1 .Privacy Policy

1.1 Where are personal data collected?
1.2 What is the reason for collecting data?
1.3 The Legal foundations that guide data collection
1.4 What types of data are collected by Alto Giro and how will it be used?
1.4.1 Website Users
1.4.2 Regarding the interest (Leads) demonstrated by the User
1.4.3 How will your data be used?
1.5 We will not share your data!
1.6 The provided data is highly personal and owned by you!
1.7 Your data will be stored for a period!
1.8 Your security in the digital environment
1.9 Our contact
1.10 Regarding constant evolution

Alto Giro is committed to the information security of its customers regarding the data and information collected. For this reason, we present our privacy and security policy, which aims to clarify the use of this information. Browsing the Alto Giro website implies full and unrestricted acceptance of the practices described in this privacy policy.

1 Privacy Policy

First of all, it is important to highlight that your information is of immeasurable value to us at Alto Giro, and, for this reason, our objective is not only to make your information available in a secure and responsible manner, but, especially, to respect your opinion. Therefore, browsing our website, using our mobile platform, being logged into our secure environment, providing information physically in our stores, and any collection of personal data, does not necessarily imply transmitting all your data to us. Instead, we clarify that it is up to you to authorize us to process only the personal information you wish. On the other hand, it is important to emphasize that the collected information, which must always be authorized by you, not only facilitates the use of our entire physical and virtual platform, but also provides you with a more pleasant and personalized experience. It is worth considering that Alto Giro's commitment is to safeguard your privacy and protect your personal data. For these reasons, the primary objective of this document, in addition to respecting your choices, is to:

• Clarify what information may be collected from our users;
• The purpose of collecting such information; and,
• When Alto Giro may use such information;
• Reiterate the commitment to the storage and maintenance of your personal data, which will not be shared with any legal entity other than those of the same Economic Group, as well as service providers who aim to protect your data, prohibiting any disclosure of the same to third parties unrelated to the activity carried out by Alto Giro;

It should also be noted that this document also serves as an essential component of the Website's Terms of Use, which defines the concept of our digital environment. It is extremely important to emphasize that our Privacy Policy will be observed whenever you use our online or offline services, which may request the collection of Personal Data. For the maintenance of our activities, our user service channels include: websites, including access to the user's secure area while logged in; applications; social media, which, although third-party, we are allocated there; customer service, whether via the world wide web, or through telephony and/or mobile data messages; physical points of sale; and even sponsored events. Acceptance of our Privacy Policy will occur:

• When you register on our website and/or use an Alto Giro owned application, whether or not making any purchase; or,
• When you access any social media and applications, including via emails and/or applications such as WhatsApp and similar, where Alto Giro is allocated, although owned by third parties; or,
• When you provide your data in person at our stores and/or sponsored events; or,
• When you provide your data in our telephone services; or,
• When you provide your data in our mobile phone message and/or world wide web services.

Although acceptance of our Privacy Policy occurs in the cases above, it is important to reiterate our commitment not only to the secure storage and maintenance of your personal data, but, especially, to respect your choices, and, therefore, only the data you authorize us to collect will be collected, with the exception, however, of mandatory cookies, which do not collect personal information, but only essential data for the functionality of the digital environment. On the other hand, it is important to emphasize that your choices can also extend to not accepting our Privacy Policy, which, we reiterate, does not offend any unauthorized data access. But, even so, in this case, if there is no acceptance, we will not be able to provide you with our products in a personalized way. Notwithstanding this, if there is a disinterest in agreeing to our Privacy Policy, we ask you to inform us, and we will aim to clarify all points that may seem dissonant, in order to then formalize a lasting partnership. Ultimately, it is worth noting that Alto Giro seeks to create an open and easy-to-understand channel for you, the user, and recipient of this document, and, therefore, although in the notes below we will seek to clarify important points, such as the types of data eventually collected, forms of storage, among others, we are already available to clarify doubts, even if there is no express connection to this Privacy Policy.

1.1 Where are personal data collected?

It is important to list that the objectives for the collection of personal data, as a rule, are subdivided into 02(two), the first of which concerns the essentiality of the information for the adequate functioning of a system, and, in this case, we speak of essential and anonymous data. And, secondly, the collection of data, which may or may not be anonymous, whose purpose is the personalization of a pleasant environment closer to what the user desires. As a consequence of the observation above, it is understood that essential and anonymous data will always be informed, and personal data, which can be safely and definitively anonymized, may be collected for a better experience and even the adequate functioning of the system. Personal data may be collected in the following user interactions with Alto Giro:

• Website: Internet pages aimed at the user, with domain owned by Alto Giro, registration by email, or even third-party social media, which, although owned by others, Alto Giro is allocated there, such as: Facebook, Instagram, Twitter, etc.;
• Website and Mobile Applications: Website or mobile applications for smartphones and/or mobile devices owned by Alto Giro and/or third parties;
• Ads stored in third-party environments: Alto Giro, through direct or indirect advertising actions, produces ads in digital environments, and the user, by "clicking" on these ads, will enable access to anonymous data capable of interacting in a personalized way;
• Collected and interpreted data: Our continuous interaction allows us to better understand your choices and opinions, and, in this way, through anonymized or non-anonymized data, we can interpret your choices and personalize information that may be useful for your decisions;
• Data collected physically: Alto Giro, through direct, promotional or non-promotional actions, in its network of stores, partner retailers, or even in the promotion of its own or third-party events, may collect data physically, through registration forms without a specific format.

Regarding the content of Alto Giro that may eventually be shared by the user on social networks, we emphasize that such publication is made by the user, and therefore, Alto Giro has no control, as the user will be using their profile for such publication, and Alto Giro has no control over this dissemination of data.

1.2 What is the reason for collecting data?

First of all, it is important to remember that Alto Giro's primacy with the user is respect for their opinion and will. However, the question about the reasons for collecting personal data will still remain. Although already previously explained, Alto Giro once again clarifies that the reasons for data collection are subdivided into 02 (two), that is, there is essential and anonymous data, which aims at the regular functioning of a digital platform, and, secondly, there is the collection of anonymous or non-anonymous data, whose purpose is the personalization of a pleasant environment closer to what the user desires.

1.3 The Legal foundations that guide data collection

Law nº 13.709/2018 and its subsequent amendments, called the General Data Protection Law (LGPD), as provided in its article 1, came to regulate the "processing of personal data, including in digital media, by a natural person or by a legal entity under public or private law, with the aim of protecting fundamental rights of freedom and privacy and the free development of the natural person's personality". It cannot be overlooked that, although the prior existence of a norm already qualifies the need for regulation, the basic principles of data collection, which can even be sought in the Federal Constitution of 1988 and the Civil Code, are consent, legitimate interest, and the regular execution of contracts.

1.4 What types of data are collected by Alto Giro and how will it be used?

1.4.1 Website Users

As we have already mentioned, accessing the Alto Giro Website implies, obligatorily, authorizing the minimum data collection for a browsing experience, and, for this purpose, it uses cookies, which are identifiers transferred to your browser or device that authorize the recognition of your browser or device, to access data on basic information, such as when and how many pages were accessed, which resources were used, and the amount of access. This data will always be anonymous and not authorizing these cookies will imply the impossibility of accessing the website. Furthermore, it is worth remembering that within the Privacy Policy, the user may choose not to authorize data collection that does not imply total access limitation, but, in return, it will not be possible for us to offer a complete and personalized experience. Recalling, we have the following cookies that Alto Giro uses to collect information:

• Mandatory cookies (strictly necessary), which do not collect any information capable of identifying the person accessing our website. The computer will delete mandatory cookies, which can also be called session cookies.
• Functional cookies, which collect data anonymously. Also called technical cookies, they aim to maintain the correct functioning of your navigation, allowing your experiences, anonymously, to remain known. As an example, authorizing these cookies will allow us to remember your preferred language.
◦ All information collected by these cookies is aggregated and therefore anonymous. Without the permission of these cookies, some website functionalities may be compromised.
• Analytical cookies, which collect data anonymously. Also called performance cookies, they aim to optimize your visit to our internet environment. As an example, these cookies allow us to count visits and traffic sources so that we can measure and improve the performance of our website.
• All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you visited our website.
• Advertising cookies, which collect data, but will not be shared with any other legal entity, except only persons of the same Economic Group, as well as service providers who aim to protect your data, and any disclosure of the same to third parties unrelated to the activity carried out by Alto Giro is prohibited. Also called marketing or tracking cookies, they aim to improve your experience with us, which we will use the best opportunities to show you our latest news according to your preferences. If you do not allow these cookies, you will have less targeted and personalized advertising for you.

Legally, we would not need to ask for your permission to collect data through functional and analytical cookies, but, however, your opinion will always be respected! It is also important to emphasize that there is a possibility that third-party cookies are already installed in your browser, and, therefore, our Privacy Policy cannot cover this responsibility. It is evident that cookies placed by third parties may continue to collect data from your activities even after you have left our Website.

1.4.2 Regarding the interest (Leads) demonstrated by the User

Do not doubt that we, at Alto Giro, will always seek a way to get your attention, and, when you show interest in our publications, whether by accessing our ads, advertisements, and even newsletters, or by registering personally on our Website, in addition to essential and anonymous data, we may request your consent to share analytical data, which will not contain any personal information, aiming only at the possibility of producing personalized content for you, but, we may also request another consent from you, which will authorize the collection of personal data with the sole objective of producing personalized content for you.

1.4.3 How will your data be used?

Alto Giro, always respecting your will and opinion, will use your data exclusively to personalize content of your interest, remembering that at any time you can choose to cancel not only access to the data, but also unsubscribe from any receipt of advertising and/or information. For example, Alto Giro may:

• Use your email to send marketing material or newsletters;
• Use your personal and/or commercial address, depending on the information provided by you when registering on our digital and/or physical channels, to send marketing material or newsletters;
• Use your phone contact, including via messages through applications, at which time Alto Giro employees may contact you, and the contact may even be made through automated digital platforms;

1.5 We will not share your data!

Alto Giro will not share your non-anonymized or anonymized personal data with any legal entity other than the brand owner, which is RECCO RECCO & CIA. LTDA. (CNPJ/MF 76.795.418/0001-02), as well as persons from the same Economic Group, in addition to service providers who aim to protect your data, being prohibited any disclosure of the same to third parties unrelated to the activity carried out by Alto Giro.

1.6 The provided data is highly personal and owned by you!

According to article 1 of Law nº 13.709/2018, the General Data Protection Law (LGPD), the objective of protecting personal data is to "protect the fundamental rights of freedom and privacy and the free development of the natural person's personality". Therefore, the legal protection mentioned above, although already protected by the Federal Constitution of 1988 and the Civil Code, only came to clarify that you, the user, will always be the owner of your personal data, which, with your express authorization, which, it should be noted, we will always ask for, will be used to optimize an environment that may interest you.

1.7 Your data will be stored for a period!

Your personal data will be stored securely, and the storage period observes not only the legal term, but also, when there is no legal determination, the necessary period for our employees to delete your information from our database. Thus, your data will be kept for the period below:

• As long as your relationship with us is maintained, through your registration on one of our physical or digital platforms, which we hope will remain indefinitely, as we always want you close, your personal data will remain with us, always secure!
• In case of a request to cancel your registration, which can be done in a simplified way, either by a simple "click" in the digital environment or an express request in the physical environment, which we hope will never happen, Alto Giro will permanently delete your data within 72 (seventy-two) hours, given only the bureaucratic period for one of our employees to securely and permanently delete your data;
• Considering that you, the user, may show interest (leads) in our ads and publications, but, however, not register on our digital and/or physical channels, allowing, on the other hand, data access through cookies, your data may be stored for a period of up to 05 (five) years. However, at any time you can deauthorize the sharing of cookies, and, in this way, your data will be deleted within 72 (seventy-two) hours;

1.8 Your security in the digital environment

First of all, your security will always be our priority, and, in this way, it begins at the time of your registration through your personal password, which is non-transferable. Therefore, do not share and do not authorize third-party access to your secure environment! On the other hand, it is important to say that Alto Giro works constantly, updating its security system that covers both the user who registers in our digital environment, as well as the user who shows interest in our publications and disclosures. For observation purposes only, Alto Giro uses numerous practices that can combat any harm to your data, such as:

• Encryption of passwords and other critical information;
• TLS for data transfer;
• Hiring cloud services with certifications and security seals, such as ISO 27001, SOC 1 and SOC 2/SSAE 16/ISAE 3402 and PCI DSS;
• System monitoring;
• Edge firewall with IDS (Intrusion Detection System) functionalities;
• Anti-malware;
• Anti-phishing;
• Content control and VPN.
Notwithstanding the repeated search for data protection, in the event that you observe something that compromises the security of your data, please contact us immediately through the service channels.

1.9 Contact Us

As we have tirelessly emphasized, your personal data is highly personal, and your will shall prevail. Thus, if you come to consider that your data has been used in a manner inconsistent with our Privacy Policy, or, even if you intend to suggest an essential point that you may have considered omitted, Alto Giro has a specific channel to assist you.

• Address: Rua Gaspar Ricardo, nº 471, Zona 10, CEP 87.040-365, in the municipality of Maringá, State of Paraná
• E-mail: dpo@altogiro.net

1.10 On Constant Evolution

In light of all points, we must note that Alto Giro's concern also involves the constant update and improvement of this Privacy Policy. Therefore, when you return to visit us, it may be necessary to provide new authorization for data use, and if this occurs, it will be due to your browser cookies having been deleted, or this Privacy Policy having been updated.