PRIVACY POLICY FOR DATA PROTECTION

POLICY OBJECTIVES

A QORE DISTRIBUIDORA DE TÍTULOS E VALORES MOBILIÁRIOS LTDA., registered under CNPJ No. 62.264.924/0001-52 referred to as “QORE” is the controller of personal data. We strive to provide appropriate protective measures in all operations, implementing consistent, effective, and strict policies and procedures. Recognizing the importance of your privacy, we have developed this Privacy and Personal Data Protection Policy (“Policy”) to inform you how we process and protect your personal data. This policy also outlines your rights e how to contact us with any questions or concerns about data protection.

This Policy applies to Users and Visitors of the website https://qoredtvm.com.br/, also known as the digital channel.

PERSONAL DATA ORIGIN

We collect and process your Personal Data from the following sources:

  • The company that hires QORE services for your benefits; and
  • Information collected through other reliable sources.

Collected information includes:

  • For individuals: name, CPF, RG, e-mail, marital status, telephone and mobile number, and date of birth.
  • For legal entities: company name, CNPJ, legal representative’s name, RG, and CPF of legal representative’s, number of employees, revenue, complete address, and telephone number.

PURPOSES FOR WHICH WE USE PERSONAL DATA

Collected Personal Data is used to provide our services, ensure their proper functioning, improve them, and maintain trust and safety.

Your data may be used for the following purposes:

  • Administrating and providing services and meeting related obligations;
  • Notifying about updates, services, features, benefits, sales, and relevant events;
  • Developing action plans to improve our services/products;
  • Complying with legal or administrative orders;
  • Any other purposes will be communicated when we collect your data

QORE does not sell or commercialize personally identifiable information.

LEGAL BASIS FOR PERSONAL DATA PROCESSING

The processing of personal data is necessary for the performance and management of our contractual relationship with you and/or the company hiring our services. It may also be based on our legitimate interests or those of third parties, provided legal requirements are met, or in compliance with legal obligations or regulatory requirements. In some cases, your personal data may be processed with your prior consent, as required.

SHARING OF PERSONAL DATA

The safety and confidentiality of your Personal Data are of considerable importance to us. Therefore, we restrict access to your personal data to our authorized professionals, who need that data to process your requests or provide the requested service(s).

We do not disclose your Personal Data to unauthorized third parties. However, we may share your Personal Data with companies within the group (clients) and authorized service providers (e.g., Call centers, relationship agents, Back-Office services, and IT consultants), that we may engage to provide our services. In these cases, we ensure that your Personal Data is processed only for the legitimate, specific, explicit purposes communicated to you, with no possibility of subsequent processing for purposes incompatible with the original intent.

Additionally, we may share your Personal Data, when we believe in good faith that we are obligated to:

  • Abide by the law, regulation or court order;
  • Respond to requests from regulatory agencies, police authorities, or other public authorities, including cases involving national security;
  • Enforce or protect QORE rights or property, including investigating fraud and helping to prevent security threats and other criminal or malicious activities; or
  • Protect the legitimate interests of third parties, including the personal safety of employees of QORE.

PERSONAL DATA STORAGE

We store your Personal Data in secure environments, ensuring confidentiality and privacy, only for the time necessary to fulfill the purposes for which it was collected. We observe legal deadlines and the need to defend QORE in legal proceedings. However, we may need to retain your personal data for a longer period of time to comply with applicable laws or regulations. Once the legal period has expired or the data is no longer needed, we will securely delete it or anonymize it for statistical purposes.

SENSITIVE PERSONAL DATA OF CHILDREN AND TEENAGERS

If it is strictly necessary to collect such data to achieve the intended purpose, we will do so in compliance with legal requirements, particularly with your prior, specific, and prominent consent for the specific purposes outlined in this Policy.

INTERNATIONAL TRANSFER OF PERSONAL DATA

QORE operates in areas aligned with customers’ activities. Occasionally, your personal data may be transferred to entities outside of Brazil that are authorized to provide services on behalf of the company. In the event of an international transfer to recipients located in other countries, we will take the necessary steps to ensure suitable safeguards are in place to protect your personal data in accordance with the LGPD and the protections outlined in this Policy.

EXERCISING OF YOUR RIGHTS UNDER THE LGPD

We respect your rights as a data subject and enable their exercise in accordance with Article 18 of Law No. 13,709/2018 (LGPD).

To ensure your privacy, security and fraud prevention, we may request proof of your identity before enforcing your rights.

APPLYING SECURITY MEASURES TO PROTECT PERSONAL DATA

We implement the best technical and administrative security practices possible to protect your Personal Data from unauthorized access, accidental or unlawful destruction, loss, alteration, communication, or disclosure, as required by current legislation.

However, be aware that no company can completely eliminate security risks associated with the processing of Personal Data. It is essential that you protect yourself from unauthorized access to your password and computer, as your access is personal and non-transferable. If unauthorized access is attempted, you must inform QORE as soon as possible.

ACCESSING AND UPDATING OF OUR PRIVACY POLICY

By accessing QORE’s DIGITAL CHANNEL, you expressly agree to this Policy. For your safety, you should read and understand all the conditions established in this Policy, as well as other documents incorporated by reference.

By accepting this Policy, you expressively agree to provide only accurate, truthful and up-to-date Personal Data. You will be solely responsible for any false, outdated, or inaccurate information you provide directly to QORE.

If any changes are made to this Policy, we will publish the updated version on the website, indicating the revision date, so you are always aware of the content.

All modifications will take effect after the Privacy Policy is published, unless otherwise specified. Therefore, we recommend that you periodically review this Policy to stay informed about any changes.

The last update date of this Policy is indicated at the end of this document and represents the effective date. You can request previous versions of this Policy by emailing the address provided in this Policy.

APPLICABLE LAW AND JURISDICTION

The Privacy Policy is governed, interpreted and enforced according to Brazilian law, in Portuguese language, with the jurisdiction of the District of São Paulo being chosen to resolve any disputes or controversies involving this document, unless otherwise required by specific personal, territorial or functional jurisdiction under applicable law.

Outside the state, JUSPRO – Justiça Sem Processo Mediação e Conciliação S/S Ltda, a Mediation Chamber may resolve disputes involving data subjects in accordance with Article 52, §7 of the LGPD.

CONTACT US ABOUT YOUR RIGHTS UNDER THE LGPD

QORE has a dedicated information security team and a Data Protection Officer (DPO), to handle data subject requests and maintain the security of Personal Data. You can reach us at lgpdl@qoredtvm.com.br.

To exercise any of your rights under this Policy, such as access to or correction of your Personal Data, send your request to: Rua Fidêncio Ramos, 302 – CJ. 101 – CEP 04551-010, São Paulo – SP, or by e-mail lgpd@qoredtvm.com.br with the subject: “LGPD – DATA SUBJECT REQUEST.” If sending a letter, include proof of receipt (AR).

If you have any questions about this Privacy Policy or our privacy practices, contact our Data Protection Officer via the email: lgpd@qoredtvm.com.br.

LAST UPDATES AND PREVIOUS VERSIONS

The last updates to this Privacy Policy was published on 01/09/2024.

Version: 01.