# Privacy Policy

VTURB's Privacy Policy aims to clarify to the visitor and user how we record, protect, use, disclose, transfer, and store our customers' information. Please take a few minutes to read and familiarize yourself with our practices. If you do not agree with this Privacy Policy, do not use our products or provide your personal information.

## 1. General Data Collection

VTURB's priority is to ensure the privacy and security of the information of registered users (“User”).

Therefore, this Privacy Policy has the main objective of defining the policies adopted by VTURB regarding the collection, use, and disclosure of personal information. By using VTURB's products and giving your consent to this Privacy Policy at the time of registration, the User acknowledges and accepts the adoption of the practices, as described in this Instrument, as provided for in Brazilian legislation, mainly the Civil Internet Framework and the Personal Data Protection Law.

VTURB reserves the right to modify this Privacy Policy at any time, to meet legal and/or technology requirements. All modifications will be notified through our official communication channels with the User with the effective date, and the User, by remaining in the system, demonstrates that they agree with the modifications made.

## 2. Registration

VTURB's goal, by allowing the User to voluntarily place their information, is to facilitate navigation in VTURB's products/services and the use of its tools.

Therefore, the User's proactivity in entering their data means that they want to benefit from the tools of VTURB's products/services and agrees with the privacy terms, including sharing with third parties, affiliates and/or VTURB partners. When selecting suppliers and partners, VTURB takes into consideration their respective data processing processes, and the concern to maintain the proper security for non-improper sharing.

To become a User, the first step is your registration, in which name, email, phone, are mandatory. If the User chooses not to provide the personal information that is requested, in many cases, VTURB will not be able to offer access to its products/services, content, services or answer your questions.

In the case of the User entering personal data of third parties, for the correct provision of the services of VTURB's products/services, the User is solely and exclusively responsible for ensuring that this third party has authorized the insertion of their data, exempting VTURB from any indemnity due to this treatment of third party data, even if this is not properly the User of VTURB's products.

The User has the right to access, modify, correct and delete the data about him regarding his decision to become a User. If the User revokes his consent and authorization for the use of his data in VTURB's products/services, VTURB will remove his data for future consultations, but some information will remain archived, for the sole and exclusive purpose of VTURB being able to meet the legal requirements of the Civil Internet Framework and its legitimate interest, in the ways permitted by legislation.

These are personal information and data about our customers that we use to identify and individually contact. All personal information is protected and guaranteed not to be improperly shared. Personal information can be requested at any time when the User is using or in contact with VTURB. Some information may be shared between Maquigeral affiliates and partners, with the maintenance of proper security for non-improper sharing. The use of this information must be in accordance with the rules of this Privacy Policy. We can combine this information with other data in order to improve our products, content, and advertising for the User.

The User undertakes to notify VTURB immediately, through the email [email protected], regarding any unauthorized use of his account, as well as unauthorized access by third parties to it. The User will be solely responsible for the operations carried out on his account, since access to it will only be possible through the password, whose knowledge is exclusive to the User.

## 3. Use of Personal Data and Collected Information

The personal and registration data provided by customers and collected by the platform, as well as any other information collected can be used for communication purposes of our team with you, from sending notifications about your activity with VTURB tools, as well as system alerts and notifications.

In addition, the personal registration data collected, as well as any other information and access records to VTURB tools can be treated and used for the following purposes:

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Enable the effective provision of services offered by VTURB, effectively and efficiently, allowing its operation in an agile and safe manner;

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Assist, whenever necessary and applicable, that the various users communicate, especially in cases of possible disputes related to the quality of the content, delay in content delivery, copyright and intellectual property;

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Perform analyzes and studies related to the behavior, interest and demographics of customers, in order to understand their demands and needs, to, in this way, provide more suitable, efficient and interesting services, improving the usability experience of VTURB tools;

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Improve our commercial and marketing strategies, aiming to improve the services offered;

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Send to customers, through messages, information related to products, services, advertising, promotions, banners and VTURB news.


Customers may request, at any time, the exclusion of their data from any lists (administered by VTURB), for sending promotional and/or advertising messages.

## 4. Storage and Protection of Collected Personal Data

All personal data of customers obtained at the time of navigation, registration at VTURB, use of the platform, or at any other time of contact/communication between the user and the platform, will be stored in our database, for a minimum period of 12 (twelve) months or for a longer period, as defined by court order and or administrative, according to current legislation, or for legitimate purposes of development and offering of services to users.

The personal data reported to Maquigeral or otherwise collected by the VTURB platform will be stored in secure databases, with access restricted only to employees with the appropriate credentials, who are obliged to maintain the confidentiality of the information and not use it inappropriately.

VTURB may store and process the personal data collected and other information collected on a server located in Brazil or abroad.

## 5. Disclosure to Third Parties of Collected Registration and Personal Data

You agree that, in an attempt to prevent illegal activities, in cases of suspected fraud, disputes, complaints about content or any indication of illegal activity committed by customers, including the dissemination of SPAM and situations involving potential threats to someone's physical safety, the personal and registration data of the customers involved may be provided to those affected. In certain cases, if it considers it necessary, VTURB may provide the data collected to the bodies and entities that intervene in the investigation or resolution of disputes between customers or between customers and third parties, such as: insurers, arbitration courts, and other competent administrative bodies.

Likewise, you also agree that VTURB may share the personal and registration data collected with VTURB's third-party service providers, in order to allow the development of their respective activities and enable the improvement of services and operations of the platform, such as, but not limited to, services of: data backup, fraud prevention services, email service providers and databases, issuance of invoices, among others. In this case, VTURB requires all service providers with whom it shares the personal data of users, include in their contracts provisions that guarantee the proper protection, secrecy and confidentiality in the processing of data.

Finally, you also agree that, in any corporate operation involving the restructuring of the business group to which VTURB belongs, as well as the purchase and/or sale of shares and assets, the personal data collected may be considered one of the commercial assets to be transferred. In these cases, VTURB may transfer the personal and registration data of customers and users, in general, if it is acquired by, or if there is a merger with another(s) company(s).

Excluding the hypotheses mentioned in this Privacy Policy, the personal and registration data, collected directly by VTURB, as well as the access records to the platform (IP address, date, time and time zone) and the data referring to transactions carried out through the platform, can only be revealed to third parties, without prior notice, in the following hypotheses: (a) applicable legislation, regulation, legal process or government request; (b) comply with investigation of possible violations; (c) fraud or for security; or (d) protect against damage to the rights, property or safety of VTURB, our users or the public, in compliance with the provisions of Law 12.965/14 and other applicable legislation.

## 6. Maintenance of Registration and Personal Data After Account Deletion

VTURB will not retain personal information longer than necessary for the fulfillment of the purpose for which they were processed, including the security of processing in accordance with legal and regulatory obligations (for example, audit, accounting and statutory retention terms), litigation regarding processing, and for the establishment, exercise or defense of its legitimate interest.

You can delete your account with Maquigeral at any time, accessing the user settings of the platform, being ineffective the use of any other means to achieve this goal.

At the customer's request, VTURB will proceed to the definitive exclusion of the registration data provided by him, throughout the relationship with VTURB, within a maximum period of 15 (fifteen) days

Access records (IP's), if any, will be discarded as they complete 180 (one hundred and eighty days) of storage, in the terms of Law 12.965/14 and other current legislation.

## 7. Spam Prohibition

VTURB vehemently repudiates any practice that promotes SPAM of any kind. Thus, we are committed to ensuring that messages sent by the platform are always of interest or importance to their respective recipients.

Users, at any time, can choose to receive or not, VTURB emails. For this, it is enough that he adjusts his preferences for receiving emails or cancels his subscription for sending promotional and/or advertising emails, as previously mentioned.

If it is verified that, the users of the platform are using the sending of SPAM, VTURB, at its sole and exclusive discretion and, regardless of prior notification and/or communication, may immediately delete the account of customers and users.

## 8. Our Commitment to Your Privacy

To be sure that your personal information is secure, we communicate our privacy and security guidelines to employees and strictly enforce privacy safeguards within the company.

We reserve the right to modify this Privacy Policy at any time and changes will take effect after the publication of the modified Privacy Policy.

When there is a change in the “PRIVACY POLICY”, VTURB will communicate its users by email or in a publication in a prominent area on the platform.

If you continue to use the tools offered after the communication of the change in the “PRIVACY POLICY”, this will mean and will be considered as your unequivocal consent and irrevocable and irretractable acceptance of all the terms and conditions contained in the modified Privacy Policy.

For clarifications and more information about this Privacy Policy contact us by email [email protected], including in the message title the following phrase: “Information - Privacy Policy”.

Thank you for your attention.