Privacy and Data Protection Policy

TERMS OF USE

The ZL BRASIL E TERMINAIS DE DIRECIO Data Privacy Policy aims to demonstrate commitment, transparency and responsibility for the protection of your personal data, preserving the privacy and security of information, in accordance with Law 13.709/2018 (Law General Data Protection – LGPD).

This document describes the personal data we collect, how and why it is used, to whom we disclose it, and how we protect your privacy when you use our services or visit our platforms.

We clarify that only individuals over 18 (eighteen) years of age are authorized to use the ZL Brasil website and services, agreeing and consenting to this condition. By agreeing to this Policy, you give us full and unquestionable understanding of this and all other details provided below.

If you do not agree with this policy, we recommend that you do not use our website or other means of communication, nor contract the products and/or services offered by ZL Brasil.

1) DATA COLLECTION

A) COLLECTION OF PERSONAL DATA, SUCH AS FULL NAME, PHONE NUMBER AND EMAIL, AS WELL AS OTHERS FOR THE PURPOSES THAT ARE NECESSARY

WHAT WE DO: identify you when you visit the website or contact us.

WHY WE DO IT: out of legal obligation.

B) CONTACT HISTORY

WHAT WE DO: we monitor or record the information transmitted to us via telephone, social media, private message or email, for any information, complaint, compliment, etc.

WHY WE DO IT: to offer a better service, carry out quality control and execute all orders and contracts.

C) TIME OF COLLECTION

Personal data is collected and/or processed by ZL BRASIL when accessing and/or browsing the website; during or after requesting products and/or services; during the relationship with the brand, whether for those who have been or are still customers. This personal data includes information such as:

In order for us to offer our services with excellence, it is necessary to collect personal data, depending on the service provided. See below in more detail the forms of data collection:

2) PROCESSING OF PERSONAL DATA

The processing of personal data of ZL Brasil's customers, representatives and other business partners is carried out for specific purposes and when permitted by legal bases or by the consent of data subjects. All processing is carried out following security procedures in relation to privacy and data protection, following the guidelines for compliance with Law 13,709/2018 (General Data Protection Law). Therefore, we present below the main hypotheses in which we will process your personal information:

• For the execution of services and orders;
• If the company has to comply with any legal or regulatory obligation;
• For the regular exercise of rights in judicial, administrative or arbitration proceedings;
• Through authorization granted by you, to send advertising, product marketing or other brand relationship materials.

3) PURPOSE OF DATA COLLECTION

The data collected by ZL Brasil is processed and used with the legal bases provided for in the General Data Protection Law (LGPD), in accordance with the specific purposes for each service provision, such as:

• Carry out and keep your registration updated, verify your identity and any other information;
• Serve our customers, potential customers and third parties, including handling questions, complaints, requests and support through our service channels, enabling them to contact us whenever necessary; • Sending communications in general;
• Contact data subjects to send information about: (a) products and/or services offered by the brand and its partners, as well as other relevant information, such as changes to the website's functionalities and other matters that the brand deems of interest ; • Improve the services and/or functionalities of the website;
• Evaluate the browsing profile of data subjects, including to understand whether they reached the website or application through direct access, links or own or third-party cookies, for example;
• Develop campaigns based on internal studies on the interests, behaviors and demographics of data subjects to better understand their personal preferences;
• Talk to the customer about processing their orders and requests, as well as informing them about offers, programs, sweepstakes or promotions from the brand or its commercial partners;
• Classify and group data subject information, as well as consolidate statistical data regarding them, including to define the composition of the website and application user base and the volume of traffic on our servers;
• Provide customer service to data subjects, which may involve various activities related to the contracted services;
• Comply with judicial, administrative and arbitration orders and decisions.

You may choose not to provide any of the data required above, however, in order to navigate the website and perform some basic services that ZL Brasil may offer, certain information will be necessary so that you can fully use all of the website's features. from ZL Brasil, so that we can maintain the best relationship with you.

4) DATA SHARING

ZL Brasil does not sell or exchange your personal data with third parties, but may share it with other people as an essential part of providing our services to you, such as service providers, partners, financial institutions (exclusively to enable payments) or regulatory bodies when necessary or relevant for the purposes set out in contracts with our customers and in this Privacy Policy, within strict security standards, always aiming at the confidentiality of your information for data protection.

Personal data may also be shared to comply with current legislation, for tax, criminal and/or consumer purposes, as well as to cooperate with the competent authorities.

5) DATA STORAGE

The period for which ZL Brasil keeps the personal data collected depends on the purpose and nature of the data processing. Therefore, we will process your data collected on websites, landing pages, pop-ups and other input channels, for the period necessary to comply with legal, regulatory and contractual obligations, to continue to provide and improve our products and services, to manage of risks, for the regular exercise of rights in administrative, judicial and arbitration proceedings and for the other purposes set out in this Privacy Policy.

All data collected will be kept for a minimum period of 06 (six) months and a maximum period of 30 (thirty) years, when it will be deleted from our servers. Data may be deleted before the end of said period when the holder of the personal data so requests or when they are no longer necessary or relevant for us to offer our services, unless there is any other reason for their maintenance, such as a possible legal obligation to retention of data, or need to preserve it to protect the company's rights.

All personal data is stored on password-protected servers, ERP system, electronic drives, computers, smartphones, electronic catalogue, in the Skype database or e-mail, as well as in lockers protected with a key (in cases of information transmitted physically) , located in Brazil. ZL Brasil may relocate and store servers in any other country that complies with privacy legislation, in order to have support or backup, always keeping them safely under our supervision.

6) RIGHTS OF PERSONAL DATA SUBJECTS

ZL Brasil guarantees customers that their requests will be met based on the rights of the data subjects provided, as described in Law 13,709 – LGPD.

I – Confirmation of the existence of treatment;
II – Access to data;
III – Correction of incomplete, inaccurate or outdated data;
IV – Anonymization, blocking or deletion of unnecessary, excessive or processed data that does not comply with the provisions of the Law;
V – Data portability to another service or product provider upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;
VI – Elimination of personal data processed with the consent of the holder, except in the cases provided for by Law;
VII – Information from public and private entities with which the controller shared data use;
VIII – Information about the possibility of not providing consent and the consequences of refusal;
IX – Revocation of consent.

Holders can exercise their rights through ZL Brasil's communication channels made available for this purpose. The data subject is aware that their requests may be legally rejected, being justified to the data subject based on the terms of Law 13,709 – LGPD.

If the user has any questions about how they can exercise these rights, please contact us via email: Qualidade@zlbrasil.com and speak to our Personal Data Protection Officer. We ask you to write in the subject field: “Personal data”.

7) DATA SECURITY

Personal data held by ZL Brasil will be stored in accordance with the strictest standards adopted by the market, using security measures to preserve the privacy and integrity of the data. We maintain access controls to our customers' data, as well as training teams to correctly process data.

We use viable technical means to protect electronic data, such as antivirus; professional hosting, encrypted passwords; SSL security certificate; firewall to minimize the risk of hacking; antispam to protect against emails that may contain viruses; and individual access control for computers, network and systems.

In other words, we protect your personal data from all types of threats: destruction, loss, alteration, unauthorized disclosure or access. ZL Brasil protects your Personal Data in accordance with the security and confidentiality standards and procedures established by Brazilian legislation.

In addition to adopting good security practices in relation to your personal data, if the user identifies or becomes aware of something that compromises the security of personal data, please contact us via email: Qualidade@zlbrasil.com and talk with our Personal Data Protection Officer.

8) COOKIES AND SIMILAR TECHNOLOGIES

Cookies are files or information that may be stored on your device when you visit a company's websites or use online services. In this way, cookies allow the collection of data related to browsing depending on the type of device used, the authorizations granted by you through your device settings and the functionalities used in each application.

ZL Brasil uses third-party cookie technology, such as Google Analytics and Facebook Pixel, on its websites and applications due to their functionality to facilitate use and better adapt its website and applications to the interests and needs of its users, as well as to assist and improve their structures and contents. Cookies may also be used to speed up your future activities and experiences on our services.

These cookies are only used to monitor behavior and optimize the browsing experience. Discover the types of cookies we use:

At any time you can deactivate or delete cookies, as well as other data collection technologies, in your browser settings and in the operating system settings of your device, with the exception of functional cookies which, if deactivated, will not allow the use of websites and applications. However, we warn you that, depending on the choice made, certain features or functionalities of our services may not function properly.

9) INTERNATIONAL TRANSFER

ZL Brasil does not directly transfer personal data collected in Brazil to other countries. The company has its headquarters located in Brazil and the data we collect is governed by Brazilian law.

10) APPLICABLE LAW AND JURISDICTION

The terms of this Privacy Policy are interpreted in accordance with Brazilian law, with the jurisdiction of the district of Santa Bárbara D’Oeste being elected to resolve any dispute, question or doubt arising, with the express waiver of any other, however privileged it may be.

11) UPDATES TO THIS POLICY

ZL Brasil reserves the right to update this Privacy Policy at any time to provide the user with greater security, convenience and increasingly improve their browsing experience. Therefore, we recommend periodic viewing so that you are aware of possible changes.

If relevant changes are made that justify new user authorizations, we will publish this update and request new consent.