Welcome to our Privacy Policy! The companies FACILITE S/A, FACILITE PAGAMENTOS, and other companies that may join the group (“FACILITE”) are committed to protecting your privacy in accordance with Federal Law No. 12,965 of 23, 2014, and Federal Law No. 13,709 of August 14, 2018. This policy applies to customers and their legal representatives, employees, and/or staff of customers, if applicable, of FACILITE and its affiliated companies, as well as any User who uses or has access to the website (here referred to as “Platform”) and/or the services offered, as well as mobile applications distributed, or in any way offered or used directly by or through FACILITE or who participates in events, promotions, or opinion surveys conducted by FACILITE (“Services”).

This Privacy Policy may be modified as a result of any updates, which is why users are invited to periodically consult this section.

1. User's personal data will be processed lawfully, fairly, and transparently (lawfulness, fairness, and transparency);

2. User's personal data will be collected only to fulfill the legal purposes related to the contracted services and cannot be used in a manner incompatible with the purpose;

3. The data voluntarily provided by the user will be processed securely, protected from unauthorized or unlawful processing, always preserving integrity and confidentiality;

4. During the use of the platform, the user will have their own password and login.

5. Use of the platform by the user will be made through acceptance of the terms of use provided, as well as the correct filling out of registration data;

6. By using the platform, the user is consenting to the Privacy Policy.

7. The user may not withdraw consent for the processing of personal data.

8. At any time, supplementary data may be requested to achieve the purposes of the contracted services within the platform;

9. The personal data of the user collected by the platform will have the purpose of facilitating, speeding up, and fulfilling the commitments made with the user;

10. The personal data of the user will be stored for a maximum period of one year or for as long as the service contract lasts, unless the user requests deletion before the end of the established period;

11. The data protection officer of the platform is the company FACILITE TECNOLOGIA;

12. The platform commits to applying technical and organizational measures to protect all user data;

13. Violations of personal data are security breaches that, either accidentally or unlawfully, cause the destruction, alteration, or unauthorized access to personal data and must be investigated for civil and criminal accountability.

14. The platform commits to treating the user's personal data confidentially, within legal limits.

15. To send Notifications via the app, the application will send an identifying key to our database to use Google Play Services and Firebase. This information will be used only for sending notifications. No third party will have access to such information.

16. The user may not engage in the following actions, by reason of or through the use of the platform:

    1. Committing any unlawful acts and/or violating current legislation;

    2. Uploading, sending, and/or transmitting any content of an erotic, pornographic, obscene, defamatory, slanderous nature, that advocates crime, drug use, the consumption of alcoholic beverages or smoking products, physical or moral violence;

    3. Uploading, sending, and/or transmitting any content that promotes or incites prejudice or any form of discrimination, as well as hatred or illegal activities;

    4. Threatening, coercing, or causing physical or moral embarrassment to other users;

    5. Violating the rights of third parties;

    6. Violating the rights of confidentiality and privacy of others;

    
    

17. To resolve controversies arising from this instrument, Brazilian Law will be wholly applied;

18. The user is responsible for entering data and correctly filling in the information required by the platform, being solely responsible for acts of omission that cause damage or loss;

19. All visual identity and functionalities of the platform belong to FACILITE TECNOLOGIA;

20. Tolerance regarding any breach of any provisions of these Terms of Use and Privacy Policy by any user will not constitute a waiver of the right to demand compliance with the obligation, nor forgiveness, nor alteration;

21. Any change and/or update to these Terms of Use and Privacy Policy will take effect from the date of its publication on the Site and/or Platform and must be fully observed by Users.

LGPD

This section clarifies how FACILITE manages your personal information obtained and used in its operations and services. We address the main topics in the following categories:

1. What Personal Information Do We Collect?

   
   

   When interacting with and/or using our services, FACILITE may process certain information provided, acquired, or associated with you, such as:

   • Initial registration information, such as name, phone contact, and email, as well as details about your company, such as the nature of the activity and the organization's registration location;

   • Additional identification details, such as residential address, phone number, CPF, password, when you register and use the services, report an incident, participate in opinion surveys or promotions, including to confirm discounts and special offers from partnerships and campaigns;

   • Financial information of the company entered into the platform by the CLIENT (via OFX or other methods);

   • Personal information found in social contracts and power of attorney documents;

   • Entity or company with which you are associated and related information;

   • Technical data collected from the device used to access our Platform (such as IP, Mac Address, IMEI, Location, Browsers, and others);

   • Information about you received from third parties, including public databases and information you have made publicly available (like profile, posts, or social media data);

   • Information about you generated from the use of the Services and other acquired data; and

   • Communications, whether oral, video, or written, between you and FACILITE.

     
     

   Note that, in certain contexts, such as in seeking a relationship with the User or in compliance with good practices and anti-corruption regulations, FACILITE may also obtain your personal data from other sources, such as public databases or background check providers, always in strict compliance with data protection laws and applicable regulations.

   
   

   According to the legal definition, sensitive personal information is that related to racial or ethnic origin, religious belief, political opinion, affiliation with unions or organizations of a religious, philosophical, or political nature, information regarding health or sexual life, genetic or biometric data (“Sensitive Data”). FACILITE only collects ethnicity from employees, as it is mandatory information for the Human Resources Department to send e-Social. This information is not shared with any other system.

   
   

   Information on Minors

   In general, FACILITE does not intentionally collect Personal Information from individuals under 18 years old.

   
   

2. For What Purposes Do We Process Your Personal Data? We employ your personal information for the purposes below:

   • To offer, provide, and maintain our services;

   • Registration and other initial contracting procedures;

   • Compliance with contractual obligations between you and FACILITE;

   • Facilitate communication between you and FACILITE, including ensuring compliance with commitments;

   • Allow the offer of support and additional services related to contracts entered into with the User, including by third-party business partners of FACILITE;

   • Manage the relationship with the User, including communication through available means, direct marketing, advertising, and promotions;

   • Prevent and combat fraud at any stage of the offering of products and services by FACILITE;

   • Ensure your safety when using our Services;

   • Respond to and address requests made by you regarding our Services;

   • Produce analyses and statistical reports on the performance and operation of our services and platform, for the benefit of FACILITE and its business partners;

   • Personalize, enhance, and develop our platform and its functionalities, combining and using the information and profile we have about you, such as your interaction with the Platform, frequency of use of our Services, and your preferences in general;

   • Conduct internal and external audits and quality control, aiming for improvements in service delivery and identifying operational failures;

   • Conduct satisfaction surveys about our services or those of our partners;

   • Detect, identify, prevent and defend against potential abusive or illegal practices;

   • Comply with legal and regulatory obligations regarding the collection, retention, and/or sharing of data, including with government authorities, in accordance with applicable legislation and regulations;

   • For the defense of FACILITE's rights in administrative, arbitral, or judicial processes, as provided by law, and for the protection of FACILITE, its rights, properties, and legitimate interests.

     
     

3. With Whom Do We Share Your Personal Data? FACILITE may share your information with:

   • Business partners, to fulfill the purposes set forth in this Privacy Policy, support activities, or to confirm special commercial conditions – if applicable;

   • FACILITE service providers acting on behalf of FACILITE and for its benefit in fulfilling the purposes of this Privacy Policy. These service providers will not have an independent right to use your information;

   • In situations where you request or authorize the sharing; with entities, agencies, authorities, and other governmental or public administration bodies, as well as with private entities, in compliance with a legal obligation or court order;

   • For the protection and defense of any rights of FACILITE, at its discretion, including in legal, arbitral, or administrative proceedings;

   • In situations of change in ownership or control of FACILITE, due to merger, acquisition, division, or sale of assets, where your information may be transferred to a new owner.

   • FACILITE does not sell or share users' personal data with companies, organizations.

     
     * This Privacy Policy does not apply to the processing of personal data performed by other companies or individuals, websites, or other third parties, including potential partners of FACILITE.

DPO

Bruno Chaves is the Data Protection Officer (DPO) at Facilite S/A, responsible for ensuring compliance with data protection regulations.

In his role, he collaborates closely with the CTO, Rita Pissarra, and the technical team to support decision-making related to information security. Although he does not hold direct expertise in this area, Bruno relies on the guidance of the CTO and the competence of the technical team to ensure that the practices of collecting, processing, and storing personal data are aligned with legal privacy standards.

His crucial role involves defining internal policies and implementing measures to ensure the integrity and protection of data managed by Facilite S/A.

To contact the DPO of Facilite, send an email via  lgpd@facilite.co or speak with our support team at: (61) 9322-7414.