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    Privacy Policy

    1. GENERAL INFORMATION

    We are committed to safeguarding your privacy and, in this regard, we clarify that we collect and use certain personal data belonging to those who use the website maintained and operated by ENGINE (www.enginebr.com.br), acting as the Controller of this data, in accordance with Article 5, item VI of Federal Law No. 13,709/2018, popularly known as the "General Data Protection Law" or simply "LGPD," and subject to the provisions of the LGPD.

    We take care to protect your personal data, and for this reason, we provide this Privacy Policy, which contains important information that should be carefully read by all.

    If you do not agree with the provisions of our privacy policy, we do not recommend browsing our website, downloading our materials, and/or using our services.

    2. IMPORTANT DEFINITIONS FROM LGPD

    The LGPD aims to protect the personal data of a natural person who is in Brazil, also known as the data subject.

    The law introduces some new concepts, including those related to the types of personal data that can be processed, and others related to who processes such data. To facilitate your understanding, please read the table below containing brief explanations of each of these concepts:

    Personal Data Any data that identifies or makes identifiable a natural person
    Sensitive Personal Data That which, by its nature, concerns information requiring greater care, especially for protection against discrimination, such as racial or ethnic origin, religious belief, political opinion, affiliation to a trade union or religious, philosophical, or political organization, data concerning health or sex life, genetic or biometric data when linked to a natural person.
    Data Owner Individual to whom the personal data refers.
    Controller Individual or legal entity responsible for deciding on the processing of personal data in its possession.
    Operator Individual or legal entity that processes personal data on behalf and according to the instructions of the controller.
    Sub Operator Any person who assists the processor in carrying out the processing of personal data on behalf of the controller.
    Data Process All activities that the controller, processor, or sub-processor carries out, directly or indirectly, concerning personal data, including but not limited to the following: collection, storage, use, and sharing of personal data.
    Legal Basis Legal hypotheses that authorize the controller, processor, or sub-processor, as applicable, to process personal data, which may include consent, compliance with a legal or regulatory obligation, execution of a contract, etc.

    3. COLLECTION AND PROCESSING OF PERSONAL DATA

    The processing of personal data refers to all operations performed with personal data, including but not limited to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, assessment, or control of information, modification, communication, transfer, dissemination, or extraction, according to Article 5, Clause X of LGPD.

    Some personal data may be collected when using our website, such as name, phone number, email, and professional position. However, when contacting ENGINE through one of our service channels, the collection of other personal data may also occur.

    Additionally, the Internet Protocol ("IP") address of the computer or proxy server used to access the web, your location via GPS tracking, the computer's operating system, the type of browser used, as well as information about how you use our services, may be collected.

    To process the aforementioned personal data, we commit to selecting one of the legal bases provided by LGPD to comply with the purpose outlined in this Policy.

    4. PURPOSES FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA

    In compliance with LGPD, ENGINE only collects data for specific purposes, avoiding generic data collection. Depending on the interaction with ENGINE (whether online, offline, by phone, or other means), we gather data regarding your company and yourself. We may collect certain personal data from you based on how you engage with us via our website.


    Corporate Contact Details: These include all information provided by you that may enable our contact, such as your name, business address, email address, social media information, or phone number.


    Website/Communication Usage Information: To enhance your interactions and experiences while browsing and engaging with our sites, we collect information related to your navigation. We employ automated data collection technologies that optimize this relationship. This includes data such as clicked links, viewed pages or content, and the duration of these interactions, providing statistical insights about behavior, such as content response times, download errors, and time spent on specific pages. Such data is obtained through automated technologies like Cookies (Browser Cookies, Flash Cookies) and third-party tracking.

    5. SHARING PERSONAL DATA

    It is crucial to understand that if you come across links to third-party pages on our website, you should check the Notice or Privacy Policy of that third party, as ENGINE is not responsible for the data processing carried out by any third parties through such pages.

    6. RIGHTS OF DATA SUBJECTS

    Data protection is of utmost importance to us, and therefore, we prioritize maintaining an appropriate channel to facilitate the exercise of your rights as the data subject.

    The data subject, in relation to their personal data processed by ENGINE, has the right at any time and upon request (as per Article 18 of LGPD), to:

    Confirmation of Existence
    Data Access
    Correction of incomplete, inaccurate, or outdated data
    Anonymization, blocking, or elimination of unnecessary, excessive, or data treated in non-compliance with LGPD
    Data Portability
    Deletion of consented data
    Revocation of Consent
    Objection to Data Processing
    Information on Data Sharing
    Filing complaints or reports before the Data Controller or National Data Protection Authority ("ANPD")

    To exercise your rights as the data subject, as outlined above, we may request certain data and/or documents to confirm the authenticity of your identity, thereby preventing a security incident. Please note that access to information may occur verbally or in writing.

    The rights will be exercised upon explicit request from the data subject or from a legally appointed representative, directly communicated to the data processing agent.

    It's important to highlight that these rights are not absolute. There might be situations where ENGINE may not be able to fulfill requests, such as cases including but not limited to the inability to delete data due to legal or regulatory obligations to retain such data; compliance with judicial, administrative, or regulatory demands from competent authorities like ANPD.

    7. PERSONAL DATA STORAGE

    The personal data collected by ENGINE will be used and stored for the provision of services or for the purposes presented in this Policy, considering the rights of data subjects and controllers.

    The collected data will be deleted from our systems when they are no longer necessary for the purpose for which they were obtained, unless required to comply with a legal, administrative, or regulatory obligation according to applicable legislation, especially the LGPD, or for the exercise of rights in judicial or administrative proceedings.

    Normally, personal data or sensitive personal data will be stored for a minimum period, according to the table below:

    PERSONAL DATA STORAGE PERIOD LEGAL BASE
    Personal Information or Financial Data Up to 5 (five) years after the termination of the existing relationship. Articles 27 and 34 of the Consumer Protection Code
    Other data For as long as the existing relationship lasts and there is no request for deletion or revocation of consent, or they may be retained according to legal requirements. Article 9, Section II, and Article 16 of the LGPD.

    8. SECURITY MEASURES

    Despite ENGINE's efforts to handle your personal data in accordance with applicable legislation, following a series of recommended security measures, there remains the possibility that malicious third parties might gain unauthorized access to information stored in our systems or physical environment. In these situations, ENGINE will be responsible only within the limits of applicable legislation.

    We clarify that if we identify and prove any activity or attempt that compromises the security of your personal data or is in violation of applicable laws or the provisions outlined in this Policy, ENGINE will spare no effort to ensure that the responsible party for such illegal activities is held accountable through appropriate legal or administrative channels.

    9. DATA PROTECTION OFFICER

    ENGINE, under the terms of the LGPD, has a person responsible for guiding it on how the holders' personal data should be treated, as well as on the way in which ENGINE should act with regard to the exercise, by the holders, of any of its rights, as highlighted in item 6 above. To this end, we provide the following service channel: dpo.engine@tsradvogados.adv.br.

    10. ALTERATION OF THIS PRIVACY POLICY

    The present Privacy Policy was drafted by ENGINE and may be altered or modified at any time, especially in cases where there is a need for adjustments or adaptations to meet more modern technical and procedural requirements, or to align this Policy with future legal modifications, always aiming to maintain the expected level of reliability and security.

    Therefore, it's important for you to regularly review this Policy to ensure that you still agree with its terms and conditions before continuing to navigate or fill in any resources on our website.

    11. GENERAL CLAUSES

    The use of the name ENGINE, the domain (and its branches), as well as the contents displayed on the website and ENGINE's social media, logos, product images, illustrations, are property of ENGINE and are protected by international laws and treaties on intellectual property.

    It is essential for you to be aware that you cannot misuse or reproduce, either wholly or partially, such contents unless expressly authorized by ENGINE.

    By using our services and providing your personal data, even after any modifications, you consent to all terms and provisions of the most current version of Engine's Privacy Policy, which will always be available for reference on our communication channels, particularly our website.

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