At Spin Engenharia, privacy and security are priorities, and we are committed to transparency in processing the personal data of our users/customers. Therefore, this Privacy Policy sets out how we collect, use, and transfer information from customers or others who access or use our website.

By using our services, you understand that we will collect and use your personal information in the ways described in this Policy, under the Data Protection rules (LGPD, Federal Law 13.709/2018), the consumer provisions of Federal Law 8078/1990 and other applicable rules of the Brazilian legal system.

In this way, Spin Engenharia de Automação LTDA., hereinafter referred to simply as “Spin Engenharia,” registered with the CNPJ/MF under No. 37.133.444/0001-05, as the Data Controller, is bound by 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 improve the user experience.

Through forms and events

• Profile data: We may collect information regarding the user’s profile, such as name, profile picture, and link to their social networks.
• Contact Information: We may collect user contact information, such as email, WhatsApp, and phone.
• Company information: We may collect information regarding the company you work for, such as name, website, number of employees, industry, and more.
• Content Consumed: We collect information about all content consumed by the user on our websites (such as e-books downloaded, and webinars watched).

Through cookies

• Preferences and pages visited: We save information regarding users’ content preferences, such as which pages were accessed. We also store information about which operating systems and devices were used to access the website.
• Geographic data: We may store information regarding the user’s physical location.
• Demographic data: In some cases, we may store demographic data about users, such as age, gender, education level, and approximate income.

Through the other contact channels (email, WhatsApp, chat and telephone)

• Collections and payments: we capture data such as CNPJ and bank details to manage payments for our services.
• Conversation history: when contacting support, commercial, administrative/financial or marketing department, we will store the conversation history (whether it is by email, WhatsApp, chat or phone).

2- How do we collect your data?

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

1. Information provided by you (forms and registration on virtual pages): we collect personally identifiable information – such as name, telephone number, e-mail, company you work for, and position – by filling out forms to download our free content or test our services.
2. Website browsing information (cookies): when you visit our website, a ‘cookie’ is placed on your browser via the Google Analytics software, to identify how many times you have returned to our address. Information such as IP address, geographic location, referral source, browser type, length of visit, and pages visited is collected anonymously. For more details, see the topic “Cookies or browsing data”.
3. Contact history: If you send an email to one of the Group companies or contact us through some other channel providing your details, we will store the information you provide as well as any history of contacts made. The goal is to personalize service and keep records about the interactions you have with our company.
4. Events: If you have registered for an event organized or supported by Spin, we may collect your data.

2.1. Consent

We process your personal data based on your consent. Consent is the free, informed, and unequivocal manifestation of your authorization to Spin Engenharia to process your data.

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

Your consent will be obtained specifically for each purpose described above, evidencing Spin Engenharia’s commitment to transparency and good faith towards its users/customers, following the relevant legislative regulations.

By using Spin Engenharia’s services and providing your personal data, you are aware of and consenting to the provisions of this Privacy Policy, as well as knowing your rights and how to exercise them.

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

It is important to note that the revocation of consent for the processing of data may imply the impossibility of adequately performing some website functionality that depends on operation. Such consequences will be informed in advance.

3- What are your rights?

 Spin Engenharia assures its users/customers of their rights as a holder provided for in Article 18 of the General Data Protection Law. In this way, you can, free of charge and at any time:

• Confirm the existence of data processing, in a simplified manner or in a clear and complete format.
• Access your data, being able to request it in a copy readable by electronic, secure, and suitable means.
• Correct your data, when requesting editing, correction or updating of your data.
• Limit your data when unnecessary, excessive or processed in non-compliance with the legislation through anonymization, blocking or deletion.
• Request the portability of your data, through a registration data report that Spin Engenharia processes about you.
• Delete your data processed based on your consent, except in the cases provided for by law.
• Revoke your consent, disallowing the processing of your data.
• Find out 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 Spin Engenharia through the following available means:

• relacionamento@spinengenharia.com.br

In order to ensure your correct identification as the subject of the personal data object of the request, it is possible that we request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

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

Your personal data collected by Spin Engenharia will be used and stored for the time necessary to provide the service or for the purposes listed in this Privacy Policy to be achieved, considering the rights of the data subjects and controllers.

In general, your data will be kept as long as the contractual relationship between you and Spin Engenharia lasts or the potential business relationship is real. At the end of the storage period of personal data, they will be deleted from our databases or anonymized, except in the cases legally provided for in article 16 of the General Data Protection Law, namely:

I – compliance with a legal or regulatory obligation by the controlling shareholder;

II – study by a research body, ensuring, whenever possible, the anonymization of personal data;

III – transfer to a third party, provided that the data processing requirements set forth in this Law are respected; or

IV – exclusive use of the controller, with access by third parties prohibited, and provided that the data is anonymized.

That is, personal information about you that is essential for compliance with legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be kept, despite the deletion of other data.

The storage of data collected by Spin Engenharia reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions capable of ensuring the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and access control to the stored information.

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

To keep your personal information secure, we use physical, electronic, and managerial tools geared toward protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the processing, and the risks that any violations would generate for the rights and freedoms of the subject of the data collected and processed.

Among the measures we have adopted, we highlight the following:

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

Spin Engenharia is committed to adopting the best postures to avoid safety incidents. However, it is necessary to note that no virtual page is entirely safe and risk-free. It is possible that, despite all our security protocols, problems that are exclusively the fault of third parties occur, such as cyber attacks by hackers, or also as a result of the negligence or recklessness of the user/customer himself.

In the event of security incidents that may generate relevant risk or damage to you or any of our users/customers, we will notify those affected and the National Data Protection Authority about the event, in line with the provisions of the General Data Protection Law.

7- With whom can your data be shared?

In order to preserve your privacy, Spin Engenharia will not share your personal data with any unauthorized third party.

Your data may be shared with our business partners:

• Ramper Desenvolvimento De Software Ltda., registered with the CPF/CNPJ under No. 29.138.927/0001-74.
• Euax – Artia Desenvolvimento de Sistemas LTDA., registered with the CPF/CNPJ under No. 17.400.505/0001-46.
• SANKHYA JIVA TECNOLOGIA E INOVAÇÃO LTDA., registered with the CPF/CNPJ under No. 26.314.062/0001-61.

They receive your data only to the extent necessary for the provision of the contracted services and our contracts are guided by the data protection rules of the Brazilian legal system.

However, our partners have their own Privacy Policies, which may differ from this one. We recommend reading these documents, which you can access here:

Privacy Policy of our partners:

• https://www.ramper.com.br/politica-de-privacidade
• https://artia.com/politica-de-privacidade/
• https://www.sankhya.com.br/politica-de-privacidade/

In addition, there are also other hypotheses in which your data may be shared, which are:

I – Legal determination, request, request or court order, with competent judicial, administrative or governmental authorities.

II – Case of corporate transactions, such as merger, acquisition and incorporation, automatically

III – Protection of Spin Engenharia’s rights in any type of conflict, including those of a judicial nature.

7.1. International data transfer

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. Under these conditions, in any case, your personal data will be subject to the General Data Protection Law and other Brazilian data protection legislation.

In this sense, Spin Engenharia is committed to always adopting efficient cybersecurity and data protection standards, in the best efforts to ensure and comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to such sharing, which will take place in accordance with the purposes described herein.

8- Cookies or browsing data

 Spin Engenharia makes use of Cookies, which are text files sent by the platform to your computer and stored there, which contain information related to the navigation of the website. In short, Cookies are used to improve the user experience.

By accessing our website and consenting to the use of Cookies, you are aware of and accept the use of a system for collecting browsing data with the use of Cookies on your device.

You may, at any time and at no cost, change the permissions, block or refuse Cookies. However, revoking consent for certain Cookies may make it impossible for some features of the platform to function properly.

To manage your browser’s cookies, simply do so directly in the browser settings, in the Cookie management area. You can access tutorials on the topic directly from 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- Modification of this Privacy Policy

The current version of the Privacy Policy was formulated and last updated on: 10/16/2024.

We reserve the right to modify this Privacy Policy at any time, mainly due to the adaptation to any changes made on our website or in the legislative sphere. We recommend that you review it frequently.

Any changes will be effective upon posting on our website and we will always notify you of any changes.

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

10- Liability

 Spin Engenharia provides for the responsibility of the agents who act in the data processing processes, in accordance with articles 42 to 45 of the General Data Protection Law.

We are committed to keeping this Privacy Policy up to date, observing its provisions and ensuring its compliance.

In addition, we are also committed to seeking technical and organizational conditions that are safely able to protect the entire data processing process.

If the National Data Protection Authority requires the adoption of measures in relation to the data processing carried out by Spin Engenharia, we undertake to follow them.

10.1 Disclaimer

As mentioned in Topic 6, although we adopt high security standards in order to avoid incidents, there is no virtual page that is entirely risk-free. In this sense, Spin Engenharia is not responsible for:

I – Any consequences arising from the negligence, recklessness or incompetence of users in relation to their individual data. We guarantee and are responsible only for the security of the data processing processes and the fulfillment of the purposes described in this instrument. We emphasize that the responsibility for the confidentiality of access data lies with the user.

II – Malicious actions of third parties, such as hacker attacks, except if proven culpable or deliberate conduct by Spin Engenharia. We emphasize that in the event of security incidents that may generate relevant risk or damage to you or any of our users/customers, we will notify those affected and the National Data Protection Authority about what happened and we will comply with the necessary measures.

III – Untruthfulness of the information entered by the user/client in the records necessary for the use of Spin Engenharia’s services; any consequences arising from false information or information entered in bad faith are the sole responsibility of the user/client.

11- Data Protection Officer

 Spin Engenharia provides the following means for you to contact us to exercise your rights as a data subject: relacionamento@spinengenharia.com.br.

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

 Rodrigo Lira Prado Borges (004.056.541-62)

rodrigo.borges@spinengenharia.com.br