Privacy Policy – LGPD

This Policy and its respective updates shall prevail over all prior policies, proposals, contracts, understandings and agreements, whether oral or written, that may exist between the parties dealing, directly or indirectly, with the subject of privacy.

The solutions contained on the website harborit.com.br (or simply the "Platform") are made available by HARBORIT (trade name), a private legal entity, enrolled with the CNPJ/MF under No. XXXXX, headquartered in XXXX, Brazil.

A. Introduction

• The privacy of our website's visitors is very important to us, and we are committed to protecting it. This policy explains what we will do with your personal information.
• Consenting to the use of cookies in accordance with the terms of this policy, when you first access our website, allows us to use cookies every time you access our website.

B. Collection of personal information

The following types of personal information may be collected, stored and used:

• information about your computer, including your IP address, geographic location, browser type and version, and operating system;
• information about your visits to and use of this website, including referral source, visit duration, page views and website navigation paths;
• information, such as your email address, that you enter when you register on our website;
• information that you enter when creating a profile on our website – for example, your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, and education and employment information;
• information, such as your name and email address, that you enter to set up subscriptions to our emails and/or newsletters;
• information that you enter while using the services on our website;
• information generated while using our website, including when, how often and under what circumstances you use it;
• information relating to anything you purchase, services you use or transactions you make through our website, including your name, address, telephone number, email address and credit card details;
• information that you post to our website with the intention of publishing it on the internet, including your username, profile pictures and the content of your posts;
• information contained in any communications that you send to us by email or through our website, including the communication content and metadata;
• any other personal information that you send to us.

Before disclosing another person's personal information to us, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

C. Use of your personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

• administering our website and our business;
• personalizing our website for you;
• enabling your use of the services available on our website;
• sending products purchased through our website;
• providing services purchased through our website;
• sending statements, invoices and payment reminders, as well as collecting your payments;
• sending marketing commercial communications;
• sending email notifications specifically requested by you;
• sending our email newsletter, if you have requested it (you may let us know at any time if you no longer wish to receive the newsletter);
• sending marketing communications relating to our business or the business of carefully selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you may inform us at any time if you no longer wish to receive marketing communications);
• providing third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
• dealing with inquiries and complaints made by or about you relating to our website;
• keeping our website secure and preventing fraud;
• verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website's private messaging service); and
• other uses.

If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.

Your privacy settings can be used to limit the publication of your information on our website and adjusted through the use of privacy controls on the website. Without your express consent, we will not provide your personal information to any third party for their, or any other third party's, direct marketing purposes.

D. Disclosure of personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our holding company and all its other subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

• to the extent that we are required to do so by law;
• in connection with any ongoing or prospective legal proceedings;
• in order to establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and reducing credit risk);
• to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
• to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information, where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

E. International data transfers

• The information we collect may be stored, processed and transferred between any of the countries in which we operate, in order to enable us to use the information in accordance with this policy.
• The information we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China and India.
• Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
• You expressly agree to the transfers of personal information described in this Section E.

F. Retention of personal information

• This Section F sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
• Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
• Without prejudice to Article F-2, we will usually delete personal data falling within the categories set out below at the date/time set out below:
  • the type of personal data will be deleted;
  • Notwithstanding the other provisions of this Section F, we will retain documents (including electronic documents) containing personal data:
    • to the extent that we are required to do so by law;
    • if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    • in order to establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and reducing credit risk).

G. Security of your personal information

• We will take appropriate technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
• We will store all the personal information you provide on our secure servers (protected by password and firewall).
• All electronic financial transactions carried out through our website will be protected by encryption technology.
• You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
• You are responsible for keeping the password you use to access our website confidential; we will not ask you for your password (except when you log in to our website).

H. Changes

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

I. Your rights

You may instruct us to provide you with any personal information we hold about you; the provision of such information will be subject to the following:

• the provision of appropriate evidence of your identity (for this purpose, we will generally accept a certified copy of your passport together with an original copy of a utility bill showing your current address).

We may withhold the requested personal information to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

J. Third-party websites

Our website includes links to, and details of, third-party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

K. Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

L. Cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use session cookies / persistent cookies / both session and persistent cookies on our website.

• The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
  • we use Google Analytics and Adwords on our website to recognize a computer when a user visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve the website's usability / analyze the use of the website / administer the website / prevent fraud and improve the security of the website / personalize the website for each user / target advertisements which may be of particular interest to specific users;
• Most browsers allow you to refuse to accept cookies – for example:
  • in Internet Explorer (version 10), you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
  • in Firefox (version 24), you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
  • in Chrome (version 29), you can block all cookies by accessing the "Customize and control" menu and clicking "Settings", "Advanced" and "Site settings", and then selecting "Blocked" under "Cookies and site data".

Blocking all cookies will have a negative impact on the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

• You can delete cookies already stored on your computer – for example:
  • in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions on how to do this at http://support.microsoft.com/kb/278835);
  • in Firefox (version 24), you can delete cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history", clicking "Show Cookies", and then clicking "Remove All Cookies"; and
  • in Chrome (version 29), you can delete all cookies by accessing the "Customize and control" menu and clicking "Settings", "Advanced", "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".

Deleting cookies will have a negative impact on the usability of many websites.

M. Data of children under 13 years of age

Processing of minors' personal data: We do not knowingly collect or request personal data from children under 13 years of age. If we become aware that we have collected personal data from a child under 13, we will cancel the account created and delete the personal data, retaining only such personal data as may be necessary to prevent a further attempt at registration.

N. Rights regarding your personal data

Rights and Guarantees: the User has rights and guarantees with respect to their personal data. We provide mechanisms, detailed below, so that Users have clarity and transparency in exercising their rights. Whenever necessary, our team will be ready to assess any requests.

Rights Provided for under the LGPD: under the terms of the General Data Protection Law (Law 13,709/2018) ("LGPD" — Brazil's General Data Protection Law), you have the right to:

• obtain confirmation that we process your personal data;
• access your personal data;
• request the correction of personal data that is incomplete, inaccurate or out of date;
• request the anonymization, blocking or elimination of unnecessary or excessive personal data, or data processed in noncompliance with the LGPD;
• request the portability of your personal data to another service or product provider, subject to our commercial and industrial secrets, once regulated by the National Data Protection Authority;
• request the elimination of personal data processed on the basis of your consent, except in the cases of personal data retention provided for under the LGPD;
• request information about with whom we share your personal data;
• request information about the possibility of not providing your consent and the consequences thereof;
• withdraw your consent to the processing of your personal data, when the processing was carried out on the basis of your consent;
• object to processing carried out in violation of the LGPD.

Additional Information: before responding to a request to exercise the rights mentioned above, we may ask you to provide us with certain information to confirm your identity.

O. Anti-Spam Practices

Our position: We are opposed to any and all practices that promote SPAM of any kind, and we are committed to ensuring that messages sent through the Platform are always of interest or relevance to their recipients. In addition, you may opt out of receiving emails at any time, by adjusting your email preferences or cancelling your account.

Guidance for Users: likewise, we require our Users not to engage in SPAM, and to ensure that any messages sent are always of interest to the recipient. Users are hereby made aware that failure to observe good practices for internet use may result in the cancellation of the offending User's account, as set out in the Terms of Use, as well as the disclosure of registration personal data, under the terms of this Privacy Policy.

P. Information and Questions

If, after reading this Policy, you have any questions or wish to submit a request regarding your personal data, you may contact our privacy team or our Data Protection Officer through this contact: