Privacy Policy

Celero is committed to transparency, privacy and the security of users' data throughout the entire process of interaction with our applications. So that you can better understand which personal data we collect and how we use, store or delete it, we set out our Privacy Policy below. This Policy applies to all users of our applications whose personal data is in any way processed by us.

We strive to keep this document as clear as possible. However, if you still have any questions on this subject, or wish to make any request regarding your personal data or exercise your rights, you may contact the DPO (Data Protection Officer) using the contact details below:

DPO CONTACT

Company: BAZZANEZE AUDITORES INDEPENDENTES S/S
Name: DANIEL BUENO DA SILVA
Contact email: dpo@celero.com.br.

In compliance with the regulation published by the ANPD (Brazilian National Data Protection Authority) on July 17, 2024, the alternate DPO, Rudolf Copi Eckelberg, will respond at the same email address above.

1. GLOSSARY

For this Privacy Policy to be properly understood, it is essential to clarify some important concepts:

• User or Data Subject: The natural person who uses our applications or whose personal data is processed by Celero.
• Client: The legal entity that uses the services provided through Celero's technology.
• Partner: Financial Institutions and Organizations that offer financial and management services to their network of suppliers, clients and distributors through Celero's technology.
• Personal data – Any information relating to a person that identifies them or that, when used in combination with other processed information, identifies an individual. Also, any information through which it is possible to identify or contact a person.
• Sensitive personal data - Personal data concerning racial or ethnic origin, religious belief, political opinion, membership of a trade union or of a religious, philosophical or political organization, data concerning health or sex life, and genetic or biometric data.
• Processing of personal data – Processing of personal data means the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, communication, transfer, dissemination or extraction of data relating to natural persons.
• Data subject – Any natural person whose personal data is processed by Celero;
• Purpose – the objective we seek to achieve by processing personal data.
• Necessity – the processing of personal data must be limited to the minimum necessary for the intended purpose. In other words, it must be relevant, proportionate and not excessive.
• Consent – the clear and objective authorization given by the data subject for the processing of their personal data for a previously specified purpose. After giving consent, you may revoke it at any time. Revocation does not cancel processing carried out previously.
• Cookies - Small data files that are placed on your computer or other devices (such as 'smartphones' or 'tablets') while you browse.
• Platform - Our digital products, which include the Organizador PJ.

2. WHAT IS THE PURPOSE OF THIS POLICY?

This Privacy Policy has the following objectives:

• To describe the personal data we collect and how it is used, stored, protected and shared, in compliance with Law No. 13,709/18 ("Lei Geral de Proteção de Dados", the Brazilian General Data Protection Law, or "LGPD").
• To inform users of their rights regarding personal data, and to provide our service channel for data subjects.

By accepting this Privacy Policy, the USER agrees to the terms described herein and to the processing of personal data for the purposes described below.

The USER's acceptance is voluntary. Use of the online Services made available by Celero by any user shall constitute express acceptance.

If the user does not agree with the terms and conditions of this privacy policy, they should not use the website or application.

3. WHAT PERSONAL DATA DOES CELERO COLLECT AND FOR WHAT PURPOSES?

Celero collects information provided directly by users, such as:

• Identification data: First and last name, date of birth, CPF (Brazilian individual taxpayer number) and mobile phone number, for the purpose of registration on our platform and to keep in touch with the user and client.
• Access credentials: login email and password, for the purpose of accessing the platform.
• Client operation data: The client may provide personal data that may be involved in its financial operations, such as: first and last name, email, phone number, date of birth, CPF and sex of an operator user, for the purpose of granting our client's employees access to our platform. In addition, personal data about payees and payers in its financial transactions, for the purposes of viewing, managing and controlling the operation.
• Electronic and interaction records: Data collected automatically when the user interacts with our website or platform, such as date and time of access, location data and mobile device data, for the purpose of improving the experience on our website and measuring the number of visits we receive; Actions performed by users within the platform may be recorded in logs, together with the date and time, user identification and action performed, for audit purposes.

Celero may also collect information from other sources, such as:

• Partner financial institutions: Bank account data, company data, administrator user data, such as first name, last name, email, phone number, CPF and email; operational data, such as financial transactions, name and banking details of payer and payee, and document numbers.
• Public information: Data made public by you may also be collected, always respecting your rights and the principles of the LGPD.

Celero may process sensitive personal data in certain situations. The following sensitive data is processed by Celero:

• Operator's gender: When registering an operator on the platform, the administrator may select "Male", "Female" or "Unknown" in the "Sex" field. If the user chooses to fill in this field, it will be treated as sensitive and may be changed at any time by the operator on the platform.

When registering a new operator, if the operator is a minor, based on the Date of Birth entered, the platform will not allow the registration.

4. WHAT IS THE LEGAL BASIS FOR DATA PROCESSING?

The USER's data may be processed:

• Upon the USER's free, informed and unequivocal consent, only when legally required or permitted, which may be revoked at any time;
• For compliance with a legal or regulatory obligation by the controller;
• For the regular exercise of rights in judicial, administrative or arbitration proceedings;
• To establish a contractual relationship between the USER and Celero and to fulfill our obligations undertaken under the terms of a contract;
• Based on any other legal basis permitted by the LGPD;
• When necessary to serve Celero's legitimate interests;

All personal data processed by Celero meets at least one of the legal bases listed above.

5. WITH WHOM DO WE SHARE YOUR DATA?

The information collected may be shared:

1. with our partners, for the proper provision of the services that are the object of their activities, such as technological and operational infrastructure providers, support providers, and financial institutions that have already shared your data with us;
2. with competent authorities, for protection in the event of a dispute, upon a court order or a request from a competent authority;

Furthermore, we may share your personal data to protect our rights or those of clients or third parties, to protect your legitimate interests or those of another person, to enforce our terms of use or other agreements, and to file or defend legal claims.

We do not license, sell or transfer your personal data to anyone, under any circumstances, for profit or in any manner contrary to this Policy.

To find out specifically with whom your data is shared, contact the DPO at dpo@celero.com.br.

6. HOW LONG DO WE STORE PERSONAL INFORMATION?

We will keep your data at least for as long as you have an active account on the platform.

In the event of termination of the platform use agreement, each item of personal data will be retained:

• If the personal data has been anonymized
• If other laws permit or require its retention, such as the statute of limitations rules of Brazilian law
• If the data is necessary to comply with regulatory and legal obligations
• If the data is necessary for the exercise of rights or legal protection

If the data subject requests the deletion of personal data processed with their consent through the official service channel for data subjects, dpo@celero.com.br, such data will be deleted within 7 business days, provided this does not conflict with the items mentioned above. The platform also provides means to update your personal data on the platform itself.

7. WHAT MEASURES DOES CELERO TAKE TO PROTECT MY DATA?

Celero takes the security of its technology very seriously. That is why we use the best security protocols to preserve the security and privacy of users' data, from the design of our products onward (Privacy By Design and Privacy By Default).

Data transmitted through Celero is encrypted in transit and at rest, which prevents unauthorized persons from understanding its content, in addition to other techniques implemented to prevent unauthorized access, accidental or intentional manipulation, loss or destruction of your personal data.

Everyone who works at Celero undergoes periodic training to handle your data securely and privately.

The user also plays a very important role in the security and protection of their personal data. Therefore:

• Never share your login information
• If you access your account on a public computer or one that is not used exclusively by you, make sure you have logged out of your account to prevent unauthorized persons from accessing and using the information without your knowledge.
• Celero does not request personal data by phone, WhatsApp, SMS or email. Never provide any information in such cases, and notify us immediately.

8. COOKIES AND SIMILAR TECHNOLOGIES

Celero uses cookies to provide the best experience while you visit our website. We use cookies to recognize your browser or device, learn more about your interests, enable faster browsing, and provide essential features and services. It is important to note that some cookies are necessary to provide essential functionality. You may change your cookie settings at any time you deem necessary.

You may block or reject our cookies, but this limits access to services that require login, and in that case parts of our website may not work properly. The cookies used are:

• Strictly necessary cookies: Cookies that are required for our website to function. They include, for example, cookies that allow you to log in to secure areas of our website.
• Analytical / performance cookies: Cookies that allow us to recognize and count the number of visitors to our website and help us improve the way our website works.
• Functionality cookies: Cookies used to recognize you when you return to our website. This allows us to personalize our content.
• Targeting cookies: Cookies that record your visit to our website, the pages you visited and the links you followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

If your browser accepts cookies automatically and you do not want cookies to be used, you may have to actively delete or block cookies. Please note that if you reject the use of cookies, you will still be able to visit our website, but some of its functions may not work properly.

9. WHAT ARE THE RIGHTS OF THE DATA SUBJECT?

The Lei Geral de Proteção de Dados (LGPD, Brazilian General Data Protection Law) gives the USER the right to request from Celero, at any time, by means of a formal request, information regarding the data processed.

Celero will only respond to requests made by the data subject themselves, upon proof of identity, and will have 30 days to respond to data subjects' requests. Requests will be analyzed as provided for in the applicable legislation. Under the text of the LGPD, data subjects may exercise their rights through:

I - Confirmation of the existence of processing;

II - Access to the data;

III - Correction of incomplete, inaccurate or outdated data;

IV - Anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the provisions of this Law;

V - Portability of the data to another service or product provider, upon express request;

VI - Deletion of personal data processed with the data subject's consent;

You may revoke your consent at any time. However, if you withdraw your consent, we may not be able to provide some of the services properly. To revoke your consent, send an email to dpo@celero.com.br stating which consent you are revoking and the means by which we can contact you to confirm your identity.

10. HOW TO EXERCISE YOUR RIGHTS?

You may exercise your rights regarding personal data by contacting us at dpo@celero.com.br. To change your preferences regarding notifications (including marketing communications) at any time, you may access “My Account”. If you do not wish to receive our marketing communications, you may also unsubscribe from them.

In order for you to exercise your rights, we may need to verify your identity and the validity of your personal data. This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it.

11. HOW TO CONTACT CELERO'S DATA PROTECTION OFFICER?

The data protection officer is the person appointed by Celero to act as the communication channel between the controller, the data subjects and the Autoridade Nacional de Proteção de Dados (ANPD, Brazilian National Data Protection Authority). Any questions may be sent to dpo@celero.com.br.

12. UPDATES TO THIS POLICY

Celero may update this policy at any time. We therefore recommend that you visit this page periodically to stay informed of any updates made.