Privacy Policy

Be Growth Brasil Internet S/A‘s Privacy Policy was created to make users of its services aware of the company’s commitment to always treat its users’ personal data with security, privacy and transparency.

This Privacy Policy describes the personal data we collect, how it is used, stored and shared, and your rights in relation to that data. We recommend careful reading.

Introduction

Be Growth aims to share information and commercial proposals of interest to its Users, making it accessible to everyone and raising awareness about products and services that are most suited to their reality, according to their needs and preferences.

Be Growth follows international and national security standards and regulations in the storage, protection, privacy and transmission of data.

By using the services, the user confirms that he has read, understood and accepted the Terms and Policies applicable to the service provided by Be Growth, including this Privacy Policy and agrees to be bound by them, being aware that the controller of your personal data, that is, the company responsible for making decisions about the processing of your personal data, will be BE GROWTH BRASIL INTERNET S.A, a business company registered with the CNPJ/MF under n. 36.563.402/0001-41 established at Av. Afonso Pena, nº 3351, Serra, Belo Horizonte – MG, CEP:30.130-008.

After reading this Privacy Policy, if you have questions, complaints, want to exercise your rights related to your personal data or communicate with Be Growth about this matter, you can contact us through our service channels or contact our Data Officer (DPO), Gabriel Delgado, by e-mail compliance@begrowth.com.br

1.Application

This Privacy Policy is applicable to all users of Be Growth. We collect your personal data whenever you:

• Fill out the registration form available on the company’s website;
• Participate in surveys or promotions offered by Be Growth;
• Report any problem to Be Growth, requesting that the company provide a solution;
• Browse the Be Growth website – https://begrowth.com.br/
• Contact us through our service channels;

This Privacy Policy is also applicable to other forms of collection of personal data by Be Growth, which allow the provision or improvement of our services. For example, we may collect information through partners or in connection with our technologies.

The practices described in this Privacy Policy only apply to the processing of your personal data in Brazil and are subject to applicable local laws, with emphasis on Law nº 13.709/2018 (General Law for the Protection of Personal Data, or “LGPD”) .

2. What personal data is collected by Be Growth

By using Be Growth services, you provide us with, and we collect, certain personal data relating to you. From the moment you interact with Be Growth, we collect your personal data. In some cases, you directly provide your personal data to Be Growth, but we may also collect your data automatically.

In addition, we also receive some personal data sent by partners that we hire for specific purposes, so that we can comply with legal obligations or applicable regulations and others that will be detailed later.

By accepting the terms of this Privacy Policy, you expressly agree to provide only true, current and accurate personal data and not to change your identity or your personal data in any way when accessing and using our products or services. You will be solely responsible for false, outdated or inaccurate information that you provide directly to Be Growth.

These are your personal data processed by Be Growth, divided by categories:

Personal data that may be requested and informed by the holder:

• Personal identification information: name, email and CPF;
• Personal details: age, marital status and gender of the user;
• Family situation: who you live with;
• Education;
• Work situation: whether you are self-employed, self-employed, unemployed, employed or retired;
• Habits of consumption;
• Financial situation: if you are negative or with some financial restriction;

Personal data we collect from third parties:

• Registration data, such as: name, date of birth, CPF, telephone number and address;
• Data on financial restrictions, such as: negatives, amounts due and due dates;
• Credit history information;
• Score generated by credit bureaus;
• Information on debts falling due or overdue, co-obligations and guarantees;

Browsing and device data:

• IP address of the mobile device used to access;
• Interactions made and website usage profile;
• Technical data, such as URL, network connection, provider, and device information;
• Cookies;
• Device attributes such as ID, operating system, browser, and model;
• Device geolocation data if you authorize collection from your device;
• application access logs;
• date and time of use of the application;
• navigation data, reflecting the areas visited;

Personal data arising from the use of our services:

• Contracting data for our services;
• Data for contracting credit operations with partners, such as personal loans, negotiation of amounts due and debt installments;
• Credit history;
• Customer service history;

3. How Be Growth uses your personal data

Be Growth uses your personal data to be able to promote and offer the best products for you.

Be Growth undertakes to continuously implement physical, technical and administrative information security measures in the processing of your personal data, in accordance with the best market practices. Therefore, we seek to protect your data against unauthorized access, accidental or unlawful situations of destruction, loss, alteration of communication or any form of inappropriate or unlawful treatment.

We detail below the purposes for which we use your personal data:

Personal data informed by the owner

Purposes:

• The correct and precise identification of the user, thus ensuring greater security and protection for the users themselves;
• Access to the services and products provided by Be Growth;
• The analysis of the profile of users with the aim of disclosing and indicating the best products and information according to their real needs and reality;
• Identification, authentication and verification of requirements for using Be Growth services;
• Answering requests and doubts;
• Contact by phone, e-mail, SMS, WhatsApp, or other means of communication, including for sending notifications or push to use Be Growth services;
• Improvement of the services provided by Be Growth, including cross-referencing information on contracted products to offer new products and services;
• Marketing, prospecting, market research, opinion research and promotion of products and services from our partners, including offering offers and sending information about products, services, news, features, content, news and other events relevant to the maintaining the relationship with you;
• Credit protection, including credit granting and limit increase;
• Prevention and resolution of technical or security problems;
• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Collaboration or compliance with a court order, competent authority or supervisory body;
• Compliance with a legal or regulatory obligation;
• Solution of questions based on the information collected, in order to solve doubts, correct problems and improve the system, improving the user experience of Be Growth.

Personal Data We Collect From Third Parties

Purposes:

• Improvement of our products and services;
• Marketing, prospecting, market and opinion research;
• Credit protection, including credit granting and limit increase;
• Prevention and resolution of technical or security problems;
• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Compliance with legal or regulatory obligations, keeping your registration up to date or complying with legal and/or regulatory obligations imposed on Be Growth.

Browsing and device data

Purposes:

• Provision of services, dissemination and offering of products and improvement of the use and experience with the Be Growth website;
• Operationalization of the dissemination of new products and services of interest to the user;
• Recommendation of new services, products or features, including services from other partners that may interest you;
• Display of advertising, whether on our website, social networks or on third-party websites;
• Generation of statistics, studies, surveys and surveys relevant to activities and behavior in the use of products or services;
• Credit protection, including credit granting and limit increase;
• Prevention and resolution of technical or security problems;
• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Compliance with a court order, competent authority or supervisory body;
• Compliance with a legal or regulatory obligation;

Personal data arising from the use of our partners’ products and services

Purposes:

• Provision of services and offering of contracted products;
• Improvement of the services provided by Be Growth, including cross-referencing information about contracted products to offer new products and services
• Development of new products and services to be offered by partner companies of Be Growth and generation of knowledge for innovation or development of new products;
• Tests to improve the models and services and products of Be Growth;
• Marketing, prospecting, market research, opinion research and promotion of our partners’ products and services, including offering offers and sending information about products, services, news, features, content, news and other events relevant to the maintaining the relationship with you;
• Credit protection, including credit granting and limit increase;
• Prevention and resolution of technical or security problems and monitoring of use and performance of Be Growth services and products;
• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Collaboration or compliance with a court order, competent authority or supervisory body;
• Compliance with a legal or regulatory obligation.

Public data

Purposes:

• Disclosure of products and services provided by Be Growth on social networks, websites, applications or institutional and advertising materials;
• Credit protection, including credit granting and limit increase;
• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Regular exercise of Be Growth rights;
• Compliance with legal and/or regulatory obligations imposed on Be Growth.

4.Sharing of personal data

Be Growth may share your data if you authorize it. Your data may be shared with companies in the Be Growth economic group, third-party partners and with authorities and regulatory bodies for different purposes, when necessary. Whenever carried out, the sharing of data will be carried out within the limits and purposes of our business and in accordance with what authorizes the applicable legislation.

Below we have prepared a summary divided by categories with the types of providers with whom we share your personal data:

Business partners, service providers and other third parties

Purposes of sharing:

• Improvement of our services and website, as well as operationalization of new products or services;
• Contact by phone, email, SMS, WhatsApp, push notification or other means of communication;
• Assistance in the development and provision of our services;
• Marketing, prospecting, market research, opinion and promotion of our products and services;
• Credit protection, including credit granting and limit increase;
• Prevention and resolution of technical or security problems;
• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Regular exercise of Be Growth rights;
• Compliance with a court order, competent authority or supervisory body;
• Compliance with a legal or regulatory obligation.

Authorities and regulatory bodies

Purposes of sharing:

• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Regular exercise of Be Growth rights, including presenting documents in judicial and administrative proceedings, if necessary;
• Compliance with a court order, compliance with a request from the competent authority or supervisory body;
• Compliance with a legal or regulatory obligation.

Authorities and regulatory bodies

Purposes of sharing:

• Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of Be Growth customers and the financial system;
• Regular exercise of Be Growth rights, including presenting documents in judicial and administrative proceedings, if necessary;
• Compliance with a court order, compliance with a request from the competent authority or supervisory body;
• Compliance with a legal or regulatory obligation.

Furthermore, when browsing our website, you may be redirected to third-party websites or applications. Once you are redirected to a third-party website or application, those third-party’s privacy practices will be governed by that third-party’s privacy policies and terms of use. We cannot control or be responsible for the privacy practices and content of third parties. Carefully read the applicable privacy policies to understand how they collect and process your data.

5. Retention and deletion of your personal data

As long as you are a Client or Prospect of Be Growth, while using our services and for the entire period in which Be Growth stores your personal data, they will be kept in an environment safe and controlled.

When applicable, and even after you stop using the services of Be Growth or its partners, we may store your personal data for an additional period of time for audit purposes, compliance with legal or regulatory obligations , for the regular exercise of rights of Be Growth or also for the necessary period according to the legal basis that justifies the retention of the data. If there is no legal basis to justify data retention, they will be deleted from the Be Growth database.

6. Your rights as a holder of personal data

As of the entry into force of the LGPD, you, as the holder of personal data, can exercise your rights against the controllers of your personal data, such as Be Growth.

We provide the mechanisms detailed below so that you understand in a clear and transparent way how to exercise your rights and our team will be ready to respond to any requests.

Confirmation of the existence of processing of personal data

The fact that you are a user of Be Growth services already means that we process your personal data, even if this treatment is, among others, the storage of personal data in a safe and controlled environment. In this sense, you can ask Be Growth to confirm that it processes your personal data.

Access to personal data

You can ask Be Growth to inform and provide the personal data it holds about you.

Correction of incomplete, inaccurate or outdated personal data

If you verify that your personal data is incomplete, inaccurate or out of date, you can ask Be Growth for correction or supplementation. For this, you will need to send a document that proves the correct and current form of the personal data.

Anonymization, blocking or deletion of data that is unnecessary, excessive or treated in non-compliance with the LGPD

If, eventually, any personal data is processed unnecessarily, in excess for the purpose for which it is intended or in non-compliance with the LGPD, you can request that Be Growth anonymize, block or eliminate this data , provided that the excess, lack of need or non-compliance with the law is effectively verified.

Deletion of personal data processed with consent

If you have given consent to the processing of your personal data for specific purposes, you may, at any time, request the deletion of such personal data.

Information from the companies with which Be Growth has shared or received your personal data

You can ask Be Growth to inform you with which third parties you have shared or received your personal data.

Information on the possibility of not giving consent and on the consequences of the refusal

If your consent is required to access or use a certain product or service, you can ask Be Growth to clarify whether it is possible to provide that product or provide that service without your consent for the processing of your personal data , or what are the consequences of not providing consent for this case.

Revocation of consent

If you have given your consent to the processing of your personal data, you can request the revocation of this authorization. The revocation of consent may result in the impossibility of using some functionalities provided by Be Growth, or even in the termination of the services provided, but does not prevent the use of (i) anonymized data; and (ii) data whose treatment is based on another legal hypothesis provided for in the LGPD.

Automated Decisions

You can request the review of decisions taken solely on the basis of automated processing of personal data that affect your interests and the indication of the criteria used for these decisions. For reasons of business secrecy, protection of confidential information and preservation of competition, Be Growth does not inform how these automated systems work.

7. Activity Log / Collected Data

We can record the activities that you carry out when using our website, creating, when possible and applicable, logs (records of activities carried out on the websites and applications and services) that will contain: the IP address, access and actions performed by you in the service provided, date and time of each action performed and information about the device used, such as operating system version, browser and geolocation.

We may also use certain proprietary or third-party technologies to monitor activities carried out while you access our website, such as:

Cookies: are internet files that temporarily store what you are visiting on the network. Be Growth has cookies on its website and also receives information from partners regarding cookies inserted on their respective websites. Cookies can be used for a variety of purposes, including remembering you and your preferences, persisting information related to your activities on the website you visit, or collecting information that can be used to deliver content in a personalized way.

The user may, at any time, change the acceptance or not of cookies in the configuration of his browser, noting that by deactivating navigation cookies, some of the functionalities of Be Growth may be impaired.

We have third-party cookies enabled on our website. Privacy practices will be governed by the privacy policies and terms of use of those third parties, so we cannot control or be responsible for the privacy practices and content of those third parties. Therefore, we emphasize that you can, at any time, block the use of cookies by activating a setting in your internet browser and your ability to limit cookies will be subject to your browser settings and limitations. You can also delete existing cookies through the same settings on your internet browser. If you choose to disable cookies, you will be able to continue browsing the websites, but some functionality may no longer work.

Web beacon: Web beacon is a technique that allows you to map who is visiting a certain web page, identifying their behavior with different websites or web servers.

Google Adsense Cookie Dart: Be Growth serves ads served by the GOOGLE ADSENSE Network. Google uses Cookies to display advertisements on websites that serve its advertisements. Cookie DART allows ads to be displayed based on user preferences and browsing habits. Users can choose to disable the Cookie DART on the page containing the privacy policy of the Google ad and content network. If the user does not agree with Google’s Cookies and wants to disable them, simply access the official Google page to control how Google uses the Cookies collected in its ad network: http://www.google.com/ ads/preferences/

Analytics tools: These tools may collect information such as how you visit a website, including which pages and when you visit those pages, other websites you have visited before, and so on.

We do not intend to collect information about anyone under the age of 18. If you have any questions about your child’s privacy in relation to our services, or if you believe your child may have entered personal data on our website, please contact us through the DPO. We will delete this information from our records within a reasonable time.

All technologies used by us will always respect the terms of this Privacy Policy.

8.International transfer of personal data

Some of your personal data, or all of them, may be transferred abroad, for example when they are stored by Be Growth on cloud computing servers located outside Brazil. For this, Be Growth observes all requirements established by current legislation and adopts the best security and privacy practices to guarantee the integrity and confidentiality of your personal data.

9. Security measures

Be Growth uses various types of security measures to ensure the integrity of your personal data, such as information security standards practiced by the industry when collecting and storing personal data.

We treat the security of your personal data with the utmost care, using standards and best practices adopted in the market. We have a highly qualified team responsible for ensuring that Be Growth adopts the best security practices, including:

• Multiple authentication factor for information access;
• Security as code, in order to enable automations and fast and efficient responses to security events in the technological environment;
• Encryption for data at rest, in transit and in use to ensure information integrity;
• Continuous monitoring of the environment;
• Continuous analysis and testing of information security in our systems, carried out by internal and external teams;
• Periodic audits.

10. Consent

Throughout this Privacy Policy, we inform you that some personal data will only be collected by Be Growth with your consent. Likewise, this personal data can only be processed with authorization and for the purposes described.

By reading this Privacy Policy and clicking on the option described at the end, you consent to the processing of personal data in the ways indicated here.

It is worth remembering that the processing of your personal data is a necessary condition for us to provide our services to you. If you have questions about any of the terms explained here, we are available in our service channels to help you.

11.Additional Relevant Information

Be Growth does not send emails to its Users requesting payments or confirmation of personal data. Therefore, if you receive an email for this purpose, we indicate that it is immediately disregarded.

Be Growth may share your personal data with partner companies in order to be able to promote and indicate products and services that are best suited to your needs or to provide products and/or services requested by the user .

Articles on the Be Growth website may include embedded content from other websites, such as videos, images, articles, etc. Embedded content from other websites behaves in exactly the same way as if the visitor were visiting the other website. These sites may collect data about you, use cookies, incorporate additional third-party tracking, and monitor your interaction with this embedded content, including your interaction with the embedded content if you have an account and are signed in to the site.

12.Changes to this Privacy Policy

Be Growth may change this Privacy Policy at any time. Whenever any relevant condition of this Privacy Policy is changed, these changes will be valid, effective and binding after the new version is posted on our website or sent by email to you.

We always value transparency: every time a relevant change is made, we will inform you on our page. By continuing to use our products and services after a change in the Privacy Policy, you will be agreeing to the new conditions, although you can always express your disagreement through our service channels, if applicable.

12. CONTACT DPO

According to Law nº 13.709/2018, Be Growth is considered the “Controller” of your personal data. If after reading this Privacy Policy you still have any questions, or for any reason need to communicate with us about matters involving your personal data, you can contact our data officer:

• In charge (DPO): Gabriel Delgado
• E-mail:compliance@begrowth.com.br
• Address: Av. Afonso Pena, nº 3351, Serra, Belo Horizonte – MG, CEP: 30.130-008.
• Attributions: Article 41, paragraph 2, of the LGPD

We are always available to clarify your doubts.