PRIVACY POLICY

A. Definitions

For the purposes of this Privacy Policy, the terms set forth herein and used, shall have the meanings assigned to it below:

Consent - Free manifestation by which the Holder agrees to the processing of his personal data for a specific purpose;

Controller – Designation granted by law to the natural or legal person, under public or private law, in the case to Ourofino, who is responsible for decisions regarding the processing of Personal Data;

Child and Adolescent – Definition provided for in Article 2 of Law No. 8.069, of July 13, 1990, which is: "a child, for the purposes of this law, is considered to be a person up to twelve incomplete years of age, and an adolescent between twelve and eighteen years of age.";

Anonymized Data – Data relating to the owner that cannot be identified, considering the use of reasonable technical means available at the time of its processing of the data, which assist the Controller in creating better user experiences when browsing the websites;

Personal data – It means information relating to an identified or identifiable natural person, including information that identifies, describes, is related to, and/or can reasonably be linked, directly or indirectly, to the owner, alone and/or combined with other information provided to and/or collected by Ourofino.

Sensitive Personal Data – Personal Data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person;

Information - Anonymized data that demonstrate the behavior of users on the websites, i.e. the pages displayed and browsed by the owner on the websites, their length of navigation and the browsing path taken;

IP – Internet Protocol is an address assigned to each device (mobile phone, personal computer, tablet, among others), in order to identify it on the World Wide Web;

General Law on the Protection of Personal Data or LGPD Law No. 13,709, of August 14, 2018, known as the General Law on the Protection of Personal Data;

Operator – Natural or legal person, under public or private law, who processes personal data on behalf of the controller;

Ourofino – Generic name given to the companies that make up the Grupo Ouro Fino Saúde Anima, being Ouro Fino Saúde Animal Participações S.A., Ouro Fino Saúde Animal Ltda., Ouro Fino Agronegócio Ltda. and Ouro Fino Pet Ltda.;

Politics Designation given to this Privacy Policy;

Customer Service Ourofino Customer Service;

Treatment – Any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or otherwise extracting;

You/Holder – Natural person browsing the websites of Ourofino, owner of the Personal Data, object of treatment; and

Websites – Ourofino Websites on which this policy is applicable, including their respective subdomains and hotsites.

B. INTRODUCTION AND PURPOSE

This Ourofino policy aims to establish the principles, guidelines and rules on the operation and use of its websites and virtual services.

Ourofino understands that the privacy and security of Personal Data are of paramount importance and is committed to respecting the privacy of all holders, demonstrating how we protect your privacy when accessing our Website.

This policy clarifies the types of data collected, the form, the treatment, and the reason for its collection, in addition to informing how the holder may exercise their rights under the law. For this reason, we recommend that you read our policy carefully.

By using our Websites and/or our services, you acknowledge and accept the entirety of the terms and conditions of this policy, and agree to be bound by it, freely and spontaneously.

In addition, this policy may be amended at any time, at the sole and exclusive discretion of Ourofino, as provided in item 9, below.

1. Personal Data collected

Ourofino may collect personal data that includes, but is not limited to your name, email, telephone, ZIP code, area of interest, occupation, information about your purchase, marital status, address and geolocation, data and numbers of personal documents (RG, CPF, functional identity number, passport, etc.), the IP address of your personal device/equipment, information about the pages displayed, length of navigation and the browsing path taken by you on our Websites (see item 3 below).

Eventually, Ourofino will collect sensitive Personal Data, especially those necessary for the creation of marketing campaigns, among others, an opportunity in which we will inform you in advance, as well as collect your specific authorization, at its sole discretion, for this purpose.

2. Personal Data of Children and Adolescents

Ourofino does not recommend that the Websites be accessed or otherwise used by Children or Adolescents. For this reason, we recommend that parents or legal guardians do not allow Children or Adolescents to use our Websites and/or virtual services. We recognize that protecting the identities of Children and Adolescents, and their respective privacy, is of utmost importance to us.

Thus, if any Personal Data of a Child is (i) accidentally collected by Ourofino, (ii) voluntarily provided by the minor Holder and/or (iii) Ourofino is misled in the collection of Personal Data by the Child, as soon as the situation and age of the holder are confirmed, such personal data will be immediately deleted from our databases.

Exceptionally, and in accordance with §3º of Article 14 of the LGPD, Personal Data of Children may be processed when Ourofino deems it necessary, and at its sole discretion, to contact the parents or legal guardian of the child to report the situation and when possible identify them (their parents or legal guardian).

If such identification is not possible or after the situation is reported to the child's parents or legal guardian, their respective Personal Data will be immediately deleted from our databases.

3. How do we collect your personal information and data?

We collect your information and your personal data in the following hypotheses:

  1. When you voluntarily fill out forms and browse our Websites;
  2. When you contact our Customer Service by phone, communication applications, third-party social networks and/or email;
  3. When you contact us by e-mail, telephone, WhatsApp or in person, to carry out registrations, marketing campaigns and/or opinion polls, upon obtaining consent for the collection of Personal Data, obtained physically or digitally (own or third-party platforms/means, for example);
  4. When you use our app intended for smartphones or tablets;
  5. Through the use of third-party platforms and social networks (Instagram, Facebook, YouTube, TikTok and LinkedIn, for example), or
  6. Through our distributors, when you purchase any of our products through these channels, by sharing certain information about your purchase.

In addition, when you interact with features or tools of the Website or when you click on any link on the Website, we also collect your information and Personal Data.

We also use some technologies to collect information and personal data, such as Cookies, Clickstream and Web Beacons, as described below:


What are "cookies"?

Cookies these are small pieces of data that a website can send to a browser, which may be stored on your device so that we can recognize you when you return to the Website. The cookies can improve your online experience by saving your personal preferences while visiting our Website. Cookies may or may not contain personal data.

If you do not wish to receive cookies, just set your browser to reject cookies or to alert you when a cookie is placed on your personal equipment. You can also delete your cookies as soon as you leave the Website.

When disabling the use of cookies on our Websites, certain functions may be compromised.

You can configure the cookies that we use on our Websites through the Cookie Preferences link available at the bottom of the page.


What is "Clickstream"?

"Clickstream" or "data clickstream" indicate the specific internet pages accessed by a user, as well as the manner or traffic pattern by which that user moves from one page to another. This data is used to improve your navigation through our Website.


What are "Web Beacons"?

The "Web Beacons" serve to help manage and improve our services, systems, advertising and online ads, and other tools. Web Beacons enable the recognition of a cookie of a browser when the Holder visits the Website on which the Web Beacon is located, and to record which banner advertising takes the user to a particular Website.

We also include pixel tags in our HTML-formatted e-mail messages that we send (or that are sent on our behalf), in order to determine which e-mail messages have been opened and to indicate whether an e-mail message has prompted a particular action.

You can make some pixel tags or Web Beacons unusable when rejecting cookies associated with them.

4. How do we use your information and Personal Data?

Your information and your Personal Data collected in the manner of item 3, above, will be used by Ourofino for the following purposes:

  • Provide the products, information and services you request;
  • Better understand your interests and needs;
  • Conduct opinion polls about us;
  • Improve our products and services;
  • Customer Service or other contact channels, own or third parties (including social networks);
  • Send  Newsletters  of subjects of your interest, related to Ourofino and animal health;
  • Carry out promotional campaigns and  marketing;
  • Offer a personalized experience, improve the content, functionality and usability of our Websites;
  • Display personalized ads when you visit our Websites;
  • For security, credit or fraud prevention purposes;
  • Comply with our contractual obligations, mainly to carry out the inspection of our authorized distributors, using only the data strictly necessary for this purpose;
  • Comply with our legal and/or regulatory obligations; and
  • For any other purpose identified in an applicable privacy notice or other agreement between Ourofino and you.

5. Rights of the Holder

Ourofino respects and guarantees you, as the Holder of Personal Data, the possibility of submitting requests based on the rights established by the LGPD.

Among them, we highlight the following rights:

  • Confirmation of the existence of the processing and access of your Personal Data, by contacting through the channels made available here;
  • Correction, anonymization, blocking and deletion of your Personal Data from our databases, stored on our own or third-party servers, when applicable and not prohibited by law;
  • Not provide or revoke consent at any time, which will not affect the legality of any treatment previously carried out;
  • Oppose the treatment carried out by us, when you consider it illegal, by means of a request made in the appropriate channel.

If you need any assistance to exercise your rights, you can contact Ourofino, according to the guidelines in this policy.

Ourofino will make its best efforts to fulfill such requests in the shortest possible time, always in accordance with the LGPD.

However, even in case of request for deletion of Personal Data, the minimum storage period of Information and Personal Data will be respected, whether to comply with legal and regulatory obligations, to preserve the rights of Ourofino or third parties in disputes of any nature. Likewise, requests to delete your Personal Data will imply the deletion of your eventual user account created on our Website.

6. Sharing with third parties

Ourofino will not disclose and/or transfer your Personal Data and/or sensitive Personal Data to third parties that do not have a legal relationship with Ourofino (signed contract, for example).

However, we may share your Personal Data and/or sensitive Personal Data with third parties that provide services to Ourofino, such as data storage and processing servers, companies contracted to perform marketing services, among others, who will act on behalf of Ourofino as operators, which will have contractual obligations of secrecy, confidentiality and protection of Personal Data.

Likewise, if requested by a competent authority in compliance with its legal attributions, or by order, decree, regulation or governmental rule, or in case of violations or suspected violations of this or the law, Ourofino may be required to make available the information and Personal Data that are stored in our possession. Ourofino, however, undertakes to strictly disclose the information and Personal Data necessary to achieve the required purposes.

Anonymized data, such as statistical reports on access, use of the Website (and other information) and market trends, which do not reveal the identity of the owners, may also be shared with subcontractors or business partners of Ourofino.

À As Ourofino develops and grows, which may be through, but is not limited to, a corporate transaction such as an acquisition, incorporation, merger, spin-off or through the sale or purchase of companies, products and/or assets, the holder's personal data may be transferred to the new company.

7. Retention of Personal Data and/or sensitive Personal Data

Ourofino will keep the Personal Data and/or sensitive Personal Data for the period necessary to fulfill the purposes set out in this policy or until eventually requested the deletion of said data by you, when possible and applicable. In this case, even after the request for deletion, Ourofino may keep the Personal Data stored for the prescribed periods provided by law.

Upon expiry of the retention period and legal necessity, Personal Data will be deleted using secure disposal methods, or used in anonymized form for statistical purposes.

8. Security

Ourofino is committed to the security of Personal Data and takes reasonable precautions to maintain this protection on all our systems and servers.

We protect the personally identifiable data stored on the servers of the Websites against unauthorized access, using technical and procedural controls, in addition to employing good market practices to protect your information and Personal Data against unauthorized access, making its best efforts so that these are not accessed by unauthorized third parties.

Some examples of these protective measures are: Firewall and protection AntiSpam, in addition to tools for security Endpoint.

In the event of data leaks or unauthorized access relating to Personal Data, if the data controller and the personal data owner are in agreement, direct conciliation may be promoted pursuant to art. 52, § 7, of the General Data Protection Law.

9. Changes to this policy

You represent that you have knowledge and irrevocably accept that Ourofino may, without prior notice and at our sole discretion, modify, add or withdraw any terms or conditions of this policy.

Any modifications to this policy will be effective immediately. For this reason, we recommend that you access this policy frequently.

Any changes to our policy will be immediately communicated on this page.

10. Contacts

In case of questions, requests for access, removal or correction/modification of Personal Data, please contact us through the following contact channels:

Any request will be fulfilled within the legal deadlines and complaints will be investigated with due exemption.

11. Applicable law

This policy shall be governed by and construed in accordance with the laws of the Federative Republic of Brazil, especially the General Law on the protection of Personal Data.

12. Policy term and updates

This policy is effective as of July 1, 2020, with the last update on July 10, 2023.