AZ4 Group

AZ4 cares about your privacy and is committed to preserving it. The processing of personal data related to your access to and use of the Platform is described in this Privacy Policy, which is part of AZ4’s Terms of Use. You should read the following conditions carefully and attentively, as they contain important information about access to or use of the Platform. This Policy may be modified, replaced or removed at any time, without prior notice. If you do not agree with a new version of this Policy, you must cease using the AZ4 website. This Policy and its respective updates prevail over any proposals, contracts, understandings and agreements, whether oral or written, that may exist between you and AZ4, especially regarding privacy or personal data.

OVERVIEW

1. This Privacy Policy establishes the rules on (a) how and for what purposes your personal data may be processed by AZ4, (b) with whom such data may be shared, and (c) how Users may manage their personal data. It applies to the use of or access to the Platform through the AZ4 website and its subdomains, as well as through other websites, interfaces or applications on which AZ4 makes its resources available, including our mobile, tablet or other electronic device applications.
2. To make this Policy easier to read, it is important that you understand the specific meaning of the following three expressions, used in the context of privacy protection and written in the Terms, this Policy or other AZ4 Policies without capital letters:

“Personal data”, in the singular or plural, means any information that identifies the User or that makes it possible to identify him/her. Therefore, as generic as this may seem, personal data can be any information that directly identifies you or any information that functions as a piece of the puzzle that leads to your identification. “Processing”, as well as the verb “to process”, means any operation performed with personal data, such as those related to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation, control, modification, communication, transfer, dissemination or extraction.

1. WHAT PERSONAL DATA IS PROCESSED BY AZ4

PERSONAL DATA. The Personal Data processed by AZ4 may vary depending on the type of interaction between the User and the Platform. This personal data may be collected directly from the User, obtained through third parties or collected automatically. Personal data may include: (a) registration information, such as email, full name, address, telephone number, cell phone number, CPF, RG, CNH, profile photo and passport; and (b) banking information, such as the name of the financial institution in which the User has a bank account, account number, account type, branch, IBAN and credit card details, including the name of the holder, expiration date and CVV code.

1.1. Personal Data collected directly from the User. AZ4 may collect personal data directly from you, relating to registration information and banking information.

1.1.1. “Offline” interaction. AZ4 may collect personal data when you interact with AZ4 by means other than accessing the Platform, such as, for example, when you participate in an event organized by AZ4 or an event organized by a third party whose activity is contractually linked to AZ4.

1.1.2. Optional fields. The Platform may make certain fields available for optional completion. These fields are highlighted as optional and are intended to improve the personalization of the content made available to the User.

1.1.3. Public data. AZ4 considers some personal data to be public because it can be viewed by anyone, both on and off the Platform, even if that person does not have an account on the Platform. Information that you enter in fields marked with the “public data” warning is considered public data. You, other people who use the Platform, and AZ4 itself may provide access to or send public data to anyone on and off the Platform. You may also view, access, re-share, or download public data through third-party tools such as search engines, APIs, and offline media, or through applications, websites, and other Third-Party Services.

1.2. Personal data obtained from third parties. AZ4 may have access to certain personal data through third parties, whether registration or banking information. This happens, for example, when, due to compliance with a legal or regulatory obligation, AZ4 needs to consult databases maintained by third parties that enable the analysis of credit restrictions, anti-fraud analyses and other risk management analyses integrated into the Platform.

1.2.1. AZ4 also collects registration information through third parties when you link, connect or log in to the Platform through a Third Party Service (for example, Facebook).

1.2.2. AZ4 may also have access to registration information through third parties for registration in events, surveys, advertising campaigns and other activities organized by these third parties, whose activity is contractually linked to AZ4.

1.3. Personal Data collected automatically when accessing the Platform. Personal data is collected automatically when you access the Platform, even if you do not have an account on the Platform. This information may include the information exemplified below.

1.3.1. Access or usage information: pages and content you view; searches for advertisements; frequency of use of the Platform; browser information; connection data; purchase history and browsing history.

1.3.2. Log data and device information: details about how you accessed and used the Platform (including links accessed); IP address; access dates and times; hardware and software information; device information; device event information; unique identifiers (e.g. AZ4 ID); crash data; cookie data and the pages you viewed or interacted with before and after accessing or using the Platform.

1.3.3. Cookies, pixel and similar technologies, as described in our Cookie Policy.

2. WHAT PERSONAL DATA IS PROCESSED ON BEHALF OF THIRD PARTIES

2.1. Processing of Personal Data at the Request of Third Parties. There is personal data that is processed by AZ4 at the request of third parties. AZ4 processes this personal data following rules formalized with these third parties through written contracts.

2.2. Responsibility for Processing Personal Data by Third Parties. The third parties mentioned in the previous items are also data processing agents responsible for personal data within the context of offering their products and services.

3. WHAT ARE THE PURPOSES OF PROCESSING PERSONAL DATA

3.1. Purposes of Processing User Personal Data. AZ4 uses personal data for the following purposes:

3.1.1 Provide and develop the Platform:

• Personalize the Platform according to browsing experience
• Conduct analyses and studies related to behavior, interest, and demographics
• Improve the Platform
• Archive purchase history
• Update registration
• Send messages, updates, and account notifications
• Perform user support activities

3.1.2. Provide and optimize advertising and marketing activities

• Send newsletters
• Send communications via email, SMS, or phone recordings
• Send educational materials or e-books
• Conduct media campaigns focused on advertising and promotions
• Manually send lists to media platforms (Facebook and Google)
• Send communications such as email marketing, remarketing, and other advertising campaigns on media channels
• Analyze browsing behavior to optimize the Platform and offer products and services

3.1.3. Maintain a secure environment

• Authenticate users on the Platform
• Verify the authenticity of the provided data and documents, including cross-checking
• Send notifications
• Conduct analysis to prevent fraud, security incidents, and abuse on the Platform
• Verify registration
• Check content

3.2. Purposes of Processing Visitor Personal Data. AZ4 may collect personal data from Platform visitors for the following purposes:

• Media campaigns focused on advertising and promotions
• Send communications such as email marketing, remarketing, and other advertising campaigns on media channels
• Analyze browsing behavior on the Platform
• Register for events
• Send newsletters
• Send communications via email, SMS, or phone recordings
• Send educational materials or e-books

4. LEGAL BASES FOR PROCESSING

4.1. Legal Bases. The processing of personal data carried out by AZ4 is always based on a legal foundation provided for in applicable laws. The legal bases used by AZ4 may vary depending on the context of processing. Below are the legal bases used:

4.1.1. Consent. When the User expressly accepts the processing of personal data, such as agreeing to receive newsletters, promotional communications, or surveys. This consent can be revoked by the User at any time.

4.1.2. Compliance with legal or regulatory obligations. When AZ4 is required to process personal data due to legal or regulatory obligations, such as using third-party tools to perform credit assessments of Users. In this scenario, automated decisions may be made to analyze the possibility of early payment on the Platform.

4.1.3. Execution of a Contract or related procedures. When AZ4 is required to process personal data due to the applicable Contract between AZ4 and the User.

4.1.4. Regular exercise of rights in judicial, administrative, or arbitration proceedings. When there is a need to process personal data due to judicial action, administrative proceedings, or arbitration.

4.1.5. Legitimate interest. When AZ4 decides to proceed with processing personal data after careful analysis involving the evaluation of the purpose and necessity of the processing for the User, the User’s expectations regarding personal data processing, and the preparation of necessary legal documentation. This legal basis is used when, for example, AZ4 sends a newsletter related to the User’s interests based on their interaction with the Platform. In such cases, AZ4 always provides the User with the option to unsubscribe from these communications.

5. RETENTION PERIOD OF PERSONAL DATA

5.1. Processing Period. Personal data is processed by AZ4 until at least one of the following conditions is met. These are:

• Achievement of the processing purpose
• Personal data is no longer necessary or relevant to achieve the specific purpose
• The User exercises their right to revoke consent in cases where personal data processing was based on this legal basis
• Any penalties imposed by the authority responsible for overseeing, enforcing, and ensuring compliance with applicable legislation or other competent bodies

5.2. Retention of Personal Data. In certain situations, AZ4 and its partner third parties may residually retain personal data even after the termination conditions for processing are met, due to compliance with legal or regulatory obligations, or when there is a legitimate purpose for AZ4 or these third parties. In such cases, personal data will be stored securely with restricted access and retained for the time necessary to fulfill the legal or regulatory obligation or to achieve AZ4’s and the third parties’ legitimate purpose.

6. SHARING OF PERSONAL DATA

6.1. Sharing. AZ4 may share personal data with third parties. These third parties sign written agreements with AZ4 and are aware of their responsibilities at each stage of processing, especially the obligation to implement security measures that meet contractual and legal requirements. Sharing may occur, for instance, in the scenarios described below:

6.1.1. User Consent. When you provide your consent, we share your information as described at the time of consent – for example, by authorizing the transfer of personal data to third parties to facilitate participation in events.

6.1.2. Compliance with the law, harm prevention, and safety. When there is a need to share personal data with third parties to (a) prevent fraud (e.g., money laundering risk analysis), which may involve automated decisions; (b) check user restriction lists; (c) authenticate submitted documentation; (d) enable support services; (e) avoid illegal activities; (f) address disputes between Users; (g) address internal investigations regarding any conduct that may violate AZ4’s Terms or Policies.

6.1.3. Response to legal requests. In certain cases, if necessary, AZ4 may provide the collected data to entities involved in investigating or resolving disputes between Users, or between Users and third parties, such as judicial authorities, arbitration tribunals, or competent administrative authorities.

6.1.4. Service Providers. AZ4 may also share your personal data with third parties involved in financial, accounting, legal advisory activities, non-profit activities, potential investors, as well as third parties involved in data backup services, cloud computing providers, or for analytical studies.

7. INTEGRATIONS AND THIRD-PARTY PARTNERS

AZ4 may, in certain cases, link third-party services to the Platform through application programming interfaces (APIs), such as the YouTube API. These third-party services are not part of AZ4’s services and are not part of the Platform, being subject to different terms and conditions, such as the YouTube Terms of Service and Google Privacy Policy. AZ4 is not responsible for these services, and when you interact with them, you are directly providing your personal data to them.

8. RIGHTS REGARDING YOUR PERSONAL DATA

8.1. Requests: You can submit a request related to your rights provided under applicable laws. These rights may include requesting confirmation of personal data processing, access to personal data, rectification of personal data, and deletion of personal data, which must be done by sending an email directly to AZ4.

9. SECURITY

9.1. Security Measures. AZ4 employs the necessary technical and organizational security measures to protect personal data. The efforts aim to mitigate the risks of accidental or illegal destruction, loss, alteration, unauthorized disclosure or access, or any other illegal or unauthorized processing. To this end, AZ4 uses strict access controls, based on the principle of least privilege, to its information technology systems to protect personal data against any security incidents.

10. PROCESSING OF MINORS’ PERSONAL DATA

10.1. Minors’ Personal Data. AZ4 does not knowingly collect or solicit personal data from minors under the age of 13. If we become aware that personal data from a minor under 13 has been collected, we will cancel the account created on the Platform and delete the personal data, retaining only the personal data necessary to prevent another attempt at registration.

11. CONTACT INFORMATION

If you wish to contact us to report any difficulties, make a request, or simply learn more about how we handle your data, we will be happy to assist you via email: faleconosco@az4.com.br