PERSONAL DATA PROTECTION AT IMEK

PERSONAL DATA PROTECTION AT IMEK

PRIVACY POLICY IMEK

PRIVACY POLICY IMEK

We at IMEK are committed to the privacy of our customers, employees, and third parties who maintain relationships of any kind, and we are committed to preserving it.

Therefore, this Privacy Policy aims to explain how your personal data is treated in a simple and transparent manner.

1.WHAT IS OUR PURPOSE WITH THIS DOCUMENT AND OUR COMMITMENT TO YOU?
IMEK acknowledges the need to protect your information and personal data.

We need your personal data to provide some of our services and we understand how important they are to you.In this way, we are committed to processing all electronic records and personal data that we receive from you when using our website, in-person service, or any other official communication means established by IMEK, responsibly and in compliance with the General Data Protection Law (LGPD - Law 13,709/2018).

The goal here is to inform how the personal data of our clients, employees, and third parties are treated, including the use of our website, social media,

SUMMARY: Privacy Policy and Personal Data Protection

SUMMARY: Privacy Policy and Personal Data Protection

2. SYNTHESIS
To better illustrate how we treat data, we present a summary of our Privacy Policy and Personal Data Protection below:
DATA PROCESSOR IMEK
ROLE IN THE PROCESSING OF PERSONAL DATA Predominantly PERSONAL DATA CONTROLLER, making decisions regarding the processing carried out.
NATURE OF PERSONAL DATA PROCESSED Personal data provided by the data subject and/or collected automatically.
MAIN PURPOSES OF PROCESSING IMEK may use personal data to provide its products and services such as registration data, geolocation data, and others.

SHARING Operators, essential service providers for our activities and affiliates; other companies in the group; authorities/governmental bodies due to legal or regulatory obligations.
DATA PROTECTION Security measures, technical and administrative implemented.

YOUR RIGHTS Confirmation of processing, access, correction of incomplete, inaccurate, or outdated data, among others, with a specific platform created for the exercise of such rights.

3. IMPORTANT DEFINITIONS
PERSONAL DATA Any information related to a natural person, directly or indirectly, identified or identifiable.

SENSITIVE PERSONAL DATA Special category of personal data concerning racial or ethnic origin, religious belief, political opinion, membership of a trade union or religious, philosophical or political organization, health or sex life, genetic data or biometric data relating to a natural person.
SUBJECT Natural person to whom the personal data refers, for example, former, current, or potential customers, employees, business partners, and third parties.

PROCESSING Any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, disposal, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.
CONSENT Free, informed, and unequivocal expression by which the data subject agrees to the processing of their personal data for a specific purpose.
CONTROLLER Natural or legal person, public or private, who is responsible for decisions regarding the processing of personal data.
OPERATOR Natural or legal person, public or private, who processes personal data on behalf of the controller.
NATIONAL DATA PROTECTION AUTHORITY Public administration body responsible for ensuring, implementing, and overseeing compliance with this Law throughout the national territory.

HOW WE USE THE DATA

HOW WE USE THE DATA

4. WHAT PERSONAL DATA IS COLLECTED?
o To provide our services and sell our products and services, we need certain information about you. Some of this information you provide directly to us, such as when you register on our platforms, like name, email, and other data, or when you make a purchase at one of our units. In summary, the data we collect from you is registration information;

o In some cases, we may also collect gender; age; date and place of birth; profession, information available on social media in public mode; financial information; certificates for hiring purposes and credit analysis;

o Other information is provided by third parties or collected automatically, through Cookies and third-party plug-ins sent to your browser. Some are strictly necessary for the operation of our site, others we use to obtain analyses of browsing patterns for continuous improvement of content, always with your knowledge and acceptance (cookie terms);

o It is also important for you to know that it is possible to disable, through your internet browser settings, the automatic collection of information through some technologies, such as cookies and caches. However, you should also know that, once these technologies are disabled, some of the features offered by our platforms, which depend on the processing of said data, may not work properly.

5. HOW ARE THE DATA COLLECTED AND PROCESSED?

o Your data may be collected through various channels, considering how you became a customer of IMEK or maintained some form of relationship with the company, such as provision of services or employment relationship. The collection can take place in printed form, through forms you fill out, contracts signed with the company, or in automatic electronic format and through mail, email, telephone, which may include, but not be limited to:
- purchase of a product or service from IMEK;
- submission of resumes;
- formalization of employment contract or provision of services;
- registration on electronic portals, such as websites;
- advertising campaigns on social networks and on our website, in which we use cookies and similar technologies to collect data to recognize you and/or your device(s) and how you interacted with our products and services.

About Personal Data Protection

About Personal Data Protection

7. HOW WILL YOUR PERSONAL DATA BE PROTECTED?

o IMEK is committed to taking all types of preventive administrative, technical, and physical security and privacy measures during the execution of its activities involving personal data, from training and awareness of employees, to the use of advanced encryption technologies and firewalls.
o It adopts existing security policies, mechanisms, and procedures for the protection of personal data and accidental or unlawful events involving destruction, loss, alteration, communication, or dissemination.

o We adjust and implement a management of unauthorized access to internal systems, with access restricted to the location where information and personal data are stored. In addition, those who have access to personal data of data subjects are committed to maintaining confidentiality, with the implementation of institutional information security measures.

o All available precautions are taken unrestrictedly by IMEK to ensure that the collected information is stored securely, with security systems compatible with market standards. However, it is possible that there may be a security incident involving personal data, and if this eventually occurs, all possible measures will be taken within our capacity to remedy any consequences, ensuring you the necessary transparency and communication, depending on the level of criticality of the incident.
o In addition to these points, we also focus on educating and raising awareness among our employees, with continuous training on the importance of privacy and personal data protection, always ensuring internal controls and confidentiality obligations.

8. WITH WHOM CAN THE DATA BE SHARED?
o The data collected in the various areas of IMEK will not be commercialized or transferred.

o They may be shared with other companies of the same group, if necessary, always aiming to better serve you, in order to fulfill the purposes expressed in this document.

o They may also be shared with data processors, companies that may process them according to the purposes defined here.

o The data may be shared with authorities, government, or third parties, always aiming to protect IMEK's interests in case of any judicial or administrative conflict, as provided by law.

o Some service providers, data processors, or data processors may receive personal data, and they will always act in accordance with IMEK's guidelines, committed to this Policy, adopting organizational and technical measures with the required security levels for the protection of privacy and personal data obtained.

o In cases of merger, acquisition of the company, or joint venture, the data may be shared with potential acquirers for the respective legal structuring of the operation.

o Personal data such as name, phone, and email may be shared with third-party platforms (personal data processors) to enable the sending (via email, SMS, WhatsApp, among others) of our content to you, the data subject.

o Credit assessment companies, for authentication, fraud prevention, and credit protection purposes

9. FOR HOW LONG WILL PERSONAL DATA BE STORED?

o IMEK adopts the following personal data retention policy:
? Personal data will be processed by IMEK in accordance with applicable law, being retained only in legal cases and only for the period necessary to achieve lawful, specific, and informed purposes, such as accountability and compliance with legal or regulatory obligations, as per applicable provisions.
? Data will be deleted whenever you request deletion, and IMEK accepts and processes your request.
? It is also important to clarify that, even with the purpose of deleting unnecessary data or the data subject's intention, IMEK may preserve the information required to comply with legal and regulatory obligations or for the regular exercise of our rights. Therefore, we reserve the right to keep the data in situations where there is a legal obligation to do so, as well as for the preservation of health and life or when there is still a contractual relationship that requires data processing.
? In summary, your data will be stored: (i) for the time required by law; (ii) until the end of personal data processing; or (iii) for the time necessary to preserve IMEK's legitimate interests.

ABOUT DATA ACCESS

ABOUT DATA ACCESS

10. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?
o Law No. 12,965/2014 (Brazilian Civil Rights Framework for the Internet) and other laws already guarantee that you, as the holder of personal data, obtain clear information about the collection, use, storage, and protection of personal data on the internet (article 7, VIII).
o The LGPD expanded these rights (article 18) by indicating that you, as the data subject, may make requests, at any time, regarding the following rights:

CONFIRMATION Confirmation of the existence of the processing of personal data.
ACCESS Access to your personal data processed by IMEK.
RECTIFICATION Rectification of incomplete, inaccurate, or outdated data.
ANONYMIZATION, BLOCKING, OR ELIMINATION Of unnecessary, excessive, or data processed in noncompliance with the General Data Protection Law.

PORTABILITY Portability of data to another service or product provider, upon express request, in accordance with the regulations of the National Data Protection Authority, always observing trade and industrial secrets.

ELIMINATION Elimination of personal data processed with the consent of the data subject, except in cases of compliance with a legal or regulatory obligation by the controller and for research purposes, ensuring the anonymization of personal data whenever possible.

TRANSFER Transfer to a third party provided that the data processing requirements set forth in the General Data Protection Law are respected or for the exclusive use of the controller, with data anonymization.

INFORMATION Information about public and private entities with which the controller has shared data. Information about the possibility of not providing consent and the consequences of refusal.
CONSENT REVOCATION Revocation of consent, through a free and facilitated procedure, maintaining the validity of treatments carried out under the previously given consent.

o All of these rights can be exercised through IMEK's PRIVACY CENTER, with specific tools for this purpose.

10.1. HOW CAN YOU EXERCISE YOUR RIGHTS AS A DATA SUBJECT?
o If you have any questions, please contact the Data Protection Officer via email at privacy@imek.com.br, informing which actions you wish to take (confirm data existence, access, migrate, edit, anonymize, delete, revoke consent). You must also prove ownership of the data by sending an official photo ID.

o The complete deletion of personal data can only be done in relation to data that is not necessary for IMEK to comply with legal or contractual obligations, to protect its legitimate interests, and in other cases legally admitted.

11. WHY DO WE USE COOKIES?
o Cookies are files or information that may be stored on your devices when you visit our website or use one of our platform channels. These files contain information used to identify the visitor, either to personalize the page according to the profile or to facilitate data transport between the pages of the same site.

o IMEK adopts an ethical and transparent policy regarding the use of cookies, using them to improve performance and enhance your user experience on our platforms. Some types of cookies we use:
- ESSENTIAL - These are essential for IMEK's websites to load and function properly. They allow navigation on the site and the use of its applications, such as accessing secure areas of the site through login. Without these cookies, the services that require them cannot be provided.
- PERFORMANCE - These help us understand how visitors interact with the pages, providing information about visited areas, time spent on the site, and any issues encountered, such as error messages.
- FUNCTIONAL - Allow IMEK's pages to remember your choices and provide a personalized experience. User preferences are stored so that it is not necessary to reconfigure the site each time you visit. For example, cookies prevent the need to enter the user's name each time they access the site.
- MARKETING - Used to provide more relevant content to you. They help target advertising according to your interests and measure the effectiveness of advertising campaigns.
- THIRD-PARTY - Used to measure the success of third-party applications and advertising on our site.

o It is important to know that you can revoke your consent to the use of cookies at any time by using your browser settings.

o All browsers allow the user to accept, refuse, or delete cookies, particularly by selecting the appropriate settings in their respective browser. You can configure cookies in the "options" or "preferences" menu of your browser. Please note that by disabling cookies, you may prevent some web services from functioning correctly, partially or totally affecting website navigation. Remember that by disabling cookies, parts of our site may not function properly.

INSTITUTIONAL PROFILES ON SOCIAL MEDIA

INSTITUTIONAL PROFILES ON SOCIAL MEDIA

12. SOCIAL NETWORKS.

o We have created or may create pages with our own profiles for institutional purposes on social networks, in order to listen to and inform our customers, and for everyone to get to know our company better. Our goal is to use this space to disseminate content of interest to citizens, as well as guidelines so that everyone can enjoy our services and products, maintaining a transparent and constructive dialogue.
o In order to ensure a healthy coexistence in social environments, IMEK's pages on social networks may be used by the user, always with the observation and respect for rights, obligations, and penalties, with the express prohibition of contents and posts that:

- Are defamatory, fraudulent, or misleading;
- Are aggressive, offensive, obscene, prejudiced, discriminatory, or contain offensive language;
- Violate any intellectual property rights of IMEK or third parties;
- Violate any law, rule, or regulation;
- Contain any form of advertising;
- Comments mentioning third-party brands;
- That may be harmful to third parties and IMEK, not limited to;

o We reserve the right, if possible, to delete, without prior notice, all content that does not comply with the company's policy, such as content that is defamatory, threatening to third parties, harassment, hate speech (based on race, ethnicity, nationality, gender, disability, or any illness), nudity, rumors, pornography, or messages with commercial and/or profitable intent or that are unrelated to the purpose of our social networks, without the need for prior communication and any compensation or reimbursement.

o IMEK is not responsible for any damages, of any kind, that may arise to third parties, as a result of the conduct of the user of its page, offensive, or in any way contrary to current legislation.

o We reserve the right to modify, suspend, cancel, or restrict the content of the respective profile/page, the links, or the information obtained through it, without the need for prior notice. We consider that, by using our social networks, the user will be expressing agreement with these terms and conditions and informs that they are subject to constant improvements and enhancements, therefore, we recommend their periodic reading.

o The collection of personal data may occur on social networks, including their official and institutional pages and relevant groups, for the strict purpose of understanding consumer preferences for eventual products and services marketed. We may even submit to social networks the data we have stored about users so that targeted and specific advertising can be carried out based on their preferences.

o In these cases, where data is collected directly by the platforms, it is important for you to know that the removal or cancellation of this data collection, in addition to the use of "opt-out," will require direct contact with the respective social media platform (Facebook, Instagram, Twitter, or any other), since IMEK does not have control over how data is collected.
o IMEK may update, modify, change, add, or remove parts of this Privacy Policy at any time. You will be informed on our portal or by email, if you have chosen to receive our communications, and will have the right to revoke the consent provided at any time.

o This PRIVACY POLICY was last updated and published on our portal in NOVEMBER 2023.

Contact us

Call: +55 (14) 99847-7052
José Pereira Guedes, 2-54
17031-420 Bauru, Sao Paulo, Brazil