1. Privacy Policy

1.1 Where is personal data collected?
1.2 What is the reason for data collection?
1.3 Legal basis for data collection
1.4 What types of data are collected by Alto Giro and how will they be used?
1.4.1 Website Users
1.4.2 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 data provided is personal and belongs to you!
1.7 Your data will be stored for a while!
1.8 Your security in the digital environment
1.9 Our contact
1.10 Of constant evolution

Alto Giro is committed to the security of its customers' information regarding the data and information collected. Therefore, 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 therefore our goal is not only to provide your information in a safe and responsible manner, but also to respect your opinion. Therefore, browsing our website, using our mobile platform, being logged into our secure environment, providing information in person at our stores, and any collection of personal data does not necessarily imply that you are transmitting all of your data to us. However, we would like to clarify that it is up to you to authorize us to process only the personal information that you wish. On the other hand, it is important to highlight that the information collected, 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 important to consider that Alto Giro is committed to safeguarding your privacy and protecting 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 can Alto Giro use such information;
• Reiterate the commitment to the storage and maintenance of your personal data, which will not be shared with another legal entity, but only with people from the same Economic Group, as well as service providers who aim to protect your data, and any disclosure of the same to third parties outside the activity carried out by Alto Giro is prohibited;

It should also be noted that this document is also an essential component of the Website Terms of Use, which sets out the concept of our digital environment. It is extremely important to note that our Privacy Policy will be observed whenever you use our services online or offline, which may request the collection of Personal Data. In order to maintain our activities, our user support services include: websites, which also include access to the user's secure area while logged in; applications; social networks, which, although third-party, are located there; customer support services, whether via the World Wide Web or by telephone and/or mobile data messaging; in-person points of sale; and even sponsored events. Acceptance of our Privacy Policy will occur:

• When you register on our website and/or use an application owned by Alto Giro, whether or not you make any purchase; or,
• When you access any social networks and applications, including via email and/or applications such as WhatsApp and similar, which, although third party, are allocated to Alto Giro; or,
• When you provide your data in person in our stores and/or sponsored events; or,
• When you provide your data during our telephone service; or,
• When you provide your data to our services via mobile phone messages and/or the world wide web.

Although acceptance of our Privacy Policy occurs in the cases above, it is important to reiterate our commitment not only to the safekeeping and maintenance of your personal data, but, in particular, to respecting your choices, and, therefore, only the data that you authorize us to collect, with the exception, however, of cookies considered mandatory, 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 may also result in non-acceptance of our Privacy Policy, which, we reiterate, does not offend any unauthorized access to data. However, even so, in this case, if you do not accept it, we will not be able to provide you with our products in a personalized manner. Notwithstanding this, if you are not interested in agreeing to our Privacy Policy, we ask that you contact us, and we will aim to clarify any points that may seem dissonant, so that we can 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, storage methods, among others, we are already available to resolve any doubts, even if they are not expressly connected to this Privacy Policy.

1.1 Where is personal data collected?

It is important to note that the objectives for collecting personal data are generally divided into 2 (two) objectives. First, the information is essential for the proper functioning of a system, and in this case, we are talking about essential and anonymous data. Second, the collection of data, which may or may not be anonymous, is highlighted, the purpose of which is to personalize a pleasant environment that is closer to what the user desires. As a consequence of the above observation, it is clear that essential and anonymous data will always be provided, and personal data, which may be securely and definitively anonymized, may be collected for a better experience and even for the proper functioning of the system. Personal data may be collected in the following interactions between the user and Alto Giro:

• Website: User-facing web pages, with a domain owned by Alto Giro, email registration, or even third-party social networks, which, although under different ownership, are allocated to Alto Giro, 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;
• Advertisements stored in third-party environments: Alto Giro, through direct or indirect advertising actions, produces advertisements in digital environments, and the user, by “clicking” on these advertisements, will be able to access anonymous data capable of interacting in a personalized way;
• Data collected and interpreted: Our continuous interaction allows us to better understand your choices and opinions, and, in this way, through anonymized or non-anonymized data, we will be able to interpret your choices and personalize information that may be useful for your decisions;
• Data collected in physical form: Alto Giro, through direct actions, promotional or otherwise, in its network of stores, retail partners, or even in the promotion of its own or third-party events, may collect data in physical form, through registration forms without a specific format.

Regarding Alto Giro content that may eventually be shared by the user on social networks, we highlight that said publication is carried out through the user, and therefore, Alto Giro does not have any control, as the user will be using his/her profile for said publication, and Alto Giro does not have any control over this dissemination of data.

1.2 What is the reason for data collection?

First of all, it is important to remember that Alto Giro's priority towards users is to respect their opinions and wishes. However, there will still be questions about the reasons for collecting personal data. Although previously explained, Alto Giro once again clarifies that the reasons for collecting data are subdivided into 02 (two), that is, there is essential and anonymous data, which aims at the regular functioning of a digital platform, and, in a second moment, there is the collection of anonymous or non-anonymous data, whose purpose is to personalize a pleasant environment that is closer to what the user desires.

1.3 Legal basis for data collection

Law No. 13,709/2018 and its subsequent amendments, known as the General Data Protection Law (LGPD), as provided in its art. 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 the fundamental rights of freedom and privacy and the free development of the personality of the natural person”. It is important to note that, although the prior existence of a rule already qualifies the need for regulation, it is necessary to note that the basic principles of data collection, which can even be found 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 they be used?

1.4.1 Website Users

As we have already mentioned, accessing the Alto Giro Website requires authorizing the collection of minimum data for a browsing experience, and to this end, cookies are used, which are identifiers transferred to your browser or device that authorize the recognition of your browser or device, access data to basic information, such as when and how many pages were accessed, which resources were used, and how many times the site was accessed. This data will always be anonymous and failure to authorize these cookies will make it impossible to access the website. It is also worth remembering that within the Privacy Policy, the user may choose not to authorize the collection of data that does not imply total limitation of access, but, on the other hand, it will not be possible for us to offer a complete and personalized experience. As a reminder, Alto Giro uses the following cookies to collect information:

• Mandatory (strictly necessary) cookies, which do not collect any information capable of identifying the person accessing our website. The computer will delete mandatory cookies, which may also be called session cookies.
• Functional cookies, which collect data anonymously. Also known as technical cookies, they aim to maintain the correct functioning of your navigation, allowing your experiences, anonymously, to remain known. For 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 functions 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 these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
• Advertising cookies, which collect data but will not be shared with any other legal entity, but only with people from the same Economic Group, as well as service providers that aim to protect your data, and any transmission of such data to third parties outside the activity carried out by Alto Giro is prohibited. Also called marketing or tracking cookies, they aim to improve your experience with us, and 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 your opinion will always be respected! It is also important to highlight that there is a possibility of third-party cookies already being installed in your browser, and therefore, our Privacy Policy cannot cover this responsibility. It is clear that cookies placed by third parties may continue to collect data about your activities even after you have left our Website.

1.4.2 Interest (Leads) demonstrated by the User

There is no doubt that we, at Alto Giro, will always seek a way to attract your attention, and when you show interest in our publications, whether by accessing our advertisements, publicity and even newsletters, or through your personal registration 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, with the sole purpose of producing personalized content for you, but we may also request further consent from you, which will authorize the collection of personal data for the sole purpose of producing personalized content for you.

1.4.3 How will your data be used?

Alto Giro, always respecting your wishes and opinions, will use your data exclusively to personalize content of interest to you. Please note that at any time you may choose to cancel not only access to your data, but you may also unsubscribe from receiving any advertising and/or information. For example, Alto Giro may:

• Use your email to send marketing material or newsletters;
• Use your personal and/or business 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 telephone contact, including via messages via applications, at which time Alto Giro employees may get in touch, and contact may even be made via automated digital platforms;

1.5 We will not share your data!

Alto Giro will not share your non-anonymous or anonymized personal data with any legal entity other than the brand owner, namely, the legal entity RECCO RECCO & CIA. LTDA. (CNPJ/MF 76.795.418/0001-02), as well as people from the same Economic Group, in addition to service providers that 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.

1.6 The data provided is personal and belongs to you!

According to art. 1 of Law No. 13,709/2018, General Data Protection Law (LGPD), the purpose of protecting personal data is to “protect the fundamental rights of freedom and privacy and the free development of the personality of the natural person”. Therefore, the legal protection 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, we emphasize, we will always request, will be used to optimize an environment that may be of interest to you.

1.7 Your data will be stored for a while!

Your personal data will be stored securely, and the retention period will not only comply with the legal term, but also, in the absence of any legal determination, the period necessary for our employees to delete your information from our database. Therefore, your data will be kept for the period below:

• As long as your relationship with us continues, through your registration on one of our physical or digital platforms, which we hope will continue indefinitely, as we always want you close by, your personal data will remain with us, always safe!
• In the event of a request to cancel your registration, which can be done in a simplified manner, either by a simple “click” in the digital environment or an express request in the physical environment, which we hope will never occur, Alto Giro will permanently delete your data within a period of up to 72 (seventy-two) hours, considering 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 advertisements and publications, but, however, do not register on our digital and/or physical media, allowing, on the other hand, access to data through cookies, your data may be stored for a period of up to 05 (five) years. However, at any time you may disallow the sharing of cookies, and, in this way, your data will be deleted within a period of up to 72 (seventy-two) hours;

1.8 Your security in the digital environment

First and foremost, your security will always be our priority, and this starts when you register using your personal password, which is non-transferable. Therefore, do not share it and do not authorize third parties to access your secure environment! On the other hand, it is important to note that Alto Giro is constantly updating its security system, which covers both users who register in our digital environment and users who show interest in our publications and disclosures. As a reminder, Alto Giro uses numerous practices that can combat any risk to your data, such as:

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

1.9 Our contact

As we have repeatedly emphasized, your personal data is highly personal, and your will will prevail. Therefore, if you consider that your data has been used in a manner that is not consistent with our Privacy Policy, or even if you wish 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, Zone 10, Zip Code 87.040-365, in the city of Maringá, State of Paraná
• Email: dpo@altogiro.net

1.10 Of constant evolution

In view of all the above, we cannot fail to note that Alto Giro is also concerned with the constant updating and improvement of this Privacy Policy. Therefore, when you return to visit us, you may need to reauthorize the use of data, and if this occurs, it will be because your browser cookies have been deleted, or this Privacy Policy has been updated.