1. Purpose, scope

The purpose of this Policy is to inform the way in which we process and collect personal data.  As Organizabil Contábil Globo breathes the culture of privacy and protection of personal data, we can inform you that we are aware of the General Personal Data Protection Law (“LGPD”), good governance practices in privacy suggested by control bodies and technical-professional associations, and above all: we are committed to transparency.

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2. Reference documents

• Item I of Article 7 and 14 of Law No. 13,709/18);

• Item II of Article 7 of Law No. 13,709/18);

• Item VI of Article 7 of Law No. 13,709/18);

• Item V of Article 7 of Law No. 13,709/18);

• Item IX of Article 7 of Law No. 13,709/18);

3.Glossary

Personal data: information related to an identified or identifiable natural person;

Holder: Natural person to whom the personal data that are processed;

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, under public or private law, who processes personal data on behalf of the controller;

Treatment: 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;

Consent: Free, informed and unequivocal expression by which the holder agrees to the processing of his/her personal data for a specific purpose;

Anonymization: Use of reasonable technical means available at the time of treatment, through which data loses the possibility of association, directly or indirectly, with an individual;

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4. Data Subjects and method of collection

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4.1. Holders

We collect and process all personal data provided by our customers. All personal data collected are strictly necessary and adequate to achieve a legitimate purpose, especially for the provision of the contracted service, whether judicial or extrajudicial, cadastral or just advisory.

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4.2. Form of collection

We receive personal data from the following holders:

• Contract for the provision of services signed;

• Electronic form via website.

• Customers (Contractors);

• Employees and Suppliers (Own internal policy).

5. How we use the data

In the personal data collected, your information is processed according to the following specific purposes:

Defend the interests of the company in judicial or administrative proceedings;

Necessary to provide the contracted service;

Legal obligation, such as for tax purposes; respond to requests from authorities for court orders;

Respond to requests or submit administrative information;

6.Legal basis for processing your personal data

The legislation that allows and controls this act is Law 13.709/2018, or General Data Protection Law. With the advent of the respective Law, we can only process your personal data for the purposes indicated above in item V, which conform to the following legal authorizations:

Execution of the contract, or preliminary procedures related to the customer's contract (item V of article 7 of Law No. 13,709/18);

Legal or regulatory obligation (item II of article 7 of Law No. 13,709/18);

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Legitimate interest in commercial support and promotion (item IX of article 7 of Law No. 13,709/18);

Consent, for those who provide the data via the website (item I of article 7 and 14 of Law No. 13,709/18);

Defense and use in legal proceedings (item VI of article 7 of Law No. 13,709/18);

In case of doubts about the legal bases for the collection, treatment and storage of your personal data, contact Organizabil Contábil Globo and its Data Protection Officer through the e-mail dpo@contabilglobo.com.br .

7. Duration of processing of personal data

The personal data collected or processed by the office will be stored for as long as the contractual relationship and the interest of the holder last, in the latter case related to the receipt of electronic messages;

The personal data processed by the company will be deleted after the end of its treatment, within the scope and technical limits of the activities, conservation authorized for the following purposes:

Compliance with legal or regulatory obligations;

Study by a research body or for statistical or management purposes of the company/controller, in these cases always by means of data anonymization;

8.Sharing of personal data

Some personal data collected from users (data subject) may be used in processing platforms (operator), with the company always remaining the controller of personal data.

We emphasize, however, that your data will never be transferred to third parties without specific authorization. Therefore, when using them on third-party platforms, (operators) we demand the same security standard and guarantees as confidentiality clauses.

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9. Communication channel

For any information, including the exercise of your rights as the holder of personal data, you can contact us by phone (11) 4433-2600 , or send us a message at dpo@contabilglobo.com.br .

10. Validity of document management

The document is valid from 01/07/2022.

The owner of this document is [name of title], who needs to check if necessary to update the document at least once a year.

When evaluating the effectiveness and suitability of this document, the following criteria need to be considered:

• Current laws and regulations.