Privacy Policy and Data Protection

1. WHO WE ARE

FCOGroup Intermediação de Negócios Ltda., registered under CNPJ No. 54.841.570/0001-33, with its registered office located at Rodovia SC-108, km 333.7, No. 4,205, Samuel Sandrini District, ZIP Code 88870-000, Orleans, Santa Catarina, Brazil, hereinafter referred to as FCOGroup, recognizes the importance of privacy, personal data protection, and transparency in its relationship with customers, suppliers, business partners, job applicants, investors, and users of its digital channels.

This Privacy and Data Protection Policy aims to clearly, transparently, and objectively explain how FCOGroup collects, uses, stores, shares, and protects personal data processed through its digital channels, in compliance with the Brazilian General Data Protection Law (LGPD – Federal Law No. 13,709/2018), other applicable legislation, and regulations issued by the Brazilian National Data Protection Authority (ANPD).

By accessing our website, completing forms, requesting information, contracting services, submitting résumés, or interacting with any of FCOGroup’s digital channels, you acknowledge that you have read and understood the practices described in this Privacy Policy.

2. WHAT IS THE LGPD?

The Brazilian General Data Protection Law (LGPD – Federal Law No. 13,709/2018) establishes rules governing the processing of personal data in both physical and digital environments, ensuring greater transparency, security, and control for data subjects.

The processing of personal data includes any operation performed on personal information, such as collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, storage, deletion, evaluation, modification, communication, transfer, and sharing.

FCOGroup conducts all personal data processing activities in accordance with the LGPD principles of purpose, adequacy, necessity, free access, data quality, transparency, security, prevention, non-discrimination, and accountability.

3. WHAT PERSONAL DATA DO WE COLLECT?

FCOGroup may collect personal data directly provided by you or automatically collected during your use of our digital channels.

Information Provided by the Data Subject

We may collect:

• Full name;
• Company name;
• Job title;
• CPF or CNPJ (Brazilian Individual or Corporate Tax Identification Number);
• Address;
• City;
• State;
• ZIP Code;
• E-mail address;
• Telephone number;
• Business unit or company of interest;
• Subject of your inquiry;
• Content of messages submitted through our forms;
• Résumé/CV and professional information;
• Other information voluntarily provided.

Information Collected Automatically

While browsing our website, we may automatically collect:

• IP address;
• Date and time of access;
• Web browser information;
• Operating system;
• Device type;
• Pages visited;
• Time spent on the website;
• Traffic source;
• Browsing information;
• Cookies;
• Pixel Tags;
• Web Beacons;
• Similar technologies.

4. HOW DO WE USE YOUR PERSONAL DATA?

Your personal data may be used to:

• Respond to requests submitted through our website;
• Answer questions, suggestions, and complaints;
• Prepare quotations and commercial proposals;
• Manage business opportunities;
• Maintain relationships with customers, suppliers, and business partners;
• Provide commercial assistance;
• Forward inquiries to other companies within the group when appropriate;
• Send institutional communications;
• Send newsletters;
• Send marketing emails;
• Promote events, trade shows, and product launches;
• Share technical materials;
• Conduct customer satisfaction surveys;
• Manage recruitment and hiring processes;
• Improve our services and digital channels;
• Comply with legal and regulatory obligations;
• Exercise legal rights in administrative, judicial, or arbitration proceedings.

5. LEGAL BASIS FOR DATA PROCESSING

FCOGroup processes personal data based on the legal grounds established by the LGPD, including:

• Consent of the data subject;
• Performance of a contract or pre-contractual procedures;
• Compliance with legal or regulatory obligations;
• Exercise of legal rights;
• Legitimate interest;
• Credit protection, where applicable.

6. CRM, MARKETING AUTOMATION, AND COMMUNICATIONS

FCOGroup may use Customer Relationship Management (CRM) platforms, marketing automation tools, behavioral analytics solutions, and e-mail marketing platforms to organize, store, and manage relationships with customers, partners, and prospects.

These platforms may be used for:

• Customer relationship management;
• Lead registration and qualification;
• Recording customer interaction history;
• Audience segmentation;
• Lead nurturing;
• Business opportunity tracking;
• Sending institutional campaigns;
• Sending promotional campaigns;
• Invitations to events;
• Distribution of technical content;
• Measuring campaign performance.

You may unsubscribe from these communications at any time by using the unsubscribe link available in our e-mails or by contacting us directly.

7. SHARING OF PERSONAL DATA

Personal data may be shared, when necessary, with:

• Companies belonging to the FCOGroup;
• Information technology service providers;
• CRM platforms;
• Marketing automation platforms;
• E-mail marketing platforms;
• Website hosting providers;
• Cloud storage providers;
• Website analytics providers;
• Law firms;
• Audit firms;
• Business partners;
• Administrative, judicial, or governmental authorities whenever legally required.

All third parties engaged by FCOGroup are contractually required to maintain confidentiality and protect the personal data they process.

8. INTERNATIONAL DATA TRANSFERS

Some technology providers engaged by FCOGroup may process or store personal data on servers located outside Brazil.

Whenever international data transfers occur, FCOGroup will adopt appropriate technical, administrative, and contractual safeguards to ensure compliance with the LGPD and maintain an adequate level of data protection.

9. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

Personal data will be retained only for as long as necessary to fulfill the purposes described in this Privacy Policy, while complying with applicable legal, regulatory, tax, contractual, and litigation requirements.

When there is no longer a legitimate need to retain personal data, it may be securely deleted, anonymized, or blocked in accordance with applicable legislation.

10. YOUR RIGHTS AS A DATA SUBJECT

Under the LGPD, you have the right to request:

• Confirmation that your personal data is being processed;
• Access to your personal data;
• Correction of incomplete, inaccurate, or outdated information;
• Anonymization, blocking, or deletion of unnecessary or unlawfully processed data;
• Data portability;
• Information regarding data sharing;
• Withdrawal of consent;
• Deletion of personal data processed based on consent;
• Review of decisions made solely through automated processing;
• Objection to data processing where applicable.

Requests may be submitted at any time through the contact channel provided in this Privacy Policy.

11. RIGHT TO ERASURE

You may request the deletion of your personal data whenever there is no legal obligation or other lawful basis requiring its retention.

If complete deletion is not legally possible, FCOGroup will inform you of the legal grounds requiring continued retention of your information.

12. INFORMATION SECURITY

FCOGroup adopts appropriate technical, administrative, and organizational measures to protect personal data against:

• Unauthorized access;
• Improper alteration;
• Unauthorized disclosure;
• Loss;
• Destruction;
• Data breaches;
• Security incidents.

These measures include:

• Access control systems;
• Continuous monitoring of technological environments;
• Permission management;
• Internal information security policies;
• Employee awareness and training;
• Confidentiality agreements;
• Incident response procedures.

Although FCOGroup adopts industry best practices, no technological environment can be considered completely immune to security risks.

Should any incident occur that may pose a significant risk to data subjects, FCOGroup will take all necessary mitigation measures and notify affected individuals whenever required by applicable law.

13. COOKIE POLICY

FCOGroup uses cookies and similar technologies to:

• Ensure the proper operation of the website;
• Improve the browsing experience;
• Remember user preferences;
• Measure website performance;
• Generate website usage statistics;
• Personalize content;
• Evaluate marketing campaigns.

Cookies may be classified as follows:

Strictly Necessary Cookies

Essential for the proper operation of the website.

Performance Cookies

Used to analyze website usage and improve performance.

Functional Cookies

Allow the website to remember user preferences.

Marketing Cookies

Used to personalize advertising campaigns and measure their effectiveness.

Users may accept, reject, or customize their cookie preferences through the tools available on the website or through their browser settings.

14. LINKS TO THIRD-PARTY WEBSITES

Our website may contain links to third-party websites.

FCOGroup is not responsible for the privacy practices, content, or policies of third-party websites. We encourage users to review the privacy policies of any external websites before providing personal information.

15. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect legal, regulatory, technological, or operational changes.

Whenever significant changes are made, users will be informed through appropriate communication channels.

The most current version of this Privacy Policy will always be available on our website.

16. DATA PROTECTION OFFICER (DPO)

If you have any questions regarding this Privacy Policy or wish to exercise any of your rights under the LGPD, please contact our Data Protection Officer (DPO).

E-mail: dpo@fcogroup.com.br

FCOGroup will review and respond to all requests within the deadlines established by applicable law.