Introduction

Esta Política de Privacidade descreve as práticas da GAAP CorpServices Group com respeito às informações coletadas dos usuários que acessam nosso site em www.gaap.com.br ou que, de outra forma, compartilham informações pessoais conosco (coletivamente: “Usuários”).

Fundamentals of data collection

The processing of your personal information (i.e. all information that could potentially allow your identification with reasonable means; hereinafter, the "Personal Information") is necessary for the performance of our contractual obligations to you as well as to provide our services, to protect our legitimate interests, and to comply with legal and financial regulatory obligations to which we are subject.

When you use the Site, you agree to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to read the Privacy Policy and use it to make informed decisions.

What information do we collect?

We collect two types of data and information from Users.

The first type of information is unidentified and non-personally identifiable information relating to a User that becomes available or is collected through use of the Site ("Non-Personal Information"). We do not know the identity of a User from whom Non-Personal Information has been collected. Non-Personal Information being collected may include your aggregate usage information and technical information transmitted by your device, including certain software and hardware information (e.g., type of browser and operating system your device uses, language preference, access time, etc.) in order to improve the functionality of our Site. We may also collect information about your activity on the Site (e.g. pages viewed, online navigation, clicks, actions, etc.).

The second type of information is Personal Information, which is individually identifiable information, that is, information that identifies an individual or can with reasonable effort identify an individual. Such information includes:

Device Information: We collect personal information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) and other information that relates to your activity through the Site.

Registration Information: When you register on our Site, you will be asked to provide us with certain information, such as your full name, e-mail or physical address, and other information.

How can we receive information about you?

We receive your Personal Information from a variety of sources:

When you voluntarily provide us with your personal data when you register on our Site;

When you use or access our Site as part of your use of our services;

From external vendors, services and public records (e.g. traffic analysis vendors).

What information do we collect?

We do not rent, sell, or share user information with third parties except as described in this Privacy Policy.

We may use the information for the following:

• To communicate with you - sending notices regarding our services, providing technical information, and responding to any customer issues you may have;
• To communicate with you and keep you informed of our latest updates and services;
• To serve you advertisements when you use our Site (see more under "Advertisements");
• To market our sites and products (see more under "Marketing");
• For statistical and analytical purposes in order to improve the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliates and subcontractors.

In addition to the purposes mentioned in this Privacy Policy, we may share personal information with our trusted third party providers, who may be located in different jurisdictions around the world, for any of the following purposes:

• Hosting and operation of our Site;
• Providing our services to you, including providing a customized display of our Site;
• Storing and processing such information;
• Serving you with ads and helping us evaluate the success of our advertising campaigns, as well as retargeting some of our users;
• Provide you with marketing offers and promotional materials regarding our Site and services;
• Conducting research, technical or analytical diagnostics.

We may also disclose information if we, in good faith believe that disclosure of such information would be useful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) to prevent damage to the rights, property or safety of us, our users, your own safety or the safety of others; or (vi) for the purpose of cooperating with law enforcement authorities and/or if we feel it is necessary to enforce intellectual property or other legal rights.

User Rights

You can request for:

Receive confirmation that non-personal information about you is or is not being processed and access to your stored personal information along with supplemental information.

To receive a copy of the personal information that you have voluntarily and directly provided to us in a commonly used, structured, machine-readable format.

Request rectification of your personal information that is under our control.

Request the deletion of your personal information.

Deny the processing of your personal information by us.

Request to restrict the processing of your personal information by us.

Make a complaint to a supervisory authority.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the above rights or would like to receive more information, please contact our Data Protection Office ("DPO") using the details provided below: contato@gaap.com.br

Retention

We will retain your Personal Information for as long as necessary to provide our services and as needed to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information collected and the purpose for such collection, taking into account the applicable requirements for the situation and the need to destroy outdated, unused information in the nearest reasonable time. Under applicable regulations, we will maintain records containing personal customer data, account opening documents, communications and anything else in accordance with applicable laws and regulations.

We may correct, amend or remove incomplete or inaccurate information at any time at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A cookie is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very useful and can be used for many different purposes. Such purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making interaction between you and our services faster and easier. Cookies are also used to help ensure that the ads you see are relevant to you and your interests, and to compile statistical data about your use of our services.

The Site uses the following types of cookies:

• a. "session cookies" which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed;
• b. "persistent cookies", which are only read by the Site, are saved on your computer for a fixed period and are not deleted when you close your browser. These cookies are used when we need to know who you are for repeat visits, for example, to allow us to store your preferences for next time access;
• c. "third party cookies", which are set by other online services that run the content on the page you are viewing, for example, third party analytics companies that monitor and analyze our web access.

Cookies do not contain information that personally identifies you, but personal information that we store about you may be linked by us to information stored in and obtained from cookies. You can remove cookies by following the instructions in your device preferences; however, if you choose to disable cookies, some features of our Site may not function properly and your online experience may be limited.

We also use a tool called "Google Analytics" to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, which pages they visit when they visit, etc. We use the information we obtain from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit the Sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share the information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Collection of information from third parties

Our policy only addresses the use and disclosure of information that we collect from you. To the extent that you disclose your information to other parties or sites throughout the Internet, different rules may apply to your use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each party to which you choose to disclose information.

This Privacy Policy does not apply to practices of companies that we do not own or control, or to individuals that we do not employ or manage, including third parties to whom we may disclose information as set forth further in this Privacy Policy.

How can we protect your information?

We take great care in implementing and maintaining the security of the Site and your information. Security practices such as: we employ industry standard procedures and policies to ensure the security of the information we collect and retain, prevent unauthorized use of any information, and require any third parties to comply with similar security requirements in accordance with this Privacy Policy]. While we take reasonable steps to protect information, we cannot be responsible for the acts of anyone who gains unauthorized access to or misuses our Site, and we make no warranty, express or implied, that we will prevent such access.

Data transfer outside the EEA

Please note that some data recipients may be located outside the EEA. In such cases, your data will be transmitted only to countries approved by the European Commission ensuring an adequate level of data protection, or we will enter into legal agreements ensuring an adequate level of data protection.

Announcements

We may use a third-party advertising technology to serve ads when you access the Site. This technology uses information about your use of the Services to serve ads to you (e.g., by placing third party cookies in your web browser).

You may opt out of many third party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, as well as your choices about having this information used by these companies, including how to opt out of third party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information such as name, e-mail address, phone number, etc. ourselves or using our third party subcontractors for the purpose of providing you with promotional materials regarding our services, which we believe may be of interest to you.

Out of respect for your right to privacy, we provide you within such marketing materials with means to opt-out of receiving further marketing offers from us. If you unsubscribe, we will remove your e-mail address or phone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving marketing e-mails from us, we may issue other types of important e-mail communications without offering you the opportunity to opt-out of receiving them. These may include customer service announcements or administrative notices.

Corporate Transactions

We may share information in the event of a business transaction (e.g., the sale of a substantial part of our business, merger, consolidation, or sale of assets). In the above case, the transferee or acquiring company will assume rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children's privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances should we allow minors to use our services without prior consent or authorization from a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without his or her consent, he or she should contact us at contato@gaap.com.br.

Updates or Changes to this Privacy Policy

We reserve the right to periodically modify or revise the Privacy Policy; changes to the material will be effective immediately upon display of the revised Privacy Policy. The latest revision will be reflected in the "Last Modified" section. Your continued use of the Platform following notice of such changes on our site constitutes your confirmation of and consent to such changes to the Privacy Policy and your agreement to be bound by the terms of such changes.

How to contact us

If you have general questions about the Site or the information we collect about you and how we use it, please contact us at contato@gaap.com.br .