Privacy Policy

Introduction

This Privacy Policy is intended to clearly and transparently inform how AIVYRO LTDA, a private legal entity registered under CNPJ No. 62.210.164/0001-09, with registered office at Alameda Rio Negro, No. 503, room 2020, Alphavile Centro Industrial e Empresarial, in the city of Barueri, State of Sao Paulo, ZIP Code 06454-000, processes personal data under Federal Law No. 13.709 (General Data Protection Law), which must be accepted by the USER who interacts with the landing page or website located at [www.aivyro.com] for the purpose of regulating the collection, processing, storage, and sharing of data.

Terminological Definitions

• USER/YOU: Refers to the natural person who uses the LANDINGPAGE and provides data, manually or automatically, for processing, storage, sharing, and use by AIVYRO.
• AIVYRO/WE: Refers to the legal entity that owns the LANDINGPAGE and acts as controller of the data collected and entered by the USER.
• LANDINGPAGE: Refers to a website whose purpose is to provide relevant information in exchange for USER data so that AIVYRO may use it strictly as provided in this Policy.

Preamble

This privacy statement defines the privacy policy only in relation to AIVYRO’s LANDINGPAGE and does not apply to third-party websites. When accessing or clicking a link to a third-party website, read that website’s privacy policy to understand the policies applicable to personal information or data processed through that website.

UNEQUIVOCAL CONSENT: We at AIVYRO will obtain your consent unequivocally through express acceptance of this Privacy Policy during your registration on the LANDINGPAGE. Under no circumstances will the acceptance checkbox be pre-marked by the USER, and communications regarding data will be publicly available and easy to access.

THEREFORE, THE USER EXPRESSLY AUTHORIZES AIVYRO, AS OF NOW, TO STORE, SHARE, PROCESS, AND USE THEIR DATA, IN ACCORDANCE WITH THE CLAUSES SET FORTH IN THIS DOCUMENT AND BRAZILIAN LAW, THROUGH MANUAL DATA PROCESSING, WHETHER CAPTURED MANUALLY OR AUTOMATICALLY THROUGH THE LANDINGPAGE, AS WELL AS ANY OTHER METHODS THAT MAY BE USED WITHIN THE ESTABLISHED LEGAL LIMITS.

THE PROVISION OF DATA IS CRITICAL FOR THE DELIVERY OF THE INFORMATION ANNOUNCED ON THE LANDING PAGE. IF THE USER DOES NOT WISH TO PROVIDE CONSENT FOR THE USE OF THE DATA, OR THE DATA ITSELF, AIVYRO WILL NOT BE ABLE TO PROVIDE ACCESS TO THE CONTENT, IMPAIRING ACCESS AND THE CUSTOMIZED DELIVERY OF INFORMATION TO THE USER.

Information Collected

AIVYRO may collect the following information from its USERS, whether through manual completion of an electronic form or automatic capture by LANDINGPAGE mechanisms:

• Personal name;
• Company name;
• Email;
• Telephone number;
• Password;
• IP address;
• Browsing data, including, but not limited to, time spent on the page, number of clicks, browser used, among others;

First Paragraph: Whenever a USER chooses to log into the LANDINGPAGE through a third-party authentication service, such as Facebook Connect, Google, among others, AIVYRO may also receive additional profile information or other information authorized by that provider.

Purpose of the Information Collected

2.2 - AIVYRO’s primary objective in using the collected data is to make the LANDING PAGE more useful to the USER. Accordingly, AIVYRO, in summary and without any prejudice to the USER, will process and may use USER data collected under applicable law and this privacy policy for the following purposes:

• a) DISCLOSE OWN SERVICES AND PRODUCTS;
• b) DEFINE THE USER PROFILE SO AS TO CLASSIFY IT INTO CATEGORIES;
• c) REGISTER USERS ON AN INTEREST LIST (WISHLIST);
• d) SCHEDULE A FREE DEMONSTRATION
• d) CARRY OUT AIVYRO MARKETING ACTIONS;
• e) CREATE AND PUBLISH CONTENT RELEVANT TO THE USER;
• f) ENSURE THAT THE LANDINGPAGE IS RELEVANT TO THE USER’S NEEDS;
• g) GRANT LIMITED ACCESS TO LANDINGPAGE AREAS;
• h) ANALYZE TRENDS, ADMINISTER THE LANDINGPAGE, IMPROVE LANDINGPAGE PERFORMANCE, AND GATHER DEMOGRAPHIC INFORMATION FOR AGGREGATE USE;

Legal Bases

3.1 - All data collected from the USER by AIVYRO complies with the following legal grounds for data collection and processing:

• Data subject consent (art. 7, I): sending communications and marketing
• Performance of preliminary procedures (art. 7, V): demonstration scheduling
• Legitimate interest (art. 7, IX): performance analysis and platform improvement

Access to Processed Data

AIVYRO processes USER data both manually and automatically, in accordance with current legislation and, more specifically, with the principles of necessity, accuracy, lawfulness, relevance, non-excess, and transparency. Whenever any specific use or processing of data not mentioned in this Privacy Policy is necessary, new specific and prior consent will be obtained from the USER.

AIVYRO restricts access to information about the USER only to employees and/or third parties who need to know such specific information and will provide those third parties only with the information necessary for service delivery, and they are prohibited from using such information for any other purpose.

AIVYRO will ensure that the service provider agrees to apply the same levels of data protection that we are required to apply to the information held, as required or permitted by applicable law.

Data Sharing and Transfer

Data collected by AIVYRO may be shared with third parties, strictly when necessary and in accordance with the principle of necessity, such as:

• technology infrastructure providers;
• email sending tools;
• analytics platforms that maintain a DPA agreement with AIVYRO;

Sole paragraph: the third parties mentioned act as processors and process data exclusively in accordance with AIVYRO’s instructions.

AIVYRO AND/OR ITS SERVICE PROVIDERS MAY TRANSFER VISITOR INFORMATION, INCLUDING PERSONAL INFORMATION, ACROSS BORDERS AND FROM YOUR COUNTRY OR JURISDICTION TO SERVERS IN OTHER COUNTRIES OR JURISDICTIONS AROUND THE WORLD, PROVIDED THAT SUCH COUNTRIES HAVE LEGISLATION AND DATA PROCESSING COMPATIBLE WITH WHAT IS REQUIRED BY BRAZILIAN LAW.

Data Subject Rights

6.1 - The following are rights of USERS, as data subjects, which may be requested from AIVYRO:

• confirmation of the existence of processing;
• access to the data;
• correction of incomplete or outdated data;
• anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• data portability to another service or product provider, upon express request and subject to commercial and industrial secrecy, in accordance with the controller authority regulations;
• information about public and private entities with which the controller has shared data;
• information about the possibility of refusing consent and about the consequences of such refusal;
• withdrawal of consent;
• objection to processing carried out based on one of the legal grounds that dispense with consent, in the event of non-compliance with the law.

The USER may access and update their data, at any time, in an easy manner, by contacting AIVYRO.

The USER may obtain, at any time, within an appropriate period and upon written request, confirmation as to whether personal data exists and receive such information in an intelligible form. The USER may also obtain an indication of the origin of personal data, the purposes and methods of processing, the logic applied in the event of processing carried out with the aid of automated tools, and identification details of those responsible for the processing of such data, as well as update, correct, and, if interested, supplement personal data.

Data Storage and Security

7.1 - Some suppliers used by AIVYRO may store or process data outside Brazil. In such cases, AIVYRO adopts measures to ensure that processing occurs in accordance with applicable law, including appropriate contractual clauses and security standards.

7.2 - AIVYRO records the USER information log that is stored in the database, as well as all changes made to it, making it possible to trace modifications to the information over time.

7.2 - AIVYRO and its service providers use commercially and technologically appropriate protection means for data storage, including the contracting of services and equipment recognized as suitable for this purpose. For better security, the USER is advised to always keep an updated antivirus and carefully read the “Internet Security Guide” available at https://cartilha.cert.br/.

7.3 - AIVYRO may store and use all records of USER access to and use of the LANDINGPAGE for up to five (5) years after data collection or until the USER revokes permission, whichever occurs first.

Data Controller, Response to Requests and Infringements

8.1 - The controller of the data entered by USERS is AIVYRO LTDA, a private legal entity registered under CNPJ No. 62.210.164/0001-09, with registered office at Alameda Rio Negro, No. 503, room 2020, Alphavile Centro Industrial e Empresarial, in the city of Barueri, State of Sao Paulo, ZIP Code 06454-000.

8.2 - AIVYRO has a professional responsible for the processing of personal data, internally and externally, who may be contacted through the following email:

The activities of this officer will consist of:

• accept complaints and communications from data subjects, provide clarifications, and take measures;
• receive communications from the national authority and take measures;
• guide the entity’s employees and contractors regarding the practices to be adopted in relation to personal data protection; and
• perform the other duties determined by the controller or established by supplementary rules.

The USER may request deletion and/or permanently revoke the use of data that may be deleted through a request addressed to the officer.

The deletion request may not be fulfilled when there is a legal or judicial obligation preventing AIVYRO from deleting the data within the timeframes or in the manner requested by the USER. In such situations, AIVYRO may not be held liable by the USER, as it will be complying with Brazilian law on the matter.

AIVYRO reserves the right to modify or amend this Privacy Policy at any time and for any reason. When amended, AIVYRO will provide clear notice of what has changed, obtain the USER’s consent again, and republish this document.

If the USER or any third party feels harmed in relation to any content or action on the LANDING PAGE, they must send an extrajudicial notice to the officer, requesting clarification and an eventual EXTRAJUDICIAL resolution of the matter.

For the above situation, the following must necessarily be submitted, under penalty of dismissal of the request:

• Identification of the subject matter of the complaint;
• Identification of the material that allegedly represents the infringement, or the information necessary for proper identification of the matter; and
• The notifying party declares that the information contained in the notice is accurate and true, under penalty of incurring the corresponding civil and criminal liabilities.

General Provisions

• This document shall be governed by the laws of Brazil.
• All disputes related to this document shall have the judicial district of Barueri/SP as the elected venue.
• If any part of these Terms of Use is considered unenforceable, this shall not affect the remainder of these Terms of Use, which shall remain in full force and effect.
• Any delay or failure to exercise or enforce any right provided for in these Terms of Use shall not be considered a waiver of such right or operate to bar its exercise or enforcement at any time thereafter.