This Privacy Policy was prepared by PRIVATE CODE SISTEMAS DIGITAIS EIRELI , company headquartered at Avenida Senador Feijó, nº 686, cj. 1231, Vila Mathias, Santos City, state de São Paulo, CEP 11015-504, registered with the CNPJ under number 35.415.602 / 0001-94 (“ Private Code ” or “ Us ”).

We have made this Policy so that you can find, in a single location, all the information to regarding the use of your personal information collected for the provision and personalization of ours services.

In other words, it is through this Privacy Policy that we will explain how we will treat their personal data whenever you hire our services, request a quote, access our websites, or respond to one of our market surveys.

By accepting this Privacy Policy and / or browsing our websites, you agree to the practices described in this document. Therefore, carefully read the content of this Privacy Policy and contact our Data Protection Officer (information from contact at the end of the document), in case of doubts or need for clarification.

1. Preliminary Provisions

• Except in some specific cases, the Controller of your personal data, for the purposes of this Privacy Policy, it is PRIVATE CODE SISTEMAS DIGITAIS EIRELI, a company with headquarters at Avenida Senador Feijó, nº 686, cj. 1231, Vila Mathias, Santos City, State de São Paulo, CEP 11015-504, registered with the CNPJ under number 35.415.602 / 0001-94.
• As we are always looking to improve our Services, this Policy may go through updates, aiming to provide more security, convenience and to improve even more the your experience. That is why we recommend that the User access our Policy periodically so that you are aware of the changes. To facilitate, we indicate at the beginning of the document the date of the last update. If they are made relevant changes, we will post this update; if you do not agree with the new terms, we recommend that you stop using our services.

2. How do we collect your personal data?

The collection of your personal data can occur by different means, namely:

2.1. Personally, when you visit one of our units;
2.2. By phone, when we receive a call from you;
2.3. Through our Site, when you send us a message using our channel “ Contact Us ”;
2.4. By e-mail, when you contact us through our e-mail [email protected] ;
2.5. By third parties, when we receive your data, in an authorized manner, from a partner of ours who has rights to do so;
2.6. Automatically, through cookies and other tracking technologies present in our site.

3. Personalization of personal data processing activities

Always aiming to fulfill your rights and interests, we will provide, whenever possible, options customization of our data processing activity, giving you the option of:

• Failing to provide personal data that would be important for personalizing our activities, but not essential for its execution;
• Set your browsing preferences and use available tools to block cookies sent in connection with your use of our websites and applications; and / or
• Request other customization options directly from our Supervisor.

4. What personal data is collected and for what purpose?

We operate in the information technology and digital security sector, developing tools on-demand technology, offering professional training, consulting and support technical, among other related activities.

In this sense, the collection of some of your personal data may be essential for us to offer our services, whether to provide training or even to develop programs computer systems for our customers.

However, the form and purpose of personal data processing activities vary from according to the context for which your data was collected. See below what is the data personal data we collect and what their respective purposes are:

Collection Context	Personal Data Collected	Purpose of Use
Sending contact using the form available on our website.	Nome Phone E-E-mail	Contact the user in order to interact with the request or subject that motivated his contact us. * other data may eventually be provided by the user in the field "Message". We use the content of this field, exclusively, to attend to request that motivated the user`s contact. Do not store the contents of this field.
Register to receive our Newsletters .	Name E-mail	Send periodic " newsletters " to users who request the registration of your email.

5. With whom do we share your personal data?

In some situations, so that we can provide our services with quality and even offer certain benefits, we eventually need to rely on the help of business partners and third parties, with whom we may share your personal data. Whenever we disclose your personal data to any third parties, we demand strict compliance with this Privacy Policy Privacy on their part.

We have listed below the third parties with whom we may share your personal data:

• Our branches;
• Contractors, service providers and other third parties that we use to support our businesses, and that are contractually linked to us;
• Our business partners, in compliance with our contracts and agreements;
• A possible buyer or other successor in the event of a merger, disposal, incorporation, spin-off, restructuring, reorganization, dissolution, sale or transfer of the company\'s assets Private Code;
• Any governmental authority, in compliance with any court order, law, process legal or administrative;
• Institution of means of payment or financial, to process the purchase of a product or the purchase of a service;
• Anyone, if we believe disclosure is necessary to protect rights, the ownership and security of Private Code, our customers or third parties.

6. How long will we retain your personal data?

We will store and maintain your information: (i) for the time required by law; (ii) until the end processing of personal data, (iii) for the time necessary to preserve the legitimate interest of the Private Code, (iv) for the time necessary to safeguard the regular exercise of company rights Private Code.

In relation to item “ii”, it should be understood by “end of data processing”, the following situations:

• When the purpose for which the Data Subject\'s personal data has been collected is achieved and / or the personal data collected are no longer necessary or relevant to the achievement of such a purpose;
• When the Data Subject is in his right to request the end of the treatment and the deletion of your personal data and you do so; and
• When there is a legal determination in this regard.

7. International Transfer of Personal Data

Private Code may transfer your personal data to business partners and service providers services located abroad, including cloud service providers.

If your personal data is transferred abroad, Private Code will adopt the measures appropriate measures to ensure adequate protection of your personal data in accordance with the requirements of the applicable data protection legislation, such as the conclusion of contracts appropriate data transfer with third parties of your personal data, when necessary.

8. Security of Stored Data

Your privacy is very important to us. In this sense, Private Code invests in implementation of security systems and technical, physical and managerial procedures usually adopted by the market to protect your data.

However, while we do our best to protect your personal information, we do not we can guarantee the absolute security of your personal data transmitted to us. Therefore, it is it is imperative that you are aware of the inherent risk of any personal data.

9. Exercise of your rights

You can contact us directly to exercise any of your rights guaranteed by law, such as access, confirmation of the existence of a data processing activity personal data, correction, rectification, portability or execution of any personal data that you have provided to us.

To do so, just send a message to our supervisor, whose data are available at the end of this document. In the event that the fulfillment of your request is not possible, due to legal determination or business secret, our Supervisor will contact you directly to clarify the situation.

Please note that if you request the deletion of your personal data, we may keep a copy stored in our files, in the cases required by law.

10. How to contact us

In case of any doubts regarding the way we treat your personal data or for questions and requests you can contact our Data Protection Officer , that will always seek to serve you in the shortest possible time:

Bruno Couty
[email protected]