GOAL:

The Privacy Policy of Góes International Corp., a legal entity governed by private law, headquartered in the British Virgin Islands, with representation in the Federative Republic of Brazil, through LG Bank Empreendimentos e Tecnologia EIRELI (the latter registered with the CNPJ/MF under No. 36.948.490/0001-08, which will henceforth be called, for the purposes of this formulation, simply by “LGBANK”), was developed with the objective of exercising the commitment to the protection of the sensitive data of its Users. We will next present how the information of customers, former customers and customers (all of which will be treated only by "Users") will be obtained, used and protected, as well as, what are the rights and how to exercise them, all so that there is transparency and clarity in relations with LGBANK.

 

ACCEPTANCE:

As a fundamental condition for accessing and using the features of LGBANK, the User declares that he/she has read this Privacy Policy completely and carefully, being fully aware that when submitting a contracting proposal, accessing the features of the institution's website and platforms and/or or by informing your personal data to LGBANK you will be freely granting your express agreement with all the terms stipulated herein.

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IF YOU DO NOT AGREE TO THE ENTIRETY OF THIS PRIVACY POLICY, WE RESPECTLY REQUEST YOU DISCONTINUE YOUR ACCESS TO THE CUSTOMER PORTAL AND OTHER DIGITAL PLATFORMS, AND DO NOT PROVIDE YOUR PERSONAL DATA OR EFFECTIVELY PURCHASE ANY PRODUCT OR SERVICE.

 

DATA GETTING:

In order to provide its services, it is imperative to obtain some information about Users. LGBANK may obtain sensitive data provided directly by the User, by third parties or obtained automatically, according to the service provided.

LGBANK will store all personal data entered or sent when accessing one of its channels (both the website and the application) or when contracting products and/or services, which are provided by any of the affiliated and/or associated companies.

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For credit analysis and protection, LGBANK may acquire data made available in databases of information providers. When using information base providers, LGBANK chooses reputable companies that respect the privacy and data protection rules, in addition to demanding that they comply with data processing rules established by it.

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When using information base providers, LGBANK will choose reputable companies that respect the rules of privacy and data protection. LGBANK can also obtain a series of information automatically, using some market technologies, such as cookies, beacons, pixel tags and local shared objects, in order to improve your browsing experience on its services, according to the preferences and habits of the Users.

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When the User browses digital platforms or uses products or services that are made available through the Internet, LGBANK collects the data reported in Annex I, especially those listed in the “Electronic Records” line.

LGBANK uses cookies to facilitate use and better adapt its website and applications to the interests and needs of its Users, as well as to improve its structures and contents. Cookies may also be used to speed up your future activities and experiences on your channels.

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Through the use of cookies, the Site stores information about browser activities. These activity records (commonly known only as logs) may include data such as the access IP address, the actions taken on the Site, the pages accessed, the dates and times of each action, and information about the device used, which include the version of the operating system, the browser, among other installed applications, being used only for the purposes of metrics and statistics of the services available, for the investigation of undue changes in their systems and records or fraud, not having as purpose, the providing the data to third parties without the User's express authorization.

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The User can configure his mobile device, if he wants to block, the collection of cookies or other data, but in this case, some features of LGBANK may be limited.

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For all data collection, LGBANK will always follow the following fundamental rules:

• Only essential information for the provision of the services offered will be obtained;

• If necessary, authorization will be requested to obtain new data, accompanied by the proper justification; and

• The sensitive data obtained will only be used to fulfill the purposes informed to the User.

 

LGBANK is not responsible for the accuracy, veracity or lack of data and/or information provided by the User or for its outdating, being the User's sole and exclusive responsibility to declare their data and information accurately and update them whenever necessary, using for that is, the service channels aimed at this purpose, which are disclosed.

 

DATA PROCESSING:

The processing of sensitive data by LGBANK has several purposes, depending on the User's relationship. Thus, the main hypotheses in which the Users' sensitive information will be treated will be presented below, in a non-exhaustive way:

• For the execution of due diligence and/or preliminary contractual acts when the User submits a contract proposal;

• For the execution of a contract that the User may enter into with LGBANK;

• To meet legal and regulatory demands to which LGBANK is submitted;

• To exercise rights in administrative, arbitration and judicial proceedings, including to serve as evidence in case of illegal acts or in disagreement with this Policy or other normative document made available by LGBANK;

• For the relationship and for the provision of information related to the products and services contracted by the Users of LGBANK;

• In the construction and evaluation of the profile of its Users, so that personalized products are offered, which are compatible with their needs;

• In the establishment of statistical research, tests, evaluations and development, aimed at managing and evaluating business risks, improving and/or creating new products;

• In cases of complaint, when there is a quote from LGBANK on social networks or specific platforms, with the purpose of resolving the claimed points, as well as adopting the necessary measures to resolve the situation in the best possible way;

• For credit protection;

• To meet the legitimate interests of LGBANK or third parties linked to it, always within the limits of your expectations, and never to the detriment of your interests, fundamental rights and freedoms; or

• For carrying out activities and tasks aimed at preventing the occurrence of fraud.

 

The treatments carried out by LGBANK meet the principles of purpose, necessity, adequacy, transparency and non-discrimination under the laws and regulations that govern privacy and the protection of sensitive data and may include the data that are listed at the end of this policy to facilitate their visualization.

 

USE, STORAGE AND INTERNATIONAL TRANSFER:

The database formed within the limits and purposes of LGBANK's business is your sole responsibility, and its use, access and sharing, when necessary, will be done in accordance with the laws and regulations that govern confidentiality, secrecy and data protection and with the guidelines of this Privacy Policy, the Complementary Privacy Policies/Notices, the Cyber Security Policy, among others.

 

The User is co-responsible for the confidentiality of their data and personal information. Sharing passwords and access data violates LGBANK's Privacy Policy.

 

Internally, User data will only be accessed by professionals duly authorized by LGBANK, respecting the principles of proportionality and necessity, as well as the purpose for the purposes of LGBANK, in addition to the commitment to confidentiality, secrecy and preservation of privacy under the terms of this Policy of Privacy.

 

The personal data processed by LGBANK, listed in Annex I, may be stored both in Brazil and abroad, on its own servers or hired by and under the responsibility of LGBANK.

 

Depending on the Product or Service, in order to operate efficiently and improve performance, LGBANK may carry out international transfer of its customers' sensitive data. In this case, LGBANK will take the necessary measures to ensure that the information processed internationally observes this Policy and also the other policies and procedures for data processing and security of LGBANK.

No information processing is completely safe, as it will always be susceptible to the possibility of technical failures, malware and/or similar actions. In this regard, LGBANK adopts its best practices to preserve your privacy and protect your sensitive data. However, in the remote possibility of occurrence of episodes of this nature, LGBANK guarantees to commit its best efforts to remedy the resulting events, always guaranteeing due transparency to Users.

 

DATA RETENTION AND DELETION:

Sensitive data, processed by LGBANK, will be deleted when they are no longer necessary for the purposes for which they were obtained, or when requested by the User, except in the event of the need to comply with legal or regulatory obligations, transfer to third parties (provided they are respected data processing requirements) and exclusive use of LGBANK, including for the exercise of its rights in judicial or administrative proceedings.

 

If there is a request for deletion of data by the User, this can only occur if there is no longer any purpose of use or legal, regulatory or judicial obligation that justifies its retention.

No information storage is completely safe, as it will always be susceptible to the possibility of technical failures, malware and/or similar actions. In this regard, LGBANK adopts its best practices to preserve your privacy and protect your sensitive data. However, in the remote possibility of occurrence of episodes of this nature, LGBANK guarantees to commit its best efforts to remedy the resulting events, always guaranteeing due transparency to Users.

 

DATA SHARING:

Sometimes, LGBANK will need to share its Users' sensitive data with third parties. The situations that will involve the sharing of your information are: Automatically or manually, with service providers or partners to support the development and provision of services made available to the User, provided that they are duly approved by LGBANK's security processes:

• With public or private information banks, for identification and/or authentication of Users in the hiring processes with LGBANK, to prevent risks, money laundering, identification of politically exposed person or FATCA, for credit analysis, registration update and prevention of fraud, including the use of biometrics (facial, digital or otherwise);

• With authorities, government entities or other third parties, for the protection of the Organization's interests in any type of conflict, including lawsuits and administrative proceedings;

• In the event of transactions and corporate operations involving LGBANK, in which case the transfer of information will be necessary for the continuity of services;

• In compliance with a court order or at the request of administrative authorities that have legal competence for your request; or

• Sensitive data may also be shared with some partner companies located abroad.

 

RIGHTS OF USERS AS DATA OWNERS:

In compliance with the applicable regulations, more specifically the respect required for the treatment of sensitive data, LGBANK respects and guarantees the User the possibility of submitting requests from the beginning of the General Data Protection Law, based on the following rights:

• Confirmation of the existence of treatment;

• Access to data;

• Correction of incomplete, inaccurate or outdated data;

• Anonymization, blocking or elimination of unnecessary, excessive or treated data in violation of the law;

• Data portability to another service or product provider, upon express request by the User;

• Deletion of data processed with the User's consent;

• Obtaining information about the public or private entities with which Bradesco shared its data;

• Information about the possibility of the User not providing consent, as well as being informed about the consequences in case of refusal;

• Revocation of Consent.

 

Part of the rights listed above may be exercised directly by the User, from the management of registration information, while another part will depend on sending a request through the available service channels, so that they are evaluated and necessary actions can be taken.

 

The User is notified that any request for deletion of basic information for the management of his registration with LGBANK, when applicable, will result in the termination of the contractual relationship.

LGBANK will use its best efforts to meet the requests made by the Holders in the shortest possible time. However, justifiable factors may delay or prevent your quick service, given that, in case of delay, LGBANK will provide the User with the due reasons.

 

Finally, the User must be aware that their request may be legally rejected, either for formal reasons (such as their inability to prove their identity), or for legal reasons (such as a request for data deletion whose maintenance is the free exercise of LGBANK's right), however, in the event of impossibility of service, it is certain that LGBANK will provide the User with the necessary justifications.

 

JURISDICTION:

This Privacy Policy is governed and interpreted in accordance with Brazilian legislation, in the Portuguese language, and the forum of the User's domicile is chosen to settle any dispute or controversy involving this document, except for the specific exception of personal, territorial or functional competence by applicable legislation. .

 

APPLICABLE REGULATION:

This Privacy Policy was prepared based on the applicable legislation on information security, privacy and data protection, including (always and when applicable) the Federal Constitution, the Consumer Protection Code (Federal Law No. 10.820/1990), the Brazilian Civil Code (Federal Law No. 10.406/2002), the Marco Civil da Internet (Federal Law No. 12.965/2014) and its regulatory decree (Decree No. 8.771/2016), the General Data Protection Law (Law Federal No. 13,709/2018), and other sectoral or general rules on the subject.

 

CHANGES:

The Privacy Policy, as well as the contents, the processing of sensitive data and the functionalities of the digital channels, may be updated at any time for legal reasons, due to the use of new technologies and functionalities and whenever LGBANK, in its sole discretion, understand that modifications, alterations, additions or removals are necessary. By continuing to access the Customer Portal and Applications after the changes, which will be posted on the Portal and Applications, the User will agree to the entirety of the changes.

The User must read the new version of the Privacy Policy when notified, so that he/she can assess whether he/she agrees with the changes made, and if he/she wishes to continue using and accessing LGBANK's services and products. LGBANK may, when necessary, establish in a supplementary instrument an additional and specific Privacy Policy for certain products or services. This information will be inserted in the contracts or Terms of Use of the products or services, in a specific clause, identified as “Complementary Privacy Policy”.

 

This Privacy Policy was last amended and posted on its Customers and Applications Portal in 01/2022.

 

PRIVACY POLICY ANNEX I