Privacy Policy

1. SCOPE

This Policy applies to all users of the Site, and your personal data is collected whenever you:

• Visit or interact with the Neugebauer Site;
• Contact us through our service channels (site tabs: contact).

2. INFORMATION WE COLLECT

Important: You are not required to provide us with your information; however, without obtaining certain information when requested, you will not be granted access to some features. In addition to the data you provide us, whenever you interact with our Site, information will be collected automatically. Such information is generally not identifiable; however, when combined with other data, generating the ability to associate it with you, it will be treated by Neugebauer as personal data.

The nature and purpose of the personal data we collect may differ according to the area of the Site accessed (for example, whether you provide your data to apply for a job or simply when you contact us).

Within the limits permitted by applicable law, Neugebauer may process the following personal data provided by you:

• Information you send through the Contact tab: name and email address;
• Information you send to express interest in reselling our products: your name, telephone, email address, name and identification data of your company (CNPJ, state and city).

As previously stated, Neugebauer may automatically collect the information listed below, even if you have not previously sent us the data described above:

• Information collected when you access the Site: information related to the User's device, operating system, internet browser used, details about how you used the Neugebauer Site (which pages of the Site were visited; the order in which they were visited; which links were clicked), IP address or other unique identifier (Device Identifier), dates and times of access, hardware and software information, cookie data, and the pages you viewed or interacted with before and after accessing the Site.
• Cookies and similar technologies: in accordance with our Cookie Policy.

Note that the personal data listed above will be collected by Neugebauer and subsequently processed only as necessary to achieve the purposes set forth herein.

We do not intentionally collect, store or otherwise process excessive or unnecessary personal data for the purpose that gave rise to its collection, data considered sensitive (those relating to racial or ethnic origin, religious conviction, political opinion, union membership or membership in religious, philosophical or political organizations, health or sexual orientation, as well as genetic data) and data of minors without the consent of their guardian. Therefore, we ask that you refrain from sharing such data with us. If we become aware that such data has been inadvertently collected and processed, it will be deleted from our records.

3. LEGAL BASIS FOR PROCESSING PERSONAL DATA

The classification of the legal basis for the data stored and processed by Neugebauer listed in Section 2 occurs through analysis of the specific context in which we collect it.

Data processed by Neugebauer tends to be collected only:

• With your consent;
• For the regular exercise of rights in judicial proceedings;
• When the processing of personal data is in accordance with the legitimate interests of Neugebauer, always with attention to your interests related to data protection or fundamental freedoms and rights. There will also be a need to process your data to protect your interests or those of third parties.

4. PURPOSE OF DATA COLLECTION

The collection of information has the sole and exclusive objective of maintaining and improving the services made available to provide you with a better experience. Thus, as necessary, the information collected will be used for the following purposes:

• To address any questions and requests for information about Neugebauer;
• To contact you regarding your request through the Contact tab;
• To respond to your expression of interest in becoming a reseller of our products;
• To improve our Site;
• To forward to government authorities when the request is made through subpoenas, court orders or other legal processes to establish or exercise our legal rights or protect our property;
• To defend ourselves against legal claims or as required by law;
• To investigate, prevent or take action regarding illegal activities, suspected fraud or situations involving potential threats to the physical and technological safety of any person and of Neugebauer, or as otherwise legally required, within the limits permitted by applicable law.

5. SHARING OF PERSONAL DATA

When necessary to achieve the purposes described in Section 4, Neugebauer may share your personal data with the third parties listed below in order to ensure the proper provision of the services offered, the security of storage of your personal data, and a better experience with Neugebauer. Whenever carried out, the sharing of data will be performed within the limits and purposes of our business, in compliance with the purpose of the processing of personal data and in accordance with applicable law. Thus, your data may be shared with:

• Providers of computing services, information technology and service providers focused on ensuring information security within our Site;
• Tax authorities and governmental, police, public and judicial bodies for the purpose of responding to complaints, investigations, judicial measures and legal proceedings; as well as complying with legal, regulatory and tax obligations.

6. RIGHTS OF PERSONAL DATA HOLDERS

In the manner and within the limits of applicable law, you, as the personal data holder, may contact us to exercise your rights, in order to request:

• confirmation of the existence of processing of your personal data;
• access to your data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of data that is unnecessary, excessive or processed in non-compliance with applicable law;
• the portability of your data to another service or product provider, observing commercial and industrial secrets;
• the deletion of your personal data, except in the cases provided for by applicable law, for the exercise of rights pertaining to Neugebauer and for compliance with legal requirements;
• information about the public and private entities with which Neugebauer has shared your data;
• information about the possibility of not providing consent and about the consequences of refusal;
• the revocation of your consent, when you have provided it, safeguarding the public interest that may justify the continuation of processing or the existence of another legal basis that authorizes it; and
• opposition to any processing of personal data based on one of the cases in which your consent is waived, provided that there has been non-compliance with applicable law and safeguarding the public interest that may justify the continuation of processing.

Your request may be made free of charge through the Privacy Center located on our Site. We will analyze your request and respond as soon as possible, considering the deadlines and terms provided for in applicable law. If it is not possible to immediately fulfill your request, we will indicate the reasons of fact and law that prevent us from doing so.

Neugebauer is not responsible for the correction, veracity, authenticity, completeness and updating of the data provided by the Holder, nor for any improper use of information published by the Holder or for fraud.

It is your sole responsibility to provide only correct, true, authentic, complete and up-to-date information, as well as to safeguard the confidentiality of your password, when applicable, not disclosing it to third parties.

7. HOW WE STORE AND PROCESS PERSONAL DATA

Neugebauer keeps the personal data collected in a controlled and secure environment to meet specific purposes, as set out in Section 4. The personal data collected is kept confidential, with strict access control through authentication mechanisms.

Neugebauer adopts security, technical and administrative measures to keep all stored data secure. Specifically with regard to the data collected through our Site, it is stored, processed and protected using the best hosting, processing and backup practices, according to its respective criticality.

Even so, the Holder must be aware that no security system on the Internet is guaranteed against unwanted intrusions, and Neugebauer's commitment is limited to adopting protective measures recommended in accordance with the current state of the art.

8. INTERNATIONAL TRANSFER OF PERSONAL DATA

Neugebauer may transfer some of your personal data to service providers and partners located abroad, including cloud service providers. When your personal data is transferred outside of Brazil by Neugebauer, we will take appropriate measures to ensure the proper protection of your personal data in accordance with the requirements of applicable data protection laws, including by entering into appropriate data transfer agreements with third parties when necessary.

9. INFORMATION RETENTION PERIOD

We store and retain your information: (i) for as long as required by law; (ii) until the end of the processing of personal data, as mentioned below; (iii) for as long as necessary to preserve Neugebauer's legitimate interest, as the case may be; (iv) for as long as necessary to safeguard the regular exercise of Neugebauer's rights in judicial, administrative or arbitration proceedings. Thus, we will process your data, for example, during applicable statute of limitations periods or while necessary to comply with a legal or regulatory obligation.

The processing of personal data will end in the following cases:

• When the purpose for which the Holder's personal data was collected has been achieved and/or the personal data collected ceases to be necessary or relevant to achieve such purpose;
• When the Holder is entitled to request the end of the processing and deletion of their personal data and does so; and
• When there is a legal determination to that effect.

Observing the principle of necessity, some data sent through the Site may be deleted from our records through the maintenance of routine records. We are not obliged to store personal data indefinitely and we disclaim any responsibility arising from or related to the destruction of such personal data.

Upon termination of the processing of your personal data, except for the cases established by applicable law or by this Privacy Policy, it will be deleted from the Neugebauer database. If deletion is not possible at first, the data will be securely stored and isolated from any further processing until deletion is possible.

10. TERM AND CHANGES TO THE POLICY

Our Site, in whole or in each of its tabs and sections, may be terminated, suspended or interrupted unilaterally by Neugebauer at any time and without prior notice, in which case we will inform you where the information contained therein will be made available, the access to which is your right in accordance with current legislation.

This Privacy Policy may be updated or changed at any time, with the changes being highlighted on our website.

11. COMMUNICATION POLICY

We seek to avoid sending unsolicited emails, restricting communications with you to matters that are relevant or of your specific interest.

When you send us your data, we may contact you through the means of communication informed therein.

You should be aware that many fraudsters try to take advantage of traditional brands to obtain personal information such as passwords and financial data. NEUGEBAUER WILL NEVER REQUEST YOUR FINANCIAL DATA THROUGH EMAIL OR TELEPHONE CONTACT. IN CASE OF ANY OTHER SUSPICIOUS BEHAVIOR, FORWARD YOUR QUESTION OR ALERT BY EMAIL TO privacidade@neugebauer.com.br

12. CONNECTIONS (LINKS) TO OTHER SITES

Our Site may contain links or frames to other sites. These links or frames seek to provide additional benefits to the content and services offered to the User.

We clarify that the inclusion of these links on our Site does not mean that Neugebauer is aware of, agrees with or is responsible for the content of such links and frames. It is important to emphasize that our objective is to only make available links or frames to reputable and reliable companies. Neugebauer is not responsible for the information, products and services obtained by the User on the referred sites, nor for the commercial practices and privacy policies adopted by such companies, and Neugebauer cannot be held liable for any losses and damages or lost profits suffered as a result of the use of these resources.

To the extent that the linked sites are not part of our Site, we do not control, recommend or endorse these sites and their contents, products, services, policies and privacy practices; we do not have access to your personal data collected and processed by them or to their advertising, cookie and terms of use policies. Therefore, we recommend that you carefully read these documents on third-party sites.

By accessing our Site and interacting with us, you agree and accept the terms set forth herein.