1) Introduction

This Privacy Notice was developed with the commitment to safeguard the privacy of your personal data. This document will be periodically reviewed, always with the aim of simplifying our communication, treating your personal data with safety, privacy, and transparency.

Thus, in accordance with its purpose, information will be processed and used solely for the purpose for which they are intended. We will always adopt the best practices to ensure the confidentiality, integrity, and availability of your personal data.

By becoming aware of the terms of our Privacy Notice, you acknowledge that the Controller of your personal data, that is, the company responsible for making decisions regarding the processing of this information, will be ALTERNATIVA COMPONENTES LTDA, which will be referred to in this document just as "ALTERNATIVA".

After reading this Privacy Notice, if you have any questions or choose to exercise your rights related to your personal data with ALTERNATIVA, you can contact us through our Data Protection Officer (DPO), 'Qualitec Consult', using the email below:

Data Protection Officer (DPO) Email: privacidade@alternativa.ind.br

From this Privacy Notice, it’s important to mention that we collect your personal data every time you:

• Register as an ALTERNATIVA customer;

• Register your interest in ALTERNATIVA products and/or services;

• Register your interest in joining the ALTERNATIVA workforce;

• Browse our digital platforms;

• Get in touch with us through our contact channels: email, phone, website, or WhatsApp;

It's worth noting that this Privacy Notice applies specifically to the Owners of the Right: natural persons (also known as "individuals") and legal entities who effectively contract, use, or access ALTERNATIVA's channels.

This Privacy Notice also applies to other forms of personal data collection by ALTERNATIVA, with the purpose of improving our service to customers, employees, and anyone else who may have had or wishes to have a relationship with our organization. However, all of the main forms of data collection and the uses of your personal data are described in this Privacy Notice.

The practices described in this Privacy Notice only apply to the processing of your personal data in Brazil and they are subject to applicable local laws, especially the Law No. 13709/2018 (General Data Protection Regulation, or "GDPR")

2) What personal data are collected?

When requesting, contracting, or using ALTERNATIVA's products and/or services, you provide us with some personal data related to you, even if you are representing a company (also known as a 'legal entity').

In addition, we also receive some personal data sent by partners we hire for specific purposes (to reinforce our fraud control and for the registration analysis), so that we can comply with legal obligations or applicable regulations. By becoming aware of the terms of this Privacy Notice, you agree and expressly declare that you will only provide us with true, current, and accurate personal data, being solely responsible for any false, outdated, or inaccurate information that you provide directly to ALTERNATIVA. Thus, here are some examples of personal data processed by ALTERNATIVA, divided by categories:

a) Personal data provided by you, as the owner of the right:

• Registration data, such as: name, identification documents (ID and social security number or driver's license), nationality, address, date of birth and parents' names;

• Contact information, such as phone number and email address;

• Current profession or occupation;

• The photograph of your identification document and your face.

b) Browsing and device data:

• IP address of the device used to access ALTERNATIVA's digital platforms;

• Interactions performed and usage profile of the ALTERNATIVA's website;

• Technical data, such as URL information, network connection, provider, and device information;

• Cookies;

• Device attributes, such as ID, operating system, browser, and model;

• Device geolocation data, if you authorize the collection from your device.

c) Public Data:

• Information about mentions or interactions with ALTERNATIVA;

• Testimonials related to ALTERNATIVA posted on social media profiles and pages, along with your name and image (including profile pictures).

3) How ALTERNATIVA uses your personal data.

ALTERNATIVA uses your personal data to provide a high-quality service and to offer the best services and/or products to you. We have detailed below the purposes for which we use your personal data:

a) Personal data provided by the owner of the right – Purposes:

• Rendering of services and offering of contracted products and/or services;

• Identification, authentication and verification of requirements for contracting ALTERNATIVA's services and/or products;

• Authentication of financial transactions;

• Addressing requests and inquiries;

• Contact by phone, email, SMS, WhatsApp, or other means of communication, including the sending of ALTERNATIVA notifications;

• Sending general communications;

• Improvement of products and/or services provided by ALTERNATIVA, including a data analysis to offer new products and/or services;

• Marketing, prospecting, market research, opinion surveys and promotion of our products and/or services, including the conduct of contests, content, news and other relevant events for maintaining the relationship with you;

• Prevention and resolution of technical or security problems;

• Investigations and measures to prevent and combat illegal activities, fraud and financial crimes, ensuring the security of ALTERNATIVA's customers;

• Regular exercise of ALTERNATIVA's rights, including presenting documents in judicial and administrative proceedings, if necessary;

• Collaboration or compliance with a court order, of competent authority or supervisory body;

• Compliance with legal or regulatory obligations.

b) Personal data that we collect from third parties – Purposes:

• Improvement of our products and/or services, as well as their offer;

• Marketing, prospecting, market research and opinion surveys;

• Periodic reevaluations of eligibility to be an ALTERNATIVA's customer;

• Prevention and resolution of technical or security problems.

c) Browsing and Device Data – Purposes:

• Rendering of the contracted services and/or offering of products, and improvement of the experience and usage of ALTERNATIVA's website;

• Operationalization of new products and/or services;

• Recommendation of new products and/or services or website features, including services from partners that may interest you;

• Display of advertisements, whether on our website, social media or on third-party websites;

• Generation of statistics, studies, research, and surveys relevant to the activities and behaviour in the use of products and/or services;

• Prevention and resolution of technical or security problems;

• Compliance with court order, of competent authority or supervisory body.

d) Personal data originated from the use of our products and/or services – Purposes:

• Rendering of the contracted services and/or offering of products;

• Authentication of transactions, customer service and support;

• Improvement of the products and/or services offered by ALTERNATIVA, including data analysis to offer new products and/or services;

• Development of new products and/or services to be offered by ALTERNATIVA and generation of knowledge for innovation or development of new products and/or services;

• Tests to improve ALTERNATIVA's product and/or service models;

• Marketing, prospecting, market research, opinion surveys and promotion of our products and/or services, including the conduct of contests, content, news and other relevant events for maintaining the relationship with you;

• Prevention and resolution of technical or security problems, and monitoring the usage and performance of ALTERNATIVA's products and/or services;

• Compliance with legal obligations.

e) Public Data – Purposes:

• Promotion of the products and/or services provided by ALTERNATIVA on social media, websites, applications, or institutional and advertising materials;

• Regular exercise of ALTERNATIVA's rights.

4) Sharing personal data.

ALTERNATIVA may share your data if you request it. The sharing of your data may also be done with third-party partners and with authorities and public or regulatory bodies for different purposes, when necessary. Whenever carried out, the sharing of data will be conducted within the limits and purposes of our business and in accordance with what is authorized by the applicable legislation. Below, we have prepared a summary divided into categories with the types of providers with whom we normally share your personal data:

a) Business partners, service providers, and other third parties: information technology service providers, customer service providers, communication providers, statistical services providers, research providers, marketing, financial services and payment providers, debt collection agencies, credit and fraud prevention agencies, banks, financial institutions, and other third parties. Purposes of sharing:

• Improvement of our products and/or services, website, and operationalization of new products and/or services;

• Contact via phone, email, SMS, WhatsApp, push notifications, or other means of communication;

• Debt collection;

• Identity verification and eligibility to contract ALTERNATIVA;

• Marketing, prospecting, market research, opinion surveys, contests and promotion of our products and/or services;

• Prevention and resolution of technical or security problems;

• Regular exercise of ALTERNATIVA's rights;

• Compliance with legal obligations.

b) Authorities and regulatory bodies – Purposes of sharing:

• Regular exercise of ALTERNATIVA's rights, including presenting documents in judicial and administrative proceedings, if necessary;

• Compliance with court orders;

• Compliance with legal obligations.

c) Upon your request – Purposes of sharing:

• Ensure transparency in our relationship with you;

• Sending non-mandatory notifications via email, push notifications, WhatsApp and SMS.

5) Retention and deletion of your personal data:

While you are an ALTERNATIVA customer, during the use of our products and/or services and throughout the period in which ALTERNATIVA stores your personal data, they will be kept in a secure and controlled environment.

When applicable, and even after the cancellation of your registration with ALTERNATIVA, we may store your personal data for an additional period of time for the purpose of complying with legal or regulatory obligations, for the regular exercise of ALTERNATIVA's rights, or for the necessary period according to the legal basis that justifies data retention. For example, we may store your data to comply with obligations imposed by the Brazilian Federal Internal Revenue, to preserve consumer rights, and also to preserve our rights in lawsuits.

6) Your rights as a data subject:

From the enactment of the General Data Protection Regulation - GDPR no. 13709/2018, you, as a Data Subject, can exercise your rights with respect to the Controllers of your personal data. Therefore, we provided below the detailed mechanisms for you to understand clearly and transparently how to exercise your rights and how our team will be ready to address any requests:

a) Confirmation of the existence of personal data processing: The fact that you are an ALTERNATIVA customer already implies that we process your personal data, even if this processing includes, among others, the storage of personal data in a secured and controlled environment. You can request ALTERNATIVA to confirm whether it processes your personal data.

b) Access to the personal data: You can request ALTERNATIVA to inform and provide the personal data it holds regarding you.

c) Correction of incomplete, inaccurate, or outdated personal data: If you find that your personal data is incomplete, inaccurate, or outdated, you can request correction or completion. In order to do this, you will need to provide a document that proves the correct and current form of the personal data.

d) Anonymization, blocking, or deletion of unnecessary, excessive, or processed data in non-compliance with the GDPR: If any of your personal data is processed unnecessarily, in excess of the purpose for which it was collected, or in non-compliance with the GDPR, you can request ALTERNATIVA to block or delete this data, as long as the excess, lack of necessity, or non-compliance with the law is effectively confirmed.

e) Deletion of personal data processed with consent: If you have given consent for the processing of your personal data for specific purposes (and not necessary for the provision of our services or delivery of our products), you may request the deletion of this personal data.

f) Information about the public and private entities with which ALTERNATIVA has shared or from which it has received your personal data: You can request ALTERNATIVA to provide information about the third parties with whom it has shared or from whom it has received your personal data.

g) Information about the possibility of not giving consent and the consequences of refusal:

g.1) Revocation of consent: If you have given your consent for the processing of your personal data, you may request the revocation of this authorization. The withdrawal of consent may result in the termination of sales to you or to the company you represent, but it does not prevent the use of: (I) anonymized data; and (II) data whose processing is based on another legal basis provided in the GDPR.

g.2) Automated decisions: You may request the review of the decisions made solely based on the automated processing of personal data that affect your interests, and the indication of the criteria used for these decisions. For reasons of business secrecy, protection of confidential information, and preservation of competition, ALTERNATIVA does not disclose how these automated systems work. It is important to emphasize that ALTERNATIVA does not guarantee a different outcome from the initial decision, but we can assure you that our technological models are consistent and guided by legal and ethical principles.

h) Portability and right for petition: When the right of portability is regulated by the National Data Protection Authority (NDPA), you may request from ALTERNATIVA the portability of your personal data to another service provider. Additionally, with the establishment of the NDPA, you will also have the right to petition regarding your data to the national authority.

➢ Should you wish to exercise any of these rights, please contact our Data Protection Officer directly (who can be simply referred to as "In Charge" or by the acronym "DPO," which stands for "Data Protection Officer"), Qualitec Consult, at the following email: privacidade@alternativa.ind.br .

In order to fulfil your rights, we may request proof of your identity as a security and fraud prevention measure.

7) Activity log.

We may record the activities you perform when using our website by creating, when possible and applicable, logs (records of activities carried out on websites, applications, and services) that will contain: the IP address, access and actions performed by you on the provided service, date and time of each action taken, and information about the device that have been used, such as: the operating system version, browser and geolocation. We may also use certain technologies, either our own or from third parties, to monitor the activities you perform while accessing our website, such as:

a) Cookies: internet files that temporarily store what you are visiting on the web.

ALTERNATIVA uses cookies on its website, and it also receives information from partners regarding cookies placed on their respective websites. Cookies can be used for several purposes, including remembering you and your preferences, storing information related to your activities on the website you visited, or collecting information that can be used to provide personalized content.

We have third-party cookies enabled on our website. Privacy practices will be governed by the privacy policies and terms of use of these third parties, and we cannot control or take responsibility for the practices and privacy content of third parties. Therefore, please note that you can, at any time, block the use of cookies by activating a setting in your internet browser - your ability to limit cookies will be subject to the settings and limitations of your browser. You can also delete existing cookies through the same settings in your internet browser. If you choose to disable cookies, you can still browse the website, but some parts of the pages may not work.

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b) Analytics tools: These tools may collect information about how you visit a website, including which pages you visit and when you visit them, as well as other sites that were visited before, among other things. All technologies used by us will always respect the terms of this Privacy Notice.

8) International transfer of personal data.

Some of your personal data, or all of it, may be transferred abroad, for example, when stored by ALTERNATIVA on cloud computing servers located outside of Brazil ("cloud" is a data storage architecture). To do this, ALTERNATIVA complies with all the requirements established by the current legislation and adopts the best security and privacy practices to ensure the integrity, confidentiality, and availability of your personal data.

9) Security measures.

ALTERNATIVA employs several security measures to ensure the integrity of your personal data, following information security standards commonly practiced when collecting and storing such data. Personal data may also be stored using cloud computing technology and other emerging technologies in the future, always aiming to improve and enhance our security systems. We handle the security of your personal data with the utmost care, utilizing the best standards and practices adopted in the market.

10) Changes to this Privacy Notice.

ALTERNATIVA may change this Privacy Notice at any time. Whenever a significant condition of this Privacy Notice is altered, these changes will be valid, effective, and binding as soon as the new version is disclosed on our website.

11) Contact us.

According to the GDPR, ALTERNATIVA is considered the "Controller" of your personal data. If, after reading this Privacy Notice, you still have any questions or, for any reason, need to communicate with us regarding your personal data, you can contact us through the channel below, with our Data Protection Officer (DPO):

Data Protection Officer (DPO): Qualitec Consult – privacidade@alternativa.ind.br

We are always available to clarify your questions and put you in control of your personal data.

This Privacy Notice was last updated on May 10, 2023.

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