Privacy Policy

1 Definitions

QUALISIGN PORTAL: it is the system made available through the internet, whose electronic address is https://qualisign.com.br or https://qualisign.com.br,including the Personalizaed Sites, with all its pages, resources and tools;.

PERSONALIZED SITE: it is the QualiSign Portal, customized with the visual identity defined by the client;

QUALISIGN: is the company QualiSign Informática S.A., responsible for the licensing, operation and management of the QUALISIGN PORTAL.

USER(S): an individual to whom the Personal Data (Data holder) refer that are subject to treatment and, therefore, who will use the services offered by th QUALISIGN PORTAL;

Personal Data or Information: information directly or indirectly related to the individual, able to identify or make it identifiable;

Applicable Laws: the LGPD Data - Act no. 13,079/2018 and other Brazilian laws and regulations applicable to the protection of Personal Data (including the Consumer Protection Code - Act No. 8,078/1990 and the Civil Internet Benchmark - Act No. 12,965/2014), and further, with regard to what is applicable, the General Data Protection Regulation (“GDPR”) of the European Union;

Controller: an individual or legal entity, of public or private law, who is responsible for decisions regarding the processing of Personal Data;

Operator or Processor: individual or legal entity, under public or private law, who carries out the processing of Personal Data on behalf of the Controller;

Treatment: any operation performed with Personal Data, such as the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, disposal, evaluation or control of information, modification, communication, transfer, diffusion or extraction;

Consent: it is a free, informed, prior and unequivocal manifestation, in writing or other means, which demonstrates the manifestation of will.

2 Collected Information

2.1 How we obtain Personal Information from our USERS

2.1.1 The QUALISIGN PORTAL collects Personal Information capable of identifyin USERS whenever they:

a.) access our pages through our URLs

b.) sign up at the QUALISIGN PORTAL;

c) interact with the various tools existing at the QUALISIGN PORTAL, providing Personal Information voluntarily;

d) use our Mobile Apps, provided directly by QUALISIGN or through third party services like Google or Apple;

e) fill in “offline” records, such as forms distributed during events and other interactions with QUALISIGN;

f) make payments for services provided by the QUALISIGN PORTAL;

g) get in touch with QUALISIGN pthrough its various service channels, including the “Contact Us” channel, electronic mail service and instant messaging systems;

h) voluntarily provide information to third parties, including, but not limited to, social networks and third-party sites such as Facebook, Instagram, LinkedIn, and the like, data adding services, QUALISIGN partners and public sources.

2.1.2 For each type of data collection, different information may be requested, according to the purpose of its collection. Thus, USERS will always be informed about the data being collected, it is up to them to provide it or not, and, depending on each case, they will also be advised of the consequences of their decision.

2.1.3 All Personal Data collected is incorporated into the database of the QUALISIGN PORTAL, becoming available for USERS to exercise any of their rights expressed in Applicable Laws.

2.2.1.4 Credit or debit card numbers provided by USERS are used only for processing payments for services provided by theo QUALISIGN PORTAL, not being stored in a database

2.1.5 QUALISIGN can confirm the Personal Data provided by the USER, by consulting public agencies, specialized companies, databases or risk centers. The information that QUALISIGN obtains from these entities will also be treated confidentially. These protection measures do not cease or diminish the responsibility of the USER as to the accuracy and veracity of the data it provides, which is why QUALISIGN may, in its sole discretion, suspend and/or cancel the registration of the USER, at any time, if any inaccuracy is detected.

2.1.6 If the USER's registration has been carried out by a relationship of this USER (QUALISIGN PORTAL, client and Data Controller) the Personal Data provided will be required, used and/or treated strictly to meet the purpose that QUALISIGN proposes in contract with this client.

2.2 What Personal Information We Collect

2.2.1 Identification Information: information that identifies the USER, specifically full name and CPF, to allow the use of the features offered by QUALISIGN PORTAL;

2.2.2 Login information: information for identification and authentication of the USER> in the services offered by QUALISIGN PORTAL, such as “User-ID”, password and security questions;

2.2.3 Contact Information: information that can facilitate our contact with the USER, specifically your email address and your phone number(s). Refer to details in the section named “Submitting Notifications and Advertising Messages”;

2.2.4 Technical information about USER computing equipment or mobile devices: details about your computer or other portable device that was used to access one of our websites, services or applications, including the record of the IP address used to connect your computer or device to the internet, your geographic location, the type and version of the operating system, and the type and version of the web browser;

2.2.5 Navigational information: information about how the USER> uses our sites and services, obtained during its interaction with our sites and services. This can include details such as which links were clicked, which pages or content were viewed and for how long, and other similar information and statistics about your interactions. This information is captured using automated technologies, such as Cookies (Browser Cookies, Flash Cookies and the like) and web beacons, as well as via third-party tracking. You have complete freedom to oppose the use of such technologies, for this see the details, in the section "Obtaining Navigational Information".

2.3 Why we collect Personal Information from our <2.2.3>USERS

2.3.1 At the QUALISIGN PORTAL the privacy of you USERS is treated with the highest priority. There is a commitment to keep Personal Information in the most complete secrecy, linking it only to your registration and using it only for the following purposes:

a.) Provide USERS with secure means so that they can perform the functionalities of the QUALISIGN PORTAL, such as creating, signing, consulting and storing Electronic Documents.

  Reasons for using Personal Data in this situation
  • Comply with contractual obligations;
  • omply with legal obligations;
  • Our legitimate interests:
    - Continuously improve QUALISIGN products and services;
    - Continuously improve the effectiveness of our customer service.

b.) Respond to questions and requests from USERS through our USER service channels;

  Reasons for using Personal Data in this situation:
  • Comply with contractual obligations;
  • omply with legal obligations;
  • Our legitimate interests:
    - Continuously improve QUALISIGN products and services;
    - Continuously improve the effectiveness of our customer service.

c.) Enable a commercial interrelationship between QUALISIGN and USER, enabling the offer and collection of products and services by the QUALISIGN PORTAL;

Reasons for using Personal Data in this situation:
• Comply with contractual obligations;
• We obtained the consent by the USER (when necessary).
• Our legitimate interests:
  - Understand which of our products and services may interest you and provide information about them;
  - Define consumers for new products or services.

d.) Develop internal studies on interests, behaviors, demographics of users, to better understand their needs and interests, improving usability and the interactive experience during the USER's navigation at the QUALISIGN PORTAL, making it possible to offer them better products and services;

Reasons for using Personal Data in this situation
• We obtained the consent by the USER (when necessary).
• Our legitimate interests:
- Understand which of our products and services may interest you and provide information about them;
- Define consumers for new products or services.

e.) Conduct research and communication and relationship marketing campaigns, as well as publicize offers of products and services by electronic mail, via direct mail, SMS (text message) or other means of communication;

Reasons for using Personal Data in this situation:
• We obtained the consent by the USER (when necessary)
• Our legitimate interests:
  - Understand which of our products and services may interest you and provide information about them;
  - Define consumers for new products or services.

f.) Provide USERS personal information to entities that intervene in the resolution of disputes, such as Arbitration Courts, Conciliation Chambers or other competent courts to resolve such disputes.

Reasons for using Personal Data in this situation:
• Comply with contractual obligations;
• Comply with legal obligations;

2.3.2 To access some sections of the QUALISIGN PORTAL USERS must fill out a form, in which they will provide some Personal Information and, when applicable, information from the legal entity they represent. This record is stored in a protected and confidential database.

2.3.3 The information requested by the QUALISIGN PORTAL to its USERS are the minimum required for the QUALISIGN PORTAL to be able achieve its main purpose, namely, provide its USERS with secure means so that they can create, sign, query and store Electronic Documents.

2.3.4 When a registration is made, QUALISIGN will have full access to it and the right to use it, always in accordance with the policies established in this document and with the Applicable Laws. After registration, a USER will be able to enjoy and enjoy the benefits of a registere USER at the QUALISIGN PORTAL.

2.3.5 A QUALISIGN will not provide USER's Personal Information without their proper authorization, unless such information is necessary to provide the service requested by the USER themselves, or even in the event that the USER's Personal Information is required for legal reasons. QUALISIGN will take all possible measures to maintain the confidentiality and security for the USER's, information, however, it does not account for any damage that may result from the disclosure of such information by the aforementioned reason.

2.4 Obtaining Browsing Information

2.4.1 In order to provide increasingly better services, the QUALISIGN PORTAL also receives and automatically stores on its servers information about the navigational profile of itsUSERS, including:

IP ADDRESS

The Internet Protocol (IP) address is a unique number assigned to each computer connected to the Internet, similar to a phone number) and other data from the connection to your computer are used to gather a series of information. These aggregated data make it possible to better understand how USERS use the QUALISIGN PORTAL.

COOKIES

The QUALISIGN PORTALN uses a technology called a cookie - small files stored in the USER's Internet browser that help to profile them. The cookies at the QUALISIGN PORTAL do not capture personally identifiable information, and the information obtained is not shared with third parties.

Cookies are used so that the QUALISIGN PORTAL recognize the USER's profile and can thus send them specific content and according to their needs and interests. It is important to say that cookies do not run programs or infect computers with viruses and can only be read by the QUALISIGN PORTAL systems.

Cookies will never be used to control or identify the USER, except when they disrespect a security rule or performs any activity that is harmful to the proper functioning of the QUALISIGN PORTAL such as, for example, attempts to hack into services or the QUALISIGN PORTAL. The purpose of installing cookies is to benefit the USER> who receives them.

Any cookie, whether from the QUALISIGN PORTAL or from other portals, can be later deleted by the USER using the tools of the Internet browser (browser). The vast majority of browsers can be configured to refuse to receive cookies. Procedures for this can be found in the browser's manuals.

If the USER chooses not to receive cookies, it is possible that the USER> will not be able to fully access the content of the QUALISIGN PORTAL, benefits, personalizations, services and facilities. In any case, if the USER chooses not to accept the receipt of cookies, access to areas of the QUALISIGN PORTAL where cookies are not strictly necessary.

2.5 Sensitive Personal Information and Children and Adolescents

2.5.1 The QUALISIGN PORTAL and QUALISIGN do not voluntarily request, collect, process, store or share sensitive Personal Data or Personal Data of minors and children. In case QUALISIGN detects the occurrence of any type of handling of said data, these data will be removed from the QUALISIGN PORTAL database in the shortest possible time

2.6 Data Retention

2.6.1 The registration information provided by the USER in the QUALISIGN PORTAL will be kept for an indefinite period of time or until the USER deletes it or requests its deletion

2.6.2 In certain cases, the exclusion of Personal Data that belong to the USER can only be carried out with the exclusion of all documents associated with this USER and their respective registration in th QUALISIGN PORTAL, with the consequent cancellation of the services provided.

2.6.3 If the registration of the USER has been carried out by a third party of your relationship (cliente do QUALISIGN PORTAL's customer and Data controller), the USER> must directly request this third party to provide for the revocation of consent and/or exclusion of their data in the QUALISIGN PORTAL.

3 User's rights regarding the personal information provided

23.1 Once registered in the QUALISIGN PORTAL, USERS can, at any time, through the tool offered by the QUALISIGN PORTAL, access, review, change and print the information provided during the registration process. We emphasize that QUALISIGN requests the validation of one's identity by using, for example, a login system with access password or similar resource, before allowing access or modification of USER's Personal Data, thus ensuring that there is no unauthorized access to any account and associated Personal Data. These features can also be requested through the communication channels detailed in the “Contacts” section of this policy.

3.2 A USER may also request details about the origin of their Personal Data, the treatment performed on them or any sharing of this data with third parties.

3.3 At any time, a USER may also limit the use and disclosure, revoke consent to any of our activities for processing your Personal Data, or even request the deletion of their Personal Data, except in situations provided for in current legislation.

3.4 We emphasize that, in certain cases, it is not possible to delete USER's Personal Data without also excluding the documents associated with this USER and their respective registration at th QUALISIGN PORTALN, with the consequent cancellation of the services provided.

3.5 If the registration of the USER has been carried out by a third party of your relationship QUALISIGN PORTAL's customer and Data controller), the USER must directly request this third party to provide for the revocation of consent and/or exclusion of their data in th QUALISIGN PORTAL.

3.6 All the requests described above, including those made available by QUALISIGN PORTAL, itself, can be made through the communication channels detailed in the “Contacts” section of this policy, being necessary to validate one's identity, once the registered USER’s data is checked, and/or by identification codes means, in accordance with the legislation in force. We emphasize that any identifying information provided to QUALISIGN will only be processed in accordance with, and to the extent permitted by the Applicable Laws

3.7 A QUALISIGN does its best to be able to answer all questions that USERS may have about the way in which we process their Personal Data. However, if a USER has unresolved concerns, the USER has the right to complain to the relevant data protection authorities.

4 Data protection and privacy

4.1 A QUALISIGN strives to provide the highest levels of security and confidentiality of the information it collects. However, it is known that no data is 100% secure on the Internet. Therefore, although QUALISIGN will always use its best efforts to protect USER, Personal Information, it is not possible to fully guarantee the security of all information that a USER may provide, which makes using the service under these conditions a personal decision made by the USER. However, QUALISIGN undertakes to inform the USERS and the relevant authorities of any occurrence of a security incident that may cause a relevant risk or damage to the USERS, responding for the event as provided by the Applicable Laws.

4.2 QUALISIGN professionals are aware of this policy and only qualified and authorized personnel are allowed to access USER's Personal Data collected by the PORTAL QUALISIGN.

4.3 QUALISIGN requires from suppliers, partner companies and service providers the guarantee of data protection and privacy ensured in this policy and in the Applicable Laws, whenever there is a need to share them.

4.4 b>USER's information and registration data are not passed on to third parties, but are used for the collection of statistical data, as well as for the identification of the USER’s profile, their wishes and needs. The USER’s email address will be used for sending notifications and express communications from the PORTAL QUALISIGN.

4.5 AThe disclosure of data and information to business partners for those with whom QUALISIGN maintains confidentiality agreements, is done only with the USER’s express authorization.

4.6 In certain cases QUALISIGN may keep USER's, Personal Data in its files, even if it has been requested to be removed, with a view to use in the possible resolution of disputes or complaints, as well as to detect problems or incidents, solve them and comply with the provisions of the Terms of Use, always in accordance with the Applicable Laws.

5 Security Procedures

5.1 The QUALISIGN PORTAL and the QUALISIGN have the most modern security measures to protect USER'sO, Personal Information, restricting access to it only by authorized personnel. All measures are taken to protect one’s Personal Information from interception, misuse and adulteration, among other undesirable or even illegal practices that can occur on the Internet. When information about a USER is transmitted, this is done in a secure environment, in which the data is encrypted (encryption is the name given to the information encoding process). The information is encrypted (scrambled) at the source and decoded at the destination, thus making it difficult for the information that travels over the Internet to be deciphered. The “Closed Padlock” icon, located in the status bar (bottom right of the USERbrowser), indicates that the information will be encrypted. Any USER will also be able to identify security with the URLs of secure pages from the https nomenclature before the domain, for example: https://www.qualisign.com.br/xxxx

5.2 It is the USER's responsibility to keep their User ID (User-/Login) and the respective Access Password. It is not appropriate to use obvious passwords such as dates of birth, names or numeric strings. A password should contain special alphanumeric characters (letters and numbers). It will be up to the USER to change their access password periodically. If the USER becomes aware or just suspects that their password has been discovered, they must change it immediately. USERS are solely responsible for keeping their password confidential and for any action taken through their account on the sites and services provided by the QUALISIGN PORTAL.

5.3 As a way of increasing the security and protection of the data of its USERS, the QUALISIGN PORTAL enables access to be made through the ICP-Brasilo Digital Certificate.

5.4 A USER should avoid using shared or public computers to use QUALISIGN PORTAL, resources, as well as accessing it through any untrusted network, such as public networks, for example.

5.5 The USER should regularly query the information provided by the QUALISIGN PORTAL on security, located at https://www.qualisign.com.br/dicas-de-seguranca

6 Sending notifications and advertising messages

6.1 The QUALISIGN PORTAL can send notifications and advertising messages to USERS using all available technologies and means of communication, whether by email, SMS, MMS, direct mail and others.

6.2 All newsletters (electronic newsletters) and advertising messages sent by e-mail will always have the option of canceling the submission of that type of message by the QUALISIGN PORTAL. The cancellation will be fulfilled in the minimum time necessary to carry out this request. The cancellation is made through the USER's Identification. Therefore, USERS who have more than one registration may continue to receive communications and/or advertising messages in e-mails from USERS that have not been unsubscribed.

6.3 Messages and notifications related to the QUALISIGN PORTAL business (technical problems, charges etc.) cannot be canceled, thus ending only once the USER's registration is cancelled at the QUALISIGN PORTAL.

6.4 Messages sent in HTML format may contain codes that enable the customization of messages according to the individual preferences selected by the registered USER at QUALISIGN PORTAL and prepare reports on message viewing, the number of times the email was opened and the number of clicks on the message. This information will be used in a generic way and will be added to produce reports on the submission of messages. These reports may be passed on to third parties, as statistical indicators of the effectiveness of campaigns or notifications, without revealing USERS' Personal Information. In no event will the QUALISIGN PORTAL disclose these data in an individualized way, that is, there will be no identification of the USER or their habits when accessing and reading e-mails. Although collectively, the data can only be used for the purposes set out in this Privacy Policy.

7 Links with other portals

7.1 Once at the QUALISIGN PORTAL, the USER may be taken, via link, to other portals. USERS should keep in mind that these other portals are collecting their Personal Information and have their own confidentiality and privacy policies USERS should be aware of the fact that when addressing such portals outside the QUALISIGN PORTAL, all the information they exchange will be not be able to be controlled by the QUALISIGN PORTAL and, consequently, it will be outside the responsibility incumbent upon QUALISIGN.

8 Veracity of information and data provided by USERS

8.1 O USERS guarantee and are responsible for the veracity, accuracy, validity and authenticity of the information and data that they may provide to the QUALISIGN PORTAL, assuming the corresponding responsibility if they are not accurate, and undertake to keep them duly updated. Consequently QUALISIGN has no responsibility in case of insertion of false data or inaccuracy of the data reported.

8.2 Any USER who registers at the QUALISIGN PORTAL using data from third parties may incur the crimes of false identity and fraud, both provided in the Brazilian Penal Code, without prejudice to any liability arising from a specific legislation.

8.3 The QUALISIGN PORTAL, given the nature of its business, requires from its USERS the legal capacity. Therefore, it will not be allowed, under any circumstances, to register individuals who have not yet reached the due legal age.

9 Changes in the Privacy Policy

9.1 In order to constantly improve and improve it, QUALISIGN may change this Privacy Policy at any time.

9.2 Any and all changes to this Policy will be immediately posted at the QUALISIGN PORTAL.

9.3 As they use the QUALISIGN PORTAL services, USERS agree and accept the terms of this Privacy Policy, and they should check it in advance every time they visit th QUALISIGN PORTAL.

10 General provisions

10.1 This Privacy Policy is an integral part of the Terms and Conditions of Use of the QUALISIGN PORTAL.

11 Cout

11.1 The jurisdiction of the District of São Paulo, State of São Paulo, is elected as competent to settle any disputes arising from this Privacy Policy, regardless of any other, however privileged it is or may be.

12 Contact info

To obtain more information, make any complaints or suggestions, answer questions or request any of your rights, we request that you contact QUALISIGN through one of the following channels:

• Via our “Contact Us” channel through https://www.qualisign.com.br/fale-conosco
• Through [email protected]
• By telephone, via +55 11 5906-7200
• In person or by mail, at Rua Correia Dias 337 - 2th floor - Paraíso - São Paulo/SP, ZIP CODE 04104-001