The Privacy Policy is based on documents and procedures, that need to be adapted to the company’s activities, implementing the data protection and privacy strategy.

Documents and procedures for applying the strategy:

• code of Conduct;
• Data Disposal and Retention Policy (Tabela de Temporalidade);
• Responsibilities of the Data Protection Officer (DPO);
• Data Subject Response Plan;
• Information Security Policy;
• Awareness Plan;
• Data Inventory;
• Access Control Policy;
• Data Protection Impact Report – RIPD;
• Valid consent, with information that it can be revoked;
• Parental Consent Form;
• Procedimento de senhas fortes;
• Confidentiality Agreement or Term;
• Contractual Adequacy.

To facilitate your understanding, we would like to clarify the terms below.:

In the processing of personal data that we carry out, We always observe the following principles (Art. 6º, LGPD):

Your personal data can reach us through various means, Below you can better understand how we carry out this collection.

• Site da INPLAC: Our website may be used to collect personal data. This includes both websites that we operate directly through our domains and IP addresses, as sites or pages that we establish on third-party services, like Facebook, Linkedin, and other third parties that offer this type of service.
• Electronic mail and instant messaging systems: Services used to maintain electronic communications with you, including those made available directly by us, or third-party services like WhatsApp, Telegram, SMS (short message service) and similar.
• Customer service and sales center: Communications carried out with you through our customer service and sales centers.
• Ads, advertisements and online forms: Interactions with any type of ads, INPLAC advertisements and online forms.
• Offline Records: Records completed offline, distributed during events and other interactions.
• Data received from third parties: Including, but not limited to social networks and third-party websites, data aggregator services, business management systems, INPLAC partners (commercial representatives), public sources and data received during acquisition of other companies.
• In person: Physical documents received from the holders' own hands or data disclosed in person.
• Electronic devices: electronic monitoring tools, like for example, CCTV, biometric point, etc.

We collect various types of personal data through previously informed means and always use them for a specific purpose., based on a legal basis, as seen below:

• Automated Decision Processes

We do not use any type of automated process, So there is nothing to worry about this process.

In some cases, INPLAC may collect personal data from children and adolescents directly from their parents or legal guardians, and with explicit consent, and in accordance with the rules of current legislation.

Cookies are files or information that may be stored on your devices, when you visit our website. Generally, a cookie contains the name of the website that originated it, its lifetime and value, which is randomly generated.

INPLAC uses cookies to facilitate use and better adapt the page to your interests and needs, as well as to compile information about the use of our websites and services, helping to improve their structures and content. Cookies may also be used to speed up your future website activities and experiences.

For more information visit our Cookies Policy.

We store your Personal Data in operating environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data.

We can use it as storage media:

• WhatsApp numbers linked to INPLAC;
• Corporate email;
• On our computers;
• On our social networks;
• In physical lockers;
• Microsiga management system;
• CCTV Server;
• Electronic devices;
• In the cloud;
• In the archive.

We may share your Personal Data with the following types of third party organizations:

• Credit analysis agencies, debt collection and financial services: As permitted by applicable law, Credit analysis and/or debt collection agencies are external companies that INPLAC may use to help us check your credit status or to collect overdue payments.
• Suppliers: We have some third-party services and applications that help us with our business demands.:

External entities that assist and assist us in providing consultancy services, trainings, storages, compliance, marketing, etc.

External entities that assist and assist us in providing IT services, such as platform providers, hosting services, maintenance and assistance to our databases, as well as our software and applications that may contain data about you (Such services may sometimes involve access to your data to carry out necessary tasks). Ex: MICROSIGA System.

• Public bodies: to respond to legal requests, normative, labor regulations and legal obligations, tax, consumerists, among others. (Ex: E-social).
• Financial institutions: for payment and receipt of amounts.
• Insurance companies: in cases of claims response.
• Audit companies: Our company has quality certifications, To do this, we need to go through inspection processes.

INPLAC contractually requires the supplier or business partner to provide the same level of data protection. Furthermore, data processing must be limited to that described in the contractual obligations, or under the instructions of the controller.

We will only retain your information for the period for which it was processed., including security in processing, with legal and regulatory obligations, disputes regarding processing, and for the establishment, exercise or defense of legal actions.

To determine the data retention period, We use the following criteria:

• Nature of data;
• Degree of Sensitivity;
• Legal and contractual obligations;
• Contract duration;
• Need;

When we no longer need to use your personal data, will be removed from our systems and records or kept anonymous so that you cannot be identified from the data.

You can obtain further details about the retention of your Personal Data through the communication channels detailed in this policy.

Periodically, the retention dates of all personal data processed by us will be revised, by reference to the Data Inventory (Mapping the flow of personal data), identifying any data that is no longer necessary in the context of the registered purpose. This data will be securely deleted/destroyed in accordance with a data disposal procedure.

We are committed to keeping your personal data secure and take all reasonable precautions to do so. We contractually require that trusted external entities that process your personal data for us do the same.

We always do our best to protect your personal data and, after we have received your personal data, We use strict procedures and security features to attempt to prevent unauthorized access. This way, we adopt, for example, the following precautions:

1. We equip our machines with appropriate antivirus;
2. We use VPN (encrypted remote access);
3. Logical and physical access control;
4. business WhatsApp;
5. Secure data disposal;
6. Protection against unauthorized access to your systems;
7. We only authorize previously established people to access the location where the collected information is stored.;
8. Environments monitored by CCTV;
9. Backup of databases;
10. Those who come into contact with the information undertake to maintain absolute confidentiality. Breach of confidentiality will result in civil liability and the person responsible will be held responsible in accordance with Brazilian legislation..

Electronic links to websites of external entities and for registration on social networks

• Our website may contain, occasionally, electronic links to and from the websites of our partner network, advertisers and affiliates. If you follow a link to some of these sites, Please note that these websites have their own privacy policies and that we are not responsible for these policies. Please check these policies before submitting any personal data to these websites.

You as holder of personal data, You have several rights in relation to your personal data and you can request these rights at any time, in an easy and free way, We quote them below for better transparency:

If INPLAC modifies this policy, such changes will be visibly published on the company's website, and whenever possible, the data subject will be informed.

If you have any questions or concerns about the way we process and use your personal data or would like to exercise any of your rights above, please contact us through the communication channels listed below:

• Name of person in charge: ALIX CORPORATE TECHNOLOGY.
• Technical consultants: Paula Dutra and Wagner K. Arendt.
• E-mail: lgpd@inplac.com.br.
• Portal do Site “Contact Us”

This Policy will be governed, interpreted and executed in accordance with the Laws of the Federative Republic of Brazil, especially Law no. 13.709/2018, regardless of the laws of other states or countries, The User's home court is competent to resolve any doubts arising from this document.

Last update: 09 April 2024.