PERSONAL DATA AND INFORMATION WE COLLECT

Website user

Information you provide to us when filling out an online form, survey field, or registering to receive alerts about our products.

Information we collect through cookies, details about your computer or other portable device used to access our website, services, or applications, including the record of the IP address used to connect your computer or device to the internet, your geographic location, the type and version of the operating system, and the type and version of your web browser. If you access the CONSTRUCT IN website or application using a mobile device, such as a smartphone or tablet, the information collected will also include, whenever permitted, the unique device ID of your device, geographic location, and other similar data from the mobile device.

We may request information about your website use if you experience issues while navigating our site.

Employees who no longer have ties to CONSTRUCT IN

We may maintain the personal data you voluntarily provide to CONSTRUCT IN and/or collect during your employment or job relationship with us. We store this data in the form and for the period required by applicable labor and social security legislation, as well as permitted by the LGPD. This data may include: Name, ID card, CPF, Address, Nationality, Gender, contact information (email and/or phone), CTPS information, military ID, voter registration, academic information, position, registration number.

Relatives

CONSTRUCT IN will handle personal data provided by collaborators or former collaborators (including: Name, ID card, CPF, degree of kinship, which may involve data of children or adolescents), exclusively for the purpose of providing benefits granted to our collaborators and/or former collaborators, which extends to their families.

During your interaction with CONSTRUCT IN, we may collect various types of personal data about you, as outlined below:

Suppliers

CONSTRUCT IN will process your registration data (including: Name, CPF, ID card, and Phone) that you provide us in order to perform the provision of services and/or supply of products by you or the company you represent.

We will use your email and phone to contact you about activities related to the provision of services and/or supply of products.

Candidates

CONSTRUCT IN will process your registration data (including: Name, ID card, CPF, address, professional and academic data) among other data as you provide us for identification purposes in the selection process and formation of the database.

We will use your email and/or phone to contact you about the status of the selection process.

We will analyze information about your academic trajectory, professional experience, and skills described in the resume you shared with CONSTRUCT IN.

In addition to the above information, if you advance in the selection process and are called for in-person interviews, we will process any personal data provided by you during the interview, which may include: details about your personal life and habits, information about your experiences and roles you have performed, expectations, etc.

Finally, if you are called for the final stage, in order to better understand our candidates, we may request additional information to conduct a background check.

SENSITIVE PERSONAL DATA

CONSTRUCT IN does not typically handle personal data considered sensitive under current legislation; thus, we do not intend to collect or process sensitive personal data in the normal course of your interactions with our products or services. When there is a need to process your sensitive personal data, for any reason, we will obtain your prior, explicit, and formal consent for any voluntary processing (for example, for marketing purposes). If we process your sensitive personal data for other purposes, we will rely on the following legal bases: (i) fraud detection and prevention; (ii) compliance with applicable law; (iii) protection of credit;

COOKIES

Cookies are used to improve the use and functionality of websites and other web services compatible with CONSTRUCT IN and to better understand how our visitors use our websites and online services.

ABOUT THE USE OF COOKIES, LOG FILES, AND SIMILAR TECHNOLOGIES

During your interaction with our websites and services, we utilize automatic data collection technologies to capture information regarding the actions you have taken. This may include details such as which link(s) you click, which pages and/or content you view, and for how long, as well as other information and similar statistics about your interactions, such as response times to content, download errors, and duration of visits to specific pages. This information is captured through automated technologies, such as Cookies (browser cookies, Flash cookies, and/or similar), web beacons, and via third-party tracking.

COOKIE DEFINITION

Cookies are small text files that may be placed on your computer or mobile device through the websites or web services you use. They are used to ensure the proper functioning of websites and other online services, as well as to provide information to the owners of the website or online service.

Cookies are used to improve the use and functionality of websites and other web services compatible with CONSTRUCT IN and to better understand how our visitors use our websites and online services, as well as the tools and services they offer. Cookies facilitate the process of adapting the CONSTRUCT IN website to your personal needs, making it easier whenever possible to use and receive feedback on customer satisfaction.

CONSTRUCT IN uses the following types of Cookies on its website and compatible services:

Session cookies: these are temporary cookies that are deleted when you close your browser. When you restart your browser and return to the site that created the cookie, that site treats you as a new visitor.

Persistent cookies: these are cookies that remain on your browser until you manually delete them or until your browser deletes them based on the duration period set by the cookie. These cookies will recognize your return as a visitor to a CONSTRUCT IN site or service.

Necessary cookies: these are cookies strictly necessary for the operation of a CONSTRUCT IN compatible site or service. They allow you to navigate the site and use our features.

Cookies that send us information about you: we place this type of cookie on a CONSTRUCT IN compatible site or service, and this type of cookie can only be read by our site and compatible services.

Cookies in CONSTRUCT IN advertisements: we place cookies in advertisements that are displayed on third-party compatible sites and services. We obtain information through these cookies when you click or interact with the advertisement. In this case, CONSTRUCT IN is placing a "third-party" cookie. We may use this data obtained from third-party cookies to send other advertisements that we believe are relevant or of interest to you based on your previous behavior.

Cookies that share your information with third parties: these are cookies placed on a CONSTRUCT IN site by our partner companies, such as online advertising services. They may use the data collected by these cookies to send targeted ads from other sites anonymously, based on your visit to CONSTRUCT IN compatible sites or services.

OTHER TRACKING TECHNOLOGIES

CONSTRUCT IN compatible websites and services may also use other tracking technologies similar to cookies, which can collect information such as IP addresses, log files, and web beacons, among others. This data is also used to help us adapt the CONSTRUCT IN compatible websites and other services to your personal needs.

See more details below:

IP addresses: an IP address is a number used on the internet or on an internal network to identify your computer. Every time you connect to the internet, your computer receives an IP assigned by your internet service provider. We may log IP addresses for the following purposes:

• Troubleshooting technical issues;

• Maintenance of the protection and security of our websites and other online services;

• Gaining a better understanding of how our websites and other online services are used;

• Adapting our content to your needs, depending on your geographic location.

Log files: CONSTRUCT IN or a third party working on our behalf may collect information in the form of log files that detail website activities and collect statistics about user browsing habits. Typically, these logs are generated anonymously and help us understand details such as:

• The type of browser and system used by users of our websites or online services;

• Details about user's session, including the source URL, date, time, and which pages the user visited on our compatible websites and services, as well as how long the user stayed using them;

• Other browsing details or click counts including website traffic reports, unique visitor counts, and similar data.

Web beacons: we may use web beacons (or transparent GIFs) on CONSTRUCT IN websites. Web beacons (also known as webbugs or web beacons) are small sequences of code that enable the delivery of a graphical image on a webpage for the purpose of transferring data back to us. We use information from web beacons for a variety of purposes, including:

• Understanding how a user responds to email campaigns;

• Traffic reports for our compatible websites and services;

• Conducting unique visitor counts, auditing and reporting advertising and email, and personalizing our compatible websites and other services.

CONSENT FOR THE USE OF COOKIES AND SIMILAR TECHNOLOGIES

It is important to remember that it is your responsibility to ensure that the settings on your computer or portable device reflect whether you consent to accept cookies or not.

CONSTRUCT IN allows you to set which cookies will be allowed or not during your browsing, with only essential cookies required for the site to operate. To define which cookies you wish to allow, simply click on Configure Cookies on the cookie notification bar and decide between opt-in (enable) and opt-out (disable) for the cookies. You do not need to have cookies enabled to use or browse most of CONSTRUCT IN's online sites and services; however, in this case, we cannot ensure that you will be able to access all of its features. Remember that if you use different browsers or even different computers and/or portable devices in different locations, you will need to ensure that each device and browser is configured and adjusted to your personal cookie preferences.

As our web beacons may be part of a webpage, it is not possible to exclude (“opt-out”) this type of resource, but you can make it completely non-functional by activating the “opt-out” feature for cookies placed by that beacon.

HOW WE USE YOUR PERSONAL DATA AND INFORMATION

The following items describe the purposes for which CONSTRUCT IN collects your personal data. Please note that not all forms of collection and use below will be relevant to all individuals and may apply only in specific situations:

Fulfilling your requests. • Sharing with service providers to perform the services offered by CONSTRUCT IN. • Responding to requests from regulatory bodies or legal obligations. • Processing of data in accordance with government regulations. • Responding to your questions and comments (for example, if you have asked a question or provided feedback through the website). • Providing information, products, or services that you have requested or that we perceive may interest you, unless you tell us otherwise. • Allowing you to participate in any interactive features of the website. • Notifying you of changes in privacy on the website. • Providing alerts or updates where you have consented to receive them by registering on the site (only if you allow it to occur). • Ensuring that the content of the site is presented in the most effective way for the device you are accessing. • Detecting and preventing misuse or abuse of this site or our services.

WHOM WE SHARE YOUR PERSONAL DATA WITH

We may share your information in order to provide you with products or services you have requested, if we have a legitimate interest in doing so (for example, managing risks, verifying your identity, combating fraud or abuse of our site or services), or where you have consented to allow us to share. We share your personal data when necessary with the following groups:

• Internal entities: Includes companies that are part of the OTTO BAUMGART and VEDACIT SOLUÇÕES TECNOLÓGICAS (VST) group. The sharing of personal data may occur when the group requests information from CONSTRUCT IN or when there is a need to report to the group.

• Service providers: Includes external companies that are used by CONSTRUCT IN to assist in the operation of our business.

• Credit analysis agencies, debt collection, and financial services: To assist and verify your credit status or to collect overdue payments.

• External entities: Compliance with service requests such as sharing data with the Post Office.

• Regulators: In situations where we are legally obligated to disclose information in the interest of the public (for example: to prevent or detect fraud, abuse of our site or services).

CONSTRUCT IN does not license or sell your personal data to third parties for their own marketing purposes.

ABOUT THE STORAGE, RETENTION, AND TERMINATION OF THE PROCESSING OF YOUR PERSONAL DATA.

We may retain your personal data for the period required by law, until the end of the processing of your personal data, or for the period necessary to achieve our legitimate interests based on legal guidelines.

When the processing period of your personal data concludes, these will be eliminated within the scope and technical limits of the activities, authorized to be retained when there are legal justifications for retaining such data.

The termination of processing will occur when it is identified:

• The purpose for the processing of the personal data specified in consent, when applicable, has been achieved, and there is no longer a need to process the personal data.

• The holder who previously provided consent for the use of personal data has requested revocation of that consent.

• Legal determination.

You have the right to request deletion, review, updating, rectification, portability, and review of automated decisions regarding your data when necessary; however, this will be done only if it is in accordance with legal obligations.

TRANSFER OF YOUR PERSONAL DATA

Given the nature of our business, it is possible that we will need to transfer your personal data stored within CONSTRUCT IN to third parties, according to the purposes established in this privacy policy. For this reason, we may transfer your personal data to other countries, as long as they have laws and regulations compatible with those in force in Brazil, and that the transfer is performed based on legal grounds or the holder's consent.

SECURITY OF YOUR PERSONAL DATA

CONSTRUCT IN adopts appropriate measures to ensure that your personal data is kept confidential and secure, such as Firewall, Access Policies, Information Security Policies, Training Plan, Antivirus, among others. We raise awareness among our employees about privacy issues (including service providers), internal procedures, access controls, responsibilities, and about best practices in the market.

ABOUT YOUR RIGHTS REGARDING PERSONAL DATA

You have a series of rights regarding the personal data we hold about you. These rights include:

Access to data: This pertains to your right to receive in a complete, simple, and clear manner the data that you own that is in the possession of CONSTRUCT IN.

Correction of incomplete, inaccurate, or outdated data: This pertains to your right to request the correction of your personal data, once they are incomplete, inaccurate (wrong), or outdated.

Anonymization, blocking, or deletion of unnecessary, excessive, or improperly processed data under the LGPD: This pertains to your right to request that your data be deleted. The law allows us to utilize other options besides deletion, once deletion is not feasible. These are: blocking or anonymization.

Portability of data: This pertains to your right to receive your information in a structured and accessible format so that you can transmit this data to another entity without limitations imposed by CONSTRUCT IN.

Deletion of personal data processed with the consent of the holder, except as permitted by the LGPD: This pertains to your right to request the deletion of your personal data from CONSTRUCT IN's database even after having provided consent for the retention of such data, with CONSTRUCT IN only retaining them based on certain purposes defined by the LGPD. These purposes are: Compliance with a legal or regulatory obligation, transfer to a third party, as long as the data processing requirements defined by the LGPD are respected, and exclusive use by CONSTRUCT IN, preventing access by a third party, ensuring the anonymization of the data.

Information about public and private entities with which the controller shared data: This pertains to your right to request that CONSTRUCT IN clearly and objectively inform which public or private entities (e.g., third parties, municipalities, regulatory agencies, etc.) your data is shared with and the purpose of this sharing.

Information about the possibility of not providing consent and about the consequences of refusal: This pertains to your right to be informed about the consequences of not consenting to the processing of personal data conducted by CONSTRUCT IN.

Revocation of consent, pursuant to the LGPD: This pertains to your right to revoke the consent regarding the processing of your data previously granted to CONSTRUCT IN. It is worth noting that you may provide the consent again.

Petitioning regarding your data against the controller before the ANPD: This pertains to your right to complain about any non-compliance with your rights to the National Data Protection Authority (ANPD), so that they can evaluate the case in light of the LGPD regulations and, if necessary, apply legal sanctions. For this right, the request is made directly by you to the ANPD, where subsequent contact will be made between the ANPD and CONSTRUCT IN.

Requesting the review of decisions made solely based on automated personal data processing that affect your interests, including decisions aimed at defining your personal, professional, consumption, and credit profile or aspects of your personality: This pertains to your right to request the review of processes that utilize automated decisions for the processing of your personal data in order to verify that automated decisions are not affecting your interests or creating your behavioral profile.

HOW TO REQUEST YOUR RIGHTS

You can exercise your rights by contacting us at the email dpo@constructin.com.br following the guidelines:
• In the email subject, fill in with: Rights Request – [YOUR FULL NAME]
• Send us an attachment of a photo of your ID (to be used for your identification)
• In the email body, inform us which right you are requesting (as presented above) by describing in detail which data should be considered.

CONSTRUCT IN will receive, investigate, and respond in a reasonable time frame to any request or complaint regarding how we handle your personal data, including complaints about violations of your rights under current privacy and data protection laws.

MORE DETAILS

For other matters related to the LGPD, you can contact the Data Privacy Officer, Queizy Sartori at the email queizy.sartori@constructin.com.br. This privacy notice may be updated annually, and you can always find the most recent version on this site.

São Leopoldo, May 31, 2023