This Privacy Policy (“Privacy Policy”) establishes the general terms according to which VELT Partners Investimentos Ltda. (“VELT Partners”) processes the personal data collected from individuals that access our website https://www.velt.com/, pursuant to the applicable laws and regulations, particularly the Brazilian General Data Protection Law - Law 13.709/2018 (“LGPD”).

Which Personal Data do we collect?

When you access VELT Partners website (https://www.velt.com/), we collect your Internet Protocol (IP) address (“IP Address”) through Google Analytics.

We adopt Google Analytics tool in order to identify traffic origins and behavior patterns that are generated through consolidated reports that show us statistics on visits to our website.

We consider your IP Address as a Personal Data for purposes of LGPD. For this reason, we treat your IP as provided for in the law.

We also track views of Vimeo’s videos through Vimeo Analytics. We collect cookies with the purpose of tracking the session, but no personally identifiable information. We have access only to the consolidated report showing the accesses and the behaviors. Vimeo uses cookies to connect devices, reproduce embedded videos, and help understand how its services are used.

For more information on Google Analytics and Vimeo, please refer to its policies available at its websites.

If you choose to receive proprietary materials prepared by VELT Partners, in addition to your IP Address, information such as name, surname, company name and contact email (“Form Information”) will also be collected, with which you expressly consent to the relevant treatment when you agree to submit such information using the applicable form available on our website.

Why do we treat your Personal Data?

According to the legal purposes set forth in the LGPD, we collect and treat your Personal Data for legitimate commercial interests and/or compliance with legal and regulatory obligations.

We may also use your information based on your consent, when it is given. Your consent may be withdrawn at any time. Please refer to the section: “Which rights do you have regarding your Personal Data?”.

Where do we treat your data?

We treat your Personal Data within the national territory, but it may be stored in back-up systems located in other countries which, in our opinion, provide a privacy protection level equivalent to (or better than) that used in Brazil.

How long do we retain your Personal Data?

Personal Data will be stored and processed for a period of time considered reasonable for compliance with the purpose set forth herein. As soon as this purpose is fulfilled, we will exclude the data in a safe manner, except for those involving any legal or regulatory obligation that may force us to retain them for a specific period.

With whom do we share your Personal Data?

We may share your Personal data in the situations below:

• Legal or regulatory requirements. If we are compelled to share your Personal Data as provided for in the law or in any regulatory requirement, or if we understand that this is reasonably necessary to fulfill any judicial proceedings and/or actions.
• International transfers. We usually treat Personal Data within the national territory. However, since we use back-up systems that are located in other countries, your Personal Data may be disclosed to technology companies that are responsible for backing up the information collected.

How can we guarantee the safety of your Personal Data?

We have a robust technology and cybersecurity structure that ensures high standards of security, confidentially and protection to your Personal Data.

We take measures to limit the access to your Personal Data to persons that must have access to them for one of the purposes mentioned in this Privacy Policy. Additionally, we seek to ensure that third parties who process and treat your Personal Data also commit to the appropriate processing, confidentiality and integrity of your data, as set forth in an agreement signed by them.

Which rights do you have regarding your Personal Data?

As the owner of the data, you have the right to:

• confirm whether the treatment exist;
• access your data;
• correct incomplete, incorrect or outdated data;
• request the anonymization, blocking or elimination of unnecessary or excessive data, or data that are not processed in compliance with the LGPD;
• request the portability of data to other service or product supplier;
• delete the Personal Data that are processed with your consent, except in the situations provided for in the LGPD;
• request information about public and private entities with which the Controller has shared the data;
• request information about the possibility of withholding your consent, and the consequences thereof; and
• withdraw your consent, if applicable.

Questions? Contact us!

If you have any questions about the treatment of your Personal Data, this Privacy Policy, or if you intend to exercise any of the rights mentioned above, please contact us.

You may do so by contacting our Data Processing Officer (DPO) – Priscila Romanizio, or VELT Partners’ LGPD Committee, of which the DPO is a member; by e-mail to lgpd@velt.com; or by phone (+55 11) 4560-6800 / fax (+55 11) 4560-6801.

Update

This Privacy Policy is reviewed on a regular basis. We will publish the updated version of this policy on our website https://www.velt.com/. We recommend that you check this Privacy Policy on a regular basis, so as to be informed about any changes thereto.