Privacy Policy

Privacy, protection of Personal Data and its treatment in a transparent, ethical, safe and responsible manner are essential values for us.

This Privacy Policy (or just the “Policy”) explains how the companies of Grupo Valini Consulting, as Controllers of Personal Data, collect, use, share or otherwise process information and Personal Data of individuals, including customers and third parties, for the performance of our activities, including through our Sites and Applications. Here you will also find information about your rights in relation to your Personal Data, in accordance with the LGPD - General Law for the Protection of Personal Data (Law No. 13.709/18), and other applicable legislation.

INDEX
 
Privacy Policy

1. Privacy Policy Update

2. What information do we use and how do we collect it?

3. What do we use your data for?

4. Can information be shared?

5. About Cookies

6. How long do we keep your data?

7. data security

8. Your rights

9. Data Protection Officer

1. UPDATE OF THE PRIVACY POLICY
Whenever Valini Consulting deems it necessary, the Privacy Policy may undergo changes that will be published on our Sites and Applications. These changes will be valid, effective and binding after the new version is posted on our Sites and Applications or otherwise communicated to you.

2. WHAT INFORMATION DO WE USE AND HOW DO WE COLLECT IT?
We process Personal Data of who is or was our client or had any relationship with us, was or is a representative, attorney, employee, partner of any client, company or entity with which we relate, carried out any transaction with us or our clients, in people with whom we intend to relate or other holders of Personal Data.

The Personal Data we process varies according to the purposes of use, including those indicated in this Policy, and the activities we carry out. This Personal Data includes registration data, such as:

• Registration data: name, business address, business and cell phones, e-mail, profession, position, company, among others.

• Information about your devices: information about your device (such as Advertising ID and technical information such as operating system, screen size), connection (such as date, time and IP address, network used), device identification, device usage . We may also collect, if you authorize us through our Applications, your geolocation, for use for fraud prevention and security, credit protection, directing you to nearby facilities, and offering products and services to you.

• Information about browsing habits : pages and features accessed on our Sites and Applications, number of clicks, pages and applications that led to access to our Sites and Applications (for example, if you access a site that has a link to our Sites and Applications, or if you access third-party pages from links on our Sites and Applications).

• Social media and platforms data: interactions you may have with our social networks, such as Facebook, Twitter, Instagram, LinkedIn and YouTube.

The data may be provided directly by you, collected as a result of the provision of services. We may also obtain Personal Data and other information from public and/or publicly accessible sources, such as the Internet, media, social media and public records, and from other sources as permitted by applicable law.

Below are some examples of these situations.

• Data may be provided by you, for example, when filling out registrations, forms, accessing, searching or expressing interest in products and services.

• Data received from third parties are those provided by third parties about you, even if you are not a customer of Itaú Unibanco, including by companies or bodies with which Itaú Unibanco or you have any relationship, as well as suppliers and partners. Some examples of cases where this occurs are.

3.WHY DO WE USE YOUR DATA?
Valini Consulting performs the processing of personal data in accordance with the legal bases provided for in the General Data Protection Law (LGPD), such as, for example, to comply with legal and regulatory obligations; contract execution.

We may process Personal Data and other information for various purposes related to the performance of Valini Consulting's activities, according to the examples described below:

• carry out our activities, provide our services and provide our products in our relationship with you:

• perform and maintain your registration updated, verify your identity and any other information;

• perform and perform actions related to the contract, including steps prior to engagement, during and after engagement. Activities such as evaluating hiring proposals, service in our channels and operational processes to ensure the best experience and service for our customers;

• serve our customers, potential customers and third parties, including dealing with doubts, complaints, claims, requests and support through our service channels, allowing you to contact us whenever necessary, and vice versa;

• sending communications about products and services contracted by you, necessary for the fulfillment of the contract;

• understand our customers and offer products best suited to their needs and profile:

• evaluate the profile, identify opportunities and carry out the offer and contracting of products, services, initiatives and benefits from Valini Consulting and/or strategic partners most suited to the profile, interests and needs, for current and potential customers and third parties, including through and -email marketing or other communications. You can manage the means by which you prefer to receive our offers or opt out of receiving them in our service channels;

• analyze Users' demographic and interest information, through analytics tools such as Google Analytics and Facebook Ads, in order to understand the target audience of advertising campaigns;

• evaluate the browsing behavior and profile of Users and customers, including to understand whether the User has reached the Sites and Applications through direct access, links or own or third-party cookies, for example;

• carry out marketing campaigns and use information technologies and online advertising solutions;

• conduct surveys with the public to improve our products, services, service and initiatives.

• Maintain, create and improve our activities:

  • analyze, create and improve our products, services, activities, whether internal or external, initiatives, projects, features and functionality of our platforms, Sites and Applications, including to improve your access and use and provide the best experience for you;

  • measure and understand the interaction of Users and customers with us, including on social networks and our channels, as well as the use of our products, services, activities, initiatives, Sites and Applications and the satisfaction of Users and customers. So we can create, maintain and improve our products, services and our service channels;

  • execution of business processes, internal and managerial management. We process your data for our activities and to help us make better decisions about our operations, business, services, products, activities and initiatives;

  • activities related to contracting and relationship with suppliers, service providers and other third parties.

• Other Treatment situations based on legitimate purposes, such as the support and promotion of Itaú Unibanco's activities or for the provision of services that benefit our customers.

• Promote events, carry out sponsorships and other activities and initiatives.

4. CAN INFORMATION BE SHARED?
Valini Consulting only shares your information when it is necessary or relevant for the purposes provided for in the contracts with our customers and in this Privacy Policy, within strict security standards, always aiming at the confidentiality of your information and following the rules of bank secrecy and other data protection and privacy standards.

Examples of sharing situations are:

• among the companies of the Valini Consulting Group, including for the development of our activities, offer and provision of services and supply of products, risk management, compliance with legal obligations and other purposes provided for in this Policy;

• with strategic partners, including for offering, contracting and using products and services from them, or even jointly developed or that may have a benefit for you;

• with service providers, suppliers, brokers, including securities and insurance, and correspondents hired by Itaú Unibanco for the development of our activities;

• with regulatory bodies, other public entities, financial system institutions and third parties, including for the fulfillment and execution of legal, regulatory and contractual obligations and for the protection and regular exercise of rights;

• to comply with requests, requests and decisions of judicial, administrative or arbitration authorities;

• for the identification, prevention and investigation of possible violations or illegal acts (including fraud, money laundering and terrorist financing);

• to prevent risks, fraud and ensure security, including the use of your biometrics (facial, digital or otherwise) in identification and/or authentication processes in own electronic systems or those of third parties, which are also Personal Data Controllers;

• ·     situations in which sharing is relevant or necessary for creating, offering, maintaining, operating and improving our Sites and Applications, as well as the activities, initiatives and products and services of Conglomerate Itaú Unibanco and strategic partners;

​​

5. ABOUT COOKIES
Cookies allow the collection of data related to browsing depending on the type of device used, the authorizations granted by you through the settings of your device and the functionalities used in each application. We may use our own or third-party cookies on our Sites and Applications.

What are cookies?
These are small text files that may or may not be added to the device's browser. These files store and recognize data that ensure the correct functioning of the Sites and Applications and help us to identify your preferences and improve your experiences.

Types of cookies and their purposes
Cookies may collect data for different purposes related to the functionality of our Sites and Applications. Check out the types we use below:

• operation: to guarantee the correct access and operation of the applications;

• authentication: to recognize the User, enabling his/her access, including areas of restricted access and also used to offer content, offers and/or services from strategic partners;

• security: to assist in the monitoring and detection of unauthorized activities, in the prevention of fraud and in the protection of the information of Users, yours, the Itaú Unibanco Conglomerate and third parties;

• research, analysis and performance: to verify, measure and analyze the audience, performance, use of applications by Users;

• advertising: to present relevant advertising from Valini Consulting and partners according to the User's profile and to know if the Users have seen it, both in our environments and on partner websites and applications. They can also be used to remember any searches carried out by Users, and based on the results of these searches, to show advertisements or offers of products, services and initiatives of interest to them.

Can I disable cookies and other forms of information collection?
You can disable or delete cookies, as well as other data collection technologies, in your browser settings and in your device's operating system settings, with the exception of operating cookies which, if disabled, will not allow the use of the Sites and applications.

We only remind you that if certain cookies are disabled, the Sites or Applications or some of their features or functionality may not function properly.

6. HOW LONG DO WE KEEP YOUR DATA?
The period for which Valini Consulting keeps the Personal Data collected depends on the purpose and nature of the data processing. We will process your data for the period necessary to comply with legal, regulatory and contractual obligations, to continue to provide and improve our products and services, for risk management, for the regular exercise of rights in administrative, judicial and arbitration proceedings and for other purposes set forth in this Privacy Policy.

7. DATA SECURITY
The security and protection of personal data and Valini Consulting information is a priority for us. Valini Consulting establishes processes and controls for the prevention, detection and response to incidents and protection of your data from unauthorized access and use, ensuring the management of security risk, including cybernetics, and the construction of a robust security foundation.

We believe that information must be protected regardless of where it resides, whether in a service provider or an international unit, or in a partner, throughout its life cycle, from the moment it is collected, through processing, transmission. , storage, analysis and disposal.

We take care of data following strict security and confidentiality standards, to provide our users and customers with a safe and reliable environment. We use tools and technologies to maintain the integrity and confidentiality of information and protect it from unauthorized access.

Additionally, we restrict access to data to the extent necessary, with strict confidentiality and secrecy obligations and by adopting security criteria.

The data protection guidelines of the organization, customers and the general public are formalized in the Corporate Policy on Information Security and Cyber Security.
 
8. YOUR RIGHTS
The LGPD guarantees rights to Data Subjects. As the Subject of your Personal Data, you can make the following requests to us:

• access and confirmation of the processing of personal data;

• updating, correction of incomplete, inaccurate or outdated data;

• anonymization, blocking or deletion of unnecessary, excessive or processed data in violation of the provisions of the LGPD;

• data portability, in compliance with applicable rules and commercial and industrial secrets;

• information from public and private entities with which the Controller made shared use of data;

• information about the possibility of not providing consent and the consequences of denial;

• revocation of consent that may be carried out at any time and free of charge, upon express manifestation;

• request the deletion of Personal Data Processed with consent, except in cases where the maintenance of data is necessary or permitted by law;

• opposition to Treatment carried out on other legal grounds, in the event of non-compliance with the LGPD, noting that there may be situations in which we may continue to carry out the Treatment and refuse your opposition request;

• request the review of decisions made solely on the basis of Automated Processing of Personal Data that affect you, such as credit decisions;

• request the cancellation of sending targeted offers of products and services from Valini Consulting through our channels.

To exercise your rights over your Personal Data, you can use our service channels.

We reinforce that we may keep some data and/or continue to carry out the Treatment, even in the event of a request for deletion, opposition, blocking or anonymization, in some circumstances, such as to comply with legal, contractual and regulatory obligations, to protect and exercise rights of the Valini Consulting, of Users and clients, for the prevention of illegal acts and in judicial, administrative and arbitration proceedings, including for questioning third parties about their activities and in other cases provided for by law.

9. DATA PROTECTION OFFICER
To obtain more information about the Policy or how we treat your personal data, you can contact us at comercial@valini.com.br with the title “at the care of the Person in Charge”.