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Privacy and Personal Data Policy

OBJECTIVE

To inform all clients of VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA about the application of the General Data Protection Law - LGPD.

SCOPE

Applies to all clients of VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA.

PROCESS DESCRIPTION

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA needs to collect and process personal data to develop its business platform, which focuses on optimizing the entire logistics process of companies (Supply Chain), and is part of a group of consulting, technology, and associated services companies. The specialty of VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA is to identify performance improvement opportunities, recommending the most suitable strategies in processes and solutions for our clients' businesses. In this sense, the present Privacy and Personal Data Policy of VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA (hereinafter "Privacy Policy") aims to help our clients understand what personal data we collect, how and why we use it, to whom we disclose it, and how we protect their privacy when using our services.

WHY?

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA is committed to protecting the security and privacy of its clients. In this context, the company has formulated this Privacy Policy to affirm its commitment and respect for privacy rules and personal data protection.

We aim for our clients to be aware of the general privacy rules and the terms of data processing that we perform, strictly complying with applicable legislation in this area, particularly Law No. 13.709 of August 14, 2018 ("General Data Protection Law - LGPD" or simply "LGPD").

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA strives to adhere to best practices in terms of personal data security and protection, promoting awareness of good practices in this area, and improving systems to manage the protection of data provided by its clients, in strict compliance with legal obligations.

The collection and processing of personal data by VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA involve the understanding of the conditions of this Policy, and any other specific terms, policies, and conditions related to the services provided.

WHAT IS PERSONAL DATA?

Personal data is defined as any information related to an identified or identifiable natural person (data subject), of any nature and regardless of its medium. A person is considered identifiable if they can be directly or indirectly identified, particularly by reference to an identification number or to specific elements of their physical, physiological, psychological, economic, cultural, or social identity.

Personal data may have a different nature in certain situations, classified under LGPD as "sensitive data". This category can include information about the racial or ethnic origin of the data subject, their political opinions, religious or philosophical beliefs, genetic information, biometric identifiers, sexual life, sexual orientation, or health.

OTHER IMPORTANT DEFINITIONS

Data Subject Consent - A free, specific, informed, and explicit expression of will by which the data subject agrees, through a declaration or a clear affirmative act, to the processing of personal data related to them.
Controller: A natural or legal person, public or private, who makes decisions regarding the processing of personal data.
Profiling - Any form of automated processing of personal data consisting of using those data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Data Protection Officer (DPO) - An individual or entity appointed to ensure, within an organization, compliance with the LGPD, ensuring efficient communication with data subjects and cooperation with regulatory authorities, and bridging the different areas of activity within VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA. The DPO does not receive instructions regarding the performance of their duties and reports directly to the governing bodies of the entity that appointed them.
Processor - A natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Third Party - A natural or legal person, service, or body other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Data Subject - An identified or identifiable natural person to whom personal data relates.
Processing - Any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Operator: A natural or legal person, public or private, who processes personal data on behalf of the controller.
Personal Data Breach - A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
Pseudonymization - The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separate and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Anonymization - A technique that results from the processing of personal data to remove sufficient elements so that the data subject can no longer be identified, irreversibly. More precisely, the data must be processed in such a way that they can no longer be used to identify an individual using the means likely to be reasonably employed, whether by the data controller or by others.
National Data Protection Authority - A public administration body responsible for overseeing, implementing, and enforcing the law.

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

This Privacy Policy aims to inform our clients about the terms of personal data processing by VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA, outlining the purposes and means of processing your data in the context of service provision. Thus, it should be considered as the Operator, according to the LGPD.

The controller (CLIENT) is responsible for the decisions regarding the processing of personal data. The Operator (VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA) will process personal data according to the instructions provided by the Controller, on their behalf.

Under the terms of this Policy, VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA is responsible for the personal data held in its database and may also be held liable in case of a data leak involving data shared with its partners, collaborators, service providers, and other third parties not in compliance with the LGPD.

WHAT PERSONAL DATA DO WE COLLECT AND BY WHAT MEANS?

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA (Operator) receives personal data when contracted by the client (Controller), who sends their database containing the personal data to be processed by VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA, in accordance with the LGPD. Data are sent to VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA via systems, but there are cases where clients send data in spreadsheets via email.

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA shares the personal data received from the client with its employees and internal and outsourced service providers to perform some form of processing of these data.

We collect your personal information when you use our platforms or contact us through other sources, such as when you: (i) visit/browse our websites; (ii) fill out forms on our websites; (iii) participate in and/or fill out forms at an event; (iv) make or attempt to make an order; (v) register an account/as a customer; (vi) send us an email; (vii) participate in surveys; or (viii) communicate or interact with a customer service representative.

For the proper conduct of the service, the client (Controller) provides some information about their clients (corporate tax ID, company address, corporate telephone, corporate email, names of partners, among others) and outsourced employees (name, personal tax ID, social security number, address, among others). The data are stored in the cloud contracted by VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA.

CATEGORIES OF DATA PROCESSED, MEANS AND METHODS OF COLLECTION

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA receives personal data when contracted by the client, and processes it according to contractual determinations.

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA is divided into 09 (nine) departments, each of which receives and processes the data provided by the client. These data relate to the clients and their outsourced employees, which include:

(i) Data received from the client (data on the operational structure of the company): name, personal tax ID, social security number, employment ID, address, telephone, mobile, email, Medical and Dental Assistance, Life Insurance, IP, labor data, job position, employee registration form, payroll, attendance control of the client's service providers (outsourced).

Note: All these data are provided by the Client when they deliver their database to VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA.

(ii) Client data: corporate tax ID, address, banking details, telephone, email, names of partners and representatives.

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA does not collect sensitive data.

WHAT ARE THE PURPOSES FOR COLLECTING YOUR PERSONAL DATA?

The personal data received by the Controller (Client) can only be used for the contracted purpose. If VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA processes data differently from what is consented, due to the contractual relationship with the client, it must obtain new consent from the data subject.

The legal basis for processing personal data is the execution of the contract, therefore, there is no need for VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA to obtain consent from the data subject, as this is an obligation of the client company (Controller). The purpose of data processing must be specific, except for the legitimate interest of the controller.

We can use the categories of personal information mentioned above for one or more of the following commercial purposes:

To process your request for information (e.g., products/services, Independent Consultant opportunities).
To process transactions of products and services and send notifications about your transactions.
To provide sales support and customer service, as well as quality assurance.
To fulfill or meet the reason for which the information is provided. For example, if you provide us with your banking details to receive commission payments, we will use this information to process the payments.
To provide targeted marketing and advertising, service update notices, and promotional offers based on your communication preferences.
To enable emails to friends. We may provide functionality to allow you to send messages about Site-related content to a friend through the Site. If you wish to use this feature, you may provide us with your friend's email address to facilitate sending the message to them.
To verify your identity, including account-related issues.
To send administrative communications related to the Site, service-related announcements, etc., which are necessary to serve you, address your concerns, and provide the high level of customer service that VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA offers. As this information may be important for your use of the Site, you cannot opt out of receiving such communications unless you explicitly withdraw your consent to our use of your personal information as described in this Privacy Policy.
To review/manage the use and operations of the Site and to comply with our Terms of Use and the law.
To troubleshoot problems with the Site, our business, or our services.
To contact you at any phone number, via a voice call or through text messages (SMS) or email, as authorized by our Terms and Conditions.
To detect, prevent, or investigate security breaches, fraud, or other suspicious/prohibited/illegal activity; or violations of our Privacy Policy.
To maintain appropriate records for internal administrative purposes.
To provide important product safety information.
We use your IP address and the IP addresses of all users for the purpose of calculating site usage levels, helping to diagnose problems with the Site's servers, administering the Site, analyzing trends, internal statistics/research, including detecting and preventing suspicious activities, managing the Site, tracking traffic patterns, and gathering demographic information for aggregate use.
To improve our site and present content to you.
For testing, research, analysis, and product development.
As described to you when collecting your personal information.
We may use these technologies to collect information for various purposes, such as analyzing how the Site is used, customizing your experience on the Site, or improving our content or offers. Your browser may provide tools to block or delete cookies. However, if your browser is set to reject cookies or you manually delete them, you may have some difficulties accessing and using some of the pages and features that are currently on our Site, or that we may place on our Site in the future (cookies).

ON WHAT BASIS DO WE PROCESS YOUR PERSONAL DATA?

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA is a business platform focused on optimizing the entire logistical process of companies. For this, it is necessary to process some personal data to perform this service. The LGPD requires that for the processing of personal data to be lawful, there must be an adequate legal basis for each specific treatment.

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA has a system for monitoring third parties, where it provides consulting and BPO (business process outsourcing) services, suggesting improvements and organizing the operational structure of client companies. The platform processes all information received from clients and identifies opportunities for performance improvements, recommending the most suitable strategies for the effective implementation of processes and solutions, with the support of specialized software, as well as for the outsourcing of associated activities.

Regarding the processing of your data by VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA to improve our services and meet our administrative and quality objectives, the appropriate legal basis will be the pursuit of legitimate interests of the Controller and the Operator, as well as Contractual Performance, when applicable, in addition to the client's own consent. This implies that data subjects may object to the processing of their data for the above effects, under the LGPD, if they present valid reasons related to their particular situation. In such an event, the Controller may present legitimate reasons that justify the continuation of this processing, in which case the right is reserved to continue processing your data for these purposes, as in cases where such processing is necessary for the declaration, exercise, or defense of a right in legal proceedings.

As for the data processing carried out by VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA in the context of fulfilling legal obligations, the legal basis for such processing - mostly, data communications to external entities - will be the need for processing for the purpose of fulfilling the legal obligations of the Controller, including contractual performance or legitimate interest.

WHICH PROFESSIONALS AT VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA HAVE ACCESS TO YOUR DATA?

In the processing of your personal data, VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA always observes the principles of data protection from the design stage (privacy by design). This commitment implies, among other aspects, that access to your personal data will be limited to individuals who need to know in the performance of their duties, strictly to the extent necessary to achieve the processing purposes we have already listed above.

WHAT ARE THE RIGHTS OF DATA SUBJECTS?

Under applicable legislation, data subjects may at any time request access to personal data relating to them, as well as request its correction, and data portability, directly through the email dpo@vem.company, or by making a personal contact with VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA.

Data subjects have the right to:

Request details about the categories of personal information collected about you and, if permitted and practical, a copy of the personal information (data portability).
Request the deletion of any personal information we have collected from you, subject to certain exceptions. Once your request is verified, we will proceed with it unless an exception applies. There is a possibility that we may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise freedom of expression, ensure the right of another consumer to exercise their freedom of expression rights, or exercise another right provided by law.
Comply with the LGPD and applicable legislation.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that complies with all other applicable ethics and privacy laws, if deletion of the information would likely render impossible or seriously impair the performance of the research, if you have previously informed your consent. o Allow only internal uses that are reasonably aligned with consumer expectations based on their relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of this information that are compatible with the context in which you provided it.

Without prejudice to any other administrative or judicial remedy, the data subject has the right to file a complaint with the ANPD or another competent supervisory authority under the law, if he/she considers that his/her data is not being legitimately processed by VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPACOES LTDA, under the terms of the applicable legislation and this Policy.

WHAT SECURITY MEASURES ARE ADOPTED BY VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA?

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA is committed to ensuring the confidentiality, protection, and security of its clients' personal data by implementing appropriate technical and organizational measures to protect the data from any improper or unlawful processing and from any accidental loss or destruction. For this purpose, we have systems and teams in place to ensure the security of the personal data processed, creating and updating procedures that prevent unauthorized access, accidental losses, and/or destruction of personal data, committing to comply with the legislation related to the protection of clients' personal data and to process these data only for the purposes for which they were collected, as well as ensuring that these data are treated with adequate levels of security and confidentiality.

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA may, in some cases, transmit your personal data to its employees and internal and outsourced service providers. VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA has established clear contractual rules for the processing of personal data with its employees, internal, and outsourced service providers and requires them to adopt appropriate technical and organizational measures to protect your personal data. However, in some cases, we may be legally required to disclose your personal data to third parties (such as regulatory authorities) over whom we have limited control regarding the protection of personal data.

It may be necessary - by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence - for VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA to disclose your personal information. We may also disclose your information if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose your information if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Furthermore, in the event of a reorganization, merger, or sale, we may transfer any and all personal information we collect to the relevant third parties.

UNDER WHAT CIRCUMSTANCES IS THERE COMMUNICATION OF DATA TO OTHER ENTITIES?

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA utilizes other entities to provide certain services. Occasionally, this provision of services may involve access by these entities to personal data of its clients.

Thus, any entity characterized as a sub-processor will handle our clients' personal data, under the strict obligation to follow the instructions of the Controller (client). VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA ensures that such entities, identified as sub-processors, provide sufficient guarantees of implementing appropriate technical and organizational measures so that the processing meets the requirements of applicable law and ensures the security and protection of the rights of the data subjects, in accordance with the contract agreement with the Controller.

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA may also transmit personal data of its clients to third parties when it deems such data communications necessary or appropriate:

In accordance with applicable law;
In compliance with legal obligations/court orders; and
To respond to requests from public or governmental authorities.
In this regard, VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA may transmit your personal data to any Contracting Public Entity, Courts, Solicitors, criminal police bodies, or the Public Prosecutor's Office when notified for this purpose or when necessary to fulfill legal obligations, as legally provided. In any of the situations mentioned above, VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA commits to taking all reasonable measures to ensure effective protection of the personal data it processes.

CONTACT US

You can contact the Data Protection Officer ("DPO") of VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA for more information about the processing of your personal data, as well as any issues related to the exercise of the rights granted to you by applicable legislation and, in particular, those mentioned in this Privacy Policy, through the following contact:

Email: dpo@vem.company

RIGHT TO NON-DISCRIMINATION IN THE EXERCISE OF YOUR PRIVACY RIGHTS

We will not discriminate against you for exercising any of the rights described above. This includes, but is not limited to: (i) denying goods or services to you; (ii) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or the imposition of penalties; (iii) providing a different level or quality of goods or services; or (iv) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

HOW DO I LEARN ABOUT CHANGES TO THE PRIVACY POLICY?

VEM TECNOLOGIAS, EMPREENDIMENTOS & PARTICIPAÇÕES LTDA reserves the right to make modifications or updates to this Privacy Policy at any time. These changes will be duly updated on our Platforms. We suggest that you regularly consult them to stay informed of any changes.