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‍WOLVEN is a technology services and consulting company with expertise spanning web & mobile development, design, and project management, we provide skilled and motivated experts that can be seamlessly integrated into any tech project.

In order for you to contract our services and during the development of the contracted project, Personal Data will need to be provided to WOLVEN. In this Privacy Notice, you will find the details regarding the use of Personal Data by WOLVEN.

We kindly ask you to carefully read this document, and if you have any questions or concerns, you can contact our Data Protection Officer via email at policy@wolven.com.br.

1. WHO WE ARE?

WOLVEN SOLUTIONS & DESIGN LTD., a business company with its registered office at Lauro Linhares Street, 728 - Room 309 - Trindade, Florianópolis/SC, ZIP Code: 88036-001, registered under CNPJ number 14.081.387/0001-62 ("WOLVEN"), presents this Privacy Notice, which applies to all users, visitors, and customers, including website(s), platform(s), and app(s), if any, who have their Personal Data processed by us.

Agreeing to the premises outlined in the Privacy Notice is a requirement for using WOLVEN’s website.

2. DEFINITIONS

This section aims to explain, in a clear and communicative manner, concepts defined in the Brazilian General Data Protection Law (LGPD).

Personal Data: Any information that identifies or may identify an individual person.

Data Processing: Any action or operation performed with Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, sharing, disposal, evaluation, control of information, modification, communication, transfer, dissemination, or extraction.

Data Subject: The individual to whom the personal data refers.

Controller: The natural or legal person responsible for making decisions on how the processing operations with the Personal Data of the data subjects will occur. In the case of this Privacy Notice, WOLVEN is the Controller of the Data.

Processor: The natural or legal person who receives the controller's instructions and acts according to their guidance.

Data Processing Agents: Controller and Processor.

Data Protection Officer: A professional who serves as the communication channel between the data subject and the controller, as well as the ANPD.

ANPD (National Authority for Personal Data Protection): It is a Federal Authority that has responsibility for privacy and data protection, as well as the competence to oversee compliance with the legislation by all those involved in the processing of Personal Data.

3. WOLVEN'S RESPONSIBILITY

WOLVEN is responsible for the privacy and data protection of its customers and users, and for ensuring that this Privacy Notice is made available to data subjects before any type of processing of their Personal Data takes place.

All WOLVEN employees who interact with data subjects are responsible for ensuring that this document is brought to the attention of the data subject and that the processing of their data is protected.

4. DATA COLLECTED AND ITS PURPOSE

You directly provide us with most of the Personal Data we collect when you access our website, call us, use our services, send a message via WhatsApp, send an email, a correspondence, and/or visit us.

We collect your Personal Data in the following ways:

• When you fill out the website form with your name, last name, email, and phone number so that WOLVEN's sales team can contact you.
• When accessing our website, we may collect non-personal information such as the type of browser you are using, your IP address, visited pages, and access times. This information is collected through the use of Google Tag Manager, which allows us to manage and deploy tracking tags such as cookies and pixels that may collect technical information about your visit to our website. Google Tag Manager is a tool provided by Google Inc. ("Google") that helps us manage and control tracking tags on our website. Google Tag Manager does not collect personal information on its own. However, it may allow other tags, such as those from Google Analytics, to be deployed and collect personal information about you, subject to their own privacy policy. We recommend that you read the Google Analytics privacy policy to understand how your information is handled by that specific tool.

We use the Personal Data you provide for the following purposes:

• To contact you and send a commercial proposal after filling out the form on the website.
• To offer personalized content such as advertisements, search results, and others.
• To improve the user experience on our website, personalize displayed content, analyze website traffic, and carry out targeted marketing campaigns.

5. RIGHTS OF THE DATA SUBJECT

We want to ensure that you are fully aware of all your rights related to privacy and protection of Personal Data, so we have listed below the following rights:

• Confirmation of the existence of processing of Personal Data.
• Access to the Personal Data that we process about you, and you may also request information about the origin of the data, the absence of a record, the criteria used, and the purpose of the processing.
• Correction of incomplete, inaccurate, or outdated data.
• Anonymization, blocking, or deletion of unnecessary, excessive, or data processed in violation of the law.
• Portability of data to another service provider, upon express request, under certain conditions.
• Deletion of Personal Data processed with the consent of the data subject, under certain conditions.
• Information about public and private entities with which the controller has shared data.
• Information about the possibility of not providing consent and the consequences of refusal, as described in item 16.
• Revocation of consent, in accordance with the LGPD.
• Filing a complaint regarding your data against the controller with the national authority.
• Objection to processing based on one of the exemptions from consent.
• Review of decisions made solely based on automated processing of Personal Data that affect your interests, including decisions intended to define your personal, professional, consumer, and credit profile or aspects of your personality.

If you wish to exercise any of these rights, please contact us through our Data Protection Officer (DPO) via email at f.maneira@wolven.com.br and we will respond as soon as possible.

6. SHARING AND DISCLOSURE

WOLVEN will not disclose or transfer your Personal Data to third parties who do not have a legal relationship with WOLVEN.

However, we may share your Personal Data with third-party service providers who work on behalf of WOLVEN as Operators. These service providers are bound by contractual obligations of confidentiality, secrecy, and protection of Personal Data.

If requested by a competent authority in the performance of its legal duties, or by an order, decree, regulation, or government rule, or in the case of violations or suspected violations of this or the law, WOLVEN may be required to provide the information and Personal Data that are stored in our possession. However, WOLVEN commits to disclose strictly the necessary information and Personal Data to achieve the required purposes.

As WOLVEN develops and grows, which may include, but is not limited to, a corporate transaction such as an acquisition, merger, consolidation, or through the sale or purchase of companies, products, and/or assets, your data may be transferred to the new controlling company without violating the terms of this Privacy Notice.

7. STORAGE

We keep your Personal Data for as long as necessary to provide our services and for legitimate and essential business purposes, such as maintaining the performance of our Site, creating products and other functionalities according to the needs of our clients, and fulfilling our legal obligations.

We have established review and retention policies in place to fulfill these obligations, and we retain some Personal Data for the period determined by relevant legislation.

Upon your request, we will delete your Personal Data in a manner that does not identify you unless it is legally required to retain certain Personal Data, including situations such as the following:

If we are obligated to retain Personal Data for our legal, tax, auditing, and accounting obligations, we will retain your necessary Personal Data for the period required by applicable law.

Whenever necessary for our legitimate business interests, such as fraud prevention or maintaining the security of our users.

When you give us your consent to use your data for direct marketing (newsletter), we will keep this data until you exercise your right to object and/or withdraw your consent or unsubscribe.

8. SECURITY MEASURES

WOLVEN values the security of information and Personal Data of its clients, employees, and business partners. Therefore, we continuously invest in and implement technical and administrative security measures to protect your data, aligned with best practices in information security. However, we acknowledge that no system is completely secure.

To safeguard against unauthorized use, access, alteration, and/or destruction of data, we employ the following mechanisms and tools:

• Physical access control to corporate environments, with restricted access.
• Data access granted only to professionals with specific roles necessary to fulfill the intended purposes.
• Implementation of access authentication mechanisms for records, capable of identifying the individuals responsible for data processing and access, with detailed logging.
• Continuous monitoring of information systems to prevent, detect, and block malicious actions.
• Secure storage and transfer of data using appropriate methods.

By implementing these measures, we aim to ensure the confidentiality, integrity, and availability of your Personal Data.

9. CHILDREN AND TEENAGERS

WOLVEN does not knowingly collect Personal Data from children and adolescents under the age of 18. Our services are not intended for minors. If you are under the age of 18, please do not use the website or provide us with any Personal Data.

If we become aware that we have inadvertently collected Personal Data from a child or adolescent, we will take reasonable steps to promptly delete the relevant Personal Data.

10. INTERNATIONAL DATA TRANSFERS

The internet is a global environment, and some of WOLVEN's services may involve international transfers of data. We may utilize products, services, or components that are hosted outside of Brazil, including the USA.

Additionally, our subcontractors or partners may be located outside of Brazil, and as a result, your Personal Data may be processed in other countries.

In the case of international transfers made by WOLVEN, subcontractors, and partners, measures are implemented to ensure that any collected Personal Data is treated securely and in accordance with data protection standards. These measures include adherence to this Privacy Notice and the use of legal instruments that ensure compliance with all applicable legal obligations.

11. COOKIES

Cookies are files that record and store details of your activity when visiting a website on your computer. They are used to store information about your interaction with the site, such as language preferences, items in the shopping cart, or login details.

WOLVEN website can adapt its operations to your needs and preferences by collecting and remembering information about your preferences. Certain cookies may contain personal data, for example, if you click on "remember me" when logging in, a cookie may store your username.

WOLVEN uses cookies on the website with the aim of making your visit more enjoyable and providing information on how our site is being used, so that we can tailor it to visitors like you.

WOLVEN uses three types of cookies on the site:

1. HttpOnly Cookies: These cookies are designed for your online security. They are configured in a way that can only be accessed and modified by the web server. This means that malicious scripts or programs running in your browser cannot read or manipulate these cookies. This helps protect your personal information against hacker attacks.
2. Secure Cookies: These cookies are used in secure connections through HTTPS. They are transmitted only through an encrypted connection, making it more difficult for someone to intercept and steal your personal data. Secure cookies are essential when dealing with sensitive information such as login details or banking data.
3. Session Cookies: These cookies are temporary and used to maintain the state of your session while you browse the site. They are stored in your browser's memory and are deleted when you close the browser. Session cookies are useful for remembering information such as your login status or items in your shopping cart during a single visit to the site.

You also have options regarding the acceptance of cookies. By modifying preferences in a browsing program, you have the option to accept all cookies, be notified when one is triggered, or reject all cookies. If you choose to reject all cookies, you may not be able to use all the services on the site that require registration as a condition for participation.

12. CONSEQUENCES OF NOT PROVIDING YOUR DATA

The provision of your Personal Data is not mandatory, but this information is necessary for the provision of our services. Therefore, if you refuse to provide this data, we will be unable to offer some or all of our services without your data.

13. CHANGES TO THE PRIVACY NOTICE

WOLVEN keeps its privacy notice under periodic review and posts any updates on this page.

14. DATA PROTECTION OFFICER

If you have any questions about our privacy notice, even after reading it, the data we hold about you, or if you would like to exercise any of your data protection rights, you can contact our data protection officer via email at f.maneira@wolven.com.br.

Name of our data protection officer: Franthescolly Maneira.

15. COMPETENT AUTHORITY

WOLVEN only processes your Personal Data in accordance with this privacy notice and in accordance with applicable data protection laws. If, however, after contacting our Data Protection Officer, you do not obtain a solution to your case, you may file a complaint with the responsible supervisory authority, according to the contact information provided via email at anpd@anpd.gov.br and phone: (61) 3411-5961. If you have any questions about the ANPD's jurisdiction and competence, please visit the official portal at the following link: https://anpd.gov.br/.

Last updated: June 16, 2023.

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