HIP Conecta

Privacy Policy - TROVA

TROVA, a private legal entity, takes your privacy seriously and safeguards the security and protection of data of all its customers, partners, suppliers and users of the website domain www.asktrova.com and any other site, store or application operated by the merchant.

This Privacy Policy is intended to inform you about how we use and disclose information collected during your visits to our store and in messages exchanged with you.

This Privacy Policy applies only to information collected through the store.

BY ACCESSING THE STORE, SENDING COMMUNICATIONS OR PROVIDING ANY TYPE OF PERSONAL DATA, YOU DECLARE THAT YOU ARE AWARE OF THE TERMS SET FORTH HERE AND AGREE WITH THE PRIVACY POLICY, WHICH DESCRIBES THE PURPOSES AND METHODS OF PROCESSING YOUR PERSONAL DATA THAT YOU MAKE AVAILABLE IN THE STORE.

This Privacy Policy provides an overview of our privacy practices and the choices you can make, as well as the rights you can exercise regarding the Personal Data processed by us. If you have any questions about the use of Personal Data, contact [email protected].

In addition, the Privacy Policy does not apply to any third-party applications, products, services, websites or social media features that may be offered or accessed through the store. Accessing those links will take you away from our site and may result in the collection or sharing of information about you by third parties. We do not control, endorse, or make any representations about third-party sites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any site you interact with before allowing the collection and use of your Personal Data.

If you send us Personal Data relating to other natural persons, you declare that you are authorized to do so and that you have obtained the necessary consent to authorize the use of such information under the terms of this Privacy Policy.

Section 1 - Definitions

For the purposes of this Privacy Policy:

"Personal Data": means any information that, directly or indirectly, identifies or can identify a natural person, for example, name, CPF (Brazilian taxpayer ID), date of birth, IP address, among others;

"Sensitive Personal Data": means any information that reveals, regarding a natural person, racial or ethnic origin, religious conviction, political opinion, union membership or membership in an organization of a religious, philosophical or political nature, data related to health or sex life, genetic or biometric data;

"Processing of Personal Data": means any operation carried out with Personal Data, by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available, alignment or combination, restriction, erasure or destruction. Any other operation provided for under applicable law is also considered Processing of Personal Data;

"Data Protection Laws": means all legal provisions that regulate the Processing of Personal Data, including, but not limited to, Law No. 13.709/18, the General Personal Data Protection Law ("LGPD").

Section 2 - Use of Personal Data

We collect and use Personal Data to manage our relationship with you and better serve you when you purchase products and/or services in the store, personalizing and improving your experience. Examples of how we use data include:

• Enabling you to purchase products and/or services in the store;

• To confirm or correct the information we have about you;

• To send information we believe may be of interest to you;

• To personalize your experience using the store;

• To contact you by a telephone number and/or email address provided. We may contact you personally, by voicemail, through automatic dialing equipment, by text messages (SMS), by email, or by any other means your device is capable of receiving, in accordance with the law and for reasonable commercial purposes.

In addition, the provided Personal Data may also be used as we deem necessary or appropriate: (a) under the Data Protection Laws; (b) to comply with court proceedings; (c) to comply with judicial decisions, regulatory rulings or decisions of competent authorities, including authorities outside the country of residence; (d) to enforce our Terms and Conditions of Use; (e) to protect our operations; (f) to protect rights, privacy or safety of ours, yours or third parties; (g) to detect and prevent fraud; (h) to allow us to take available actions or limit damages we may suffer; and (i) in other ways permitted by law.

Section 3 - Non-provision of Personal Data

You are not required to share the Personal Data we request. However, if you choose not to share them, in some cases we may not be able to provide you with full access to the store, certain specialized features, the necessary assistance, or enable delivery of the product or provision of the service you contracted.

Section 4 - Data Collected

The general public may browse the store without registering or submitting Personal Data. However, some store features may depend on registration and submission of Personal Data such as completing a purchase/contracting a service and/or enabling product delivery/provision of a service by us.

When contacting the store, we may collect:

• Contact data: first name, last name, phone number, address, city, state and email address;

• Submitted information: information you send via forms (questions, complaints, suggestions, feedback, compliments, etc.).

During general navigation in the store, we may collect:

• Location data: geolocation data when you access the store;

• Preferences: information about your preferences and interests regarding products/services (when you tell us what they are or when we infer them from what we know about you);

• Store navigation data: information about your visits and activities, including the content (and any ads) you view and interact with, information about the browser and device you are using, your IP address, your location, the website address from which you arrived. Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons and embedded web links. To learn more, read how we use Automatic Data Collection Tools in Section 7 below;

• Anonymous or aggregated data: anonymous responses to surveys or anonymous and aggregated information about how the store is used. In certain cases, we apply a de-identification or pseudonymization process to your data so that it is reasonably unlikely that you can be identified through use of those data with available technology;

• Other information we may collect: information that does not specifically reveal your identity or that is not directly related to an individual, such as information about browser and device; store usage data; and information collected through cookies, pixel tags and other technologies.

We do not collect Sensitive Personal Data.

Section 5 - Sharing Personal Data with Third Parties

We may share your Personal Data:

• With partner company(ies) you select or choose to send your data, questions, etc., as well as with service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the United States, Argentina, Brazil or other global locations, including servers for testing and production, and providers of hosting and data storage, fraud management, customer support, sales on our behalf, order fulfillment, content personalization, advertising and marketing activities (including digital and personalized advertising) and IT services, for example;

• With third parties to help us manage the store;

• With third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or transmission of all or part of our company, assets or equity (including related to bankruptcy or similar proceedings).

Section 6 - International Data Transfers

Personal Data and information of other kinds collected by us may be transferred to or accessed by entities belonging to the corporate group of partner companies worldwide in accordance with this Privacy Policy.

Section 7 - Automatic Collection of Personal Data

When you visit the store, it may store or retrieve information in your browser, mainly in the form of cookies, which are text files containing small amounts of information. This information may be about you, your preferences or your device and is primarily used so the store functions as you expect. The information typically does not identify you directly but can provide a more personalized online experience.

Under this Privacy Policy, we and our third-party service providers, with your consent, may collect your Personal Data in various ways, including, but not limited to:

• Through the browser or device: some information is collected by most browsers or automatically by internet access devices, such as the type of computer, screen resolution, name and version of the operating system, device model and manufacturer, language, type and version of the web browser you are using. We may use this information to ensure the store functions properly.

• Use of cookies: information about your use of the store may be collected by third parties via cookies. Cookies are information stored directly on the computer you are using. Cookies allow the collection of information such as browser type, time spent in the store, pages visited, language preferences, and other anonymous traffic data. We and our service providers use this information for security protection, to facilitate navigation, display information more efficiently, and personalize your experience using the store, as well as for online tracking. We also collect statistical information about store usage for continuous improvement of our design and functionality, to understand how the store is used and to help you resolve store-related issues.

If you do not want your information collected via cookies, most browsers offer a simple procedure to automatically reject cookies, or offer the option to accept or reject transfer of a specific cookie(s) from a given site to your computer. However, this may cause inconvenience in using the store.

The settings you choose may affect your browsing experience and the functionality that requires the use of cookies. In this respect, we disclaim any responsibility for consequences resulting from limited store functionality caused by disabling cookies on your device (inability to set or read a cookie).

• Use of pixel tags and similar technologies: pixel tags (also known as web beacons and invisible GIFs) may be used to track actions of store users (including email recipients), measure the success of our marketing campaigns and collect statistical data about store usage and response rates, and for other unspecified purposes. We may hire behavioral advertising companies to obtain reports about the store's ads across the internet. For this, these companies use cookies, pixel tags and other technologies to collect information about your use, or other users' use, of our store and third-party sites. We are not responsible for pixel tags, cookies and other similar technologies used by third parties.

Section 8 - Categories of Cookies

The cookies used in our store comply with legal requirements and are classified in the following categories:

• Strictly necessary: these cookies allow you to navigate the site and enjoy essential features securely. An example is security cookies that authenticate users, protect your data and prevent fraudulent login creation.

• Performance: cookies in this category collect information in an encoded and anonymous form related to our online store, such as the number of visitors to a specific page, sources of site visits and which pages are accessed by the user. All collected data are used only for possible site improvements and to measure the effectiveness of our communication.

• Functionality: these cookies are used to remember user preference settings to improve your visit to our site, such as layout settings or your responses to promotion and registration pop-ups—so you won't be asked repeatedly.

• Advertising: we use cookies to create targeted campaigns and deliver ads according to your consumption profile in our online store.

Section 9 - User Rights

You may, at any time, request: (i) confirmation that your Personal Data are being processed; (ii) access to your Personal Data; (iii) corrections to incomplete, inaccurate or out-of-date data; (iv) anonymization, blocking or deletion of unnecessary, excessive, or unlawfully processed data; (v) portability of Personal Data to another service provider, provided this does not affect our trade or business secrets; (vi) deletion of Personal Data processed with your consent, to the extent permitted by law; (vii) information on the entities to which your Personal Data have been shared; (viii) information about the possibility of not providing consent and the consequences of refusal; and (ix) revocation of consent. Your requests will be handled with special care so that we can ensure the effectiveness of your rights. You may be asked to prove your identity to ensure that Personal Data are disclosed only to the data subject.

You should keep in mind that, in certain cases (for example, due to legal requirements), your request may not be immediately satisfied and we may not be able to comply due to our legal obligations.

Section 10 - Security of Personal Data

We strive to adopt the technical and organizational measures provided for by the Data Protection Laws appropriate to protect Personal Data within our organization. Unfortunately, no transmission or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe the security of any of your accounts has been compromised), please notify us immediately.

Section 11 - Hyperlinks to Other Sites and Social Networks

The Store may, from time to time, contain hyperlinks that will redirect you to sites of our partners, advertisers, suppliers, etc. If you click one of these links, remember that each site has its own privacy practices and we are not responsible for those policies. Consult those policies before submitting any Personal Data to those sites.

We are not responsible for the data collection, use and disclosure policies and practices (including data protection practices) of other organizations such as Facebook, Apple, Google, Microsoft, or any other software developer or app provider, social media platform, operating system, wireless internet service provider or device manufacturer, including any Personal Data you disclose to other organizations through apps related to such apps or posted on our social media pages. We recommend that you review the privacy policy of each site you visit or each service provider you use.

Section 12 - Updates to this Privacy Policy

If we modify our Privacy Policy, we will publish the new text in the store with the updated revision date. We may change this Privacy Policy at any time. If there is a significant change in the terms of this Privacy Policy, we may inform you via the contact information we have in our database or by posting a notice in our store.

We remind you that we are committed not to process your Personal Data in a manner incompatible with the objectives described above, except as otherwise required by law or court order.

Your use of the store after the changes means you have accepted the revised Privacy Policy. If, after reading the revised version, you disagree with its terms, please stop accessing the store.

Section 13 - Data Protection Officer

If you intend to exercise any of the rights provided herein, including withdrawing your consent under this Privacy Policy and/or the Data Protection Laws, or to resolve any questions related to the Processing of your Personal Data, please contact us at [email protected].