UBETON – MODERNIZING BUILDINGS

Updated July 15, 2021.

Ubeton Máquinas e Serviços para Construção Civil LTDA. – EPP, registered with the CNPJ/ME under nº 22.100.701/0001-35, presents this Privacy Policy, which is applicable to all information collected by Ubeton and hosting https://www.ubeton.com.br/ , as well as providing you with information about the collection, use, maintenance and disclosure of your information collected by Ubeton.

Acceptance of this Privacy Policy and Personal Data Protection (“Privacy Policy”) and data collection will be carried out in three ways: (i) through the website operated by Ubeton; (ii) for the use of the services and; (iii) on any occasion where personal data is provided to Ubeton, in any capacity.

By using or interacting with the Ubeton website, services or products, information may be collected about your interactions, the services you use and how you use them. The information collected may include: device information, location information, unique application identification, cookies and similar technology.

This Privacy Policy applies partially to users who access the Ubeton website in an unidentified way (see more in our Cookies Policy), and fully from your registration, contact, Ubeton product or service or, further, the acceptance thereof when providing personal data to Ubeton.

If you do not agree with the provisions contained throughout the text, you must not complete the registration, contracting, enrollment, or provide your personal data to Ubeton. If you receive this Privacy Policy because you have previously provided personal data to Ubeton and you disagree with its terms, you may request the deletion of your data, in accordance with the procedure contained in this Policy.

1. WHAT INFORMATION DOES UBETON OBTAIN AND HOW IS IT USED?

This Privacy Policy consolidates Ubeton's commitments regarding the collection, use, maintenance, disclosure, storage, security and all other forms of processing of personal data, as well as informs about the rights of its Holders and how to exercise them.

By reading and accepting this Privacy Policy, the Data Subject confirms that he is legally capable, according to the Brazilian Civil Code (Law nº 10.406/2002), for those who make use of the website, which is why it is recommended to carefully read the documents .

2. PROCESSING OF PERSONAL DATA OF MINORS

Ubeton does not request personal data or offer its products and/or services to children and adolescents under the age of 18. However, if a parent or legal representative becomes aware that the minor has provided information without his/her consent, he/she may contact Ubeton immediately via the e-mail oficial.dados@ubeton.com.br . The minor's personal data will be deleted from Ubeton's systems within a reasonable period of time, which will be informed to the parent or guardian.

3. PROCESSING OF THE HOLDERS' PERSONAL DATA

3.1. Collection of Personal Data from Holders

The Holder agrees and consents to the collection and storage, by Ubeton, of their personal data provided under the terms of this Privacy Policy. It should be noted that the provision of data is optional.

3.2. Types of data collected by Ubeton

a) Data collected in the case of registration on the Ubeton website, in the registration to receive content, contact, product or service, promotions or offers from Ubeton:

• E-mail: used as differentiation in the database and as a means of contact;

• First and last name: used for identification of the Holder, personalization of their experience and to facilitate contacts by the Ubeton team;

• Mobile number and landline: used as a means of contact by the Ubeton team;

• CPF/CNPJ: used to identify the Holder, mainly for the issuance of invoices by Ubeton;

• RG: used to identify the Holder, as a security measure;

• Date of birth: used to identify the Owner's profile, and allow the individualization of content offers and/or commercial proposals for products or services;

• Profession, company you work for and title:

• Social Media: Used for specific promotions, marketing and content targeting campaigns both to improve the customer experience with the brand and Ubeton's products and services.

• Data on works and projects in progress: depending on what is provided by the user, he will be sent to a form in which he will be asked if Ubeton's products or services will be used for (a) his own work; (b) builder or dealer; (c) how many works in progress; (d) type of work; (e) amount of work carried out per year. This will be done in order to profile the users who visit the website for a better experience when sending content, contact, product or service, promotions or offers from Ubeton; (f) or any other technical information that is necessary for the development of Ubeton's service and products.

b) Data not collected: Ubeton will not collect (and the user must not provide) any information related to financial information, such as, but not limited to, bank account and credit card numbers, driver's license, passport number, among others. others who verify that information contains sensitive data under the terms of the General Data Protection Act.

It should be noted that such data will only be collected by payment partners, when purchasing products and services from Ubeton. Additionally, Ubeton also does not collect any data provided to third-party sales channels. For a better understanding of how these sales websites handle the personal data provided, it is recommended to read their respective Privacy Policies.

c) Data collected automatically: Ubeton may also collect information automatically during users' browsing on its website, and the automatic capture of information will be through Cookies.

3.3. Ubeton's use of cookies

Cookies are small text files installed in the device's browsers in order to store the user's browsing preferences, improving and optimizing their experience. These files make it possible to identify whether the same device has already visited the website and whether or not the user has a registration, among other features.

If a Cookie is stored on the hard drive of the user's device, the next time the user visits the same website, Ubeton will be able to recognize it.

3.3.1. Which cookies are used by Ubeton and for what purpose?

• General and operational use: they serve both to guarantee the correct access and operation of the applications, as well as to provide and enrich your experience on the website through your browsing habits. They facilitate and assist the user in receiving and filling out forms.

• Audience behavior: they help to scale Ubeton's own audience. They track, store and measure browsing behavior information in order to offer a more personalized service, with content recommendation, benefiting the user experience on the website and for the improvement of products and/or services.

• Security: protect and allow the user to browse the website in its full functionality, with the monitoring and detection of unauthorized activities, with authentications to prevent fraud and in the protection of user information, Ubeton itself and third parties;

• Research, analysis and performance: to verify, measure and analyze the audience, performance, use of applications by users;

• Delivery of advertisements and advertisements: used to deliver advertisements according to your user's consumption profile, as well as to know if users have viewed it. They can also be used to remember any searches carried out by users, and based on the results of these searches, to show advertisements or offers of products, services and initiatives of interest to them.

3.3.2. What information is collected by cookies?

• Browser type and its settings;

• Information about your device, other identifiers assigned to the device, as well as device usage;

• Navigation preferences;

• The IP address from which the device accesses the website or mobile application, as well as information about the date, time and network used to connect to the website.

• Information about the device's geographic location when it accesses a website or mobile application, for the use of fraud prevention and security, expansion of the sales area, indication of Ubeton representatives close to the user, as well as for product offers and services.

• Credentials, a set of data that the Holder uses to authenticate himself in order to access certain restricted areas and/or exclusive features;

• Browsing habits to map which areas are visited, mainly to verify pages and functionalities accessed on the Ubeton website, number of clicks and pages and applications in which access to the Ubeton website originated;

• Time interactions, in order to estimate the period of stay on the website;

• Interactions with Ubeton's social networks, such as Instagram, Facebook, Linkedin and Youtube.

If the user is accessing the website anonymously, that is, without registering or logging in, Ubeton will only have access to the browsing profile information, but without being able to identify as an individual.

However, if you register or log in, the information captured by cookies may be linked to the user, due to the crossing of information.

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3.3.4. How long will cookies be stored?

The storage period of cookies that collect information from users may vary. If the user does not agree with the capture of cookies, you can always configure your browser so that the collection of cookies is blocked or deleted from the browser settings. However, it is important to keep in mind that cookies will be recreated when browsing is resumed.

3.3.5. Is it possible to prevent data collection through cookies?

If the user wishes, it is always possible to disable the collection of information through cookies by configuring their own browser. The user can consult general guidelines for the configuration of Cookies in different types of browsers in the Ubeton Cookies Policy.

3.4. Use of Web Beacons

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Ubeton uses web beacons alone or in conjunction with Cookies to help collect information that helps track the existence and/or nature of web-based interactions that occur by users on the Ubeton website.

A web beacon is a clear electronic image and will recognize certain types of information on your computer, such as cookies. Ubeton may also use users' anonymous information when visiting its website to improve products and services and help them provide useful and relevant information about products or services that may be of interest to the user.

3.5. Ways of Use of Personal Data of Holders

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In the course of the activities carried out by Ubeton, the personal data collected from users may be used for some specific purposes, identified below:

• To fulfill the contract: personal data will be used to (a) register the user on the website; (b) feed Ubeton's personal databases; (c) receive, direct and respond to user demands made through Ubeton's contact channels; (d) pay for the products or services contracted with Ubeton and; (e) for the delivery of products to the user's address.

• In response to Ubeton's legitimate interest: personal data will be used to prepare general statistics, without identifying users, by anonymizing the personal data used.

• With the acceptance of this Privacy Policy, the user freely, informed and unequivocally consents to the following purposes for the use of their personal data:

  • Incorporation of the data provided to the database of UBETON MÁQUINAS E SERVIÇOS PARA CONSTRUÇÃO CIVIL LTDA. – EPP, located at Rua José Cadilhe, nº 1461, store 02, Bairro Água Verde, Curitiba/PR, CEP: 80.620-240;

  • Contact, from time to time, by Ubeton and/or its representatives, to provide information and notices about products and services purchased, to inform about new products and/or services from Ubeton, to conduct satisfaction and behavior surveys or, further, to inform the user about Ubeton's own promotions and marketing campaigns, whether by email, SMS or other similar means of communication, based on the data provided by the user;

  • Inform about products, services, promotions and offers from Ubeton itself, by email, SMS or other means of communication, without the data being shared with third parties;

  • Respond to queries and requests made by the user;

  • Identify the user in comments entered by the user and other interactions allowed on the website.

3.5.1. In the event that satisfaction and behavior surveys are carried out, the information eventually provided by the user regarding their habits and preferences regarding the use of the Ubeton website, products or services, in addition to characteristics such as age group, education level, region of domicile , among others similar, that serve the segmentation and better understanding of our base, in favor of the improvement of products or services, will not be linked to the profile of the user who provided them, being, therefore, treated anonymously by Ubeton.

3.6. Hypotheses of Sharing the Data Subjects' Personal Data

Ubeton undertakes to maintain exclusive custody of the personal data collected. These data will only have their information shared when they are necessary within strict security standards, always aiming at the confidentiality of your information and following the other data protection and privacy rules. In the cases listed below, data sharing may be carried out:

• For contract fulfillment: personal data will be shared with representatives hired by Ubeton, only when necessary to guarantee the execution or delivery of products, the provision of services or maintenance of these, provided that such representatives have contractually committed to use the data. personal data in accordance with the limiting rules established in this Privacy Policy and in compliance with the General Data Protection Law.

• To comply with a legal or regulatory obligation: personal data will be shared as required by law, such as (a) by court order and (b) by request of a competent administrative authority, in both cases the sharing of data will be limited to what was required.

• For the regular exercise of Ubeton's rights: personal data will be shared with the Judiciary and the Public Administration for (a) defense and compliance with subpoenas in judicial, administrative or arbitration proceedings; (b) when we have a good faith belief that disclosure is necessary to protect our rights, protect your safety or that of others, investigate fraud, or respond to a government request.

• The user, in this way, freely, unequivocally and informed consent to the sharing of their data:

  • with representatives hired by Ubeton, to assist in conducting satisfaction and behavior surveys, in which case the guidelines for the anonymization of the information collected also apply;

  • with Ubeton partners, aiming at enriching the Data Holders' contact data, such as e-mail and telephone, provided that these partners have the Holders' consent to share the data or, as long as it is public data that do not need of consent;

  • with Ubeton's sponsors and advertisers, provided that the Holder has expressly consented to this sharing, when choosing to participate and provide their personal data in commercial campaigns, marketing, promotions or events offered by these partners, in which case the data collected will be also treated by the partner, according to its own Privacy Policy, which will be available to the Owner at the time of data collection;

  • with other companies, if Ubeton is involved in a merger, acquisition or sale of all or part of its assets, provided that the transaction involves ownership over Ubeton's databases. In this case, the Holder will be notified via email and/or will see a prominent notice on our website about any change regarding the ownership or use of their personal data;

  • with foreign companies in the cases mentioned above, and Ubeton guarantees that any international transfer to which personal data may be submitted will comply with all the rules of this Privacy Policy, as well as with the applicable legal obligations, as provided in the General Protection Law. of Data - LGPD.

• Anonymized data: Sharing anonymized data does not require the consent of the user, who will not be identified in these data processing operations. Anonymized data may be periodically transmitted to service providers who help to improve the Ubeton website, products or services.

3.7. Storage of Data Holders.

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Ubeton will store the personal data of Data Subjects for the time necessary until its purpose is fulfilled, with the exception of when there is a need to comply with legal storage obligations, such as, for example, the custody obligations arising from the Civil Rights Framework for the Internet (Law 12.965/2014), or when Ubeton has a legitimate interest in maintaining the data.

If it is of interest to you, the Data Holder  dos may request the permanent deletion of your registration and personal data through the e-mail oficial.dados@ubeton.com.br .

4. RIGHTS OF OWNERS

In accordance with the General Data Protection Law, the Data Subject has, among other rights, to fulfill the following requirements:

• Access, update, correction of incomplete, inaccurate or outdated data and confirmation of the existence of processing of personal data;

• The deletion, blocking or anonymization of data that is unnecessary, excessive or treated in violation of the law;

• Interrupt the collection of your personal data by the website when you close your registration .

• Data portability, subject to applicable rules and commercial and industrial secrecy;

• Request to opt-out of sending you targeted offers and promotions for Ubeton products and services;

• Information on public and private entities with which the Controller shared data use;

• Revocation of consent, which may be carried out at any time and free of charge, upon express manifestation;

• Request the deletion of personal data processed with consent, or oppose the treatment carried out on the basis of other legal bases, except in cases where the maintenance of data is necessary or permitted by legislation.

5. SECURITY

Ubeton is concerned with safeguarding confidentiality and protecting the personal data of Data Subjects, which is a priority for us.  The Data Subject understands that, even though it is not possible to guarantee that their personal data will be fully secure at all times, Ubeton, in view of its security and protection program, meets or exceeds accepted practices and requirements established in the General Data Protection Law.

It should be noted that Ubeton restricts access to data to the extent necessary, with strict confidentiality and secrecy obligations and by adopting security criteria.

If it is identified that the user's personal data has been compromised, Ubeton guarantees that it will use all reasonable means to mitigate the risks and remedy the damages that arise, as well as that it will keep the user informed of the measures taken within a reasonable time.

Ubeton disclaims liability for damages that may be caused to Holders exclusively by third parties, including by viruses or data leakage, unless proven guilty.

6. CHANGES

Ubeton reserves the right to modify this Privacy Policy at any time as necessary. The Owner will be notified, through the website on the first access made by the user, if there is any change to this Policy that results in a relevant modification regarding the treatment of personal data.

Ubeton recommends that the Holder frequently review this Privacy Policy, especially when there are changes.

If the Holder does not agree with the new version of the text, he may request the deletion of his data by contacting us at the e-mail address in charge.dados@ubeton.com.br .

7. CONTACT

In case of doubt, requests about the use of personal data or about this Ubeton Privacy Policy can be made through the email oficial.dados@ubeton.com.br , with the title “Data Protection Officers” .