PRIVACY POLICY AND DATA PROTECTION ↩

At Squadra, privacy and security are priorities, and we are committed to transparently handling personal data of our users/customers. Therefore, this Privacy Policy outlines how we collect, use, and transfer customer information or other individuals who access or use our website.

By using our services, you understand that we will collect and use your personal information as described in this Policy, under the standards of the Federal Constitution of 1988 (art. 5, LXXIX; and art. 22, XXX – included by EC 115/2022), Data Protection laws (LGPD, Federal Law 13,709/2018), consumer protection provisions of Federal Law 8078/1990, and other applicable Brazilian legal regulations.

Thus, Squadra Tecnologia SA, hereinafter referred to simply as "Squadra," registered with CNPJ/MF under no. 41,893,678/0001-28, as the Data Controller, undertakes to comply with the provisions of this Privacy Policy.

1. What data do we collect about you and for what purpose? ↩

Our website collects and uses some of your personal data to enable service provision and enhance user experience.

1.1. Personal data provided by the data subject ↩

• Name, email, and phone: Within our website, you may fill out forms, submit comments and questions, contact our team, or register on our platform, and your data will be saved for further assistance.

1.2. Automatically collected data ↩

• Device data: We collect data linked to the device accessing our website, mainly for security reasons – data such as: hardware model, operating system, device identifiers (location, etc.).
• Access Logs: We collect and process actions linked to data usage, from inclusion to deletion of data, user/customer IP, date (day/month/year), access time.
• Browsing data: We collect and process browsing-related data, allowing for a better user/customer experience – browser used by the user and accessed pages.

2. How do we collect your data? ↩

In this regard, the collection of your personal data occurs as follows:

• User's personal data: Collected through forms, FAQs, Contact Us, etc.
• Device data: Collected/Transmitted/Transferred through service access via the internet.
• Access logs: Collected/Transmitted/Transferred through service access via the internet.
• Browsing data: Collected through cookies during website browsing.

2.1. Consent ↩

It is with your consent that we process your personal data. Consent is the free, informed, and unequivocal manifestation by which you authorize Squadra to process your data.

Therefore, in accordance with the General Data Protection Law, your data will only be collected, processed, and stored with prior and express consent.

Your consent will be obtained specifically for each purpose described above, demonstrating Squadra's commitment to transparency and good faith towards its users/customers, following relevant legislative regulations.

By using Squadra's services and providing your personal data, you are aware of and consenting to the provisions of this Privacy Policy, as well as knowing your rights and how to exercise them.

You may revoke your consent at any time at no cost.

It is important to note that revoking consent for data processing may result in the inability to perform certain website functions. Such consequences will be communicated in advance.

3. What are your rights? ↩

Squadra guarantees its users/customers their rights as data subjects provided for in article 18 of the General Data Protection Law. Thus, you can, freely and at any time:

• Confirm the existence of data processing, in a simplified or clear and complete format.
• Access your data, requesting them in a readable copy in printed form or electronically, securely and reliably.
• Correct your data, by requesting their editing, correction, or updating.
• Limit your data when unnecessary, excessive, or processed in violation of the law through anonymization, blocking, or deletion.
• Request the portability of your data, through a report of personal data that Squadra processes about you.
• Delete your data processed with your consent, except as provided by law.
• Revoke your consent, disallowing the processing of your data.
• Be informed about the possibility of not providing your consent and about the consequences of refusal.

4. How can you exercise your data subject rights? ↩

To exercise your data subject rights, you must contact Squadra through the following available channels:

• Email: [email protected]

To ensure your correct identification as the data subject of the requested personal data, we may request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

5. How and for how long will your data be stored? ↩

Your personal data collected by Squadra will be used and stored for the time necessary for service provision or for the purposes listed in this Privacy Policy, considering the rights of data subjects and controllers.

In general, your data will be kept while the contractual relationship between you and Squadra lasts. After the storage period of personal data ends, they will be deleted from our databases or anonymized, except for cases legally provided for in article 16 of the General Data Protection Law.

6. What do we do to keep your data secure? ↩

To keep your personal information secure, we use physical, electronic, and managerial tools aimed at protecting your privacy.

We apply these tools considering the nature of the collected personal data, the context and purpose of the treatment, and the risks that any breaches would generate for the rights and freedoms of the data subject.

Among the measures we adopt, we highlight the following:

• Only authorized persons have access to your personal data.
• Access to your personal data is only granted after signing a confidentiality commitment.
• Your personal data are stored in a secure and reliable environment.

Squadra is committed to adopting the best practices to prevent security incidents. However, it is necessary to highlight that no virtual page is entirely risk-free. Despite all our security protocols, incidents may occur due to third-party negligence or misconduct, such as cyberattacks by hackers or due to user/customer negligence or imprudence.

In case of security incidents that may generate relevant risk or damage to you or any of our users/customers, we will notify the affected parties and the National Data Protection Authority about the incident, in accordance with the provisions of the General Data Protection Law.

7. Who can your data be shared with? ↩

To preserve your privacy, Squadra will not share your personal data with any unauthorized third parties.

Your data may be shared with our business partners:

Digitalbot Tecnologia da Informação Ltda 43,304,803/0001-42

Geosite Tecnologia SA 50,086,075/0001-05

Gobuyer Digital Ltda ME 43,999,042/0001-90

Wings For Business Digital Ltda ME 44,016,315/0001-00

They receive your data only to the extent necessary for the provision of contracted services, and our contracts are guided by the data protection regulations of the Brazilian legal system.

However, our partners have their own Privacy Policies, which may differ from ours.

In addition, there are other cases in which your data may be shared, including:

I – Legal determination, requirement, request, or court order, with competent judicial, administrative, or governmental authorities.

II – Societary movements, such as merger, acquisition, and incorporation, automatically.

III – Protection of Squadra's rights in any type of conflict, including judicial ones.

7.1. International data transfer ↩

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. In these conditions, however, your personal data will be subject to the General Data Protection Law and other Brazilian data protection laws.

In this sense, Squadra is committed to always adopting efficient cybersecurity and data protection standards, making the best efforts to comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will occur according to the purposes described in this instrument.

8. Cookies or browsing data ↩

Squadra uses Cookies, which are text files sent by the platform to your computer and stored on it, containing information related to website navigation. In summary, Cookies are used to improve user experience.

By accessing our website and consenting to the use of Cookies, you acknowledge and accept the use of a navigation data collection system using Cookies on your device.

You can change permissions, block, or refuse Cookies at any time and at no cost. However, revoking consent for certain Cookies may make it impossible for certain platform features to function correctly.

To manage your browser's cookies, simply do so directly in your browser settings, in the Cookies management area. You can access tutorials on the subject directly from the links below:

If you use Internet Explorer.

If you use Firefox.

If you use Safari.

If you use Google Chrome.

If you use Microsoft Edge.

If you use Opera.

9. Amendment of this Privacy Policy ↩

The current version of the Privacy Policy was formulated and last updated in: January/2024.

We reserve the right to modify this Privacy Policy at any time, especially to adapt to any changes made to our website or in the legislative scope. We recommend that you review it frequently.

Any changes will take effect upon publication on our website, and we will always notify you of the changes made.

By using our services and providing your personal data after such modifications, you consent to them.

10. Responsibility ↩

Squadra foresees the responsibility of agents acting in data processing processes, in accordance with articles 42 to 45 of the General Data Protection Law.

We undertake to keep this Privacy Policy updated, observing its provisions and ensuring compliance.

Furthermore, we also undertake to seek technically and organizationally secure conditions apt to protect the entire data processing process.

If the National Data Protection Authority demands the adoption of measures regarding data processing carried out by Squadra, we undertake to follow them.

10.1 Disclaimer of liability ↩

As mentioned in Topic 6, although we adopt high security standards to prevent incidents, no virtual page is entirely free of risks. In this sense, Squadra is not responsible for:

I – Any consequences arising from users' negligence, imprudence, or incompetence regarding their individual data. We guarantee and are responsible only for the security of data processing processes and compliance with the purposes described in this instrument.

We emphasize that the responsibility regarding the confidentiality of access data lies with the user.

II – Malicious actions by third parties, such as hacker attacks, except in cases of proven Squadra misconduct or deliberate conduct.

We emphasize that in case of security incidents that may generate relevant risk or damage to you or any of our users/customers, we will notify the affected parties and the National Data Protection Authority about the incident and comply with the necessary measures.

III – Inaccuracy of the information entered by the user/customer in the records necessary for the use of Squadra services; any consequences arising from false information or entered in bad faith are entirely the responsibility of the user/customer.

11. Data Protection Officer ↩

Squadra provides the following means for you to contact us to exercise your rights as a data subject:

Email - [email protected] .

If you have any questions about this Privacy Policy or the personal data we process, you can contact our Data Protection Officer through the following channels:

Reginaldo Silva - [email protected]