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Privacy Policy

PRIVACY POLICY


Randoncorp's privacy policy is based on the principles of transparency and respect in its relationships with users.

YOUR DATA BELONGS TO YOU
We know that you care about your personal data and how it is used, and we want you to trust Randoncorp to handle your personal data with care. This Privacy Policy will help you understand the protection and processing of personal data collected by us.

Please take a few moments to familiarize yourself with our privacy practices, and if you need any clarification, contact us by email at dpo@empresasrandon.com.br or through our data subject portal.

COLLECTION OF PERSONAL DATA


Any personal data provided by you or collected by Randoncorp through other monitoring technologies are processed by Randoncorp or partners responsible for the operation.

This Privacy Policy also applies to Randoncorp's marketing content, including offers and advertisements for products and services from our companies, which we (or a service provider acting on our behalf) present to you on websites, platforms, and applications of third parties based on your usage information of our platforms. These third-party platforms typically have their own Privacy Policies. We recommend that you read them before using these platforms.

TYPES OF PERSONAL DATA COLLECTED
It is important for you to know that personal data is any information that can be directly or indirectly related to a natural person (the data subject), identified or identifiable. In other words, the natural person can be identified, for example, through a name, identification number, location data, genetic data.

Please note that you are not obligated to provide the personal data requested by Randoncorp, but if you choose not to do so, we may not be able to offer you our products and services, provide high-quality service, or respond to any questions you may have.

We may collect personal data from various sources. These include:

Personal data you provide to us directly;

Personal data we collect automatically;

Personal data we collect from other sources.

You may be asked for your personal data when you contact us. Randoncorp may share your personal data among the group companies and use it according to this Privacy Policy. We may also associate this data with other information to improve our products, services, content, and advertising.

HOW WE COLLECT YOUR PERSONAL DATA


We may collect your personal data from various sources. These include:

Personal data you provide to us directly. We collect information about your use of our services and products, such as the type of content you view or interact with, or the frequency and duration of your activities. We also collect personal data you provide when subscribing to a marketing newsletter, filling out a form, or registering an account to purchase our products. In these actions, we may request some of your personal data, such as your name, gender, date of birth, email address, and phone number.

Personal data we collect automatically. We also collect and store certain types of personal data whenever you interact with us online. For example, we use cookies and monitoring technologies to obtain personal data whenever your web browser accesses our platforms or ads and other content offered by Randoncorp or on its behalf on third-party platforms. Examples of personal data we collect include IP address, device ID, location data, information about the computer, time zone settings, types and versions of plug-ins used by the browser, operating system, and history that Randoncorp occasionally aggregates with similar information from other users. During part of your navigation on Randoncorp's platforms, we may also use software tools to measure and collect session information, including page response times, download errors, visit duration to certain pages, information about your interaction with them, and methods used to exit them. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.

Personal data we collect from other sources. We collect personal data from other sources, including third parties with whom we have trusted partnerships and on third-party platforms where we operate Randoncorp accounts. For example, when you use the "like" feature on Facebook. Additionally, we receive information about your interaction, as well as other users, with our advertising to assess if it is relevant and successful.

WHEN AND HOW WE COLLECT SENSITIVE DATA


Some personal data, such as that revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, genetic data, biometric data to unequivocally identify a person, health-related data, or data related to sexual life or sexual orientation, is classified as sensitive data.

We limit the circumstances in which we collect and process these sensitive data. However, Randoncorp may request such data to present relevant advertising and promotions to your profile. We only collect and use these personal data in situations where you have given us your consent or where the processing of the data is required by law.

PROCESSING OF PERSONAL DATA OF CHILDREN


We understand the importance of taking additional precautions to protect the privacy and security of children and teenagers who may use Randoncorp's platform.

Most of our platforms are intended for use by adults. In cases where one of our websites is intended to be used by a younger audience, consent from at least one parent or legal guardian will be obtained, in strict compliance with applicable laws and regulations. Additionally, if we become aware that we have received or collected personal data from a child or teenager without the consent of the responsible legal guardians, where this should have been obtained, we will delete that personal data as soon as possible.

Therefore, we may sometimes use your personal data to conduct age verification and enforce any age restrictions.

PURPOSES OF USING YOUR DATA


We collect, process, and disclose your personal data only for specific and limited purposes. For example, to process your requests, to develop and improve our products, services, communication methods, and the functionality of our platforms, to offer you personalized products and communications, as well as targeted advertising and product recommendations. We may also create profiles by analyzing information about your online browsing, search, and shopping habits, and your interactions with our brand communications, by creating segments (groups with common characteristics) and placing your personal data in one or more of these segments.

Additionally, Randoncorp processes your personal data using automated means. An automated decision is one made exclusively by automated means.

We may collect, process, and disclose your data for the following purposes:

To process and respond to your requests or to contact you to address your questions and/or requests;

To develop and improve our products, services, communication methods, and website functionality;

To communicate with you and manage your registration and/or subscription to our newsletter or other communications;

To authenticate the identity of individuals contacting us by phone, electronic means, or otherwise;

For training and quality assurance purposes;

To understand and assess changing consumer interests, desires, and needs, to improve our website, platforms, current products, and services, and/or develop new products and services; and

To provide you with personalized products and communications, as well as targeted advertising and product recommendations.

Where we collect and use your personal data for the purposes mentioned above or other purposes, we will inform you in advance or at the time of collection.

When applicable, we will ask for your consent to process your personal data, and when you have provided your consent for processing activities, you have the right to withdraw your consent at any time.

LEGITIMATE INTEREST


In many cases, there is a legitimate interest to process your personal data. This legal requirement is used where necessary to achieve a fundamental objective, for example, to assist in the execution of a contract or optimize a service, and it does not compromise your rights as an individual. We can assure you that if legitimate interest is used as a reason for processing your personal data, we will keep a record of that action, and you have the right to request that information.

We also process your personal data to execute a contract in which you are or will become a party. For example, we need to process your personal data to deliver a product or service you have purchased.

We also process your personal data when necessary to comply with a legal obligation (e.g., a fiscal or social security obligation) that requires us to process your data.

Randoncorp may also use your personal data to create profiles. We create profiles by analyzing information about your online browsing, search, and service acquisition habits, and your interactions with our brand communications, by creating segments (groups with common characteristics) and placing your personal data in one or more segments. These segments are used by Randoncorp to personalize platforms, websites, and our communications to suit you (e.g., showing you relevant content when visiting our site or in a newsletter addressed to you), and to display offers and relevant advertising from our brands on Randoncorp platforms and third-party websites. The segments may also be used for third-party campaigns on our platforms. Randoncorp creates profiles with your data only if you have given us your consent to do so, for example, by accepting cookies in your web browser or subscribing to newsletters from one of our brands via email.

You can withdraw your consent at any time to prevent the use of your personal data in this way, by using the cookie management section of our Cookie Policy or unsubscribing from the use of your email address if you have registered on one of our websites or subscribed to a marketing newsletter.

Randoncorp, in particular, collects data with your consent:

On our platforms based on what you view and how you interact with our content;

In our digital advertising presented on social platforms and other websites; and

In forms you fill out online and send us with your interests.

We also monitor the products you click on in our ads and continue to request or purchase a product or service. Also, if you have requested contact by email, SMS, WhatsApp, or other communication methods, we log when you open, read, or click on its content to see what interests you, so we can offer more content we think you would like.

Sometimes, with your consent, we may use your current location to offer you local promotions or events we think are of interest to you.

DATA SHARING BETWEEN Randoncorp COMPANIES


We inform you that we may share your data among Randoncorp companies. All our companies follow the same personal data protection standards and adhere to the same purposes for using your data as described in this policy, such as:

Developing new products and services;

Offering products and services that best meet your interests; and

Generating statistical and aggregate data about the usage of our products and services and user profiles.

To know the corporate structure of Randoncorp, visit our investor relations website (https://ri.randoncorp.com/).

INTERNATIONAL DATA TRANSFER


Randoncorp may share personal data within the group or with third parties for the purposes described in this Privacy Policy. If an international transfer of personal data occurs, Randoncorp ensures that the data is protected.

PROTECTION OF YOUR PERSONAL DATA


For Randoncorp, privacy and the protection of your personal data are important. We make every effort to protect your personal data from misuse, interference, loss, unauthorized access, alteration, or disclosure.

Access to your personal data is only allowed among our employees and agents as necessary, and is subject to strict contractual confidentiality and protection obligations when processed by third parties.

We will retain your personal data for the time necessary for the purpose for which it was collected. We will store identifiable data collected directly for specific purposes for the minimum time necessary, after which we will take steps to permanently delete it. We actively review the personal data we hold and will securely delete or anonymize it when the legal, commercial, or user obligation to store it ends.

KNOW YOUR RIGHTS


You are entitled to a set of rights concerning your personal data and how it is processed. You may exercise these rights at any time. You can exercise your rights by sending a request via email to dpo@empresasrandon.com.br or by submitting a direct request through the data subject portal.

For your knowledge, we describe below some of your rights, but we emphasize that we respect all your rights according to the applicable data protection laws:

Right to Information. You, as the data subject, have the right to be provided with concise, transparent, comprehensible, and easily accessible information, using clear and plain language, about how we use your personal data and your rights. For this reason, we present this Privacy Policy.

Right of Access and Rectification. You, as the data subject, have the right to access your personal data, as well as to rectify any inaccurate personal data, or complete it if it is incomplete.

Right to Data Portability. The personal data you provided may be portable. This means that it may be transferred, copied, or transmitted electronically under certain circumstances, when requested.

Right to Deletion of Personal Data. Under certain conditions, you, as the data subject, have the right to request the deletion of your personal data from the data controller. If you wish to delete your personal data, please inform us, and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer necessary for any purpose and we are not legally required to retain it, we will make our best efforts to permanently delete, destroy, or anonymize it.

Right to Restriction of Processing. Under certain conditions, you, as the data subject, have the right to restrict the processing of your personal data.

Right to Object. You, as the data subject, have the right to object at any time, for reasons related to your particular situation, to the processing of your personal data. Specifically, when personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of their personal data for such marketing purposes (e.g., receiving notification emails).

Right to Withdraw Consent. If you have given your consent for us to use your personal data, you, as the data subject, have the right to withdraw your consent at any time by informing us of your intent through the provided contact details.

Right Related to Automated Decisions. You, as the data subject, have the right not to be subject to decisions solely based on automated processes that have legal or significant effects. In general, you have the right to obtain human intervention, to obtain justification for the decision made after an assessment, and to contest the decision.

Further information or advice about your rights can be obtained from the regulatory authority in accordance with the applicable data protection laws.

CONTACT INFORMATION – DPO


The Data Protection Officer (DPO) responsible for personal data protection, appointed by Randoncorp, can be contacted at the address Avenida Abramo Randon, nº 770, Bairro Interlagos, Caxias do Sul – RS, Brazil, ZIP: 95055-01, or by email at dpo@empresasrandon.com.br or through the data subject portal on our platforms.

DATA SUBJECT PORTAL


Access: portaldotitular.randoncorp.com

If you have any questions or concerns about this Privacy Policy or data processing, please contact us. We have a dedicated team to respond to your request or inquiry.