PRIVACY POLICY

LIMPPANO S.A., a legal entity governed by private law registered with the Corporate Taxpayer Registry (CNPJ) under number 33.033.556/0001-33, headquartered at Rod. Presidente Dutra, 1338, ZIP Code 21.535-502, Bairro Vigário Geral, Rio de Janeiro-RJ (“LIMPPANO”), considers the electronic records and personal data left by you (“Data Subject”) when using the various websites and services (“Services”) of LIMPPANO to be extremely relevant. This Privacy Notice (“Notice”) serves to regulate, in a simple, transparent, and objective manner, what personal data will be obtained, as well as when and how it may be used. This Notice applies to Services related to any of LIMPPANO’s brands and activities, own or through its partners, understanding as such all those listed on its official website, at https://limppano.com.br/ and https://www.lojalimppano.com.br/, encompassing all its products.

 

This Notice is aimed at LIMPPANO’s customers and the general public, and covers the ways in which we process the personal data of these individuals. If you are an employee, collaborator, or supplier of LIMPPANO, or if you are participating in a specific project or activity with us, you can also verify the existence of a specific privacy notice in your employment contract or service contract. If you have any additional questions or requests, please contact our Data Protection Officer at the email address listed below:

LGPD is the acronym for General Data Protection Law, enacted in August 2018. The LGPD establishes rules on the collection, storage, processing and sharing of personal data, imposing more protection and penalties for non-compliance with its provisions. LIMPPANO, in order to provide greater security and transparency in the use of its customers’ personal data, has adopted the following measures, among others, to comply with the LGPD guidelines: review and mapping of internal processes, appointment of a DPO, preparation and review of documents, establishment of information security mechanisms.

 

To better illustrate how we process data, we present a summary of our Privacy and Personal Data Protection Notice:

 

DATA PROCESSOR LIMPPANO S.A., a legal entity governed by private law registered with the CNPJ under number 33.033.556/0001-33, headquartered at Rod. Presidente Dutra, 1338, ZIP Code 21.535-502, Bairro Vigário Geral, Rio de Janeiro-RJ
ROLE IN PROCESSING Predominantly controlling.
NATURE OF THE DATA PROCESSED Personal data provided voluntarily by the Data Subject and/or collected from partners, suppliers, and others involved automatically.
MAIN PURPOSES OF THE PROCESSING Personal data used to access, respond to or maintain contact before, during, or after a contractual relationship with the Data Subject, in order to comply with the contract. Legal basis:

· Execution of a contract with the Data Subject;

· Compliance with a legal or regulatory obligation;

· The processing of personal data of children shall be carried out with the specific and prominent consent given by at least one parent or legal guardian;

· Use of personal data for advertising purposes, such as sending information about LIMPPANO brands, products, promotions, and discounts, as well as for publicizing events;

· Consent of the Data Subject.
SHARING With operators, partners, and suppliers of essential services for our activities; and government authorities/agencies due to legal or regulatory obligations.
DATA PROTECTION Appropriate security, technical, and administrative measures.
YOUR RIGHTS Confirmation of data processing status and data access; rectification of incomplete, inaccurate, or outdated data; anonymization, restriction, or erasure of data that is unnecessary, excessive, or processed non-compliant with legislation; data portability; disclosure of public and private entities with whom data has been shared; information on the option to withhold consent and its consequences; and withdrawal of consent.

 

LIMPPANO may update this Notice at any time, making the new version available at https://limppano.com.br/ and https://www.lojalimppano.com.br/.

 

I. DEFINITIONS

 

PERSONAL DATA: Any information related to an individual, directly or indirectly, that identifies them or makes them identifiable.

SENSITIVE PERSONAL DATA: Special category of personal data relating to racial or ethnic origin, religious belief, political opinion, union or religious, philosophical, or political organization membership, relating to health or sexual life, genetic or biometric data relating to the natural person.

DATA SUBJECT: Natural person to whom the personal data refers, such as individuals interested in entering into contracts with LIMPPANO, customers or potential customers, employees, contractors, suppliers, business partners, and third parties.

PROCESSING: Any operation involving personal data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, destruction, evaluation, or control of information, change, communication, transfer, dissemination, or extraction.

ANONYMIZATION: Process by which the data loses the possibility of association, direct or indirect, with an individual, considering the technical means reasonable and available at the time of processing.

 

II. WHAT DATA DO WE USE

 

LIMPPANO may collect the information actively entered by the Data Subject at the time of contact or registration and also information automatically collected when using the Services from business partners, public agencies, regulatory systems, and suppliers, as well as through the computerized network, such as, for example, identification of the commercial establishment used, IP with the date and time of the connection, among others.

In addition, there will be the collection of personal data at the time of contracting, consisting of all the data required for registration or required by the Company such as: name, Identity Card (RG), Individual Taxpayer Registry (CPF), among others.

Thus, two types of personal data are processed:

a) Personal data provided by the Data Subject: LIMPPANO may collect all personal data actively entered or forwarded by the Data Subject when contacting or accessing LIMPPANO’s communication channels, such as full name, email, gender, date of birth, city and state, among others; when providing or filling out forms in the services provided, suppliers and partners by the Data Subject; with the addition of other personal data actively provided by the Data Subject when contacting LIMPPANO. Regardless of what data the Data Subject actively provides to LIMPPANO, we will only use those that are effectively relevant and necessary to achieve the purposes declared to it on a case-by-case basis, according to item III.

b) Data collected automatically: LIMPPANO also collects a series of information automatically, such as: characteristics of the access device, browser, IP (with date and time), IP source, information on clicks, pages accessed, search terms typed in our portals, among others. For such collection, LIMPPANO will make use of some standard technologies, such as cookies, pixel tags, beacons, and local shared objects, which are used for the purpose of improving the Data Subject’s browsing experience on the Services, according to their habits and preferences. It may also collect relevant information from the network of service providers, suppliers, and partners.

 

It is possible to disable, through your internet browser settings, the automatic collection of information through certain technologies such as cookies and caches, as well as on our own website, according to item IV. However, the Data Subject must be aware that, if these technologies are disabled, some features offered by the website, which depend on the processing of these data, may not work correctly.

The Data Subject may access, update, and supplement their data, as well as request the deletion of their data collected by LIMPPANO, through the Data Protection Officer at the email address: dpo@limppano.com.br. We will make all efforts to respond to you as quickly as possible, respecting the retention periods established by law.

LIMPPANO does not process, for the general purposes set forth herein, data considered sensitive by Law No. 13.709/2018, understood as those related to racial or ethnic origin, religious belief, political opinion, union or religious, philosophical, or political organization membership, sexual life, genetic data, etc.

 

III. HOW WE USE THE DATA

 

Processing includes any operation involving personal data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, destruction, evaluation or control of information, change, communication, transfer, dissemination, or extraction. The personal data processed by LIMPPANO is primarily used for the purpose of establishing a contractual relationship or for the management, administration, provision, expansion, and improvement of Services to the Data Subject, tailoring them to their preferences and tastes, as well as for the creation of new services and products to be offered to Data Subjects. LIMPPANO may centralize the personal data collected, which could be used in other Services related to LIMPPANO’s brands, respecting the purposes set out herein and the Data Subject’s consent, whenever required by law.

In some cases, LIMPPANO may also process personal data when necessary to comply with a legal or regulatory obligation. In addition, LIMPPANO may also process personal data based on its legitimate interest, always within the limit of what is expected by the Data Subject, and never to the detriment of their interests, rights and fundamental freedoms. In addition, the information collected may, with the consent of the Data Subject, be used for advertising purposes, such as sending information about LIMPPANO brands, products, promotions and discounts, as well as publicizing events or conducting research related to its activities.

Any Data Subject wishing to no longer receive advertising information from LIMPPANO may contact LIMPPANO at any time through the Data Protection Officer, through the email address: dpo@limppano.com.br.

 

IV. HOW WE USE COOKIES

 

Cookies are files or information that may be stored on your devices when you visit the websites or use LIMPPANO’s online services. Generally, a cookie contains the name of the website that created it, its lifespan, and a randomly generated value.

LIMPPANO uses cookies to facilitate the use and better adapt its pages to the interests and needs of the Data Subjects, as well as to compile information about the use of our websites and services, helping to improve their structures and contents. Cookies may also be used to speed up your future activities and experiences on our portal.

Types of Cookies:

 

NECESSARY: These cookies are essential for LIMPPANO pages to load correctly and make it easier to browse our websites and make use of all features. Examples.: visid_incap_{Site-ID}; incap_ses_{Site-ID}; visid_incap_{Site-ID}.

PERFORMANCE: These cookies help us understand how visitors interact with LIMPPANO’s pages, providing information about the areas visited, the time spent on the website and any problems encountered, such as error messages. Examples: _ga; _gid; _gat_UA-103613208-1; _gat_UA-11684720-3.

FUNCTIONAL: These cookies allow LIMPPANO pages to remember your choices and to provide a more personalized experience. They also allow Data Subjects to watch videos and use social tools, comment fields, forums, and other features.

MARKETING: These cookies are used to deliver content that is more relevant and of interest to the Data Subjects. They can be used to show more targeted advertising or limit the number of times an advertisement is displayed on the web pages of LIMPPANO. They also make it possible to measure the effectiveness of a LIMPPANO advertising campaign. In addition, these cookies may be used to indicate to LIMPPANO pages which websites the Data Subject has visited, and LIMPPANO may share this information with third parties, such as contracted advertising agencies.

After the Data Subject consents to the use of cookies, when using LIMPPANO’s pages, LIMPPANO will store a cookie on their device to remember this in the next session. At any time, the Data Subject may revoke their consent to cookies directly with LIMPPANO or by making adjustments to their preferred browser settings.

For more information on how to manage cookies in browsers, go to:

Finally, we remind you that, if the Data Subject does not accept some cookies from LIMPPANO’s pages, certain services may not work optimally.

 

V. WHO WE SHARE DATA WITH

 

LIMPPANO maintains partnerships with various companies in order to ensure the implementation of its services, as well as to provide benefits or ancillary services to its customers. With this in mind, the complete list of companies with which LIMPPANO may share its customers’ data, solely for business purposes, is available for interested parties to view in our business unit or may be requested from the Data Protection Officer at the email address: dpo@limppano.com.br.

LIMPPANO works in partnership with various companies throughout Brazil. In this way, information collected through the pages or by contacting the Data Subjects may be shared in the following cases:

i. With partner Companies and suppliers, in improving the Services intended for the Data Subject (See descriptive table below);

ii. With authorities, government entities or other third parties, for the protection of LIMPPANO’s interests in any type of conflict, including lawsuits and administrative proceedings (See descriptive table below);

iii. In the case of transactions and corporate changes involving LIMPPANO, in which case the transfer of information will be necessary for the continuity of services;

iv. Through a court order or at the request of administrative authorities who are legally empowered to make such a request.

 

Purpose Legal Basis
E-commerce platform for creating virtual stores Article 7, V of Law No. 13.709/18
Marketing Solutions
Shopping Portal Article 7, V of Law No. 13.709/18
Sales solution in marketing place
Issuance of Tax Invoices

 

 Article 7, II of Law No. 13.709/18
Customer service tool via chat for website Article 7, V of Law No. 13.709/18
Platform used for registering and launching products Article 7, V of Law No. 13.709/18
Telephone Contact Management Article 7, V of Law No. 13.709/18
Sales Management Tool Article 7, V of Law No. 13.709/18
Corporate Expense Reimbursement Tool Article 7, IX of Law No. 13.709/18
Shipping companies Article 7, V of Law No. 13.709/18
Email platform Article 7, V of Law No. 13.709/18
BI Tool Article 7, V of Law No. 13.709/18
Website management Article 7, IX of Law No. 13.709/18
Internal Monitoring and Security Tool Article 7, IX of Law No. 13.709/18
Internal and External Communication Tool Article 7, IX of Law No. 13.709/18
Digital Certificate Article 7, II of Law No. 13.709/18
Business Management System Article 7, IX of Law No. 13.709/18
Information Technology Management Software Article 7, IX of Law No. 13.709/18
Sector Integration Tool Article 7, IX of Law No. 13.709/18
Service Providers Article 7, V of Law No. 13.709/18
Employee Recruitment and Selection Platforms Article 7, IX of Law No. 13.709/18
Corporate Benefits Administrators Article 7, IX of Law No. 13.709/18
Human Resources Management System Article 7, IX of Law No. 13.709/18
Public Agencies Article 7, II of Law No. 13.709/18

 

In addition, it is possible that some of the transfers indicated above may occur outside Brazil, in which case LIMPPANO undertakes to do so only to countries that provide a level of personal data protection adequate to that provided for in applicable law or through the use of guarantees and safeguards such as specific clauses, standard clauses, global corporate standards, among others; as well as with the specific consent of the Data Subject or in compliance with other cases authorized by law.

 

VI. HOW WE KEEP YOUR DATA SECURE

 

LIMPPANO uses reasonable market and legally required means to preserve the privacy of the personal data it collects. This is why it adopts a number of precautions, in compliance with the guidelines on safety standards established in current legislation, such as:

i. Using the standard market methods to provide security to the data collected and processed;

ii. Protecting against unauthorized access to your systems;

iii. Only individuals who have been registered in advance are authorized to access the location where collected information is stored;

iv. Requiring absolute secrecy from those who come into contact with personal data. The breach of confidentiality will result in civil liability and the individual responsible will be held liable in accordance with Brazilian legislation;

In addition to technical efforts, LIMPPANO also adopts institutional measures aimed at protecting personal data, maintaining a privacy governance program applied to its activities and governance structure, which is updated on an ongoing basis.

Although LIMPPANO makes its best efforts to preserve the privacy and to protect the data of the Data Subjects, no transmission of information is fully secure. As such, LIMPPANO cannot fully guarantee that all the information it receives or sends will not be the target of unauthorized access perpetrated through methods specially developed to obtain information improperly. For this reason, we encourage Data Subjects to take appropriate measures to protect themselves, such as keeping all Data Subjects’ names and passwords confidential, provided that such information is personal, non-transferable, and the sole responsibility of the Data Subjects.

At any time, if the Data Subject feels the need, they may request a copy of their data stored on LIMPPANO’s systems.

 

VII. RETENTION OF COLLECTED INFORMATION

 

In order to protect the privacy of Data Subjects, the personal data processed by LIMPPANO will be automatically deleted when it is no longer required for the purposes for which they have been collected, or when the Data Subject requests its deletion, unless the need for keeping the data is expressly authorized by applicable law or regulation.

Likewise, the information may be kept to comply with legal or regulatory obligations, transfers to third parties—provided that the data processing requirements are respected—and LIMPPANO’s exclusive use, including for the exercise of its rights in judicial or administrative proceedings.

 

VIII. YOUR RIGHTS

 

In compliance with the applicable regulations, with regard to the processing of personal data, LIMPPANO respects and guarantees the Data Subject the possibility of submitting requests based on the following rights:

i) Confirmation of the existence of processing;

ii) Access to the data;

iii) Correction of incomplete, inaccurate, or outdated data;

iv) Anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in violation of applicable rules;

v) Portability of data to another service or product provider, upon express request by the Data Subject;

vi) Deletion of personal data processed with the consent of the Data Subject;

vii) Obtaining information about the public or private entities with which LIMPPANO has shared its data;

viii) Information about the possibility of not providing your consent, as well as being informed about the consequences in case of refusal;

ix) Withdrawal of consent;

x) Right to object to processing, in the event there are any concerns as to how data is being used;

xi) Right to review automated decisions.

 

These rights may be exercised by sending a request to our Data Protection Officer at the email address: dpo@limppano.com.br, for further evaluation and adoption of other measures by LIMPPANO.

LIMPPANO will analyze any requests for deletion of the data, and, if it is found that this data consists of essential information for managing and maintaining the existing contractual relationship, the company reserves the right to retain this data due to an explicit legal provision allowing them to do so.

LIMPPANO will make every effort to respond to such requests as quickly as possible. However, justifiable factors, such as the complexity of the requested action, may delay or prevent a rapid response.

Finally, the Data Subject should be aware that their request may be legally rejected, either for formal reasons (such as their inability to prove their identity) or legal reasons (such as a request to delete data whose maintenance is a free exercise of right by LIMPPANO).

 

IX. LAW AND JURISDICTION

 

This Notice shall be governed by, construed, and enforced in accordance with the Laws of the Federative Republic of Brazil, particularly Law No. 13.709/2018, regardless of the Laws of other states or Countries, and the domicile of the Data Subject shall be competent to settle any disputes arising from this document.