PRIVACY POLICY

Gruv Comunicação e Moda LTDA - ME, (hereinafter Gruv) offers marketing, advertising and design services for companies, with no restriction on size.

We at GRUV respect and value your information and privacy. In this way, we want to make your online experience safe and satisfying. To demonstrate our commitment, we will make our Privacy Policy available on the home pages of the site and in all registration procedures.

Acceptance: By accessing, using or browsing the service, the user accepts and agrees with this Privacy Policy. In case you do not agree with this policy, we recommend that you do not proceed with the registration, as well as that you refrain from accessing and using our services.

Legal Basis: In these cases, data processing is carried out based on consent, contract execution, legal obligation, legitimate interest or credit protection, as authorized by items I, II, V, IX and X of article 7 of Law no. 13.709/2018, the General Data Protection Law (“General Data Protection Law – LGPD”).

Sharing: Gruv may share the information collected through the pages of third-party companies hired by Gruv to process User and Customer data, as well as in other cases provided for in this Policy.

Data Protection: Gruv uses reasonable market means and legally required to preserve the privacy of data collected on its Pages.

Users' Rights: In compliance with the applicable regulations, with regard to the processing of personal data, Gruv respects and guarantees the user the possibility of submitting requests based on the provisions of Law 13.709/2018, the General Data Protection Law .

1. Data Collection

Gruv collects data actively provided by Users, such as registration and financial data, as well as automatically generated information, such as IP with date and time, browser, access device characteristics, identification of the commercial establishment used, fiscal and financial data, information about clicks and also through the use of standard technology, such as cookies, in order to improve your browsing experience​.

Thus, two types of personal data are processed: (i) those provided by the User; and (ii) those collected automatically.

(i) Information provided by the User: Gruv collects all information actively entered by the user on the pages, such as: full name, email, telephone, position, company name, company website, city and state, company segment when filling out forms on Pages by the user. Gruv will use this information to promote the dissemination of advertising material, promotions, discounts, events and loyalty programs, as well as to carry out satisfaction surveys.

(ii) Data collected automatically: Gruv also collects a series of information automatically, such as: characteristics of the access device, browser, IP (with date and time), IP origin, information on clicks, pages accessed, the following pages accessed after exiting the pages, or any search term entered on the sites or in reference to them, among others. For such collection, A Gruv will use some standard technologies, such as cookies, pixel tags, beacons and local shared objects, which are used for the purpose of improving the User's browsing experience on the Pages, according to their habits and their preferences.

However, it is possible to disable, through the settings of your internet browser, the automatic collection of information through some technologies, such as cookies and caches, as well as on our own website, specifically regarding cookies. However, the user must be aware that, if these technologies are disabled, some features offered by the website, which depend on the processing of said data, may not work correctly.

In addition, Gruv may promote satisfaction and preference surveys during the use of its website, collecting this information to improve our services, to better understand your preferences and evaluate the quality and your impressions about our services, as well as for purposes statistics and advertising. For the latter hypothesis, Gruv provides functionalities for the user to authorize (or not) the processing of their data, given that such acceptance is not a condition for user registration.

(iii) Data from Customers: Gruv also processes data from Customers and Customers' customers, such as full name, CPF, gender, age, address and purchase history and browsing history, for the exclusive purpose of providing contracted services by the Customer.

Users can access, update and add their data, as well as request the deletion of their data collected by Gruv, through the email address Ouviria@gruv.com.br. We will spare no efforts to answer you in the shortest possible time, respecting the retention periods established by law.

Therefore, by accepting this Policy, the User declares that he is aware of the information collected when used by Gruv, and expresses his free, express, unequivocal and informed consent regarding the collection of such data.

2. Use and Processing of Data

The information collected by Gruv is intended to establish a contractual relationship or to manage, administer, provide, expand and improve the Pages for the user, adapting them to their preferences and tastes.

The information collected may also be used for advertising purposes, such as sending information about Gruv's services, products, promotions, as well as the dissemination of events and loyalty programs, direct sales activation, calls, sending emails. -mail marketing or to carry out a satisfaction survey, with the owner's consent to do so.

If you no longer wish to receive advertising information from Gruv, at any time, the user may contact Gruv via email address Ouviria@gruv.com.br or via the unsubscribe link provided in marketing emails.

3. Cookies

Cookies are files or information that may be stored on your devices when you visit Gruv's pages. Generally, a cookie contains the name of the website that originated it, its lifetime and a value, which is randomly generated.

Gruv uses cookies to facilitate use and better adapt the pages to your interests and needs, as well as to process information about the use of our sites and services, helping to improve their structures and content. Cookies can also be used to speed up your future activities and experiences on the pages.

3.1. Types of Cookies

At any time, the user may revoke their consent to cookies, so they must delete cookies from Gruv pages using their preferred browser settings. For more information on how to manage cookies in browsers:

● Internet Explorer: https://support.microsoft.com/pt-br/help/17442/windows-internetexplorer-delete-ma nage-cookies

● Mozilla Firefox: https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-queos-sites-usam

● Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform=Desktop& hl=pt-BR

● Safari: https://support.apple.com/pt-br/guide/safari/sfri11471/mac

Finally, we remind you that if the user does not accept some cookies from the Gruv Pages, certain services may not work optimally.

4. With whom Gruv will share user data

Gruv may share the information collected through the pages, in the following cases:

i. With companies providing technological infrastructure services, which undertake to use the information for the contracted purposes and under the rules of this Privacy Policy;

ii. With partner companies in the development of Gruv's commercial activities, within the limits of the contracted services and under the rules of this Privacy Policy;

iii. To protect Gruv's interests in any type of conflict, including lawsuits;

iv. In the case of transactions and corporate changes involving Gruv, in which case the transfer of information will be necessary for the continuity of services; or,

v. By legal determination, court order or by request of administrative authorities that have legal competence for its request​.

The roll above is not exhaustive, and other hypotheses may be included at any time by Gruv, which will inform its users that they must carry out a new acceptance of this Policy if any other hypothesis of sharing is included.

5. Security of collected data

Gruv will store the information collected on its pages on its own servers or those contracted by it. Gruv uses reasonable market means and legally required to preserve the privacy of data collected on its Pages. Therefore, take the following precautions:

i. Gruv uses standard and market methods to encrypt and anonymize the collected data;

ii. Gruv has technical and administrative measures to protect against unauthorized access to its systems;

iii. Gruv only authorizes previously established persons related to the purpose of treatment to access the location where the collected information is stored;

iv. Those who come into contact with the information must undertake to maintain absolute secrecy. The breach of secrecy will entail civil liability and the person responsible will be held accountable in accordance with Brazilian legislation; It is

v. Inventory maintenance indicating time, duration, identity of the employee or person responsible for access and the object file, based on connection and application access records.

Gruv makes the best efforts to preserve the privacy of user data. ​However, no website is completely secure and Gruv cannot fully guarantee that all the information that travels on the pages is not the target of unauthorized access perpetrated through methods developed to improperly obtain information. For this reason, we encourage users to take appropriate steps to protect themselves, such as keeping all usernames and passwords confidential and recommending that passwords be changed periodically​.

6. Information Storage

The information collected by Gruv through the pages will be automatically deleted from its servers at the end of the purposes for which it was collected, or when the user requests the deletion of their personal data.

Without prejudice, the information may be kept for compliance with legal or regulatory obligations, transfer to a third party – provided that the data processing requirements are respected – and exclusive use by Gruv, access by a third party is prohibited, provided that it is anonymized.

7. Exclusion of Information

The deletion of data stored by Gruv may be requested at any time by the User through the email Ouviria@gruv.com.br. Gruv is committed to making the best efforts to respond to all requests for exclusion as quickly as possible.

Such exclusion, however, will also lead to the termination and exclusion of the user's registration from Gruv's database.

Finally, upon acceptance of this Policy, the user acknowledges that he is aware that, even in the event of a request for data deletion, Gruv will observe the minimum information storage period determined by current Brazilian legislation.

8. User Rights

In compliance with the applicable regulations, with regard to the processing of personal data, Gruv respects and guarantees the User the possibility of submitting requests based on the following rights:

i) confirmation of the existence of treatment;

ii) access to data;

iii) the correction of incomplete, inaccurate or outdated data;

iv) the anonymization, blocking or deletion of unnecessary, excessive or non-compliant data;

v) the portability of your data to another service or product provider, upon express request by the User;

vi) the deletion of data processed with the User's consent;

vii) obtaining information about the public or private entities with which Gruv shared its data;

viii) information about the possibility of not giving your consent, as well as being informed about the consequences, in case of refusal;

ix) the revocation of consent.

Part of these rights can be exercised directly by the User, from the management of information about the account, on the page your data. The other changes will depend on the submission of a request for further evaluation and adoption of other measures by Gruv.

If you need any assistance to exercise your rights, or if you have any questions about this Privacy Policy, the User can contact Gruv through the email address Ouviria@gruv.com.br.

The User is aware that the exclusion of essential information for the management of his account with Gruv will result in the termination of his registration.

Gruv will make every effort to respond to such requests as quickly as possible. However, even in the event of an exclusion request, the minimum storage period for Internet application user information, determined by Brazilian law, will be respected.

9. Update

Gruv may update this policy at any time, and the changes will be effective immediately. However, if this policy changes significantly, all users will be informed about the change, via virtual notification to the email addresses registered in the database.

10. Legislation and Jurisdiction

This Policy will be governed, interpreted and enforced in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13,709/2018, regardless of the Laws of other states or countries, with the central jurisdiction of Brasília - Federal District being competent to resolve any doubts arising from this document.

Data Protection Officer: Miguel Rieth Marinho Contact: Ouviria@gruv.com.br

Creation date: October 22, 2020.