Olos Tecnologia e Sistemas Ltda. takes your privacy very seriously. This Privacy Policy is incorporated into our Terms and Conditions of Use. There, you will find the privacy practices of Olos Tecnologia. By accessing or using our Services, you confirm that you accept the practices and policies described in this Privacy Policy. Olos Tecnologia reserves the right to change this Privacy Policy. In such case, we will inform you by a notice on the website Olos Tecnologia or by email. Should you decide to use the Services after any changes to the Privacy Policy are posted, the reviewed Privacy Policy will apply. The Personal Data collected by Olos Tecnologia is used only internally and for the purpose to provide our Services, and for their provision and improvement as well. At certain times, Olos Tecnologia will need to share some of your personal data with third parties, which will only be done in the way and under the circumstances described in this Policy. The collection will be of your Personal Data. This Policy will define how this data will be collected, stored, analyzed, and shared. This Policy does not apply to the practices of companies not owned or controlled by Olos Tecnologia, or any other third party linked to the Service provided by Olos Tecnologia. Olos Tecnologia will not collect children´s Personal Data. No Personal Data will be requested from anyone under the age of 16, unless we have first obtained the consent of the parents or verifiable legal guardian, as required by the applicable legislation. If you are under 16 years of age, please do not attempt to register for the Services or send us any Personal Data about yourself without the consent of your parents or legal guardian. If we become aware that we have collected Personal Data of a child under 16 without verifiable consent from the child’s parents or legal guardian, we will delete that data as soon as is reasonably possible. If you believe that your child under 16 years of age has provided us with Personal Data without your consent, please contact us at juridico@olos.com.br. Olos Tecnologia may also automatically collect certain Personal Data and information from you while you are interacting with our Services. We may also receive information about you from different support sources to improve our Services, affiliated entities, business partners, and other data sources. This Policy aims to record your free, informed, and unequivocal consent to the processing of your personal data for the specific purpose(s) described in this Policy, in accordance with the provisions of Law 13,709/2018 – GENERAL DATA PROTECTION LAW (LGPD).

1. DATA COLLECTION
When you access our website and register, we will collect your Personal Data, such as: first and last name, username and password, email address, mobile phone number or other telephone number, and mailing address with postal code. If you associate your Olos Tecnologia registration with any social media profile or otherwise interact with us through a social media site (for example, by logging in through Facebook or clicking the Facebook “like” button), the social media network may share information with us. You can access and review their information sharing practices in the privacy settings on those social media sites. We will collect information about how you interact with and use our Services. We will also collect information when you communicate with us, through emails you send us, exchange through the website, exchange through social media, or messages. If we ask you to provide your opinion by responding to a survey, we will collect any information you decide to include in your answer. When you interact with our Services, we automatically receive and record on our servers tracking information taken from your browser or device. This information may include your IP address, geolocation data, device ID, cookie data (more details below), the type of browser and/or device you are using to access our Services, the website or feature you requested, and the time of access. We may use this data to provide you with a personalized experience based on your use patterns, or redirect marketing or other analytics. We may also use the data to improve the Services – for example, this data may tell us how often the users use a particular feature, information we may use to improve our users’ experience.

2. COOKIES
2.1. “Cookies” are identifiers we transfer to your browser or device. These cookies allow us to recognize your browser or device and tell us how and when the websites and features of our Services are visited, and by how many people. By means of cookies, we may collect data about your online activity after you leave our Services. As with any other use of data we collect, this data allows us to improve the Services and customize your online experience.
2.2. We use cookies for the following purposes:
• Authentication and website login status. We use cookies to identify you when you open our website and to know if you are logged in to our website.
• Customization. We use cookies to help us identify use patterns on our website, and to help us display customized content which is relevant to you.
• Analytics. We use Google Analytics to analyze use patterns on our website, and Google collects data about website and app use through cookies and uses this data to create reports about the use of our website and app. By means of Google’s Privacy Policy, you can make choices regarding these collection methods.
2.3. You can be able to change the preferences on your browser or device to prevent or limit the acceptance of cookies on your device, but this may prevent you from taking advantage of some of our features. We emphasize that this Privacy Policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your online activities even after you leave our Services.

3. USE OF PERSONAL DATA
3.1. We use your Personal Data to provide our Services and manage the website. This includes, for example, record your registration, respond to your questions, deliver more relevant experience with our Services, and fulfill our other business purposes. We may also use your Personal Data to administer your account through a contracted solution platform to offer and develop our Services. We use your Personal Data for these purposes because we have a legitimate interest in offering and improving our Services, to respond to your interactions with the Services and our registered users, or because you have consented to the use of the data. We may use this data to contact you, cross-reference it with other Personal Data we hold about you and in compliance with the applicable law, and share it with our third-party partners. We may use your Personal Data specifically for the following purposes listed below.
3.2. We process your Personal Data to facilitate our contract relationship with you as a registered user or recipient of our Services, including to provide you with administrative and user support, making it easier for you to use the website.
3.3. Your personal data will be used to provide you with services or products you request, purchase, or download; to help you quickly find products, services, or information; notify you about product updates, special offers, updated information, and new services by email, phone, chat, or other means; answer questions or communicate with you through welcome messages, newsletters, or direct marketing; facilitate participation in our online communities; conduct market research or surveys, unless you have requested us not to contact you for this purpose; customize the user experience and allow us to provide the type of content and product offers you are most interested in; send you periodic emails, calls, or chats about your order or other products and services; improve our marketing and improve our Website, services, and products; consider you for employment, if you have provided information for this purpose; or comply with legal requirements and prevent activities that may violate our policies.

4. COMMUNICATION: EMAILS, TEXT AND VOICE MESSAGES
4.1. Olos Tecnologia may contact you, if you provide the means to do so. For example, we may use your Personal Data to present you with special offers, promotions, and information about Olos Tecnologia and our Services. By providing us with your mobile phone number, email address, and social media account credentials, you confirm that you want Olos Tecnologia to send you, through these channels, information we believe may be of interest to you, such as, but not limited to, offers from Olos Tecnologia, promotions, and updates about Olos Tecnologia partners. Where required by the applicable law, we will obtain your consent to send you marketing communications. If you do not want to receive our communications through one of these channels, please indicate your preference in the privacy area of your profile or by observing the terms of each channel, for example, the unsubscribe link for emails, and the reply STOP for text messages. Olos Tecnologia will make all reasonable efforts to fulfill your request without undue delay, as required by the applicable law. However, please note that even if you decide to be excluded from the marketing communications, you will continue to receive administrative and operational communications.

5. PURPOSES OF THE USE OF PERSONAL DATA
We may use your Personal Data for our business purposes, such as to operate and improve our business and Services, conduct market research, and improve the security of our Services. We may also use your Personal Data to protect against and prevent fraud, lawsuits, and other liabilities, and comply with the legal or regulatory requirements.

6. SHARING OF PERSONAL DATA
We may share your Personal Data in the ways described in this Privacy Policy or when we provide you with prior notice, and have, to the extent permitted by the applicable law, obtained your consent. Olos Tecnologia may share your Personal Data with the following parties and for the following reasons: with other companies from Grupo Olos; to protect the rights or property of Olos Tecnologia; if Olos Tecnologia hires third parties to host its online communities or provide website analytics, the same security and management defined here will be provided for your collected personal data. However, if you find links to third-party websites (e.g., business partners), and although a connection may be made to these websites, we are not responsible for their privacy policies, and this Privacy Notice does not cover their practices; we may share Personal Data with companies which provide services on our behalf, including providers who help us send communications, analyze data, and maintain our websites; from time to time, we may allow advertisers and/or third-party partners (“Advertisers”) to select demographic data from users who have viewed advertisements and/or promotional offers, and where you have agreed that we provide any of the data we collect from you, in a non-personally identifiable form, to an Advertiser to select the appropriate audience for such advertisements and/or offers. We use Google Tag Manager, Facebook, and LinkedIn to communicate with users and with data collected by these advertising partners. You can access these partners’ policies on their separate websites: LinkedIn Privacy Policy, Google Privacy Policy, and Facebook Privacy Policy; and Instagram Privacy Policy. We may disclose your Personal Data as required or permitted by law, regulation, or legal process, including to respond to an inquiry from a government or law enforcement agency, to investigate suspected or actual fraudulent or illegal activity, enforce or apply our Terms of Use or other agreements we may have with you, and when we believe disclosure is appropriate to protect the rights, property, or safety of Olos Tecnologia, its business partners, our users, employees, or third parties. We may decide to acquire or sell assets and share and/or transfer clients´ data in relation to the evaluation and completion of such transactions. Additionally, if we (or our assets) are acquired, or if we close our business, file for bankruptcy, or undergo another change of control, your Personal Data could be one of the assets transferred or acquired by a third party. Certain information from your registration, including your name, location, and any video, image, or text content you have uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or manage your order for our Services. Please remember that any content you upload to your public user profile, along with any Personal Data or content you voluntarily disclose online in any way viewable by other users (in discussion groups, message boards, and chat, among others), may become public, be collected, and be used by anyone. Your username may also be displayed to third parties if you interact with third parties, for example, by sending messages, comments, or uploading content.

7. PERSONAL DATA PROTECTION
7.1. Olos Tecnologia strives to protect the privacy and the security of your account and your Personal Data. However, the internet is not 100% secure, and we cannot guarantee or warrant the security of any information you provide to us. We do not undertake any liability for unintentional disclosure. You must protect your account against unauthorized access to your password, phone, and computer by taking measures, such as logging out of your account after using a shared computer, selecting and appropriately protecting your password and/or other access mechanisms, and limiting access to your computer or device and browser, logging out after you have finished using your account. Olos Tecnologia is not liable for any lost, stolen, or impaired passwords, or any activity on your account through unauthorized password activity.
7.2. If you access your registration through a third-party website or service, you must adopt additional or different protections for connecting through that third-party website or service.
7.3. Olos Tecnologia has implemented security systems to protect your Personal Data against loss or misuse, and unauthorized access or disclosure. However, it should be pointed out that the internet is not a completely secure environment, and Olos Tecnologia does not guarantee that the implemented security measures are impenetrable.

8. LINKS TO THIRD PARTY SERVICES
Our Services may contain links to third-party websites and services. Please be aware that your access to any third-party website through one of these links is not governed by this Privacy Policy, and that the privacy policies of these third parties govern their use of Personal Data. We are also not responsible for their privacy practices.

9. DATA SUBJECT´S RIGHTS
When required by the applicable law, you have the following rights regarding your Personal Data: right to access; right to data portability. You have the right to receive a copy of the Personal Data we hold about you and how we use this information. You also have the right to receive your Personal Data in a structured format and the right to have your Personal Data transmitted directly from Olos Tecnologia to another data controller. Right to rectification. You have the right to obtain from us, without undue delay, the correction of inaccurate Personal Data about you. Right to deletion. You have the right to request the deletion of Personal Data about you, unless processing is necessary to exercise the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest, or to establish, exercise, or defend a legal claim. Right to restrict or object to processing. You have the right to object to or restrict the processing of your Personal Data if you contest the accuracy of the data; the processing is unlawful and you object to its deletion; or you object to the processing. If your Personal Data is processed by us for direct marketing purposes, you have the right to object to the processing at any time. Right to file a complaint. You have the right to file a complaint with your Data Protection Officer or a supervisory authority. As a general rule, you can contact the supervisory authority where you live. Right to withdraw consent. You may withdraw your consent to us to process your Personal Data at any time. You can always decide not to disclose data to us, but please note that some data may be required to register with us or to take advantage of some of our features. You can access and update the data you have provided to us through your account settings. If you wish to exercise any of your rights and this option is not already available through your account settings, please contact us and we will handle your request. Please note that we own and may use data aggregated in an anonymized way, derived data or data which incorporates your Personal data after it has been provided to us.

10. DATA LOCALIZATION AND TRANSFER
Olos Tecnologia e Sistemas Ltda. is situated in Brazil, and the data collected is processed in accordance with the Brazilian law. The Personal Data may be transferred to affiliated companies and other recipients located in countries other than the one in which it has been originally collected. Such transfers will be carried out in compliance with the applicable legislation, including Resolution CD/ANPD No. 19/2024, fully observing the requirements set forth by the General Data Protection Law (LGPD) and the norms of the National Data Protection Authority (ANPD) regarding international data transfers. The necessary measures will be adopted to assure that the personal data keeps the same level of protection, governance, and security required by the applicable law. By using the Olos Tecnologia website, the user agrees to any transfer, storage or processing of information outside their country.

11. CONTACTS
Should you have any questions or concerns regarding our Privacy Policy or how to exercise any of your rights, please, send us a detailed message to juridico@olos.com.br and we will try to resolve your concerns. Olos Tecnologia may, at its sole discretion, make changes to this Privacy Policy. In such case, you will be notified by means of a prominent notice on the Website.

12. CONTACT DPO
The purpose of the “Contact DPO” channel is to comply with the legal provisions on the data subjects’ rights regarding their personal data and direct communications and requests to the person responsible for the administration of confidential information at GRUPO OLOS. The data subjects will have free access to the communication with GRUPO OLOS, in accordance with articles 18 and 20 of Law 13.709/2018 – General Data Protection Law (LGPD). The service may be provided online or in person, completely free of charge, and within the deadline stipulated by law or a norm issued by the National Data Protection Agency (ANPD). If the data subjects request any processing of their personal data, their ownership or legal representation over the data must be confirmed, and for this purpose, as a security measure, GRUPO OLOS may require submission of all necessary documentation for analysis and verification. Furthermore, the data subjects can review the Olos Privacy Policy available on the website.
Data Protection Officer (DPO): Edson Ferreira
E-mail: dpo@olos.com.br
Telephone: (11) 2281-1650
Address: Av. Francisco Matarazzo, 1.400 – 13th floor. ZIP CODE: 05001-000
Service Hours: Monday to Friday from 9 AM to 6 PM.
Should you have any questions about the Privacy Notice, please, contact us at privacidade@olos.com.br.