Privacy Policy

1. Purpose

MATILHA is built on industry best practices regarding information security; this Privacy Policy is intended to provide information about the collection, use, storage, protection, and rights of the USER and DATA SUBJECT in relation to their personal data, in accordance with the Brazilian General Data Protection Law (Law No. 13.709/2018 — LGPD) and, where applicable, the General Data Protection Regulation (GDPR).

The purpose of this document is to inform all DATA SUBJECTS about how MATILHA handles Personal Data and Sensitive Personal Data collected and processed through the matilha.digital website and related services.

2. Definitions

This Privacy Policy is a legal statement explaining how MATILHA may collect and share your information and how the DATA SUBJECT may limit such sharing. Some terms used in this Policy have the following meanings:

• Personal Data: information relating to an identified or identifiable natural person.
• Sensitive Personal Data: personal data concerning racial or ethnic origin, religious beliefs, political opinions, trade union membership, data concerning health or sex life, genetic or biometric data when linked to a natural person.
• Usage Data: data collected automatically, generated by the use of the website or services offered by the company, including IP address, browser type, pages visited, and device identifiers.
• Cookies: small pieces of data stored on the user's device. For details, please refer to our Cookie Policy.
• Data Processing Agents: the set comprising the Data Controller and the Data Processor.
• Data Processor: a natural or legal person, of public or private law, that processes personal data on behalf of the Data Controller.
• Data Controller: a natural or legal person, of public or private law, who determines the purposes and means of processing personal data.
• Data Subject: any living individual who is the subject of Personal Data.
• User: an individual who uses the MATILHA website or services.

3. Data Protection Officer Contact

MATILHA has appointed a Data Protection Officer (DPO), and such information shall be transparent and publicly available, accessible to Data Subjects on the company's website and in this document.

The DATA SUBJECT may contact the company's internal data protection resource if they have questions or concerns about policies or practices related to Personal Data, via email at talk@matilha.digital.

4. Data Collection

MATILHA collects different types of information for communication and service delivery purposes. Below is a description of each type of data collected:

Personal Data: when using MATILHA's services, you may be asked to provide personally identifiable information that can be used to contact or identify DATA SUBJECTS. Personally identifiable information may include, but is not limited to: name, email, subject, and message, provided through the website's contact and careers forms.

Usage Data: information about how the service is accessed and used may also be collected. This Usage Data may include information such as the USER's Internet Protocol (IP) address, browser type, browser version, the website pages the USER visits, the time and date of the visit, time spent on those pages, device identifiers, and other diagnostic data, including through analytics and marketing cookies when consented.

The collection and processing of requested data serve the following purposes:

• Enable MATILHA to identify and contact the DATA SUBJECT for commercial relationship and service delivery purposes.
• Enable MATILHA to prepare commercial contracts with the DATA SUBJECT.
• Enable MATILHA to structure, test, promote, and advertise its services, whether or not personalized to the DATA SUBJECT's profile.
• Enable MATILHA to use such data in Market Research.
• Enable MATILHA to use such data in preparing service quotations.
• Enable MATILHA to use such data to facilitate the delivery of services beyond those primarily contracted, provided the DATA SUBJECT also demonstrates interest in contracting new services.
• Enable MATILHA to use such data to maintain a database of market professionals to facilitate contact for future opportunity invitations.
• Enable MATILHA to contact the DATA SUBJECT with newsletters, marketing, or promotional communications.
• Monitor website usage and maintain its availability.
• Detect, prevent, and resolve technical issues on our website or services.
• Improve the User's online experience.
• Digital marketing, including through tools such as Meta Pixel and Google Analytics, when consented.

5. Retention of Personal Data and Sensitive Personal Data

Personal data and sensitive personal data provided will be retained by MATILHA: (i) while the contractual relationship is maintained; (ii) deletion is not directly requested by the USER; (iii) it is necessary to execute contracts and/or legal policies; or (iv) as long as necessary to comply with a legal obligation or for the establishment, exercise, or defense of legal claims.

6. Transfer of Personal Data

Information collected, including Personal Data, may be transferred to and maintained on computers located outside the state, province, country, or other governmental jurisdiction where the DATA SUBJECT is located, where data protection laws may differ from those in force in their jurisdiction, but provide an adequate level of personal data protection as provided for in the Brazilian General Data Protection Law (Law No. 13.709/18) and the GDPR, where applicable.

The DATA SUBJECT acknowledges the possibility of data storage abroad and agrees to it. In the event of storage outside Brazilian territory, there will be an international transfer of data.

MATILHA will take all reasonably necessary steps to ensure that data is treated reliably, securely, and in accordance with this Privacy Policy, and will not allow the transfer of Personal Data to an organization or country unless there are adequate controls in place, including the security of data and other personal information.

7. Data Disclosure

MATILHA may share data pursuant to a court order and with employees/service providers.

8. Data Security

MATILHA is committed to adopting preventive measures against any harm in the processing of its USERS' personal data, using security measures capable of protecting such data from access by any unauthorized third party.

MATILHA, in accordance with regulatory recommendations, uses technical and administrative security measures capable of protecting personal data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication, or any form of inadequate or unlawful processing.

It should be noted that even though MATILHA has reasonable administrative, physical, and electronic security measures to protect collected information against loss or misuse, due to the very nature of the internet, no data transmission over this medium or method of electronic storage can be considered absolutely inviolable by third parties acting unlawfully and targeting controls established by MATILHA. Although MATILHA strives to use all commercially acceptable means to protect personal data, it cannot guarantee absolute security.

MATILHA has acceptable technical standards to apply good governance and information security practices, considering the nature of the information processed, the specific characteristics of the processing, and the current state of technology, especially in the case of sensitive personal data, as well as safeguarding the principles set forth (purpose, adequacy, free access, data quality, transparency, security, prevention, non-discrimination, accountability) in the LGPD.

Information collected by MATILHA will be stored in a secure environment, observing available technical standards, using security policies and technologies such as encryption, access controls, and specific security certifications, and may only be accessed by qualified persons authorized by MATILHA.

9. Data Processing

MATILHA may process DATA SUBJECTS' personal data in the following situations: (i) when the DATA SUBJECT directly permits the processing of their data, expressly consenting to its use; (ii) when used to comply with a legal or regulatory obligation by the Data Controller; (iii) when necessary for the performance of a contract or preliminary procedures related to a contract to which the DATA SUBJECT is a party; (iv) when necessary for the company to fulfill an offer, contact, or send documentation requested by the USER; and (v) when processing is based on the legitimate interest of the Data Controller and does not override rights or violate the DATA SUBJECT's personality rights and civil liberties.

10. Responsibilities, Rights and Duties of the Parties

Personal data processing carried out by MATILHA will observe all principles set forth in Law No. 13.709/2018 (Brazilian General Data Protection Law), always acting in good faith.

MATILHA will guarantee USERS, as personal data subjects, free, facilitated, and cost-free access to and consultation of their personal data.

MATILHA will store proof that DATA SUBJECTS consented to the processing of their personal data, as it bears the burden of proof of such fact.

MATILHA is committed to maintaining a record of all personal data processing operations it performs.

In the event of consent withdrawal or exercise of the right to erasure by the USER, personal data will be kept blocked during legally established periods.

Any security incident affecting USERS' personal data that may entail relevant risk or harm will be communicated to Data Subjects by MATILHA.

Any information that DATA SUBJECTS provide will be collected and stored according to strict security and confidentiality standards.

Personal information passed to MATILHA will be collected by ethical and legal means and may have one or more purposes.

MATILHA will take reasonable measures to allow the DATA SUBJECT to request correction, inclusion, alteration, erasure, anonymization, blocking, or limitation of the use of their personal data by contacting talk@matilha.digital.

The DATA SUBJECT shall have all rights provided for in Article 18 of the LGPD:

• Right to request confirmation of the existence of processing of their Personal Data and how such processing is carried out.
• Right to access the information MATILHA holds about the DATA SUBJECT, in a structured and accessible format.
• Right to correct their information if it is inaccurate, incorrect, and/or incomplete.
• Right to anonymization, blocking, or erasure of unnecessary, excessive, or unlawfully processed data under the LGPD.
• Right to object to the processing of their personal data.
• Right to information about public and private entities with which the Data Controller has shared their data.
• Right to data portability to another service or product provider, upon express request.
• Right to withdraw their consent at any time.
• Right to request the erasure of their Personal Data from MATILHA's systems.
• Right to information about the possibility of not providing consent and about the consequences of refusal.
• Right to request review of decisions taken solely based on automated processing of personal data that affect their interests.

Personal data processing carried out by MATILHA will terminate in the situations provided for in Article 15 of the Brazilian General Data Protection Law, at which point personal data may be erased after processing ends, subject to periods during which data must be archived, as provided in Article 15 of the Brazilian Internet Civil Framework (Law No. 12.965/14).

11. Service Providers

MATILHA may employ third-party companies and individuals to facilitate its service and perform services related to its operations. These third parties have access to DATA SUBJECTS' Personal Data strictly and solely to perform these tasks on MATILHA's behalf, and are obligated not to disclose or use them for any purpose other than those explicitly highlighted in this policy.

Among the providers used by the matilha.digital website are: Meta (Meta Pixel), Google (Google Analytics, when active), Hostinger (email delivery via SMTP), Vimeo (video embedding), and Cloudflare (region detection for language preference).

12. Sharing

This MATILHA privacy policy does not cover the privacy practices of suppliers and third parties with whom data is shared, as they are separate and independent legal entities. However, MATILHA makes efforts to encourage these companies to comply with such policies, always choosing to work with companies that care about secure and transparent personal data processing.

MATILHA will not communicate or share data with third parties unless necessary to enable registration, access, and use of the website, as well as in situations requiring third-party intervention for the delivery of the company's services.

MATILHA may communicate and share Users' personal data with employees, partners, servers, and software used in the execution of its services.

13. Links to Other Sites

MATILHA's website may contain links to other sites not operated by us, such as social networks, WhatsApp, and Google Maps. If the USER clicks on a third-party link, they will be directed to the third-party site. We strongly recommend that the USER review the Privacy Policy of all sites they visit, as MATILHA has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

14. Children's and Adolescents' Privacy

The processing of personal data of children and adolescents will be carried out in accordance with the understanding of Article 14 of the Brazilian General Data Protection Law (Law No. 13.709/2018).

If any personal data of children is collected without verification of parental consent, MATILHA will take measures to remove such information from its servers.

15. Changes to this Privacy Policy

MATILHA reserves the right to change this Privacy Policy from time to time, publishing its new version on the MATILHA website and informing users of any changes, and the DATA SUBJECT must consent again to the new conditions when applicable.

DATA SUBJECTS are advised to review this Privacy Policy periodically.