Privacy Policy

Avanti’s Privacy Policy (hereinafter referred to as “Policy”) demonstrates our commitment to handling the personal data of our customers or prospects (“Users”) with security, privacy and, above all, transparency.

This Privacy Policy will describe (i) how Avanti handles the processing of personal data, including its collection, use, storage and sharing; and (ii) the rights of data subjects – Users – have in relation to their data.

1. Avanti Principles for the Protection of Personal Data

Avanti respects the protection of your personal data as well as your rights to it. The five principles below support our stance in relation to Personal Data Protection are:

• Valuing the User’s trust in us to provide us with their personal data. • The User has the right to clear information about how and where we use his personal data. We will always be transparent about what information we collect, what we do with it, who we share it with and whom the User should contact in case of doubt. • We will cooperate with the User to promptly clarify any doubts that may exist about how we use their personal data. • We will take all reasonable steps to protect your information against any form of breach of personal data and to keep it secure. We will comply with all applicable data protection laws and regulations as well as cooperate with data protection authorities. In the absence of specific legislation on the subject, we will act in accordance with generally accepted principles governing data protection.

2. Policy Application Avanti is committed to protecting privacy and ensuring that the personal data of its Users are properly protected while we carry out any type of data processing under our responsibility.

This Policy will apply to customers as well as potential prospects of Avanti.

This Policy will not apply to employees or candidates for job vacancies at Avanti, holders who have their own Privacy Policies.

3. Basis for the Processing of Personal Data Avanti only processes the personal data of its Users in cases where there is a legal basis, for example, when it is necessary for the execution of a contract to which the User is a party, in order to fulfill an obligation legal or regulatory, when necessary to meet Avanti’s legitimate interests or when the User has expressly consented to their performance. The personal data that is collected to enter into a contract with Avanti are mandatory for the development of the contractual relationship and to fulfill the applicable legal obligations.

Marketing activities are generally handled on the basis of the consent given by the User or Avanti’s legitimate interest in providing advertisements to Users with a pre-existing business relationship. In any case, the User may choose not to receive any type of communication from Avanti at any time and free of charge. In situations where Avanti handles personal data of Users based on legitimate interest, a proportionality test will be carried out to ensure that no rights of the holder are violated.

4. How do we collect Personal Data? Avanti collects personal data related to the services it offers. Avanti may collect User data through: • customer service centers; • direct marketing campaigns, sweepstakes and contests; • through our websites; • subscriptions to newsletters; • third-party applications accessed or used through such third-party websites or platforms that are operated by or on behalf of Avanti (“Avanti Websites or Applications”).

5. What Personal Data do we collect? Nesta Política, dados pessoais são todas informações relacionadas a pessoa natural identificada ou identificável. De modo geral, essas informações são coletadas diretamente durante a interação do Usuário com a Avanti , seja para a celebração de contrato ou para utilizar serviços da Avanti.

In this Policy, personal data is all information related to an identified or identifiable natural person. In general, this information is collected directly during the User’s interaction with Avanti, whether to enter into a contract or to use Avanti’s services.

• Registration data, including: name; user name; address; date of birth, gender, nationality, number of identification documents, among others. • Contact details, including: email address and phone number; • Credit card information or other payment information; • Interaction with own or third-party services and products; • Content generated, stored or shared by the User himself, including third-party receipts, publications and other content that the User has uploaded to the Avanti Sites or Applications; • Any other personal data provided voluntarily.

5.2. Personal Data that we collect automatically through the Avanti Website We use cookies and other tools (such as web analytics tools and pixel tags) to automatically collect information when the User uses the Site, in compliance with the terms of this Privacy Policy and applicable laws and regulations for protection data, including storage obligations. The types of information we may automatically collect are: • Information about the type of browser the User uses; • Details of the web pages that the User accessed; • User’s IP address, date, time, duration, terminal, location and means of access; • Hyperlinks accessed through Avanti’s Websites or Applications; • Username, profile picture, gender, networks of contacts and any other information that the User authorizes to share when using Third Party Sites or Applications (for example, when using the “Like” feature of Facebook) • The pages that the User accessed before reaching an Avanti Site or App.

Most browsers are initially set to accept cookies. You can change the settings to block cookies or to alert you when your machine is sending cookies.

Your experience on the Avanti Sites or Applications may be affected if cookies are disabled . We emphasize that digital cookies allow Avanti to provide a differentiated experience for the User when using Avanti Websites or Applications, allowing Avanti to disclose products, promotions, coupons or information that are relevant to the User. Furthermore, only by accepting Cookies, the user of the Avanti Site or Applications will be able to:

• Register as a member; • Post comments or opinions; • Request sample and print discount coupons; • View information related to your interest.

Thus, we emphasize that personal data obtained through cookies will be treated based on the consent obtained by the holder through the acceptance of the pop-up that should lead the holder to the rules contained in this Policy. In addition, the User may at any time revoke his consent to cookies.

5.3. Personal Data Collected from Other Sources We may obtain personal data from Users through other sources, provided the User has previously consented to such sources for such information to be shared. It can be information from sources that are publicly available or information from third parties.

The types of personal data we may collect from these sources are: • Registration data, including: name; address; age, among others; • Purchasing habits, including geolocation data; • Publicly available information, such as User-generated content, blogs and publications, as permitted by law.

6. How is Personal Data used? We may use the personal data of Users to: • Evaluate the use of Avanti products, services and Websites or Applications; • Analyze the effectiveness of our advertisements, contests and promotions; • Customize the experience on our websites, as well as to evaluate (anonymously and in general terms) statistics on website activities, such as time of visit, number of previous visits and websites that led to the analyzed website; • Facilitate the use of the Avanti Sites or Applications and to better tailor the Avanti Sites or Applications and our products to your interests and needs; • Helping to accelerate the User’s future activities and experiences on the Avanti Sites or Applications. For example, a page can recognize if the User has already provided his/her personal data, avoiding asking for the same information again; • Collect information about the devices used to view the Avanti Site or Applications, such as IP address or the type of browser or operating system used, as well as to correlate this data with personal data in order to ensure that the Avanti Sites or Applications provide the User the best virtual experience possible; • Contacting the User about products and services that may be of interest to the User, provided that consent has been given to this or provided that there is a request for our products or services, and the relevant communication or related to such previous request is made to us. deadlines established by applicable laws; • Suggest products or services (including from third parties) that we believe to be of interest to the user; • Offer the opportunity to participate in contests or promotions; • To provide requested products or services; • For purposes of contests or promotions in which the User has entered; • To send requested information, products or samples; • To respond to User questions or comments.

6.1. How do we use your information when sending emails? Avanti regularly sends promotional emails and newsletters to its Users. The links contained in these emails always take the User to Avanti’s webshop or blog. All emails are sent from the Avanti address.

To no longer receive our promotions, please click on the link found at the bottom of our emails. • All our emails have a direct link to our online store or partner sites, and under no circumstances do they contain executable files or download links. • The entire Avanti database is secure. • All applicable legal measures are taken, with the purpose of protecting our company, our brands and, mainly, our Users.

Unfortunately, it is possible for malicious third parties to send emails on Avanti’s behalf containing false promotions offering high value product rewards or gift cards. Know what to do: If the User has received any email involving our brand or referring to this type of award or similar, be suspicious and do not execute any file. Please contact us at contato@penseavanti.com.br so that we can take the necessary measures and avoid inconveniences.

9. Storage and Deletion of Personal Data Users’ personal data will be stored in a safe and secure environment for the period necessary to carry out the purposes indicated in item 5 or until there is a request, by the User, to delete the personal data contained in our databases owned by him. All personal data stored are encrypted by SSL software, filed in an internal environment of Avanti’s exclusive access. This means that no information travels over the network without being encrypted (encoded) using the best algorithms available on the market. It should be noted that, even if there is a request for deletion, Avanti may store the user’s personal data for an additional period for purposes of legal or regulatory obligations,regular exercise of Avanti’s rights or for a period that is in accordance with the legal basis that justifies such retention.

9. Who do we share Personal Data with? As a general rule, we do not share your personal data with third parties outside Avanti. However, we may share them with third party partners and regulatory authorities and bodies, depending on the purpose and need. We may share your personal data with: • our advertising, marketing and promotion agencies to help us develop and analyze the effectiveness of our advertising campaigns and promotions; • third parties from whom we request the delivery of a product or service to the User, such as courier services or couriers that deliver the products that the User has ordered; • supervisory bodies or public bodies, when they have followed the due legal processes to request us to make the information available; • third parties who wish to send the User information about products or services, but only if the User has given us consent to do so; • third-party service providers, such as companies that process data for Avanti; • web analytics tool providers such as Google.

We may also share Users’ personal data with companies, organizations or individuals outside of Avanti, if we believe that such sharing is necessary for legal reasons. We may share the User’s personal data to: • enforce the applicable terms of use for the Avanti Sites or Applications; • investigate possible violations of applicable laws; • detect, prevent and protect against fraud and any technical or security vulnerability; • comply with applicable laws and regulations, cooperate in any lawful investigations, and comply with orders from public bodies. In addition, Avanti may share personal data with third parties in the event of corporate restructuring, including, for example, mergers, incorporations, transformations and spin-offs. If we share personal User data with third parties, we will use our best efforts to ensure that recipients keep it secure, take all reasonable steps to protect it from misuse, and use it only in accordance with this Policy, applicable laws and regulations for protection of data.

11. Rights of Users as Owners of Personal Data. The User, as holder of personal data, may exercise his rights against Avanti upon express request through the channels indicated at the end of this item. The rights of Users over their personal data are: • Right to confirm the existence of processing. Avanti will inform you whether or not the processing of the requesting holder’s personal data is carried out. • Right of access to data. Avanti will inform all personal data that it handles related to the requesting holder. • Right to correct incomplete, inaccurate or outdated data. Avanti allows the User to correct or update their personal data through the website itself, as will be described at the end of this item. However, if the User cannot correct or update by himself, Avanti will do so as informed by the requesting owner. • Right to anonymization, blocking or deletion of unnecessary, excessive or treated data in violation of the LGPD. If the User understands that Avanti is treating their personal data unnecessarily, excessively for the purpose highlighted or in disagreement with the LGPD, Avanti may carry out the anonymization, blocking or deletion of these, if the basis is verified by Avanti. • Right to delete personal data processed with consent. If the legal basis for the processing of the User’s personal data is exclusively his/her consent, he may withdraw this consent at any time, as well as all personal data that have been processed up to that moment with this legal basis by Avanti. • Right of data portability. If duly requested by the User, Avanti will carry out the portability of their personal data to another controller. • Right to information about companies or public entities that Avanti may have shared or received from you. The User may request that Avanti inform all companies or public entities with which it has shared or received its personal data, if applicable. • Right to the possibility of not providing consent and its possible negative consequences. Avanti will inform the User of all consequences of not providing consent to carry out the treatment. • Right to revoke consent. If requested by the User, Avanti will revoke the consent and, consequently, the legal basis for carrying out certain processing of personal data. All treatments based solely on consent performed until revocation will be valid. However, it should be noted that it will not prevent Avanti from processing the User’s personal data if its legal basis is different from that obtained by consent. • Right to review automated decisions.

The User may request the review of any automated decisions, that is, taken solely on the basis of automated processing of personal data that affect the User’s interests. If the User wishes to exercise any of the rights listed above, he/she must contact us through the website www.penseavanti.com.br or by e-mail contato@penseavanti.com.br from our Data Supervisor (DPO). It is noteworthy that the User has full right and at any time to request: • That he does not wish to be contacted by us in the future; • Report any misuse of your personal data via contato@penseavanti.com.br

12. Changes to our Privacy Policy Avanti reserves the right to modify this Policy at any time. However, whenever there is a change in the way we use Users’ personal data or any terms of this policy, we will notify the User through communication within our own website. We recommend that the User keep their data updated and access our website regularly to stay informed about our Privacy Policy. 13. Legislation and Jurisdiction This Policy will be governed, interpreted and executed in accordance with Brazilian legislation, especially Law No. 13.709/2018, in Portuguese, the forum of Florianópolis/SC being elected to settle any litigation or controversy involving this document , with express waiver of any other, however privileged it may be.

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