortx Streamliner, Sales Performance 4.0, Agro 4.0, Aquarela Tactics, Aquarela Tactics Energy (collectively referred to as the “Services”).

Our responsibility is to take care of your personal data and use it for the purposes described herein. If after reading you still have questions, feel free to contact us at email dpo@aquare.la.

How is this policy divided?

To make it easier for you to understand, this policy is divided as follows:

Basic concepts – what do I need to know to understand this policy?
For what purposes do we use your personal data?
With whom does AQUARELA share your personal data?
Does AQUARELA transfer data to other countries?
Cookies – what are they and how does AQUARELA use them?
How long is your personal data stored?
How do we protect your personal data?
What are your rights as a data subject?
How to talk about privacy with AQUARELA?
Changes to the Privacy Policy

1. Basic concepts – what do I need to know to understand this policy?

To make this policy clearer, some expressions, singular or plural, shall have the following meanings:

Privacy policy or policy: this is AQUARELA’s privacy policy. Personal data or data: is data relating to a natural person, which is capable of identifying or making they identifiable, within a certain context. For example: name, social security number, RG, address, mobile phone, e-mail, including sensitive personal data.
Processing: the use that AQUARELA makes of personal data, including, without limitation, the collection, storage, consultation, sharing, classification, reproduction, processing and evaluation of this data.
Data subject: is the person to whom the personal data relates. In the context of this policy, it may be you, a visitor to the Website, or a user of the Services.
Website: is the website of AQUARELA – https://www.aquare.la/ – and all other domains managed by us.
Services: applications, projects and services offered by AQUARELA, including, but not limited to, Smart Pricing, Smart Assortment, Smart Maintenance, Smart Stock – OTIF, Geo Expansion, Smart Product Development, Vortx Streamliner, Sales Performance 4.0, Agro 4.0, Aquarela Tactics, Aquarela Tactics Energy, and custom projects solutions and products.

2. For what purposes do we use your personal data?

The types of personal data and how AQUARELA uses it depends on how you relate to us and why. Below we list the main purposes for which AQUARELA uses personal data.

TABLE OF PURPOSES

Purpose	Description	Categories of personal data
Access to the Website and Services	Enable the use of the services available on our Website.	Website and Services Interactions and Usage Data.
Registration on the Webite and Services	Registration to enable access and use of the Services offered by AQUARELA.	Registration data and contact details.
Conducting transactions and invoicing	To enable and process transactions and invoicing for the purchase of our Services.	Registration and contact data, transaction and billing data.
Enhancement and improvements	To make improvements and enhancements to our Websites and Services, to personalize content, make changes to our products and services, provide new features, products and promotional dynamics, etc.	Website and Services Interactions and Usage Data.
Marketing, advertising, newsletter and promotions	Send you commercial and marketing communications about products, services, promotions, news, updates, events, and other matters you may be interested in.	Registration and contact data, data on interactions and use of the website and the Services, communications and customer service data.
Customer service	Solve problems and doubts, ensuring the quality of our Services and customer service. Establish a relevant and assertive dialogue, respecting your interaction preferences, as well as for sending important notices, such as announcements, registration of important changes and updates, features, conditions and policies, among others.	Registration and contact data, communications and attendance data.
Analytics	Analyze the performance, trends and measure the audience of the Website and Services, check your browsing habits on the Website and Services, the way in which you arrived at our Website (for example, through links from other websites, search engines or directly), evaluate statistics related to the number of visits to and use of the Website and the Services, its features and functionality.	Webite and Services Interactions and Usage Data.
Safety	Assess and monitor security risks to the Website and Services by improving and developing our security tools.	Website and Services Interactions and Usage Data.

At any time, you may set your privacy preferences on our Website, for example by limiting the publication of your information.

Below you can find a detailed list of which personal data may be processed in each of the categories mentioned in the table of purposes:

TABLE OF TYPES OF PERSONAL DATA

Category of personal data	Personal data
Registration and contact details	Email, profile picture, gender, date of birth, marital status, interests and hobbies, educational and employment information.
Device data	IP address, geographic location, browser type and version, operating system.
Professional data	Job title, name and segment of the company where you work, number of employees in the company, educational background, and years of experience.
Transaction and billing data	Information relating to what you purchase, services you use, or transactions you make through our Website, including name, address, social security number, telephone number, email address, bank details, and credit card details.
Website and Services Interactions and Usage Data	Referral source, frequency and duration of visit, page views and navigation paths on the Site, filling in fields, publications created.
Communications and attendance data	Your interaction on our service channels is also recorded, as well as other details of your contact, which may include chat conversation content and metadata.

3. With whom does AQUARELA share your personal data?

We may work with third parties, whether partners or suppliers, to carry out our activities and provide their products and services. Below we describe the main types of AQUARELA partners, with whom we may share personal data:

i. Suppliers and Partners:

AQUARELA uses suppliers and partners to properly provide its Website and Services, such as, for example, database and cloud computing service providers, advertising agencies, law firms, consultancies, development companies, among others. We always seek to enter into contractual obligations for the protection of personal data and information security with our partners and suppliers.

Eventually, AQUARELA makes available on the Website some links to partner websites. In these cases, we emphasize that AQUARELA does not control the information collected by these partners on their respective websites and that it has no responsibility with regards to the privacy and data protection practices employed. We recommend that you always read the privacy policies of these partners.

ii. Public authorities:

We may share your personal data with authorities to comply with a legal or regulatory obligation. For example, Procon or a Court of Justice may require AQUARELA to share certain personal data. If AQUARELA understands that a certain order is abusive, we seek to privilege your privacy to the extent legally possible.

iii. Protection of rights:

We reserve the right to share any personal data that we believe is necessary to comply with a legal or regulatory obligation, enforce our contracts, or protect the rights of AQUARELA, our employees and customers.

iv. Group Companies: We may transfer personal data between the companies of the AQUARELA Group, including internationally, to provide proper service to our customers and consumers, in addition to ensuring compliance with AQUARELA’s legal and regulatory obligations.

v. Auditing and corporate transactions: we may share your personal data in audit processes for corporate transactions or with partners and service providers in cases necessary for the proper execution of the contracts signed by AQUARELA.

4. Does AQUARELA transfer data to other countries?

Some of the data we collect may be transferred to other countries to fulfill the purposes set out in this policy. Some of our suppliers and partners may be located outside of Brazil, such as in the United States, Russia, Japan, China and India.

These transfers only involve companies that demonstrate compliance with applicable data protection laws and maintain a similar or even stricter level of compliance than that provided for in applicable Brazilian law.

5. Cookies – what are they and how does AQUARELA use them?

Cookies are small text files that are stored on your browser or device while using the Website. The use of cookies is linked to the operation of the Website. For example, some user information is saved through cookies, and when the same user visits the Website again, the browser is recognized and configures the Website according to the preferences previously made.

Cookies usually have an expiration date. For example, some cookies are automatically deleted when the browser is closed (so-called session cookies), while others may be stored for a longer time on the device until they are manually deleted (so-called persistent cookies).

In general, AQUARELA may use the following types of cookies:

Strictly necessary cookies: in order for our Website to function properly.
Analysis cookies: to improve the content of the Website by providing information about how the pages are being used, allowing you to improve your user experience. They automatically collect certain Personal Data to identify, for example, how many times a particular page has been visited.
Marketing cookies: to target advertisements that may be of particular interest to specific users.
Functionality cookies: these are used to record the data previously provided, such as your login information, to improve the browsing experience.

If the user wishes to refuse the installation of these cookies on their device and/or choose to remove cookies, the user can do so through the configuration of their browser. For more explanations on how to configure the use of cookies in your browser, please check the website of the browser developer you use, such as:

It is important to clarify that AQUARELA is not responsible for the use of cookies by third parties. The user should be aware that cookies installed by third parties may eventually continue to monitor their online activities, and it is recommended to regularly manage the cookies installed in their browser.

Please be advised that blocking cookies will have a negative impact on the usability of our Website, so some functionality and features of the Website will not be available.

6. How long is your personal data stored?

Personal data is stored for as long as necessary to fulfill the purposes for which this information was collected. In some situations, we will need to keep personal data for an additional period of, for example, compliance with legal or regulatory obligations, contractual obligations, among others. Such maintenance and storage of data will always be based on a legal basis, guaranteeing the right of the data subject to request the deletion of their information, as informed in item 8.

7. How do we protect your personal data?

To ensure your privacy and the protection of your personal data, AQUARELA adopts the necessary technical and organizational precautions to avoid the loss, misuse or alteration of your personal data. Personal data will be stored on cloud servers securely, protected by password and firewall.

We strive to protect the privacy of your account and other personal data we hold for our records, but unfortunately, we cannot guarantee complete security. Unauthorized account entry or use, hardware or software failure, and other factors can compromise the security of your personal data at any time, so please help us maintain a safe environment for everyone by adopting good security practices regarding your account and data.

8. What are your rights as a data subject?

The Brazilian General Data Protection Law guarantees you several rights related to your personal data. We are committed to the fulfillment of these rights and, below, we explain what they are and how you can apply them with AQUARELA:

Rights	Explanation
Obtaining information on the use of personal data (Confirmation, Access, and Sharing)	You can ask AQUARELA for confirmation about the use of your personal data, information about how we use it, with whom it is shared, and copies of the records we have about you.
Correction	You may request AQUARELA to correct incomplete, inaccurate or outdated personal data.
Anonymization, blocking, or deletion	You may request AQUARELA: (i) the anonymization of your personal data, so that it can no longer be related to you and, therefore, ceases to be personal data; (ii) the blocking of your personal data, temporarily suspending the possibility of processing it for certain purposes; and (iii) the deletion of your personal data, in which case we shall delete it without the possibility of reversal.
Portability	You may request that AQUARELA provide your personal data in a structured and interoperable format for its transfer to a third party, provided that such transfer does not violate AQUARELA's trade and business secrets.
Information about the possibility of not consenting	You have the right to receive clear and complete information about the possibility and consequences of not providing consent requested by AQUARELA for the use of your personal data. Whenever we ask for your consent, you are free to deny it – in such cases, it is possible that some Services may not be able to be provided.
Revocation of consent	If you have consented to any purpose of processing your personal data, you can always choose to revoke your consent. However, this will not affect the lawfulness of any processing carried out prior to the revocation. If you withdraw your consent, we may not be able to provide you with certain services, but we will notify you when this occurs.
Opposition	The law authorizes the processing of personal data even without your consent. In these situations, we will only process your personal data if we have legitimate grounds to do so. If you do not agree with any purpose of processing your personal data, you may file an objection by requesting its interruption.
Automated decision review	You may request a review of the decisions made based on the solely automated processing carried out by us, when applicable, provided that any commercial or business secrets of AQUARELA are respected.

For your security and seeking to prevent fraud, when you submit a request to exercise your rights by e-mail dpo@aquare.la, AQUARELA may request some additional information to prove your identity. We do this to ensure everyone’s security and privacy by preventing the disclosure of personal data to unauthorized people.

In some cases, AQUARELA may have legitimate reasons for failing to comply with a request to exercise rights. These situations include, for example, cases in which the disclosure of specific information may violate AQUARELA’s or third parties’ trade secrets, as well as cases in which AQUARELA has the obligation to keep the data, either to comply with legal and regulatory obligations or to enable the defense of AQUARELA’s or third parties’ rights. in disputes of any nature.

Also, some requests may not be answered immediately, but AQUARELA undertakes to respond to all requests within a reasonable time and always in accordance with the applicable legislation.

9. How to talk about privacy with AQUARELA?

If you would like to exercise any right, or understand that your personal data has been used in a way that is incompatible with this policy, or if you have any questions, comments or suggestions related to this policy, please contact our Data Protection Officer:

E- mail: dpo@aquare.la.

10. Changes to the Privacy Policy

As we are always looking to improve our products and services, this privacy policy may be updated. Therefore, we recommend that you periodically visit this page so that you are aware of the changes that have been made.

Last updated on July 31, 2023.