Privacy Policy

Update date: August 07, 2023

      I. INTRODUCTION

We appreciate your trust in sharing your personal data with us and recognize that you may want to know how we handle this information. Sitawi created this policy to help you understand how we process personal data. This Privacy Notice (“Notice”) is intended for the following individuals (“you” or “you”):

  • To all those who interact with our digital portal www.sitawi.net (?Website?), owned and managed by Sitawi (?Us?, ?Our?), with our social networks and messaging applications;
  • To all those who participate in our Impact Crowd Lending Platform;

This Notice serves to give you full transparency on how we handle your Personal Data ("Personal Data"). You may access and view this Notice at any time via the Website. Also, the Terms of Use (?Terms?), also available on the Website, apply, together with this Notice, so we recommend that you read them.

a) SUMMARY TABLE

 Data controller:

Sitawi Finance for Good

CNPJ: 09.607.915/0001-34

Address: Teodoro Sampaio, 1629 / 1633 – Bairro Pinheiros – CEP: 05.405-150 São Paulo, SP.

What data is collected

· Personal data provided by You via the Fale Conosco (Contact) system of our Website;

· Personal data provided by You when filling in forms on our Website and Registration Pages;

· Personal data provided by You when participating in our corporate events or those that we participate in;

· Personal data provided by You when choosing to participate in our newsletter or in our promotional and marketing campaigns;

· Personal data provided by You when communicating with us via Whatsapp;

· Personal data provided by You on the Benfeitoria platform;

· Personal data provided by You on the MOVA platform;

. Personal data provided by You on the Collective Loan for Impact Platform;

· Personal data automatically collected when interacting with us on our Website or Registration Pages

· Information resulting from the normal use of our Website;

 If you want more details, see the Topic II below.

What we use your data for:

· We may use your data to respond to demands, complaints or suggestions made by you;

· We may use your data to improve the content available on our Website and on our social networks, as well as to carry out marketing campaigns and emails;

· We can use your data to carry out the registration in projects, participations and donations and carry out communication about the services provided and activities carried out by Sitawi;

 If you want more details, see the Topic III below.

With whom we share your data:

The data you enter on our Website and Registration Pages may be shared with Sitawi partner companies, with government authorities or institutions or for the performance of our services, in accordance with the terms described in this Privacy Notice.

 To learn more, see the Topic V below

How we protect your data:

We implement all security measures at our disposal to protect your data.

If you want more details, see the Topic VI below.

How long do we keep the data:

Personal data will only be stored for the time necessary for our activities, observing, whenever applicable, the legal and regulatory provisions that indicate a specific retention period:

· Access logs (date, time, IP): 6 months

· Data collected by Cookies: 90 days

· Other personal data: 5 years

If you want more details, see the Topic VII below.

Your rights as data subject:

We are proud to be an organization that takes the rights of visitors to our Website and participants in our Programs seriously. Therefore, we guarantee that all rights over your data can be exercised, respecting the applicable legal limits.

If you want to understand what your rights are, see the topic XIII below.

Contact:

For questions and requests, visit: mail dpo@sitawi.net

If you want more details, see the Topic IX below.

II. WHAT DATA IS COLLECTED

Sitawi may collect data provided by you or automatically when accessing our website or interactions on our Website and Registration Pages. We list below all the hypotheses in which we collect your data, as well as what information is collected. These are:

Personal data provided by You via the Fale Conosco (Contact) system of our Website

· Name

· Surname

· Organization

· Email

· Telephone

Personal data provided by You when filling out forms on our Registration Pages

· Name

· Telephone

· Email

· Professional address

· Profession

· Office

· Company

Personal data provided by You when participating in our corporate events or those that we participate in

· Name

· Telephone

· Email

· Professional address

· Profession

· Office

· Company

Personal data provided by You when choosing to participate in our newsletter or our promotional and marketing campaigns

· Name

· Surname

· Organization

· Email

· Telephone

· CPF

· Complete address

Personal data provided by You when communicating with us via Whatsapp

· Name

· Telephone

· WhatsApp ID

Personal data provided by You on the Benfeitoria platform

· Full name

· RG

· CPF

· Email

· Telephone

· ID

· Credit card details

Personal data provided by You on the Collective Lending Platform for Impact

· Full name

· RG or CNH

· Issuing agency

· CPF

· Email

· Telephone

· Bank data

· Investor Profile

· Filiation

· Profession

· Schooling

· Income

· Patrimony

· Nationality

· Gender

· Marital status

· Naturalness

· Proof of address

· Photo of Document with Photo

· Address

Personal data collected automatically when interacting with us on our social networks

· Name

· Social media IDs

· Social network link

Information arising from the normal use of our Website

· Records of interactions in each activity

· Characteristics of the access device, the browser

· IP (with date and time)

· Geolocation

· Information on clicks, pages, materials accessed, access time and frequency of use of the Website

· The following pages accessed after leaving the Website

For such collection, we may make use of certain standard technologies, such as Cookies, pixel tags, beacons and local shared objects, which are used for the purpose of improving your browsing experience on the Website, according to your habits and preferences.

III.             HOW WE USE YOUR DATA

Personal data may be used for the following purposes:

  • Communication: The information collected by the Contact system of our Website and that collected during your interaction with us through social networks or Whatsapp will be used to respond to demands, complaints or suggestions made by you. Depending on the severity of the complaint, we may send the collected data to the legal sector to better address your demands.
  • Content targeting and participation in marketing campaigns: We may use the data collected from our newsletter participants, our events and our website visitors to improve the content available and on our social networks, as well as to conduct campaigns and send marketing messages through any means of communication, such as , but not limited to emails and messaging apps.
  • Data shared with partner companies: When necessary, we may share your data with operators and service providers that participate, directly or indirectly, in the development of our Program activities. To learn more about this, please read the data sharing section of this Notice.
  • Data collected to comply with legal obligations: We are required by law to retain some basic data for accessing our Website, such as the IP address of the source connection, with date and time. Such data are kept for the legally prescribed minimum period of 6 (six) months. Eventually, other data may also be stored to comply with legal obligations, such as those related to participation in our Programs.
  • Secondary purposes: We may also use the data collected for secondary purposes that are not conflicting or excessive in relation to the purposes listed above, such as, or to defend itself in judicial or extrajudicial conflicts, always in compliance with Brazilian legislation in compliance with your rights and freedoms individual

 

 

IV. HOW WE USE COOKIES

What are Cookies?

Cookies are small files that collect personal data as you browse the internet. Cookies serve different purposes, such as:

Types of Cookies

What they do?

 necessary

These cookies are essential for the Website to load correctly and allow you to browse and use all available functionality as normal.

 Functional

These cookies allow the Website to remember Users' choices to provide a more personalized experience. They also allow Users to use social tools, fields for comments, among others.

 Marketing

These cookies are used to provide more relevant content of interest to Users. They may be used to display targeted advertising or limit its placement on the Website. RD Station and Google Analytics can also be used to indicate the sites that the User has visited.

  • How we use cookies

We may use cookies to facilitate use and better adapt the Website to your interests and needs, as well as to compile information about the use of our Website, helping to improve its structures and content.

  • How to refuse or disable cookies

When you enter our Website for the first time from a device, we will collect your registration for the use of cookies. After this registration, we may store cookies on your device to remember you in the next session.

If you are interested in deactivating, deleting or managing cookies, each platform offers step-by-step instructions on how your tool can be configured. The links are provided below:

O   Microsoft Edge

 Mozilla Firefox

 Google Chrome

 Safari

Finally, we remind you that if you disable some cookies, certain services may not work optimally.

V. WITH WHOM DO WE SHARE THE COLLECTED DATA?

We may share data collected through our Website and participation in our Programs in the following cases:

  • With partner companies, when necessary or pertinent for the execution of our services, including, but not limited to, technical support for maintaining the availability of the Website and the systems used by the company, such as in collective loan projects, and demands received through the Fale system With us;
  • To protect our interests in any conflict or litigation, even if judicial, administrative or arbitral;
  • In the event of changes or corporate operations involving us, in case the sharing of data proves necessary for the regular continuity of the Website services and those related to our Programs;
  • With administrative and/or judicial authorities, upon judicial determination in this regard or request from authorities that have legal competence to do so.

SAW. INFORMATION SECURITY MEASURES

We consider all information collected through the Website, or during participation in our events or Programs, confidential, ensuring that it will be treated and stored in accordance with the determinations of this Notice and with the adoption of adequate technical and administrative security measures, in accordance with the degree of data sensitivity and the risks inherent to the activity.

Among the security measures we adopt are the use of data encryption, information access control, the use of firewalls and the implementation of an internal information security policy, software solution architecture with intrusion prevention, use of HTTPS.

However, despite our best efforts, it is impossible to guarantee that malicious actors will not be able to gain access or misuse this data. For this reason, we encourage Users to take appropriate technical security measures, such as browsing secure networks.

VII. DATA RETENTION POLICY

We will only retain your Personal Data for as long as necessary to satisfy the purpose for which the data was collected or upon your request, as explored in this Notice.

In cases where data was collected for sending newsletters and marketing campaigns, we will keep your data as long as there is engagement on your part. In practice, this means that, after 180 days (6 months) without any type of engagement and direct or indirect interaction with our content, we delete any information that could identify you.

Furthermore, the data may be stored for a period of time:

  • Legal possibly linked to the legal relationship with you;
  • Necessary for any contractual negotiation;
  • Necessary for compliance with any legal or regulatory obligation;
  • Or if there is another just reason to store it.

When the Personal Data we collect is no longer needed, we will securely delete it or anonymize it so that it cannot be associated with or traced back to you.

VIII. WHAT ARE USER RIGHTS?

We take your rights seriously and therefore have listed your personal data rights below. Are they:

Rights of Users and Customers

What does this right mean?

Confirmation

You may question whether your personal data is being processed by Sitawi

Access

You can request access to your personal data stored by the Website, or as a result of one of our services, upon request in our contact channel. dpo@sitawi.net

Correction

In case of incorrect data, you can request the correction or update of your data, upon request in our contact channel dpo@sitawi.net

Exclusion

At any time, you can request the deletion of your personal data through our contact channel. dpo@sitawi.net. It is possible that after requesting the deletion of your data, some data will remain stored, for the purposes of complying with legal obligations or for the protection of the legal interests of Sitawi or its business partners.

 

unsubscribe

Sitawi maintains an easy opt-out option applicable to situations in which it is requested.

portability

You may request the portability of data stored on our systems. This means that, in the event of this type of request, Sitawi will deliver a copy of your personal data in a common and interoperable reading format, however, compatibility between such format and the technical configurations of the company receiving such data cannot be guaranteed.

Opposition

If you understand that your personal data is being processed in breach of the law, you may object to this treatment, upon request in our contact channel. dpo@sitawi.net.

All requests presented above will be treated free of charge, and will be subject to a prior assessment of their identity and the feasibility of the service, in order to comply with any legal obligations that prevent the complete fulfillment of the requests of the right holders.

VIX. COMMUNICATION CHANNEL WITH THE HOLDER OF PERSONAL DATA

Transparency regarding the processing of your personal data is a priority for Sitawi. In addition to the information provided in this Privacy Policy, you may also exercise your rights, at any time, by sending requests via email: dpo@sitawi.net, which will be met within the legal deadline.

X. LEGISLATION AND JURISDICTION

This Notice will be governed, interpreted and enforced in accordance with the Laws of the Federative Republic of Brazil, in particular Law No. , to resolve any doubts arising from this document.

XI. Changes to this Privacy Statement

Sitawi may update this Privacy Policy periodically, and the current version will always be the most recent. If we make any changes to the Policy in material terms, we will post a notice on our website or send you an email, along with the updated Privacy Policy. To check the current version date, check the ?Update date? at the beginning of this document.

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