PRIVACY POLICY
LGPD – Law No. 13,709/2018

Last updated: June 5, 2023.

This document, hereinafter referred to as the "Privacy Policy," outlines how HEDRO INTELLIGENT SYSTEMS LTD, located at Hélio Ribeiro Street, 212, Center, Entre Rios de Minas/MG, registered under CNPJ No. 26.199.823/0001-81, represented according to its constitutive acts, collects, stores, and uses the personal data of users of its solutions, as well as its business partners.

1. DEFINITIONS

1.1. For the purposes of reading and interpreting this document, the terms listed shall have the meanings as per Law No. 13,709/2018 - LGPD (General Data Protection Law), as detailed below:
User: Any person, natural or legal, whether a client or business partner, providing User Data for the use of the HEDRO Platform.
User Data: Identifying data of a specific user, subdivided, for the purposes of this document, into: personal data (such as, but not limited to: name, ID, CPF, email address, residential address, phone); browsing data (such as, but not limited to: login and access password when necessary, time spent on the HEDRO site); and financial data (bank account information, credit card data).
Cookies: Automatically created files stored on devices (computers, mobile devices, etc.) of Users when accessing websites on the internet, storing device and browsing identification data.

2. PURPOSE
2.1. The purpose of using user data at HEDRO is both for the execution of services provided through our Platform and for the improvement and creation of services and content promoted by HEDRO, such as:
Improvement of services: user data is used for performance improvement, content layout, among others;
Periodic sending of advertising and informational material from HEDRO to the email address registered by each User, to keep them updated on the solutions offered by HEDRO, as well as major market news;
Credit protection, anti-fraud, and risk assessment: user data is used to add value to the protection of our services and clients, making the environment more secure.
2.2. Purpose for the use of banking data: We use this data to facilitate the processing of payments for services that our clients contract through our Platform.

3. COLLECTION
3.1. HEDRO only collects User Data for legitimate purposes and maintains its practices in compliance with all applicable laws and regulatory authorities, both national and international.
3.2. The collection of User Data can be done in the following ways:
Manual and voluntary: by filling out forms by the User themselves (example: filling out data such as name, CPF, and address when registering a new client); Automated via software: when basic access pattern information, device type, and other non-directly identifiable information are collected automatically and stored on the User's side and also communicated to our suppliers, and may be stored and processed on both sides of the communication.

4. STORAGE
4.1. All collected User Data is stored on servers and databases of HEDRO or our suppliers or partners (national or international), all in full compliance with market best practices and the necessary information security measures to ensure compliance with current legislation.
4.2. The information collected is for our exclusive use for the purposes mentioned here, therefore, it will not be sold to third parties under any circumstances. However, we may disclose your personal data in good faith belief that such action is necessary to:
Legal compliance. Understanding (i) legal processes and requests; (ii) establishment or exercise of our legal rights or defense in legal proceedings; or (iii) as required by law; and
Third-Party Service Provision. We may also work together with other companies in various activities to facilitate our service, to perform the service, as well as sponsors of the services to be provided. These receive your data only to the extent necessary for the provision of contracted services. We emphasize that our contracts are guided by the data protection standards of the Brazilian legal system, prohibiting these third parties from disclosing or using the data for any other purpose.
4.2. User Data will be stored until:
The User requests its deletion, as per item 7.1, "a" of this Policy;
HEDRO decides to render the data useless, at its sole discretion;
Deletion of data is determined by a government authority (administrative or judicial).
4.3. You can exercise the rights described here through written communication by sending your request to the email: support@hedro.com.br

5. USE AND PROCESSING
5.1. HEDRO processes all User personal data in full compliance with the limits provided for in Law No. 13,709 of 2018 (LGPD – General Data Protection Law) and other current regulations.
5.2. User Data is used by HEDRO and shared by it with partners (national or international) in possible ways:
Anonymized, when deprived of personal data that allows the individualization of the User (example: for the preparation of studies and management reports);
Encrypted, when data needs to be transmitted securely and in accordance with encryption standards (e.g.: capture and transmission of payment data);
Non-anonymized, when encryption is unnecessary and personal data must be used and/or shared with partners, in accordance with the permissions provided in item 5 below.
5.3. HEDRO may share user data with police and judicial authorities, as well as with the data owner themselves when notified to do so, or at its own discretion when it deems necessary or appropriate to cooperate with investigations into fraud (improper use of third-party personal and financial data) or any other type of illegal activity by Users.

6. USER CONSENT
6.1. By registering as a user, client, or partner in one of HEDRO's services or channels, the User expressly agrees that their User Data:
Be collected as provided in clause 2 of this term;
Be used to personalize their navigation on HEDRO's sites (e.g.: optimization of visual navigation, viewing the solutions list; viewing promotional banners);
Be included in HEDRO's communication receiving lists (via email; SMS or Whatsapp messages, and the like), including offers and promotions, with their effectiveness allowed or disabled according to the opt-in and opt-out functions available in the client's authenticated area;
Be used anonymously (without individual identification) for the preparation of statistical studies and management reports;
Be stored in secure databases and used for service optimization;
Be shared in anonymized form with HEDRO's partners (national or international) for statistical studies, with their security and compliance of use according to the contracts established between HEDRO and its partners;
Be shared with HEDRO's partners (national or international)
for the delivery of contracted services; 8) Be shared with HEDRO's partners (national or international) for the purpose of consulting the database for credit protection, such as: SERASA, SPC, SCR – BACEN; 9) Be shared with HEDRO's partners (national or international) for the purpose of offering services from these partners on the platforms and communication channels used by HEDRO.

7. USER RIGHTS
7.1. The User is entitled to:
Delete, partially or completely, their user data from HEDRO's databases, upon written request sent to the email address indicated in item 4.3, or direct request to the respective commercial area, in the case of business partners, except for data protected by higher sovereignty laws or legal needs;
Delete Cookies, through a procedure performed at their own risk on their own devices;
Be removed from receiving offers and promotions lists through the removal link contained in the messages themselves;
Update data, upon request sent to the email address indicated in item 4.3;
Not complete the registration in HEDRO's contact and hiring means if they do not agree with any terms provided in this Policy.

8. COOKIE MANAGEMENT
8.1. Cookies are files created by the websites you visit. They make the online experience easier for users, saving browsing information. With cookies, sites can keep users connected, reminding them of their site preferences and providing locally relevant content.
8.2. Cookies are generally used to:
Track your preferences to send only ads of interest;
Track items stored in your shopping cart;
Conduct surveys and diagnostics to improve content and services;
Prevent fraudulent activities;
Improve security.
8.3. Users can block or reject our cookies.
8.4. For more information and details about cookies, send your request to the email: support@hedro.com.br

9. RESPONSIBILITIES
9.1. HEDRO undertakes to:
In addition to complying with security standards required by regulations, make its best efforts to maintain the privacy of user data, using technology and information security protocols, observing the state of the art available according to market standards;
Delete and/or update User Data after a request as per item 6.1 clauses "a, c, and d" above;
Only enter into partnerships with third parties involving data sharing if these third parties also undertake to comply with all standards and obligations required by law regarding the collection, storage, and processing of data;
Report to competent authorities and Users any events involving undue exposure of User Data, as well as make its best efforts to prevent harm to Users due to such events.
9.2. HEDRO is not responsible for losses or damages suffered by Users due to undue exposure of their Data that has occurred for any reason other than proven fraud or non-compliance with the law.
9.3. This Privacy Policy may be unilaterally changed by HEDRO at any time. HEDRO undertakes to publish the text of the new policy on all its websites, platforms, and portals, notifying users of the update made. Any new hiring made by users after the change in the Privacy Policy implies tacit acceptance of the new conditions provided.

10. CONTACT
10.1. Any contact regarding privacy and data protection can be made through direct email communication with the data protection officer. For this, the email support@hedro.com.br should be used.
10.2. To exercise the rights established by the Law, the user can contact both the data protection officer, at the aforementioned email, or contact HEDRO's service channels.