Privacy and Cookie Policy

Introduction

In compliance with the General Data Protection Law – LGPD (Law No. 13.709/2018), Velip, a brand of the company Tradeal Tecnologia de Informações Ltda, hereinafter referred to as VELIP, has prepared this Privacy and Cookie Policy (the "Policy") to clarify to its users and clients (the "Users") how personal data is collected and processed.

The objective of this Policy is to allow the User to understand what data is collected, the reasons why it is collected and used, how data and privacy are protected, and to clarify the rights of Users regarding their personal data.

Consent

By requesting information, contracting, or accessing the website, the User declares to have read this Policy and expresses, freely and consciously, their consent to the collection and processing of personal data under the terms of the LGPD and this Policy. Withholding consent or its subsequent revocation is a right of the User; however, in these cases, some features or services offered by VELIP may not be provided or enjoyed by the User.

User Rights (Art. 18, LGPD)

The User has the right, at any time and upon request, to:

• Confirmation of the existence of data processing;
• Access to the data;
• Correction of incomplete, inaccurate, or outdated data;
• Anonymization, blocking, or elimination of unnecessary or excessive data, or data processed in non-compliance with the LGPD;
• Data portability to another service or product provider, safeguarding commercial and industrial secrets;
• Elimination of processed personal data, except for retention or in cases explicitly specified within the LGPD;
• Information regarding the potential sharing of data with third parties;
• Information about the possibility of withholding consent and its consequences;
• Revocation of consent, observing precisely the terms of the LGPD.

Communications and Revocation

If VELIP sends messages to the User via mailing list or other form of communication based on the collected data, the User is guaranteed the right to revoke consent, withdraw authorization, or object, free of charge, at any time.

Data Collection

VELIP may collect User data whenever they express, in any way, such as by email, phone, forms, accessing the website, or using its platforms, social networks, etc., an interest in contracting services, or also in cases of entering into service provision agreements or other legal business with the User.

In these cases, without prejudice to other specific data, depending on the particular case, the following may be requested: email, full name, identification documents, professional information (position, company, etc.), full address, and contact information (landline or mobile phone). Additionally, financial information may be requested, such as bank, branch, and checking account, as well as additional information from third parties for registration verification or credit restrictions, in the legitimate interest of VELIP.

Whenever the User is a legal entity, personal data of representatives, employees, or collaborators may be requested.

Cookies

VELIP may also collect data automatically or semi-automatically through the use of cookies (files stored on the User's access device during internet browsing) to enable more efficient, fast, and personalized navigation, improving the User experience and communication efficiency.

In this scenario, for example, the IP address, date and time of access, and the history of pages visited on VELIP's website or platforms may be collected. VELIP clarifies that the User may, at any time, activate alert or blocking mechanisms for the use of cookies in their browser, which, however, may affect or limit some functionalities.

Google Services Integration (OAuth)

For users who choose to use the integration feature with Gmail, VELIP requests access to the following data via Google OAuth:

Limited Use and Data Protection: The use and transfer of information received from Google APIs to any other application by VELIP will comply with the Google API Services User Data Policy, including the Limited Use Requirements.

VELIP does not share, sell, or use data from Google APIs for advertising or training generalist AI models.

Data Processing and Purpose

Personal data is processed in compliance with the LGPD, ensuring the rights of Users for the purpose of contract execution, compliance with legal obligations, and in the legitimate interest of VELIP, or, when necessary, with the User's consent.

In this way, in addition to improving its communication with the User, VELIP may protect its rights and the rights of the User or third parties, and, subject to the rules of the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet), retain access logs to its platforms for the potential identification of responsible parties in the event of legal or authority inquiries.

Data Disposal

Data that is not used or whose storage is no longer necessary will, at VELIP's discretion, be properly disposed of.

Third-Party Data

VELIP may process, as a data processor (as defined under the LGPD), third-party data shared by controllers under the terms contractually agreed with the User. The data controller declares, under their personal responsibility, that they have obtained the necessary consent or clarify the situations in which it is dispensable.

All provisions of this Policy are applicable to these data, where appropriate, noting, however, that the exercise of rights by the User in this case must be directed to the controller, who is responsible for decisions regarding the processing of personal data.

Data Sharing

VELIP clarifies that it will share collected data with third parties, in good faith, only to the extent strictly necessary for the regular exercise of its rights, execution of contracts, and other legal obligations.

Data may also be shared if VELIP believes, in good faith, that sharing is necessary to protect its legitimate interest or that of third parties; for national security; compliance with the law; litigation; criminal or civil investigation; to protect the safety and integrity of third parties; or to prevent damage.

Data may be shared with third parties if VELIP initiates a process of sale or transfer of ownership.

Storage and Conservation

The collected data will be processed and stored on third-party servers, which may be located outside the national territory, adhering to the best security and confidentiality practices.

The collected data will be retained for as long as VELIP deems necessary for the provision of services, for its legitimate business interests, improvement of its platforms, business decision-making, compliance with legal obligations, or resolution of disputes. At the User's request, and provided such request does not conflict with other rights, legitimate interests, or legal obligations, the data may be anonymized or deleted.

Data Security

VELIP undertakes to protect User data and employ appropriate technical and organizational measures for its security; however, the User is advised that no system is completely secure. All security measures implemented by VELIP consider, under the terms of the LGPD, the nature of the data and its processing, the risks involved, existing technology, its availability, and economic feasibility.

Children and Adolescents

VELIP does not intentionally collect data from children and adolescents, and its services, platforms, and website are not directed to this audience. If the User is under 18 (eighteen) years of age, they may not provide any data; if collected involuntarily, such data will be deleted as soon as we become aware of it. VELIP will proceed in the same manner if it involuntarily gains access to any sensitive personal data.

Changes to this Policy

This Policy may be updated or changed in the future, and in such cases, VELIP will provide appropriate notification on its website and platforms, and may potentially send an email notifying of the changes.

Contact — Data Protection

If the User has any questions, comments, or requests, they should contact the Data Protection Officer: