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Privacy Policy

1. Introduction

Brasporto Logística e Assessoria Aduaneira Ltda. (“Brasporto”), a Brazilian company headquartered at Alameda Terracota, 215 – Torre Union – Cj 1213, Espaço Cerâmica, CEP 09531-190, São Caetano do Sul – SP – Brasil, registered under CNPJ No. 22.084.878/0001-95, is responsible for the processing of personal data collected through the website www.brasporto.com. This Privacy Policy explains, in a clear and accessible way, which personal data we collect, how it is used, stored, shared and protected, and what rights data subjects have, in accordance with Brazil's General Data Protection Law (Law No. 13,709/2018 – LGPD) and other applicable rules. By accessing and using our website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the website or provide any personal data to Brasporto.

2. Data Controller

For the purposes of this Policy and the LGPD, the controller of your personal data is:

Company name: Brasporto Logística e Assessoria Aduaneira Ltda.

CNPJ: 22.084.878/0001-95

Address: Alameda Terracota, 215 – Torre Union – Cj 1213, Espaço Cerâmica, CEP 09531-190, São Caetano do Sul – SP – Brasil

Phone: +55 (11) 2376-3596

Email: brasporto@brasporto.com

Website: www.brasporto.com

For specific data protection matters, please write to the email above with the subject “Data Protection”.

3. Personal Data We Collect

3.1. Data you provide

We only collect the data you give us in the website forms:

Quote request: name, company, CNPJ (Brazilian company ID), email, phone and the cargo details (origin, destination, mode, Incoterm, packages, weight, value and description of goods);

Request for documents under NDA: name, company, email and phone of the requester;

Download of documents from the Transparency page: corporate email, confirmed by a verification code sent to it, the document downloaded and the date and time of the download.

The website has no job application form. Our openings are posted on LinkedIn, and candidate data is handled under that platform's rules and our recruitment process.

3.2. Data collected automatically

As with any website, the hosting server records technical access information:

IP address;

Browser and operating system type and version;

Page accessed, date and time of access.

The website currently uses no visitor analytics tools and no tracking cookies (see Section 8).

4. Purposes of Processing

Personal data is processed for the following purposes:

4.1. Quotes and documents

Quote request data is used to prepare and send the proposal and for commercial contact about it. Data from requests for documents under NDA is used to formalize the confidentiality agreement and release the documents.

When documents are downloaded from the Transparency page, the record of who downloaded which document and when serves the control and traceability of the documents of our AEO (OEA) management system. Our Quality team is notified of each download.

4.2. Customer service and communications

Contact data may be used to answer requests sent through the website, WhatsApp or email, provide support and give information about our foreign trade services.

4.3. Website security and operation

Technical access records are used to keep the website running, identify failures and prevent abuse, such as automated form submissions.

4.4. Compliance with legal obligations

When required by applicable law, including foreign trade, labor, tax or customs law, data may be processed to comply with a legal or regulatory obligation.

4.5. Legitimate interest

Brasporto may process personal data when necessary to conduct its business, always balancing its legitimate interest with the rights and expectations of data subjects.

5. Legal Bases for Processing

Brasporto processes personal data on the following legal bases set out in article 7 of the LGPD:

Consent (art. 7, I): when you voluntarily provide your data, especially in the quote and document request forms;

Performance of a contract (art. 7, V): to provide contracted services or carry out pre-contractual steps;

Compliance with a legal or regulatory obligation (art. 7, II): when the law requires certain data to be stored or disclosed;

Legitimate interest of the controller (art. 7, IX): for purposes related to the regular operation of the company, such as the download record of the AEO management system documents and website security, provided they do not override the fundamental rights of the data subject;

Credit protection (art. 7, X): when applicable in the company's commercial relationships.

6. Sharing of Personal Data

Brasporto does not sell personal data. Data may be shared only in the cases below, always as necessary and proportionate:

Service providers and technology partners: companies that support our operations (website hosting, email platform and management systems, listed in Section 7), which act as processors and are bound by confidentiality obligations;

Logistics partners: our 13 support points with partners at the main ports and airports in Brazil (Itajaí, Viracopos, Guarulhos, Curitiba, Suape, Santos, Rio de Janeiro, Paranaguá, Rio Grande, Fortaleza, Vitória, Salvador and Uberlândia), when needed to quote or carry out the import or export operation;

Public authorities and regulators: when required by law, court order, decree, customs regulation or request from a competent authority;

Third parties in corporate transactions: in the event of a merger, acquisition, spin-off or other corporate restructuring of Brasporto, with prior notice to the data subject of any change in processing.

Brasporto requires all third parties receiving personal data to respect its security and privacy and prohibits its use for purposes other than those agreed.

7. International Data Transfer

Due to the nature of its international trade activities, Brasporto may transfer personal data to other countries when a supplier, forwarder or foreign authority is part of the logistics process.

The website and its forms also rely on technology providers that may store or process data outside Brazil:

Microsoft 365 (Microsoft Corporation): sending and receiving the emails generated by the website;

Vercel (Vercel Inc., United States): website hosting and form processing.

Such transfers will only take place when the destination country provides an adequate level of protection, or under contractual safeguards consistent with article 33 of the LGPD and the regulations of Brazil's National Data Protection Authority (ANPD).

8. Cookies and Tracking Technologies

8.1. What cookies are

Cookies are small text files stored on your device when you visit a website. They allow the website to recognize your browser and, in some cases, store preferences and usage information.

8.2. Cookies used today

The website uses no analytics, advertising or tracking cookies. The language is chosen by the page address, without a cookie.

Brasporto's Instagram and LinkedIn profiles are reached through links. The website does not embed content from these networks, so they do not set cookies while you browse here.

8.3. Marketing tool (RD Station)

Brasporto may start using the RD Station Marketing platform (RD Gestão e Sistemas S.A.) to measure website browsing and register people who fill in the forms as business contacts. When that happens, this tool's cookies will only be activated after your consent, requested through a notice shown on the website, and this Policy will be updated with a new version.

8.4. Managing cookies

You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. However, disabling essential cookies may affect how the website works.

Most browsers let you manage cookies in their privacy settings. For more information, see your browser's help section.

9. Data Retention and Deletion

Personal data collected by Brasporto will be kept for as long as needed to fulfill the purposes for which it was collected, as follows:

Quote requests and requests for documents under NDA: kept for up to 5 (five) years from the request, for commercial follow-up and possible evidence, unless the data subject asks for earlier deletion;

Download record of the documents on the Transparency page: kept for 5 (five) years, for traceability of the AEO management system;

Customer and partner data: kept for the contract term plus the applicable legal period (e.g. 5 years for tax purposes, under the Brazilian National Tax Code);

Website access records: kept for at least 6 (six) months, as required by article 15 of Brazil's Internet Civil Framework (Law No. 12,965/2014), and deleted afterwards, unless requested by an authority;

Data subject to legal obligations: kept for the minimum period required by applicable law.

After the retention period, data will be securely deleted or anonymized so that it can no longer be linked to the data subject.

10. Information Security

Brasporto adopts appropriate technical and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, disclosure or any form of improper processing, including:

Restricted access to personal data, based on profiles and job needs;

Secure connections (HTTPS) on the website;

Monitoring of systems and access logs;

Regular staff training on data protection;

Internal information security policy.

In the event of a security incident that may cause relevant risk or harm to data subjects, Brasporto will notify the ANPD and, where applicable, the data subjects themselves, within the legal deadline, stating the nature of the incident, the categories of data affected and the measures taken.

11. Data Subject Rights

Under the LGPD (art. 18), as a data subject you have the following rights, which may be exercised at any time:

Confirmation: to know whether Brasporto processes your personal data;

Access: to obtain a copy of the personal data we hold about you;

Correction: to request the correction of incomplete, inaccurate or outdated data;

Anonymization, blocking or deletion: of unnecessary or excessive data, or data processed in breach of the LGPD;

Portability: to receive your data in a structured and interoperable format (subject to ANPD regulation);

Deletion: to request the deletion of data processed based on consent;

Information about sharing: to know which public and private entities your data has been shared with;

Information about the possibility of not consenting: to be informed of the consequences of refusing consent;

Withdrawal of consent: to withdraw consent at any time, without affecting the lawfulness of prior processing;

Objection: to object to processing based on other legal bases in case of non-compliance with the LGPD;

Review of automated decisions: to request a review of decisions made solely on the basis of automated processing that affect your interests.

To exercise any of these rights, contact us at brasporto@brasporto.com with the subject “Data Subject Rights – LGPD”, stating your full name, registered email and the right you wish to exercise.

Brasporto will respond within 15 (fifteen) business days, extendable depending on the complexity of the request and within legal limits.

12. Data Protection Officer (DPO)

Brasporto will appoint, under the criteria of the LGPD and ANPD regulations, a Data Protection Officer (DPO).

Until a DPO is formally appointed, the channel for data protection matters is:

Email: brasporto@brasporto.com

Subject: Personal Data Protection

13. Social Networks and External Links

The Brasporto website contains links to social network profiles (Instagram and LinkedIn) and to third-party platforms (such as WhatsApp). This Privacy Policy does not apply to these external services. We recommend reading each platform's privacy policy before interacting with it.

Brasporto is not responsible for the privacy practices or content of third-party websites linked from our website.

14. Data of Minors

The Brasporto website and services are intended for companies and adult professionals. We do not knowingly collect personal data from children or adolescents under 18 (eighteen) years of age without the express consent of their legal guardians.

If we find that data from minors has been collected without proper safeguards, we will delete it immediately.

15. Changes to This Policy

Brasporto may update this Privacy Policy at any time due to legal, technological or operational changes. The latest version will always be available at www.brasporto.com.

Relevant changes will be properly communicated. We recommend checking this Policy periodically. The effective date of the current version is shown at the top of the document.

16. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the Federative Republic of Brazil, in particular Law No. 13,709/2018 (LGPD), the Consumer Protection Code (Law No. 8,078/1990) and the Internet Civil Framework (Law No. 12,965/2014).

The courts of São Caetano do Sul, State of São Paulo, Brazil, are elected to settle any disputes arising from this Policy, to the exclusion of any other, however privileged.

17. Contact

For questions, suggestions or complaints about this Privacy Policy or the processing of your personal data, contact:

Brasporto Logística e Assessoria Aduaneira Ltda.

Alameda Terracota, 215 – Torre Union – Cj 1213, Espaço Cerâmica

CEP 09531-190, São Caetano do Sul – SP – Brazil

Phone: +55 (11) 2376-3596

Email: brasporto@brasporto.com

Website: www.brasporto.com