At ACR Safety Solutions, privacy and security are priorities, and we are committed to transparency in the processing of our users' and customers' personal data. Therefore, this Privacy Policy outlines how customer or other individuals' information is collected, used, and transferred when accessing or using our website.

By using our services, you understand that we will collect and use your personal information as described in this Policy, in compliance with Data Protection regulations (LGPD, Federal Law 13.709/2018), consumer protection provisions of Federal Law 8078/1990, and other applicable Brazilian laws.

Therefore, ACR Safety Solutions, registered under CNPJ/MF No. 04.632.102/0001-80, hereinafter referred to simply as "ACR Safety Solutions", in its capacity as Data Controller, is committed to the provisions of this Privacy Policy.

1. What data do we collect about you and for what purpose?

Our website collects and uses some of your personal data to enable the provision of services and enhance your user experience.

1.1. Personal data provided by the data subject:

• Name, Email, Phone, Position, Address for registration in our CRM and ERP systems.

1.2. Personal data collected automatically:

• Name, Email, and Position for sending information/promotions.
• Location (GPS).

2. How do we collect your data?

In this sense, the collection of your personal data occurs as follows:

• Through CRM, ERP platforms, and lead capture platforms.

2.1. Consent

We process your personal data based on your consent. Consent is a free, informed, and unequivocal manifestation in which you authorize ACR Safety Solutions to process your data.

In accordance with the General Data Protection Law, your data will only be collected, processed, and stored with prior and express consent.

Your consent will be obtained specifically for each of the purposes described above, ensuring ACR Safety Solutions' commitment to transparency and good faith towards its users/customers, in line with the relevant legislative regulations.

By using the services of ACR Safety Solutions and providing your personal data, you acknowledge and consent to the provisions of this Privacy Policy, as well as being aware of your rights and how to exercise them.

At any time and at no cost, you may withdraw your consent.

It is important to note that withdrawing consent for data processing may impact the proper performance of certain features on the website that depend on it. Such consequences will be communicated in advance.

3. What are your rights?

ACR Safety Solutions ensures the rights of its users/customers as data subjects under Article 18 of the General Data Protection Law. Therefore, you can, free of charge and at any time:

• Confirm the existence of data processing in a simplified or clear and comprehensive format.
• Access your data, requesting it in a readable copy, whether printed or electronically, securely and reliably.
• Correct your data by requesting editing, correction, or updating.
• Limit your data when unnecessary, excessive, or processed in violation of the law by anonymization, blocking, or elimination.
• Request data portability through a report of the data ACR Safety Solutions processes regarding you.
• Delete your data processed with your consent, except in cases provided by law.
• Withdraw your consent, preventing the processing of your data.
• Be informed about the possibility of not providing your consent and the consequences of refusal.

4. How can you exercise your rights as a data subject?

To exercise your rights as a data subject, you must contact ACR Safety Solutions through the following available means:

Email:

Valquíria Pires Motta

Email: dpo@acr1.com.br

To ensure your correct identification as the data subject, we may request documents or other proofs to confirm your identity. In such cases, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by ACR Safety Solutions will be used and stored for as long as necessary to provide the service or fulfill the purposes outlined in this Privacy Policy, considering the rights of data subjects and controllers.

In general, your data will be kept for as long as the contractual relationship between you and ACR Safety Solutions lasts. After the retention period, the data will be deleted from our databases or anonymized, except for cases provided by law under Article 16 of the General Data Protection Law, namely:

I – Compliance with a legal or regulatory obligation by the controller; II – Study by a research body, ensuring anonymization of personal data when possible; III – Transfer to a third party, provided that the data processing requirements in this law are met; IV – Use exclusively by the controller, prohibited from access by a third party, and the data anonymized.

That is, personal information necessary for fulfilling legal, judicial, and administrative determinations and/or for exercising the right to defense in legal and administrative proceedings will be kept, despite the exclusion of other data.

The data storage collected by ACR Safety Solutions reflects our commitment to the security and privacy of your data. We employ technical measures and solutions to ensure the confidentiality, integrity, and inviolability of your data. Additionally, we also implement security measures appropriate to the risks and control access to stored information.

6. What do we do to keep your data safe?

To keep your personal information safe, we use physical, electronic, and managerial tools designed to protect your privacy.

We apply these tools considering the nature of the personal data collected, the context and purpose of processing, and the risks that any violations might pose to the rights and freedoms of the data subject.

Among the measures we take, we highlight the following:

• Only authorized persons have access to your personal data.
• Access to your personal data is granted only after a confidentiality commitment.
• Your personal data is stored in a secure and reliable environment.

ACR Safety Solutions is committed to adopting the best practices to avoid security incidents. However, it is important to highlight that no virtual page is entirely secure and free of risks. Despite all our security protocols, third-party-exclusive issues may occur, such as cyberattacks by hackers, or also due to negligence or recklessness of the user/customer themselves.

In case of security incidents that may pose a significant risk or harm to you or any of our users/customers, we will notify the affected parties and the National Data Protection Authority about the incident, in accordance with the provisions of the General Data Protection Law.

7. Who can your data be shared with?

In order to preserve your privacy, ACR Safety Solutions will not share your personal data with any unauthorized third parties.

However, there are situations where your data may be shared:

I – Legal requirement, request, requisition, or court order with judicial, administrative, or governmental authorities. II – In cases of corporate transactions such as mergers, acquisitions, and incorporations, automatically. III – Protection of the rights of ACR Safety Solutions in any type of conflict, including judicial.

7.1. International data transfer

Some of the third parties with whom we share your data may be located in foreign countries. In such cases, your personal data will be subject to the General Data Protection Law and other Brazilian data protection laws.

ACR Safety Solutions is committed to always adopting effective cybersecurity standards and data protection measures, making every effort to ensure compliance with legal requirements.

By agreeing to this Privacy Policy, you consent to this sharing, which will occur as per the purposes outlined in this document.

8. Cookies or browsing data

ACR Safety Solutions uses Cookies, which are text files sent by the platform to your computer and stored on it, containing information related to your browsing activities. In summary, Cookies are used to improve the user experience.

By accessing our website and consenting to the use of Cookies, you acknowledge and accept the use of a navigation data collection system with Cookies on your device.

You can, at any time and at no cost, change permissions, block, or refuse Cookies. However, withdrawing consent for certain Cookies may hinder the proper functioning of some platform features.

To manage cookies in your browser, you can do so directly in your browser settings, in the Cookie management area. You can access tutorials on the topic directly through the links below:

• If you use Internet Explorer.
• If you use Firefox.
• If you use Safari.
• If you use Google Chrome.
• If you use Microsoft Edge.
• If you use Opera.

9. Changes to this Privacy Policy

The current version of the Privacy Policy was last formulated and updated on: October 21, 2021.

We reserve the right to modify this Privacy Policy at any time, mainly due to adjustments made to our website or legislative changes. We recommend reviewing it frequently.

Any changes will take effect once published on our website, and we will always notify you about the changes.

By using our services and providing your personal data after such modifications, you consent to them.

10. Responsibility

ACR Safety Solutions holds the responsibility of the agents involved in the data processing, in accordance with Articles 42 to 45 of the General Data Protection Law.

We are committed to keeping this Privacy Policy updated, ensuring its provisions are followed and ensuring compliance.

Additionally, we also take responsibility for ensuring appropriate technical and organizational conditions to protect the entire data processing process.

If the National Data Protection Authority requires us to take measures regarding the data processing conducted by ACR Safety Solutions, we commit to complying with them.

10.1 Disclaimer

As mentioned in Topic 6, despite adopting high security standards to prevent incidents, no virtual page is entirely risk-free. Therefore, ACR Safety Solutions is not responsible for:

I – Any consequences arising from user negligence, recklessness, or inexperience regarding their individual data. We guarantee and take responsibility only for the security of data processing and compliance with the purposes described in this document.

II – Malicious actions by third parties, such as hacker attacks, unless it is proven that ACR Safety Solutions acted with fault or intent.

III – Inaccuracy of information provided by the user/customer in records necessary for using ACR Safety Solutions services; any consequences resulting from false or fraudulent information are entirely the responsibility of the user/customer.

11. Data Protection Officer

ACR Safety Solutions provides the following means for you to contact us to exercise your data subject rights: email.

If you have any questions regarding this Privacy Policy or the personal data we process, you can contact our Data Protection Officer via the following channels:

Valquíria Pires Motta (CPF: 270.897.288-03)

Email: dpo@acr1.com.br