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Reservas Votorantim thanks you for your access to www.reservasvotorantim.com

Reservas Votorantim is committed to the privacy of the User (“User” (“Data Subject” or “You”). Therefore, Reservas Votorantim has prepared this Privacy Policy (“Privacy Policy” or “Policy”) which describes how Reservas Votorantim collects, uses, utilizes, accesses, reproduces, transmits, processes, files, shares, or deletes your personal data.

Please read this Policy carefully before you use the Site. By using the Site, you acknowledge that you have read this Privacy Policy and agree to commit to it.

This Privacy Policy does not apply to information collected by third parties, including sites, applications or other content which may be accessible through this Site or connected to it. Reservas Votorantim is not responsible for the content or privacy practices of any site which does not belong to Reservas Votorantim, to which this Site is connected.

For further information about the processing carried out within the scope of the activities of Reservas Votorantim, please contact the DPO at Reservas Votorantim.

IF YOU DO NOT AGREE WITH ANY OF THE PROVISIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SITE, OUR OTHER INTERNET APPLICATIONS, OR HIRE OUR SERVICES.

Who is the controller of your personal data?

Reservas Votorantim, a company enrolled with the Taxpayers’ Registry CNPJ/MF under n. 23613510/0001-30, with headquarters at Rua Manuel Bandeira, 261, 1 floor, Vila Leopoldina, State of São Paulo, is the company controlling the personal data processed within the scope of this Privacy Policy. For the purposes of the applicable legislation, “controller” is who is in charge of decisions related to the processing of personal data. In addition, as will be detailed in this Privacy Policy, your personal data may be shared with Reservas Votorantim’s partner companies and investees for purposes of management and operation of the Site and of the remaining Internet applications of Reservas Votorantim, as well as to improve the services provided by Reservas Votorantim, in which cases such companies may also be controllers of your personal data.

Personal data we process:

Reservas Votorantim may collect your information at various moments and in different manners in this Site, as described below:

Information provided directly by the User: Name, address, e-mail, telephone, company and country.

Navigation information and Cookies: Cookies are information that a site transfers to the computer of an individual in order to keep records. These cookies will be placed as a file text in the browser of your computer. You can set your browser to refuse cookies, but you may consequently not be able to access or use parts of the Site. Web beacons are small code pieces incorporated into web pages or e-mails that help to deliver the cookies. They help Reservas Votorantim to determine if a web page has been visualized and, if so, how many times. Reservas Votorantim may also use web beacons in e-mail messages to determine what the recipient did with the message. Although you are unable to refuse the web beacons when you visit a web page, you may choose not to receive them by e-mail if you disable the HTML images or if you refuse e-mail messages in HTML. Reservas Votorantim may automatically collect other information, including the kind of computer, kind of browser and plug-ins, language, Internet Services Provider (ISP), operational system, java script enabling, reference and exit pages, click flow data, and city and country. In addition, Reservas Votorantim may automatically collect and register your Internet Protocol address (“IP address”). Your IP address is a unique numeric address, comprised by four numbers separated by dots, which provides the location of an individual computer on the Internet. The IP addresses are used to identify the computer from which you are accessing the site. Reservas Votorantim may also obtain data about you when you interact with the Site, for example, when you look at a page or send a message through the Site.

Access records and other automatized information. Reservas Votorantim may collect and store some information it automatically receives every time the User interacts with the Site. Internet Protocol (IP), the kind of browser, as well as dates and times of the User’s interactions with the platforms, are a few examples of this collection.

For which purposes do we collect your data?

• The personal data of the Users, according to each case, are processed by Reservas Votorantim for the following purposes:

• To provide high effectiveness while rendering its services and adequate support for the performance of its corporate purpose;

• To adjust the appearance and the content to the preferences of the users, in order to provide them with faster, more pleasant and effective access.

• To authenticate accesses;

• To seek adequate security for the services offered and means of identification in the event of inappropriate or illegal use;

• To solve problems and prepare notifications related to the use of the sites, platforms and Internet applications of Reservas Votorantim;

• To keep users informed about the services, changes to the Terms of Use or the Privacy Policy, updates or improvements in the sites, platforms and Internet applications of Reservas Votorantim, or yet about the status of their accounts and operations;

• To disclose promotional actions on the sites, platforms and Internet applications of Reservas Votorantim or other Reservas Votorantim initiatives, always providing means for the user to cancel the receipt of promotional e-mails (opt out);

• To disclose promotional actions of partner companies that adopt similar privacy protection measures to those of the present policy, through the User’s prior consent;

• To obtain statistical information;

• To provide and improve the customer service to Data Subject, which may involve registration of a new password on the Site, generation and issuance of invoices, complaints, questions about fees, information about claims, reimbursements etc.;

• To improve the services and/or functionalities of the Site and the platforms of Reservas  Votorantim.

With whom do we share your personal data?

Reservas Votorantim may share your personal data with third parties, business partners, companies from the same economic group as Votorantim or companies controlled by Votorantim which are relevant to enable the use of the Site and other Platforms by the Users or to enable the provision of services to the Client. Such sharing occurs based on the following criteria and for the purposes described below:

Service providers or business partners: We may share your personal data with service providers hired by Reservas Votorantim to (a) provide operational management software or other information technologies for management and registration of Clients. Such agents receive your personal data with the specific purpose of providing services to Reservas Votorantim and do not have any rights to use your data with exception of this hypothesis.

Request from a competent authority: Reservas Votorantim may also share your personal data with third parties (including government agencies) in order to answer to investigations, judicial measures, judicial proceedings, or to investigate, prevent or adopt measures related to illegal activities, suspected fraud or situations involving potential threats to the physical safety of any person, or if otherwise required by legislation.

For how long will we keep your personal data?

 We store and keep your information: (i) for as long as required by law; (ii) until the end of the processing of personal data, as mentioned below; or (iii) for as long as necessary to preserve the legitimate interests of Reservas Votorantim. Thus, we will process your data, for example, during the applicable statutes of limitation or for as long as necessary to comply with a legal or regulatory obligation.

• The processing of personal data shall end in the following cases:

• When the purpose for which the personal data of the Data Subject were collected is reached and/or the personal data collected is no longer necessary or relevant to reach such purpose;

• When the Data Subject is entitled to request the end of the processing and the deletion of his personal data, and does so; and

• When there is a legal determination in this sense

• In these events of termination of the processing of personal data, with exception to the hypothesis established by the applicable legislation or by this Privacy Policy, the personal data shall be eliminated.

Your rights in respect of the personal data we process about you:

You will have certain rights in respect of your personal data. Such rights include, but are not limited to:

• Receiving clear and complete information about the processing of your personal data, including about events in which your personal data is shared;

• Requesting the access to your personal data and/or the confirmation of the existence of data processing;

• Requesting that we rectify any inaccurate, incomplete, or outdated personal data;

• Opposing to the processing activities, requesting the anonymization and elimination of personal data, in specific circumstances;

• Requesting the portability of your personal data;

• Revoking consent at any time, when Reservas Votorantim processes your personal data based on your consent; and

• Requesting the revision of automated decisions that may affect your interests.

You may exercise such rights by contacting the DPO or on the Site.

Safety, guarantees and precautions using the Site:

We are committed to delivering a safe and reliable Site for you, and guarantee we take the necessary measures to provide a better experience in this sense.

The Site is a safe place for us to provide an environment in which any data transmission is confidential and safe. This Site uses several physical, electronic and administrative procedures to protect the confidentiality of your personal data. The access to your personal information is restricted and only the IT support team of Reservas Votorantim, its affiliates and its service providers who absolutely need to access for specific purposes are granted access to your personal data. The servers in which Reservas Votorantim stores your personal information are kept in a safe environment and protected by protected by the performance of the information security department, which guarantees ISO27001 security requirements, in addition to good market practices.

However, we note that, as with any interaction taking place on the Internet, it is not possible to guarantee a level of security which is flawless and free of all and any threats, considering the speed in which new technologies are developed. In this scenario, we are committed to use our best efforts to ensure that the Site is, as far as possible, always updated and protected from invasions and failures.

Changes to this Privacy Policy

Reservas Votorantim reserves the right to change this Privacy Policy at any time, by publishing the updated version at https://www.votorantim.com.br/politica-de-privacidade. In the event of relevant changes to this Privacy Policy, you will receive a notice in this respect.

Interactions with third party sites

We may provide links to other sites on the Internet. RESERVAS VOTORANTIM IS NOT RESPONSIBLE FOR THESE SITES AND CONTENTS AND DOES NOT SHARE, SUBSCRIBE, MONITOR, VALIDATE OR ACCEPT THE MANNER IN WHICH THESE SITES OR CONTENT STORAGE TOOLS COLLECT, PROCESS AND TRANSFER YOUR PERSONAL INFORMATION. We recommend that the User refers to the respective privacy policies of such sites to receive adequate information about the use of his/her personal information by other sites or other tools.

Identification of the DPO

Luis Rabello is the Reservas Votorantim’s Data Protection Officer (“DPO”)

If you have any doubts, please access www.votorantim.com or contact the Officer in Charge at privacidados@votorantim.com