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General Privacy Policy of Immunity

General Privacy Policy of Immunity

The purpose of this General Privacy Policy of “IMMUNITY” (“Privacy Policy”) is to inform you, the user of the IMMUNITY platform (“User” or “You”), as well as any other persons who may visit or interact with the digital platform (“Platform” or “Site”) maintained by IMMUNITY (IMMUNITY SOLUÇÕES EM SAÚDE LTD.), registered with the CNPJ No. 29.426.682/0001-80, located at Avenida Nova Cantareira, 1389, cj. 22 – CEP 02331-002, about the collection, treatment and use of your information spontaneously provided or automatically collected through the Platform, being certain that this information identifies or may reasonably identify You (“Personal Information”).

Careful reading is imperative, especially because You, from the moment you click on the option “I accept the Privacy Policy”, will show full, clear and unchangeable understanding and acceptance of how the Platform will collect and process your data, in this way, You will show your free, express and informed consent, based on the most diligent and enlightened exercise of the economic freedom to contract, agreeing and authorizing access to your data by using the Platform. If you do not agree with the Privacy Policy, please leave the Site and refrain from using the Platform.

The User and/or Partner may access this Privacy Policy at any time through the Platform and https://www.immunityinitiative.com.br/politica-de-privacidade. Furthermore, all the provisions contained in the General Terms and Conditions of Use of the “IMMUNITY” Site (in this Privacy Policy simply referred to as the “Terms of Use”), available for access on the Platform and at https://www.immunityinitiative.com.br/termos-de-uso, apply to this Privacy Policy. Furthermore, all contracts entered into through the Platform, as set forth in the Terms of Use, apply to this Privacy Policy.

The changes, however, will not be valid in relation to each step of negotiations or Advertisements already started before the date on which the new version became valid. These cases will be regulated by the previous version of this Privacy Policy. However, once you have completed one step of the search process for Experiences with IMMUNITY, the next step will be governed by the new provisions. Failure to comply with the new practices will result in immediate termination of the use of the Platform.

I – DATA AND INFORMATION COLLECTION

1. As part of the dynamic operation and maintenance of the Platform, IMMUNITY collects personal data and information. To provide You with a better understanding, we collect personal information when You participate in any interactive features of our Services, fill out a form, connect with us on social media sites, request support for customers, partners or when You contact us. The types of personal information that we may collect when You provide it to us include your name, email or physical address, company information, payment information, photos, property descriptions, and other information that You may choose to provide.

1. The Platform is not intended for children or persons under the age of 18. If You are under the age of 18, please do not use or provide personal information about Yourself in any way, and You must absolutely comply with the terms and conditions set forth in the Terms of Use.

1. When You access or use the Platform, we automatically collect personal and other information which may include:

1. Registration Information: When You sign up on our Platform, we record personal information during the use of our services, including browser information, page views, IP addresses, and the site you visited before navigating to our site to help us improve our site and services.

2. Hardware Information: Information about the device You use to access our Platform, including the hardware model, operating system type and version, unique device identifiers, and mobile network information, which may help improve our site and services.

3. Location Information: Information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information because our services are location-based.

4. Information Collected by Cookies and Other Tracking Technologies: We may use various technologies to collect information, including cookies. Cookies are small data files stored in your device’s memory that help us improve our users’ experience with our Site and Services, identify popular features and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails to help with delivering cookies, counting visits, understanding campaign usage and effectiveness, and determining whether an email has been opened and applied. If your browser is set to not accept cookies, you may not be able to use the Site or Services.

1.4.4. Information may also be collected from other sources and may be combined with information we collect through our Platform. For example, when you create or access your account through a social media site, we will have access to certain information from that site, such as your name, account information, and list of friends and connections, in accordance with the authorization procedures determined by such social media sites, except to the extent that the social media Platform you choose allows you to disable this functionality. We may use publicly available tools, such as Google Analytics, to better understand User preferences. Collection of data by third party tools is subject to their respective privacy policies.

1.4.5. Remember, the collection of data and personal information, as exposed above, will occur with your express, full, clear and unchangeable authorization, from the moment you click on the option “I accept the Privacy Policy”.

II – GUARANTEES FOR CHOICES AND CONTROL BY THE USER

1.4.1. The General Personal Data Protection Law of Brazil (LGPD) guarantees Brazilian citizens respect for the privacy and personal data of natural persons. In attention to such provisions, the Platform seeks to ensure transparency and access controls in order to allow Users to benefit from the rights mentioned.

1.4.2. The rights granted to You, as a natural person, without prejudice of the limitations provided by the applicable legislation, are the following:

1. Right of access: the right to be informed and to request access to the personal data processed by the Platform;

2. Right to rectification: the right to request, through the communication channels, the amendment or modification of your personal data when they are incorrect or incomplete;

3. Right to erasure: the right to request the removal of your personal data;

4. Right to restriction: the right to request that the Platform cease, temporarily or permanently, to process all or some of your personal data;

5. Right to object: the right, at any time, to object to the processing of your personal data for reasons relating to your particular situation; the right to object to the handling of your personal data for direct marketing purposes;

6. Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit said personal data for use in the service of a third party; and

7. Right not to be subject to automated decision-making: the right not to be subject to decisions made solely in an automated manner, including with respect to profiling, if the decision has a legal effect on You or has an equally significant effect.

1.7.3. To learn more about these rights, and to exercise them easily and record your preferences regarding how the Platform uses your personal data, we have provided the following resources:

1. “Settings”(which you can access through your account page): allows you to access your account settings and there you will find the “Privacy” option, where you can choose the type of processing of certain personal data and the automated function “Access your data” enables you to download basic information about your account and usage, and it is also possible to request data rectification and erasure.

2. “Contact Us”: We have several customer service pages on our website which provide additional guidance on personal data protection and may include answers to “frequently asked questions” about the processing of personal data on the Platform.

1.2.4.The Platform may also anonymize or pseudonymize to remove any identifying attributes or aggregate personal information with a sufficiently large number of other pieces of information so that it cannot be reasonably linked to You (“Anonymity”). We may use this anonymized data for internal or public analysis or reports, but we will not identify You in the anonymized data without Your consent.

1.2.5 At any time, a User registered at IMMUNITY may request the permanent erasure of their data or the cancellation of their registration, except in the case of maintenance provided by law.

1.2.6. If you still have questions about your options, choices, and the control of your data, please contact the Platform through the Contact Us Channel or by email: contato@immunityinitiative.com.br.

III – USE AND TREATMENT OF DATA AND INFORMATION

1.2.1. IMMUNITY considers the personal data and information collected by the Platform as confidential, thus ensuring that they will be treated and stored under the terms of this Privacy Policy by adopting the appropriate security measures. Thus, the information collected will be used by IMMUNITY to provide the Services related to the Platform, as well as to develop the Platform and improve the Users’ browsing experience.

1.2.2. The User authorizes the use of the collected data, whether they are registration, personal, credit, or communication data for the validation, consultation, and other appropriate operations with financial and credit institutions, as well as the provision and use of such data to the Partner, IMMUNITY and/or IMMUNITY’s partner companies, including but not limited to those involved in matters of financial, economic, contractual, business or dealing with the User’s credit.

1.2.3. In accordance with this Privacy Policy, the User freely, expressly, and knowingly consents that IMMUNITY and its Partners, as described herein, may use the data collected through the Platform for the development of promotional campaigns, product offerings and targeted marketing, as well as for the execution of IMMUNITY’s business activities.

1.2.4. Under this Privacy Policy, IMMUNITY may use personal data and information provided to the Platform to:

1. monitor and analyze trends, usage and activities in connection with our Services;

2. customize and improve our Services and provide content or features through the Service that match Users’ profiles or interests, link to or combine with information that the Platform receives from others to help understand your needs and provide You with better service; and

3. perform any other purpose for which the information was collected.

1.3.5. Furthermore, the User agrees to receive promotional emails from IMMUNITY and its partners, as well as communications about the Services provided by means of text messages or WhatsApp, if it is used and is solely responsible for carefully and fully reading the Privacy Policy implemented by IMMUNITY. However, if the User chooses to stop receiving such communications, they may communicate their decision by email to contato@immunityinitiative.com.br.

1.3.6. Through the Platform, links may be presented that lead the User to other electronic pages, including those made available by third parties, which may present Privacy Policies that differ from the provisions of this document. IMMUNITY is not liable for the collection, use, sharing and storage of User data by those in charge of such sites.

IV – INFORMATION SHARING

1.3.1. The Platform may share personal information as follows or as otherwise described in this Privacy Policy:

1. With suppliers, Partners, and other Service providers who need access to such information to perform work on behalf of the Platform as required by the Services;

2. With third parties to provide marketing and promotional purposes on behalf of the Platform, provided that they have agreed to handle personal information in a manner consistent with this Privacy Policy;

3. In response to a request for information if we believe disclosure is required by applicable law, regulation or rule; or administrative, court or other governmental order;

4. If we believe that your actions are inconsistent with the spirit or language of our agreements or User policies, including our Community Guidelines, or to protect the rights, property, and safety of IMMUNITY, Users and others; In connection with or during negotiations of any merger, sale of company assets, financing or acquisition of all or part of our business for another company, as well as any corporate change of IMMUNITY or the companies comprising the group to which it belongs, in consideration of the need for continuity of the Services;

5. With your consent or at your direction; and

6. With the competent authorities and with third parties that are supported by the need for strict compliance with laws, court orders and related requirements.

V – INFORMATION STORAGE

1.6.1. IMMUNITY may store information collected through the Platform on its own servers or on servers of third parties contracted by it, located in Brazil or abroad. All reasonable efforts are made in order to preserve the security of its systems in the storage of such data.

1.6.2. IMMUNITY uses its best efforts to protect the information of the Users of its Platform. However, due to the inherent nature of the Internet, there is no way to ensure that unauthorized third parties will not succeed in improperly accessing the information stored by IMMUNITY.

1.6.3. The responsibility for the protection and safekeeping of data relating to payment information, such as credit card number, billing address, are the sole responsibility of the company responsible for making the payment, which is a company that is not IMMUNITY.

VI – CONFLICT RESOLUTION, LEGISLATION AND JURISDICTION COURT

1.6.1. If any disputes, conflicts, issues or discrepancies of any nature relating to: (i) the existence and/or the exercise of any right arising from this Privacy Policy; and/or (ii) the existence and/or the occurrence of any damage; and/or (iii) the interpretation of the terms (hereinafter jointly referred to as a “Conflict”) arise in relation to this Privacy Policy, coming from any relations between Users or between Users and the Platform, the Parties shall use their best efforts to resolve the Conflict amicably. To this end, any Party may notify the other of its intention to initiate the procedure described in this Clause, by which the Parties shall meet to attempt to resolve such Conflict through amicable discussions, of good faith and negotiations held directly between the parties (“Conflict Notification”).

1.6.2. Except as otherwise provided in this Term, in case the Parties fail to reach a resolution in accordance with the provisions above, within thirty (30) days, counted from the receipt of the Notice of Conflict by any of the Parties, the Conflict will be legally resolved under the laws of the Federative Republic of Brazil, being elected the Jurisdiction Court of the District of São Paulo, State of São Paulo, with express waiver of any other, however privileged it may be.

VII – INFORMATION AND CONTACT

1.6.1. Please email us at contato@immunityinitiative.com.br with any questions or comments about this Privacy Policy.

We wish you an amazing experience at IMMUNITY!