ALACERO'S PRIVACY POLICY
Version 002 - 03/2022

OBJECTIVE With the intention of simplifying how we treat personal data, as well as providing our specific communication channel for the subject, we have prepared this Privacy Policy that aims to clarify the methods and main information related to the processing of personal data carried out, such as its purposes, storage, sharing and the legal hypotheses that legitimize our activity. Our Policy is based on the best data privacy governance practices, in compliance with the procedures and guidelines disseminated by the National Data Protection Authority and the LGPD itself. DEFINITIONS To facilitate the understanding of this document, we have brought some important concepts that the General Data Protection Law (LGPD) establishes, which are the following: Personal data: Information regarding the living natural person, which identifies or enables identification, such as e-mail, telephone, full name, among others; Sensitive personal data: personal data about racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature; data relating to health or sex life, genetic or biometric data, when linked to a natural person; Data subject: natural person to whom the personal data that are processed; Data processing: any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification , communication, transfer, diffusion or extraction. Controller: natural or legal person, governed by public or private law, responsible for decisions regarding the processing of personal data; Operator: natural or legal person, governed by public or private law, who processes personal data on behalf of the controller; Person in Charge (DPO): person indicated who will act as a communication channel, to meet internal demands and those of our customers, regarding the processing of personal data, as well as those that may come from the National Data Protection Authority, which can be contacted via email: dpo@alacero.org THE LEGAL HYPOTHESES We carry out the processing of personal data within the hypotheses established by the General Law for the Protection of Personal Data - LGPD, set out in its articles 7 and 11, legitimizing the use of the information, provided that all legal provisions are complied with. Within the list of legal hypotheses presented by the Law, we mostly use the following bases that legitimize our treatment: • Consent (item I of article 7 and item I of article 11); • Legal or regulatory obligation (item II of article 7 and item 'a' of item II of article 11); • Compliance with the contract (item V of article 7); • Legitimate Interest (Article 7, item IX). YOUR RIGHTS AS A HOLDER OF PERSONAL DATA All holders of personal data are guaranteed the following rights, in accordance with article 18 of the General Law for the Protection of Personal Data: (i) Confirm with the existence of processing of personal data and obtain, at any time, access to such data; (ii) Request together the correction or update of data that is incomplete, inaccurate or out of date; (iii) Request the deletion of data from our database, within the minimum legal period related to data storage; (iv) Request the traceability of your data by requesting information from public and private entities with which we have shared data; (v) Request data portability to another service provider; (vi) Request the blocking or elimination of personal data, in case of unnecessary, excessive collection, or inadequate treatment; (vii) Revoke consent, after granting, as well as request the elimination of data obtained under its protection. If the holder wants to exercise their rights, or resolve any doubts, they must forward their request to the DPO, via email: dpo@alacero.org WHO DOES THE DATA PROCESSED BY ALACERO BELONG TO? We only use the data that is strictly necessary for the execution of our activities. The information we process belongs to the following holders, without prejudice to others who may be directly or indirectly involved: • Associates; • Partners; • Customers; • Collaborators; • Candidates for vacancies; • Participants in events related to our activity; • If you are interested in becoming a member, please send your details to comunicaciones@alacero.org PURPOSES OF PERSONAL DATA PROCESSING In respect of the principles and provisions protected by the LGPD, the entire