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The Privacy Policy of Jndev Sistemas e Softwares ('NumWeb') was created to demonstrate our commitment to always treating your personal data with security, privacy, and transparency ('Privacy Policy').

This Privacy Policy describes the personal data we collect, how it is used, stored, and shared, and your rights regarding this data.

We recommend a careful reading, but if you still have questions, our support channels indicated below are at your disposal.

INTRODUCTION

When you hire NumWeb's services, you provide us with some personal data so that we can enable the hiring of our products and services and also deliver the best possible experience to you. At NumWeb, privacy, security, and transparency are fundamental values, and we will always adopt the best practices to ensure the confidentiality and integrity of your personal data.

By accepting the terms of this Privacy Policy, you are aware that the controller of your personal data, i.e., the company responsible for making decisions about the processing of your personal data, will be Jndev Sistemas e Softwares, registered under CNPJ nº 26.147.250/0001-42, headquartered in the city of São Paulo, State of São Paulo, at Rua Padre João Manuel, 222, room 21.

After reading this Privacy Policy, if you have questions, complaints, wish to exercise your rights related to your personal data, or communicate with NumWeb about this matter, you can contact us through our support channels or contact our Data Protection Officer (DPO) at dpo@numweb.com.br.

FIRST CLAUSE - APPLICATION

Every time you read a term in capital letters in this Policy, it means that it is a term with a specifically defined meaning.

Whenever the terms 'NumWeb,' 'we,' or 'our' are mentioned, we are referring to NumWeb; similarly, whenever the terms 'you,' 'your,' 'yours' are mentioned, we are referring to You.

This Privacy Policy applies to all NumWeb customers in Brazil. We collect your personal data whenever you:

1. Hire or use any of our products or services
2. Browse the NumWeb website – https://numweb.com.br
3. Contact us through our support channels

This Privacy Policy specifically applies to:

1. NumWeb customers: natural persons who effectively hire, use, or access one or more services or products of NumWeb (whether for yourself or for your legal entity)
2. NumWeb prospects: natural persons prospected by NumWeb or who have already requested the hiring of one of the services or products but have not become a NumWeb customer for any reason

This Privacy Policy is also applicable to other forms of personal data collection by NumWeb, which allow the provision or improvement of our services. For example, we may collect information through partners or related to our technologies. All forms of collection and uses of your personal data are described in this Privacy Policy.

The practices described in this Privacy Policy only apply to the processing of your personal data in Brazil and are subject to applicable local laws, especially Law nº 13.709/2018 (General Data Protection Law, or 'LGPD') from its effective date.

SECOND CLAUSE - WHAT PERSONAL DATA IS COLLECTED BY NUMWEB

When requesting, hiring, or using NumWeb's products or services, you provide us, and we collect, some personal data related to you. From the moment you interact with NumWeb, we collect your personal data. In some cases, you directly provide your personal data to NumWeb, but we may also collect your data automatically.

By accepting the terms of this Privacy Policy, you expressly agree to provide only true, current, and accurate personal data and not to alter your identity or personal data in any way when accessing and using our products or services. You will be solely responsible for any false, outdated, or inaccurate information you provide directly to NumWeb.

These are your personal data processed by NumWeb, divided by categories:

Personal data provided by the data subject:

1. Registration data, including name
2. Contact data, such as address, phone number, and email

Browsing and device data:

1. Interactions performed and usage profile on NumWeb's websites and platform
2. Technical data, such as URL information, network connection, provider, and device information
3. Cookies
4. Device attributes, such as ID, operating system, browser, and model
5. Device geolocation data if you authorize collection from your device

Personal data originating from the use of our products and services:

1. Data on the location of the device that logs into the NumWeb platform

Public data

1. We may collect information about you that is publicly available or that has been made public by you
2. Information about mentions or interactions with NumWeb
3. Testimonials regarding NumWeb posted on social media profiles and pages, along with your name and image (including profile pictures)

THIRD CLAUSE - HOW NUMWEB USES YOUR PERSONAL DATA

NumWeb uses your personal data to provide a high-quality service and offer the best products to you. We detail below the purposes for which we use your personal data:

Purposes for personal data provided by the data subject:

1. Provision of services and offering of contracted products
2. Identification, authentication, and verification of requirements for hiring NumWeb's services and products
3. Handling requests and inquiries
4. Contact by phone, email, or other means of communication, for sending general communications, including notifications or push notifications about the use of NumWeb's services
5. Improvement of services provided by NumWeb
6. Marketing, prospecting, market research, opinion research, and promotion of our products and services, or those of our partners, including enabling offers and sending information about products, services, news, features, content, news, and other relevant events for maintaining the relationship with you
7. Account activation
8. Account deactivation or accounts not used for a long period
9. Prevention and resolution of technical or security issues
10. Regular exercise of NumWeb's rights, including presenting documents in judicial and administrative processes, if necessary
11. Collaboration or compliance with court orders, competent authorities, or regulatory bodies
12. Compliance with legal or regulatory obligations

Purposes for browsing and device data:

1. Provision of services, offering of contracted products, and improvement of the use and experience with NumWeb's website and platform
2. Operationalization of new products and services
3. Recommendation of new services, products, or platform features, including services from partners that may interest you
4. Generation of statistics, studies, research, and surveys relevant to the activities and behavior in the use of products or services
5. Prevention and resolution of technical or security issues
6. Geolocation data for better service
7. Regular exercise of NumWeb's rights, including presenting documents in judicial and administrative processes, if necessary
8. Collaboration or compliance with court orders, competent authorities, or regulatory bodies
9. Compliance with legal or regulatory obligations

Purposes for personal data originating from the use of our products and services:

1. Provision of services and offering of contracted products
2. Customer support and assistance
3. Improvement of services provided by NumWeb
4. Development of new products and services to be offered by NumWeb and generation of knowledge for innovation or development of new products
5. Testing for improvement of models and services and products of NumWeb
6. Marketing, prospecting, market research, opinion research, and promotion of our products and services, or those of our partners, including enabling offers and sending information about products, services, news, features, content, news, and other relevant events for maintaining the relationship with you
7. Prevention and resolution of technical or security issues and monitoring of use and performance of NumWeb's services and products
8. Regular exercise of NumWeb's rights, including presenting documents in judicial and administrative processes, if necessary
9. Collaboration or compliance with court orders, competent authorities, or regulatory bodies
10. Compliance with legal or regulatory obligations

Purposes for public data:

1. Disclosure of products and services provided by NumWeb on social media, websites, applications, or institutional and advertising materials
2. Regular exercise of NumWeb's rights, including presenting documents in judicial and administrative processes, if necessary
3. Collaboration or compliance with court orders, competent authorities, or regulatory bodies
4. Compliance with legal or regulatory obligations

FOURTH CLAUSE - SHARING OF PERSONAL DATA

NumWeb may share your data if you request it. The sharing of your data may also be done with third-party partners and with authorities and regulatory bodies for different purposes, when necessary. Whenever carried out, the sharing of data will be done within the limits and purposes of our business and in accordance with what is authorized by applicable legislation.

Below we have prepared a summary divided by categories with the types of providers with whom we normally share your personal data:

Purposes of sharing with business partners, service providers, and other third parties, such as information technology service providers, customer service providers, communication providers, statistical service providers, research providers, marketing providers, and payment providers:

1. Improvement of our services, website, and platform and operationalization of new products or services
2. Assistance in the provision of services
3. Contact by phone, email, push notifications, or other means of communication
4. Assistance in the development and offering of our products
5. Marketing, prospecting, market research, opinion research, and promotion of our products and services
6. Prevention and resolution of technical or security issues
7. Regular exercise of NumWeb's rights, including presenting documents in judicial and administrative processes, if necessary
8. Collaboration or compliance with court orders, competent authorities, or regulatory bodies
9. Compliance with legal or regulatory obligations

Purposes of sharing with authorities and regulatory bodies:

1. Investigations and measures for the prevention and combat of illegal activities, fraud, crimes, and ensuring the security of NumWeb's customers
2. Regular exercise of NumWeb's rights, including presenting documents in judicial and administrative processes, if necessary
3. Compliance with court orders, requests from competent authorities, or regulatory bodies
4. Compliance with legal or regulatory obligations

Purposes of sharing upon your request:

1. Ensure transparency in our relationship with you
2. Sending non-mandatory notifications via email and push notifications

In addition, when using our platform or browsing our websites, you may be redirected to third-party websites. After you are redirected to a third-party website, privacy practices will be governed by the privacy policies and terms of use of these third parties. We cannot control or be responsible for the privacy practices and content of third parties. Therefore, we emphasize that you can, at any time, block the use of cookies by activating a setting in your internet browser, and your ability to limit cookies will be subject to the settings and limitations of your browser. You can also delete existing cookies through the same settings in your internet browser. If you choose to disable cookies, you may continue browsing the website and platform, but some parts of the pages may stop working.

FIFTH CLAUSE - RETENTION AND DELETION OF YOUR PERSONAL DATA

While you are a Customer or Prospect of NumWeb, during the use of our products and services and for the entire period that NumWeb stores your personal data, they will be kept in a secure and controlled environment.

After the cancellation of the NumWeb account, all customer personal data is immediately deleted.

SIXTH CLAUSE - YOUR RIGHTS AS A DATA SUBJECT

From the effective date of the LGPD, you, as a data subject, can exercise your rights against the controllers of your personal data. We provide the detailed mechanisms below so that you clearly and transparently understand how to exercise your rights, and our team will be ready to handle any requests.

Confirmation of the existence of personal data processing:

The fact that you are a Customer of NumWeb already means that we process your personal data, even if this processing is, among other things, the storage of personal data in a secure and controlled environment. You can request NumWeb to confirm whether it processes your personal data.

Access to personal data:

You can request that NumWeb inform and provide the personal data it holds about you.

Correction of incomplete, inaccurate, or outdated personal data:

If you find that your personal data is incomplete, inaccurate, or outdated, you can request NumWeb to correct or complete it. For this, if it is not possible to make the change through the NumWeb platform itself, you will need to send a document proving the correct and current form of the personal data.

Anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data under the LGPD:

If any personal data is processed unnecessarily, excessively for the purpose for which it is intended, or in non-compliance with the LGPD, you can request NumWeb to anonymize, block, or delete such data, provided that the excess, lack of necessity, or non-compliance with the law is effectively verified.

Deletion of personal data processed with consent:

If you have given consent for the processing of your personal data for specific purposes (and not necessary for the provision of our services or delivery of our products), you may request the deletion of such personal data.

Information about the companies with which NumWeb has shared or from which it has received your personal data:

You can request NumWeb to inform you with which third parties it has shared or from whom it has received your personal data.

Information about the possibility of not providing consent and the consequences of refusal:

If your consent is necessary to access or use a specific product or service, you can ask NumWeb to clarify whether it is possible to provide this product or service without your consent for the processing of your personal data, or what the consequences of not providing consent are in this case.

Revocation of consent:

If you have given your consent for the processing of your personal data, you can request the revocation of this authorization. The revocation of consent may result in the inability to use some features of the platform, or even the termination of the services provided, but it does not prevent the use of (i) anonymized data; and (ii) data whose processing is based on another legal hypothesis provided for in the LGPD.

Portability and right to petition:

When the right to data portability is regulated by the National Data Protection Authority (ANPD), you may request NumWeb to port your personal data to another service provider. In addition, with the establishment of the ANPD, you will also have the right to petition regarding your data before the national authority.

If you wish to exercise any of these rights, please contact our Data Protection Officer (DPO) directly at dpo@numweb.com.br. To fulfill your rights, we may request proof of your identity as a security and fraud prevention measure.

You may exercise the rights described in this sixth clause from the date the LGPD comes into effect.

SEVENTH CLAUSE - ACTIVITY LOGGING

We may log the activities you perform when using our platform or website, creating, when possible and applicable, logs (records of activities performed on the websites and platform) that will contain: the IP address, access and actions performed by you on the service provided, date and time of each action performed, and information about the device used, such as the operating system version, browser, and geolocation.

We may also use certain technologies, either our own or third-party, to monitor the activities performed while you access our website or platform, such as:

Cookies: these are internet files that temporarily store what you are visiting on the network. NumWeb has cookies on its website and platform and also receives information from partners about cookies inserted on their respective websites. Cookies can be used for various purposes, including remembering you and your preferences, persisting information related to your activities on the visited website, or collecting information that can be used to offer content in a personalized way. Our websites may also use locally stored objects to provide certain content, such as video on demand, video clips, or animation.

We have third-party cookies enabled on our website and platform. Privacy practices will be governed by the privacy policies and terms of use of these third parties, so we cannot control or be responsible for the privacy practices and content of third parties. Therefore, we emphasize that you can, at any time, block the use of cookies by activating a setting in your internet browser, and your ability to limit cookies will be subject to the settings and limitations of your browser. You can also delete existing cookies through the same settings in your internet browser. If you choose to disable cookies, you may continue browsing the website and platform, but some parts of the pages may stop working.

Web beacon: Web beacon is a technique that allows mapping who is visiting a specific web page, identifying your behavior with different websites or web servers.

Analytics tools: These tools can collect information such as how you visit a website, including which pages and when you visit such pages, as well as other websites visited before, among others.

All technologies used by us will always respect the terms of this Privacy Policy.

EIGHTH CLAUSE - INTERNATIONAL TRANSFER OF PERSONAL DATA

Some of your personal data, or all of it, may be transferred abroad, for example when stored by NumWeb on cloud computing servers located outside Brazil. For this, NumWeb observes all requirements established by current legislation and adopts the best security and privacy practices to ensure the integrity and confidentiality of your personal data.

NINTH CLAUSE - SECURITY MEASURES

NumWeb uses various types of security measures to ensure the integrity of your personal data, such as information security standards practiced by the industry when collecting and storing personal data.

Personal data may also be stored through cloud computing technology and other technologies that may emerge in the future, always aiming at the improvement and enhancement of our services and security.

We treat the security of your personal data with the utmost care, using standards and best practices adopted in the market. We have a robust, highly qualified team responsible for ensuring that NumWeb adopts the best security practices, among them:

1. Security as code, to enable automation and quick and efficient responses to security events in the technological environment
2. Encryption for data at rest, in transit, and in use, to ensure the integrity of information
3. Continuous monitoring of the environment
4. Continuous analysis and testing of information security in our systems
5. Periodic audits

TENTH CLAUSE - CONSENT

Throughout this Privacy Policy, we inform you that some personal data will only be collected by NumWeb with your consent. Similarly, this personal data can only be processed with authorization and for the purposes described. This information is mainly in the second and third clauses of the Policy.

By reading this Privacy Policy and clicking, at the end, on 'I have read, I am aware of the conditions for the processing of my personal data and I give my consent, when applicable, as described in this Privacy Policy.', you consent to the processing of personal data in the forms indicated here.

It is worth remembering that the processing of your personal data is a necessary condition for us to provide our services and deliver our products to you. If you have any questions about any of the terms explained here, we are available through our support channels to assist you.

ELEVENTH CLAUSE - CHANGES TO THIS PRIVACY POLICY

NumWeb may change this Privacy Policy at any time. Whenever any relevant condition of this Privacy Policy is changed, these changes will be valid, effective, and binding after the new version is published on our website or sent to you by email.

Whenever a relevant change is made, we will send you a notice indicating the new version in force. By continuing to use our products and services after a change in the Privacy Policy, you will be agreeing to the new conditions – but you can always express your disagreement through our support channels, if applicable.

In cases where changes to this Privacy Policy result in changes in personal data processing practices that depend on your consent (see item 10 above), we will request your consent with the new terms of the Privacy Policy regarding the processing of data and the indicated purposes.

TWELFTH CLAUSE - CONTACT US

According to Law nº 13.709/2018, NumWeb is considered the 'Controller' of your personal data. If after reading this Privacy Policy you still have any questions, or for any reason need to communicate with us regarding matters involving your personal data, you can contact us through the channels below:

1. Chat on the NumWeb website and platform
2. Data Protection Officer (DPO): Email: dpo@numweb.com.br

We are always available to clarify your doubts and put you in control of your personal data.