TERMS OF USE/NAVIGATION AND USAGE POLICY

1. CONCEPTS.

TR SOLUÇÕES uses essential cookies and other similar technologies for data collection and processing - for audience control, navigation, security, and advertising. For the purposes of these Terms of Use and Privacy Policy, the following concepts are considered, in accordance with art. 5 of the LGPD:

If not possessing such capacity, the USER declares to have previously obtained all necessary authorizations to accept this Privacy Policy and other documents presented by TR Soluções.

2. DATA COLLECTION.

In summary, we collect USER Data as they provide it to us, directly or indirectly, when accessing and using the websites, applications, and services offered by TR SOLUÇÕES or by partners duly authorized by the COMPANY (and who follow TR SOLUÇÕES Data privacy guidelines according to this policy). We also explain what Cookies are and how USERS can manage them.

2.1. Data will be collected:

When entered or voluntarily submitted by USERS on the websites, applications, and services offered by TR SOLUÇÕES, such as login, browsing, interaction with content, and service acquisition;

When Data is submitted automatically and without the need for any action by USERS, such as through Cookies; or by partners who have obtained authorization to share them with TR SOLUÇÕES;

2.2. The information that TR SOLUÇÕES collects may include, but is not limited to:

1. Name;
2. Address;
3. Email;
4. CNPJ and/or CPF;
5. Phone number;
6. In the case of e-commerce and payment methods, information for such purposes;
7. Information about the browser and operating system of the device;
8. IP address;
9. Visited pages or information about the USER's session;
10. Links and buttons clicked.

2.3. TR SOLUÇÕES is not responsible for the accuracy, inaccuracy, or outdated nature of the information and Data provided by the USER, which is the responsibility of the USER to provide accurately and keep updated.

TR SOLUÇÕES may periodically request that the USER update the information provided and the Data provided.

2.4. Cookies used by TR SOLUÇÕES may be classified in various ways:

(i) Regarding validity:

a) Session: temporary and remain until the web page or browser is closed. They can be used in e-commerce (to allow USERS to continue browsing without losing items in the cart, for example), to analyze internet traffic patterns, and to provide a better experience and contextualized content to USERS.

b) Permanent: remain even after the browser has been closed. They can be used to remember login information and passwords, for example, or to ensure a better user experience across different sessions.

(ii) Regarding ownership:

a) Own: owned by TR SOLUÇÕES, which has complete control over the Cookies.

(iii) Regarding purpose:

a) Strictly necessary: essential to allow USERS to use the websites, applications, and services offered by TR SOLUÇÕES, which could not be properly offered without these Cookies. They are usually Session-based and Own.

b) Performance: collect anonymous information about how USERS use and interact with the websites, applications, and services offered by TR SOLUÇÕES, allowing the recognition of their profiles and counting visits and interactions. They are usually Own.

c) Functionality: allow TR SOLUÇÕES to remember choices made by USERS (such as login) and provide more personalized experiences. This information can be anonymized (turning into Anonymous Data) and does not track activities outside the websites, applications, and services offered by TR SOLUÇÕES. They are usually Own and Persistent.

d) Analytics: Remember certain USER preferences and are used to help profile them to improve USER experience. They are usually Persistent and may be Third-party (such as Google Analytics, mentioned below).

e) Social media: allow USERS to connect with social media platforms such as LinkedIn and Facebook. They are usually Persistent and Third-party.

f) Security: help TR SOLUÇÕES monitor fraudulent activities and protect USER data from unauthorized access. They are usually Persistent and Third-party.

2.5. USERS may choose not to accept Cookies to use the websites, applications, and services offered by TR SOLUÇÕES, but in these situations, the company cannot guarantee the correct functioning of these websites, applications, and services.

Cookies can be accepted, deleted, or rejected through browser management tools used by USERS themselves.

2.6. TR SOLUÇÕES uses Google Analytics and Google ReCaptcha for the collection and processing of Data, in accordance with Google's policies available at google.com/intl/en/policies/privacy/partners/, policies.google.com/privacy, and policies.google.com/terms,

Any uses made by Google or its partners of USER Data collected through these tools will be the sole responsibility of Google, with TR SOLUÇÕES exempt from any liabilities resulting from such use.

2.7. TR SOLUÇÕES will also record activities performed by the USER on the websites, applications, and services provided by the company itself, creating logs that may include, but are not limited to:

1. USER's IP address;
2. Actions performed by the USER on the websites, applications, and services provided by TR SOLUÇÕES;
3. Addresses of pages and screens accessed by the USER on the websites - referred to as sessions in applications and services provided by TR SOLUÇÕES;
4. Dates and times of each action by the USER on the websites, applications, and services provided by TR SOLUÇÕES, in addition to the access made to pages and screens and the tools and functionalities used;
5. Information about the device used by the USER, operating system version, browser, among other installed applications and software;
6. Session and User ID, when available;
7. Type of connection used by the USER, such as Wi-Fi or cellular networks (EDGE, 3G, and 4G, for example);

2.8. Other technologies may be used to obtain browsing data from the USER. However, they will always respect the terms of this Privacy Policy and the USER's options regarding their collection and storage, with the USER being informed in advance of any changes.

If other Data not listed above start to be collected, the USER will be informed in advance.

The information collected by TR Soluções may be combined with information collected from other sources (including third-party partners) or from other technologies - plugins, for example.

3. DATA USE.

Data may only be accessed by TR SOLUÇÕES itself, partners, subcontractors, and authorities. However, if the USER accesses functionalities or sites from partners, they will be subject to the practices and policies of those partners. We also list the uses we will make of the data collected from USERS.

3.1. Data collected from USERS may be used for the following purposes:

1. Identification, authentication, and authorization;
2. Properly address requests and inquiries, as well as provide support to USERS;
3. Keep registries updated for contact purposes via phone, email, SMS, direct mail, or other means of communication;
4. Enhance usage and interactive experience during navigation on websites, applications, and services provided by TR SOLUÇÕES;
5. Conduct statistics, studies, research, project planning, and relevant surveys regarding USER activities and behaviors while using websites, applications, and services provided by TR SOLUÇÕES, performing such operations in an anonymized manner with Anonymized Data;
6. Protect TR SOLUÇÕES' rights and obligations related to the use of websites, applications, and services provided by them;
7. Collaborate and/or comply with judicial orders or requests from administrative authorities, as well as meet obligations to proactively report certain activities to competent authorities;
8. Proceed with payment requests made by USERS on their e-commerce platform;
9. Send newsletters and emails that the USER expressly agreed to receive;
10. Manage risks and detect, prevent, and/or remedy fraud or other potentially illegal or prohibited activities, as well as violations of applicable policies or terms of use;
11. Consult Data with private and public bureaus to verify accuracy, update them, or request additional data.

3.2. The use, access, and sharing of the database formed under this Privacy Policy will be carried out within the limits and purposes of TR SOLUÇÕES' activities, and may be provided and made available for access and/or consultation to business partners, suppliers, service providers, subcontractors, authorities, or third parties in general, provided that the provisions of this Privacy Policy and applicable laws or court orders are complied with.

3.3. Within its e-commerce scope, TR SOLUÇÕES undertakes to safeguard the financial and banking confidentiality of its clients and USERS by not sharing this information with TR SOLUÇÕES with whom the USER has not agreed.

The USER acknowledges that TR SOLUÇÕES is obliged to comply with a series of legal obligations under the applicable laws related to the identity of its customers.

Thus, TR SOLUÇÕES is authorized to request, and the USER is obliged to provide, additional documents and information, including for the implementation of know-your-customer procedures and prevention of money laundering.

Information obtained by TR SOLUÇÕES in response to the questions raised will be treated as confidential information. TR SOLUÇÕES is authorized to share data required by applicable laws with competent authorities and with third parties who need access to the Data to prepare/validate reports on TR SOLUÇÕES' activities under said legislation.

3.4. The USER is responsible for confidentiality, use, and all acts in the use of Credentials (such as, but not limited to, login, password).

If the USER identifies or suspects that a third party has access to their password, they must change it directly in the systems or services.

Sharing Credentials resulting from USER action constitutes a violation of this Privacy Policy.

3.5. The USER hereby acknowledges that TR SOLUÇÕES may perform (i) anonymization of Personal Data, making it Anonymous Data; and (ii) processing of Personal Data based on TR SOLUÇÕES' legitimate interest, as provided for in the applicable laws.

The USER expressly consents to such activities by agreeing to the terms of this Privacy Policy.

3.6. The USER acknowledges and agrees that TR SOLUÇÕES may use the Data to profile the USER in order to improve its services or comply with applicable laws, including, but not limited to, know-your-customer obligations.

3.7. Internally, Data will only be accessed by professionals/employees duly authorized by TR SOLUÇÕES, respecting the principles of purpose, adequacy, and necessity, among others provided for in the applicable laws, for the purposes of TR SOLUÇÕES, in addition to the commitment to confidentiality and privacy preservation under this Privacy Policy.

3.8. Anonymous Data may be collected, processed, stored, used, transferred, and disclosed for any purpose, regardless of USER authorization.

3.9. Data provided by the USER to partners will be their responsibility, thus subject to their own data acquisition and usage practices, without any liability burden to TR SOLUÇÕES regarding such Data.

4. DATA STORAGE.

Collected data is stored in a secure location. At any time, the USER may request to view, correct, or delete their data. Unless specific cases apply, we may retain collected data for legal compliance, auditing, and preservation of rights, for the period necessary to fulfill these responsibilities.

4.1. Collected data will be stored in a secure and controlled environment. However, considering that no security system is infallible, TR SOLUÇÕES disclaims any responsibility for damages and/or losses resulting from failures, viruses, or intrusions into the database of websites, applications, and services offered by TR SOLUÇÕES, except in cases of willful misconduct or negligence.

However, if TR SOLUÇÕES identifies that any of these situations have occurred, affected USERS will be notified informing them of the data breach and recommending that they take appropriate measures – risk mediation and occurrence plan.

4.2. Data obtained from the USER may be stored on TR SOLUÇÕES' own server or on a third-party server contracted for this purpose, whether located in Brazil or abroad, and may also be stored using cloud computing technology and/or other technologies that may emerge in the future, always aiming to improve and enhance TR SOLUÇÕES' activities.

TR SOLUÇÕES will ensure that third parties maintaining the servers where the data is stored comply with security and control standards as required by applicable laws.

4.3. Through the customer service tools available on TR SOLUÇÕES' websites, applications, and services, USERS may (subject to proving their identity):

1. request access to their data, including its display, correction to rectify incomplete, inaccurate, or outdated data, or deletion of Personal Data concerning them;
2. request the deletion of all their Personal Data collected and recorded by TR SOLUÇÕES, provided that the contract/service provision between the USER and TR SOLUÇÕES has ended, the account has been canceled, and the minimum legal period for legal obligations of TR SOLUÇÕES has elapsed;
3. revoke consent for future collection, processing, use, and processing of Personal Data concerning them or restrict the processing of Personal Data. This will not affect the legality of processing and processing of Personal Data carried out before revocation, based on their consent or legitimate interest of TR SOLUÇÕES. Revocation of consent may prevent the USER from fully using or even making it impossible to use the websites, applications, and services offered by TR SOLUÇÕES;
4. request portability of their data;
5. request that TR SOLUÇÕES no longer use Personal Data for marketing purposes such as using success cases.

4.3.1. Even if the USER has requested the deletion of their data and revoked their consent, in some specific cases, TR SOLUÇÕES may be subject to laws and regulations that prevent the deletion/revocation of Data.

4.3.2. The USER's Personal Data will also be deleted when no longer necessary, except where there is a legal or contractual justification for its maintenance (for example, to comply with any legal obligation to retain data or the need to preserve such data to protect the legitimate rights and interests of any party involved in the contract).

4.4. USER privacy settings influence the USER's Data obtained by TR SOLUÇÕES.

4.5. For auditing and rights preservation purposes, TR SOLUÇÕES may maintain a record history of USER Data, with TR SOLUÇÕES having the authority to permanently delete them as convenient or in cases where law or regulatory norms require.

5. GENERAL PROVISIONS.

We may update this document at any time. Therefore, please check it frequently. If we outsource any activity, we will ensure that the contracted companies comply with all provisions of this document.

5.1. The content of this Privacy Policy may be updated or modified at any time, as necessary or convenient for TR SOLUÇÕES, including for legal compliance with laws or regulations having equivalent legal force, and the USER should review it whenever accessing TR SOLUÇÕES' websites, applications, or services.

5.1.1. In the event of updates to this document, TR SOLUÇÕES will notify the USER through available tools on TR SOLUÇÕES' websites, applications, and services and/or contact methods provided by the USER. The USER will be bound by the new terms of this document upon delivery of notification about the updates.

5.2. The contact for the Data Protection Officer (DPO) is the email address contato@trsolucoes.com, with the name Joana Marins de Andrade Coutinho. The USER may contact this address to clarify any doubts regarding the provisions of this Privacy Policy.

5.3. If the USER believes that TR Soluções has violated any legal provision or this Privacy Policy, the USER has the right to file a complaint with the National Data Protection Authority (ANPD), in addition to contacting TR SOLUÇÕES.

5.4. If TR SOLUÇÕES outsources the processing of any data collected by TR SOLUÇÕES, the contracted parties must comply with the conditions stipulated herein and TR SOLUÇÕES' Information Security standards.

5.5. If any provision of this Privacy Policy is deemed illegal or illegitimate by the authorities in the USER's place of residence or their internet connection jurisdiction, the remaining conditions shall remain in full force and effect.

6. SERVICE MANAGEMENT/PAYMENT PARTNERS IN E-COMMERCE.

6.1. When making purchases on the TR SOLUÇÕES e-commerce platform, USER's data will be shared with credit card administrators, payment receiving institutions, for computation of amounts, to comply with legal obligations and legitimate interest for service provision – such as issuing an Invoice for service provision, as imposed by Applicable Legislation.

6.1.1. TR SOLUÇÕES uses as its payment and electronic commercial feasibility platform – or 'payment partner', the payment system of Mercado Pago, from the Mercado Livre group, for payments, plugins, platforms, and checkout methods, according to Mercado Pago's policies available at https://www.mercadopago.com.br/privacidade which USER fully agrees to by accepting this Privacy Policy.

6.1.2. Exact personal data will be collected by the aforementioned payment partner, varying by payment method, but including information such as: (i) name; (ii) date of birth; (iii) Credit or debit card type, expiration date, and certain digits of your card number; (iv) CPF (Brazilian Taxpayer Registry); (v) postal code; (vi) phone number; and (vii) details of your purchase and payment history.

6.1.3. TR SOLUÇÕES shares your personal data with the partner as strictly necessary to allow them to process payments and also to combat potential fraud.

6.1.4. None of this information will be retained – except as allowed by Applicable Legislation, by TR SOLUÇÕES, and not processed by TR SOLUÇÕES due to partner interaction, not being responsible for information leakage on the Mercado Pago payment platform.

6.2. Payment through the payment partner, TR SOLUÇÕES will only receive strictly necessary data for sending invoices, processing information for service provision by TR SOLUÇÕES, according to the legal basis of contract execution.

7. JURISDICTION AND APPLICABLE LAWS.

7.1 This Privacy Policy shall be construed in accordance with Brazilian legislation, in Portuguese language, with the court of Itajubá in Minas Gerais elected to settle any dispute or controversy involving this document, except for specific personal, territorial, or functional jurisdiction provided by Applicable Law.