Privacy Policy
INVESTOR PRIVACY POLICY
Last updated: August 1st, 2024
Esta Política de Privacidade (nomeada como “Política”) da AZZAS 2154 S.A. (nomeada como “AZZAS 2154”), inscrita no CNPJ/ME sob o nº 16.590.234/0001-76 e com sede na cidade de Belo Horizonte/MG, na Rua Fernandes Tourinho, nº 147, sala 402, Savassi, CEP 30.112-000, visa demonstrar a você, acionista, investidor, analista e titular dos dados pessoais (nomeados como “Titular”), como a AZZAS 2154 trata seus dados pessoais.
This Privacy Policy (hereinafter, the “Policy”) of AZZAS 2154 S.A. (hereinafter, “AZZAS 2154”), enrolled before the tax authorities under CNPJ/ME No. 16.590.234/0001-76 and with registered offices in the city of Belo Horizonte, state of Minas Gerais, at Rua Fernandes Tourinho, 147, suite 402, Savassi, Postal Code CEP 30.112-000, is intended to show you, a shareholder, investor, analyst and owner of personal data (hereafter “Owner”), how AZZAS 2154 treats your personal data.
The present Policy is subject to change due to changes to the Site and to Websites associated therewith, the use of new technologies, and changes in the applicable law. Therefore, we recommend frequent review of the present Privacy Policy, which may be viewed at any time on the Site.
The following brands are part of AZZAS 2154: Arezzo, Schutz, Anacapri, Alexandre Birman, Alme, Vans, AR&CO (Reserva, Reserva Mini, Oficina, Reserva Ink, Reserva Go, Reversa, and Simples), TROC, ZZ Mall, Baw Clothing, Carol Bassi, Vicenza, Animale, A Brand, Cris Barros, Fábula, Hering, Dzarm, Off Premium, Animale Oro, Foxton, Farm, Maria Filó, and NV. If you would like additional details on how each of these brands treats your personal data, please visit the respective Privacy Policy.
1. Treatment of Personal Datas
AZZAS 2154 treats Personal Data in strict compliance with security and confidentiality standards. We describe, below, certain situations in which your data may be collected and the purposes for which we use them:
- Mailing: data such as your name, e-mail address, company and profession are requested from you to register for alerts on AZZAS 2154’s investor relations, in line with the relationship you have or intend to have with us.
- Talk to IR: data such as your name, e-mail address, company, telephone number, subject line and message are requested when you with to contact our investor relations are, so that we may respond to your inquiries.
- Analyst coverage:: syour institution, name and e-mail address may be necessary to disclose information to our analyst contacts list. This information is needed so that other potential investors may get in touch with you to learn more about AZZAS 2154.
- Obligations:: some personal data may be treated for the purposes of compliance with certain legal and regulatory obligations, such as issuing earnings reports and meeting capital markets requirements, such as Brazilian Securities Exchange Commission (CVM) standards and stock exchange regulations.
- Browsing: we may collect Site browsing data, such as your IP address, browser type and version, operating system type and version, approximate geolocation information inferred from your IP, and aspects associated with your behavior while using the Site, including pages viewed, interaction with buttons, and certain types of Site content, based on cookies. This data may be used so that we can understand your browsing behavior and how the Site is being used as a means to improve your experience. In addition, we are legally bound to store some of your information (such as your IP, access date and time) so that we may provide it to the authorities if so required.
What are cookies, anyway?
Cookies are small files that are installed to collect information on your browser or device. They let us know how and when the Site is viewed, and how many people view it. Cookies may be useful, for example, to make the Site fit your display and for us to better understand your preferences as to the Site’s contents.
We may use cookies for certain purposes, as discussed below:
- Statistical cookies (analytics): cookies that provide information on your browsing behavior and on how the Site is being used. The data collected is aggregated and our purpose is to better understand how the Site is viewed and what contents get the most views.
If you would like an overview of what cookies are installed in your device, or if you wish to exclude or restrict them, use your browser’s setup feature. You will find more information on how to proceed by clicking the links below. For information on other browsers, visit the developer’s Website.
Bear in mind that, if you block our Site’s use of cookies, we cannot guarantee the proper functioning of all features, and you may be unable to access certain documents and services. In addition, it is likely that certain features and pages will not function properly.
2. Third-party sharing
We rely on the support of other businesses to maintain our operations. Therefore, we must in some case share data with third parties. AZZAS 2154 requires its service providers to maintain care, secrecy and prudence as concerns protection of the Owners’ personal data, and constantly strives to execute agreements to ensure data protection at all stages. However, the present Policy only applies to AZZAS 2154’s Site and, therefore. It is important at all times to view the specific privacy policies of Websites that may be linked to this one. Finds next illustrative examples of cases in which your data may be shared:
AZZAS 2154. Your information may be shared across the AZZAS 2154 group’s brands and companies, which are in compliance with the present Privacy Policy. We do so, mainly, to: (i) serve our legitimate purposes; and (ii) to meet legal obligations.
Suppliers and partners We rely on support from suppliers and partners that may treat personal data. We always attempt to evaluate our suppliers and partners and execute contractual personal data protection obligations to minimize risks to the Owners. These suppliers and partners may include, for example, advertising agencies, data hosting servers, and businesses that help us manage the Site.
Financial institutions. We may share your personal data with financial institutions – in particular our bookkeeping agent – to ensure compliance with legal and regulatory obligations and to enable proper corporate governance.
Public Authorities. Your data may be shared with public authorities in compliance with legal requirements, such as when a judge or duly empowered authority demands the sharing of certain personal data for the purposes of investigation, for example.
Protection of rights. We reserve the right to share any personal data we deemed needed in compliance with a legal obligation or to protect our rights and those of our employees and third parties.
Other jurisdictions. . We may transfer your data to other countries for storage purposes, such as in the case of servers located abroad. We strive to execute robust contractual terms and conditions with the recipient third parties to protect personal data and ensure the Owners’ privacy.
If you have any questions as to who these third parties may be, please contact our person in charge of data treatment using the contact channels provided at the end of the present Policy.
3. Data storage and security
AZZAS 2154 abides by strict internal rules governing the retention and disposal of personal data, and has guidelines setting forth the appropriate retention period for each type of personal data collected, in the light of the nature thereof, the need for collection, and the purposes of data treatment. Personal data are only store for the time needed to meet the needs for which they have been collected, except where any different reason may exist for retention, such as, for example, the need to meet legal, regulatory, contractual and other obligations.
We respect your information’s secrecy and security. Thus, advanced encryption methods are used for data transportation and storage. Based on this, all information provided by the Owner to our Site is protected and kept secret in secure servers. In addition, AZZAS 2154 adopts appropriate security and governance practices to safeguard your privacy and the protection of your data.
4. Rights
All information on the Site, such as text, images, sounds or applications are protected by copyright pursuant to the applicable law. Therefore, no alteration, modification, reproduction, transmission, copying, distribution or other forms of usage thereof are permitted, including, and above all the brand’s, without the formal consent of AZZAS 2154.
You are the owner of your personal data and Brazilian law affords you a series of rights in connection therewith. We provide, below, a list of all of these rights, in addition to information on how to exercise them:
| Confirmation and Access | Allows you to determine if we do treat your personal data and, if so, to request a copy of the personal data we may have on you. |
| Correction | Allows you to request corrections to incomplete, inaccurate or outdated personal data. |
| Anonymization, blocking or elimination | Allows you to ask us to (a) anonymize your data so that it can no longer be associated with you and, therefore, cease to be personal data; (b) block your data, temporarily suspending our ability to treat it; and (c) eliminate hour data, in which case we will delete all of our data without the possibility of reversal, except as legally provided. |
| Portability | You have the right to request, by means of an explicit demand, the provision to you or to a third party you may appoint, your personal data in structured and interoperable format, as long as this is not in breach of our intellectual property or trade secrets. |
| Information on data sharing | You have the right to know what public and private entities we share data with. |
| Opt-out information | You have the right to receive clear and complete information on the possibility and consequences of not providing consent. Your consent, when required, must be free and informed. Therefore, whenever we ask for our consent, you will be free to withhold it – albeit, in such a case, we may have to limit certain activities. |
| Withdrawal of consent | ou have the right to withdraw our consent in connection of treatment activities based on consent. This, however, will not affect the legal status of any treatment conducted beforehand. |
| Opposition | The law authorizes treatment of personal data even absent your consent. If you disagree with this treatment, you may oppose it in some cases, requesting interruption. |
Upon receipt of a request from you, we may need to verify your identity before we can meet such a request. This verification may include request for certain additional data to ensure proper identification. Furthermore when you appoint a third party to place such request on our behalf, such a third party must produce documentation indicating the authority to act on your behalf, such as a power-of-attorney signed by you.
To exercise any of the foregoing rights, you may contact us at the e-mail address provided in the present Policy.
5. Contact
If you have any questions, comments or requests in connection with your personal data, please contact our person in charge of personal data treatment, as identified below:
Entity in charge: Baptista Luz Advogados
Person in charge: Fernando Bousso
Postal address: Rua Ramos Batista, 444. 2nd floor, Vila Olímpia, São Paulo/SP, Postal Code CEP 04552-020, Brazil
Contact e-mail: privacidade@arezzo.com.br
