DATA PRIVACY POLICY OF INBETTA S.A.

Introduction
Your privacy is important to us. This privacy policy explains how InBetta SA and its affiliated companies (except those that have their own privacy policies) obtain, process, use, protect and share the personal data we receive about you, according to your privacy rights and relevant legislation, including the General Data Protection Law of Brazil (Law 13709 / 2018).

Affiliated Companies
InBetta S.A. And its affiliated companies all share the same Privacy Policy.

Company Name Location
Bettanin S.A. Esteio / RS
Sanremo S.A. Esteio / RS
Atlas S.A. Esteio / RS
Bettanin SuperPro S.A. Esteio / RS
Ordene S.A. Esteio / RS
Sandene S.A. Recife / PE
Lots Home Shop S.A. Esteio / RS

An Overview of our Privacy Policy

The Information that we Collect About You. We collect personal information directly from you through your interactions and use of our website, products and services. We also obtain your information indirectly from our business partners and third party sources. For more information about the types and sources of information we collect about you, please refer to the section “information we collect about you” in this document.
How we use and share your information We use your personal information to introduce and provide our products and services to you, customize your experience as a customer of InBetta or any of our companies, improve and customize our products and services, make relevant recommendations to you, market our products and services to you, and to comply with relevant legislation. We also use your information to improve the security of our website, products and services, which includes identifying, preventing, investigating and responding to risks in those areas that could harm you or InBetta and its companies.

We may share your personal information with our affiliated companies and business partners, in order to complete a transaction, provide the latest information about our products and services or share our latest offers.

For more information, see “how we use and share your information”
How We And Our Partners Use Cookies And Web Beacons Our Websites, online services, interactive applications, email messages and advertisements may use cookies and similar technology to help us customize your experience, understand your preferences better, tell us which parts of our sites you have visited, improve and measure the effectiveness of our interest-based ads and internet searches. We also use web beacons to help deliver cookies and collect usage and performance data. You can choose how InBetta and our business partners can interact with you. For more information, see the section on “Use of Cookies”.
Acquire, delete or use your information and contact you If you wish to exercise your right to privacy, please send an email to dpo@inbetta.com

If you have a privacy query, problem, concern or complaint, please contact us at dpo@inbetta.com dpo@inbetta.com or write to us at:

InBetta S.A.
Att. Data Protection / Legal Department
Rodovia BR 116, Km, 256 – Novo Esteio – Post Code: 93260-000 Esteio/RS - Brazil
Business Partners A "Business Partner" means any contractor, supplier, service provider or debit or credit card processor with whom we have a business relationship: promoting our offers, providing services, marketing products or services or processing your payments, to provide better predictions and deliver content and market offers that may interest you.
Changes to the Privacy Statement We will make changes to this privacy statement, whenever greater transparency is needed or in response to:

• Feedback from our customers, service providers, third parties, the industry or any other interested party.
• Changes to our privacy policies, products or services.
• Changes to relevant privacy legislation.
Should there be any material changes to the privacy policy, we will update the “last update” section at the end of the document. We encourage you to review this privacy policy regularly to understand how InBetta looks after your information.

The Information that we Collect About You.
The different types of information we collect about you depends on how you use our products and services and how you interact with us. This can include information on:

• How you use or visit our websites and your accounts with which you access InBetta, affiliated companies or applications.
• How you use our services and products and interact with us.
• Contact details, billing and other information you provide.
• Improve and develop our products and services.
• Customization of our products and services and recommendations about them.
• Sending advertisements and offers to you, including promotional messages, targeted advertising and providing relevant offers.

We may also obtain information from third party sources. We retain information obtained from third parties in accordance with the privacy practices described in this privacy policy. These third-party sources vary over time and may include:

• Communication services, including email providers and social networks, who you allow to access your information through third party platforms or networks.
• Partners we work with to provide products or services in partnership or where we take part in joint marketing activities.
• Publicly available sources, such as open databases.

The personal information we collect may include the following:

• Contact details such as your name, address, email address and contact phone numbers.
• Professional background information, such as your current job and previous ones, as well as other information about related businesses or companies, places where you have worked, skills you possess, training or certificates you have received.
• Registration Information such as your passwords, password hints and security details to enable access and authentication on our websites, where we promote or sell our products and services.
• Demographic information such as your age, sex, country, interests and preferences.
• Web form information that you have filled in on our web forms (when you complete a form it will indicate whether the information requested is mandatory or voluntary, allowing you to choose).
• Payment information to process payments, such as credit / debit card details or any other identity keys that are needed to complete the purchase of our products and services.
• Account history information about the products or services you have purchased and your account activity.
• Cookies and tracking information, such as IP address, device identifier, location data, browser type and language, access times, URL (Uniform Resource Locator), other unique identifiers and other technical data that can uniquely identify your device, system or browser.
• Browsing History about the sites you visit.
• Information using images, for when you visit or are near to one of our physical locations.
• Error reports and performance information on our products and any problems you have reported.
• Troubleshooting and help information from when you contact InBetta to make a purchase or for technical support or customer service, telephone conversations, or chat sessions with our representatives, which are monitored and recorded.
• Information on media consumption (for example, TV, apps and games) that you access through our products.
• Information on Feedback and Ratings, that you give us, such as feedback from customer surveys and product reviews you write.

How we use and share your information
We use and share your information to:

• Deliver and maintain our products and services.
• Set up and maintain your account with InBetta.
• Assess credit and payment risk.
• Providing services and information related to your account.
• Help to resolve problems or issues with customer service.
• Improve and customize our products and services.
• Send messages on marketing and offers, targeted advertising with offers that are relevant to you, which includes customized content and marketing offers that may interest you.
• Check and verify your account access.
• Detect and prevent fraud.
• Manage and look after our employees, facilities, communications networks, services, products and customers.
• Comply with legal and regulatory requirements.
• Conduct research related to our products and services.

Your Right to Privacy

Brazilian legislation gives you certain privacy rights, including:

• The Right to Information: you have the right to be told about whether we keep personal data that we collect about you, how we deal with it and for what purpose.
• The Right of Access: you have the right to request information about the personal data we have and obtain a copy of that personal information.
• The Right of Correction: You have the right to request that incomplete, inaccurate or outdated data be corrected.
• The Right to Object: You have the right to object to your personal data being processed, when applicable, and to revoke your consent to it being used or to access being granted to your personal data.
• Automated decision making: You have the right not to have a decision made about you that is based solely on automated processing, if that decision has legal or similarly significant implications for you.
• The Right to Portability: You have the right to request your personal information, in a commonly used and machine-readable, structured format, and to have that information sent to another organization in certain circumstances.
• The Right to Exclusion: You have the right to request that your personal information that we collect from you be deleted, provided that this is not in contravention of any legal or regulatory requirement.
• The Right to be free from discrimination: InBetta will not discriminate against you on the basis of any information or for exercising your privacy rights.

Data Requests and Data Deletion
If you have any questions about the type of personal information we may hold on you or if you wish to request that your personal information that we may have about you is deleted, or exercise any other privacy right as set out above, please contact us:
a. Send a written request to dpo@inbetta.com
b. By writing to us at the postal address provided in the “overview” box above and at the end of this privacy policy.

Please be aware that your request will be dealt with in accordance with the relevant legislation, which may need or require data to be kept in certain circumstances.

How we look after your information
InBetta uses appropriate technical, organizational and security measures, including physical information security, to protect your personal data against misuse, interference and loss, as well as unauthorized access, modification or disclosure, as required by Brazilian law. The ways we may do this include:

• The use of encryption when receiving or transferring confidential information, such as credit / debit card details.
• Establishing data security measures to ensure ongoing security, integrity, availability and resilience in our processing systems and services.
• Limiting physical access at our facilities.
• Limiting access to the information we collect about you.
• Checking and monitoring that our business partners have appropriate technical and organizational security measures in place to keep your personal information secure.
• Destroying or anonymizing personal information, when required by law.

We encourage you to keep your passwords confidential and to be careful to avoid "phishing" scams, for example, where you may receive an email that appears to be from InBetta or any of its companies asking for your personal information. InBetta will never ask you for your password or email address.

Obtaining and Using Information on Children and Teenagers
We understand the importance of taking extra precautions to protect the privacy and safety of children and teenagers who use our products, services and websites. Children and teenagers, under the age of 18, should not share their personal details unless their parents or guardians provide verifiable consent. If a parent or guardian needs to access or delete data associated with their child's or ward’s account, at any time, they can contact us using one of the options listed in this privacy policy.

International Transfer
InBetta may transfer your personal information to other companies in the InBetta group or to its business partners, for the purposes described in this privacy policy, where it is strictly necessary. This may involve transferring your personal information to countries outside of Brazil, which may have different standards for data protection in their country. To ensure your personal information remains properly protected, we have established contractual agreements (as appropriate) with our subsidiaries, affiliates and business partners for such transfers. We take all appropriate technical and organizational measures to ensure the security of the personal information we transfer.

Use of Cookies

A cookie is any text string that requires authorization, before it can be stored on your electronic device. If you accept, then the browser aggregates the text into a small file. If you have set up your browser to notify you before accepting a cookie, you will be notified that Inbetta or one of its affiliated companies is asking you to agree to accept cookies. Its purpose is to notify us when you visit one of our websites. This information may include the pages you have visited, the items you viewed or even what you put in a shopping cart or your response to our ads and messages. This information allows us to give you more relevant ads from InBetta. InBetta, its companies and its partners may use the information about your visits to their websites and other related websites to help improve your browsing experience.

You can choose to accept or decline cookies. Most browsers automatically accept cookies. However, you can generally change your browser settings to refuse cookies, if you prefer. If you choose not to accept cookies, you may not be able to access or use other interactive features of the websites and services that rely on cookies.

We want to ensure that you understand that accepting a cookie does not give us access to your device or any additional personal details.

We also use cookies to store your preferences and other information on your device in order to save you time, so that you do not need to enter the same information again and again.

We also work with third party advertisers and customization partners that use web beacons to help us display personalized content and relevant advertising while you are visiting the Inbetta website and its affiliated companies. The cookies placed by our partners also help us to measure how successful our advertising campaigns are.

Links to Third Party Websites and Services
Sometimes, we may provide links to other websites; if you click on them you will be redirected to those websites and information may be collected from you. The information practices of these third party websites that link to our site are covered by the third party's own privacy policy and we encourage you to read them.

Contact us
If you want to exercise any of your privacy rights as described in this privacy policy, or if you have any questions, concerns or complaints involving data privacy, please contact our Data Protection Officer at dpo@inbetta.com or write to us at:

InBetta S.A.
Att.: Data Protection / Legal Department
Rodovia BR 116, Km 258 – Novo Esteio Post Code 93370-000
Esteio/RS - Brazil

Latest Update to the Policy: October/2020

Desenvolvido por Grupo Plan Marketing
© 2014 InBetta.