INTRODUCTION
The Alares (“We”) is committed to safeguarding your privacy and protecting your personal data in a transparent, secure, and ethical manner. Therefore, this document (“Policy” or “Privacy Policy”) has been created to demonstrate our commitment to the security and privacy of information collected from users of our Investor Relations website (“IR Site” or “Site”).
Investors and other users (“Data Subject” or “You”) may visit this Site using most of its features to learn about the services we offer without providing personal data. If you provide any information through “Contact IR,” “Subscribe to Mailing List,” or through automated means during your navigation, this Policy will clarify how we treat your personal information.
We aim to provide clear and transparent clarification on how your personal data is collected, for what reasons, with whom they are shared, what measures we use to keep them secure, and how You can contact us in case of doubts or requests.
Access to the collected information is restricted only to authorized employees, for legitimate purposes and the proper use of this information in accordance with applicable law. Employees who misuse this information will be subject to legal and disciplinary penalties according to Alares’ policies.
We recommend that You carefully read this document and review it periodically, as its update is not conditioned to prior notice. If You have any questions or requests, feel free to contact our Data Protection Officer through the email address: dpo@alaresinternet.com.br.
HOW WE COLLECT YOUR PERSONAL DATA AND FOR WHAT PURPOSES
HOW WE COLLECT YOUR PERSONAL DATA
Information about you is collected when You fill out forms related to the functionalities of “Contact IR” and “Subscribe to Mailing,” or automatically as You navigate any area of Alares’ IR Site.
A. Contact IR
Your information is collected through the completion and submission of the digital form available at Contact IR.
B. Subscribe to Mailing
Your information is collected through the completion and submission of the digital form available at Subscribe to Mailing.
C. Browsing Data
The collection of your browsing information occurs automatically through some standard technologies, such as cookies, pixel tags, among others. In this case, some purposes are optional, while others are necessary for the operation of the available features.
WHAT PERSONAL DATA DO WE PROCESS
- Registration Data: Name, email, company, user category, group category, and other information You provide in your message.
- Automatically Collected Data: Characteristics of the access device, browser, IP address (with date and time), location, IP origin, geolocation information, clicks, pages accessed, the subsequent page accessed after leaving the site, or any search term entered on the sites or in reference to them, among other data that support the measurement and improvement of the quality of our services. For such collection, Alares will use some standard technologies, such as cookies, pixel tags, among others, which are used to enhance the user browsing experience according to their habits and preferences.
FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA
Your personal data collected on this Site may be used by Alares for the following purposes:
- Fulfillment of contractual, legal, and regulatory obligations;
- Processing of requests directed to IR, as well as keeping the applicants informed about their progress;
- Facilitation of supervisory actions by administrative agencies and authorities, including all activities related to access, acquisition, and verification of data and information, through procedures and techniques applied by supervisory agents with the purpose of gathering evidence for the investigation of compliance with obligations and regulations by the supervised entity;
- Optimization of user browsing experience and directing our business strategies according to their habits and preferences.
Lastly, it is worth mentioning that, according to our legislation, any acceptance, consent, or other legal act that You may perform will only be considered valid if You have the legal capacity to exercise it. Our IR Site is not intended for children and adolescents, and Alares does not allow these users to use it without authorization from their guardians.
SHARING OF PERSONAL DATA
Alares may share your data to fulfill legal obligations and to meet the requests made by You. For this purpose, there are partners who assist Alares with its administrative management, data hosting, and conducting analysis activities to offer better products and services.
Below, we inform you with which organizations we share your personal data and for what reasons:
- Partners and Third-Party Companies: To deliver our service management, such as hosting services for data storage, third-party providers that offer management services and customer service (“call centers”).
- Analysis Companies: Some information obtained from customer service, such as satisfaction survey results, may be shared with specialized companies so that we can optimize and improve our products and services. We do not seek to identify or make identifiable the data subjects, and the shared information is only that necessary for the analysis. Whenever possible, we will anonymize personal data that could identify our client.
- Social Media Profiles or Other Submissions: Accessing or registering on Alares’ platforms and social media causes the sharing of certain personal data with Facebook and Instagram. Thus, when using these platforms, some of your personal data will be shared with the companies responsible for these platforms and social networks. We do not control the policies and practices of any other third-party website or service.
- Marketing Companies: For the sending of communications and offers, for this process, we will use an appropriate legal basis and respect your privacy and your right to object to the processing of this data for this purpose.
- Regulatory and Supervisory Bodies: We may share your personal data with regulatory bodies, funding agencies, or supervisory bodies to respond to judicial processes, comply with laws or regulations, when requested in case of legal obligation. Also, for the regular exercise of our rights in judicial and administrative proceedings, if necessary or complying with a court order, or meeting the request of a competent authority or supervisory body.
- Telecommunications Service Providers: For consumer complaints handling and compliance with norms and obligations applicable to the telecommunications segment, such as for procedures related to number portability between fixed-line or mobile telephony service providers, including through MVNO technology. Among the companies, we can mention:
i. ABR Telecom (Administrative Entity of Number Portability in Brazil);
ii. Telecall – Telexperts Telecommunications (MVNO Provider);
iii. TIP – TIP TECNOLOGIA LTDA (Voice SCM Provider);
iv. DATORA – DATORA TELECOMUNICACOES LTDA (Voice SCM Provider); and
v. Other Fixed Switched Telephone Service (STFC) operators present in the portability environment. - To safeguard and protect the rights of Alares and its employees: To comply with legal obligations, court orders, or protect the rights, property, or safety of our organization and our employees.
INTERNATIONAL TRANSFER OF PERSONAL DATA
Alares is headquartered in Brazil but may conduct international transfer of personal data through operators, especially for the storage of this information. The transfer of such data will only occur through partners and/or suppliers who adhere to adequate criteria for the protection of personal data.
Furthermore, users accessing or using our services located outside the country consent to the transfer of their personal data to Brazil and other countries, within the limits of legality of the Brazilian legal system.
By using our products or services or providing personal data to Us, You agree to the processing and international transfer of your personal data in cases where it is essential for the provision of services and execution of your contract with us.
AUTOMATED DECISION-MAKING, SEGMENTATION, AND PROFILING<>/h2>
The IR Site features restricted functionalities in terms of personal data processing, as it is designed to meet the needs of investors with minimal privacy impact. Thus, the treatments carried out in this environment, as it currently stands, do not involve automated decision-making, segmentation, or profiling of users.
If this context were to change and your personal data were to be subjected to an automated decision-making process, You will have the right to request a review of the outcome by submitting a request to our Data Protection Officer.
THE DATA SUBJECT’S RIGHTS
The rights and guarantees of the data subject, as established in the General Data Protection Law (Law No. 13,709/18), are as follows:
| Direito | Explicação |
| Right of access | You can request information and receive a copy of your personal data when processed by Us. |
| Right of correction | You can request the correction and/or alteration of your personal data if they are inaccurate. |
| Right of deletion | You can request the deletion of your personal data from our platforms. The request may be fulfilled when the data are no longer necessary or if our business relationship has ended. However, your data will be retained to fulfill our legal obligations, for the regular exercise of our rights, or if there is a valid reason for their retention. In case of deletion request, the minimum storage period for user information of internet applications, as determined by Brazilian legislation, will be respected. |
| Right to object to data processing | You can request the deletion of your personal data from our platforms. The request may be fulfilled when the data are no longer necessary or if our business relationship has ended. However, your data will be retained to fulfill our legal obligations, for the regular exercise of our rights, or if there is a valid reason for their retention. In case of deletion request, the minimum storage period for user information of internet applications, as determined by Brazilian legislation, will be respected. |
| Right to object to data processing | You have the right to contest how Alares companies are treating your personal data. |
| Right to request blocking or deletion | If there is no legal justification for us to continue processing your data, You may request the deletion, anonymization, or blocking of the information. |
| Sharing | You can request information about the public and private entities with which your personal data is shared. |
| Right to restrict processing | You can fully or partially object to the processing of your personal data. |
| Right to review automated decision | You can request a review of decisions that affect your interests and have been made based on automated processing operations of personal data. |
| Right to explanation of the logic behind data collection | You have the right to obtain information about the possibility and consequences of not providing your consent for a specific data processing operation. |
| Right to revoke consent | You have the right to revoke your consent; however, this means that the processing carried out with your personal data before the revocation was unlawful. It is worth noting that revoking your consent may make it impossible to contract or access products and/or services marketed by Alares companies, or prevent access to features of certain products and/or services contracted by You. Whenever You request the revocation of your consent, we will communicate to You the consequences of this request. |
| Right to data portability | You can also request the transfer of your personal data to another service or product provider. |
When You make a request to us, we will ask You to provide information to confirm your identity. This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. If You have any questions, are interested in discussing any issue related to your data, or have a request, feel free to contact our Data Protection Officer.
RETENTION OF PERSONAL DATA
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected them, except in situations where we have to retain them to comply with legal, regulatory, tax, contractual, accountability obligations or to safeguard or regularly exercise our rights.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use, the purposes of processing, whether we can achieve those purposes through other means, and applicable legal requirements.
SECURITY OF YOUR DATA BY ALARES
We at Alares have implemented a series of security measures to protect the personal data we receive.
We follow market best practices to protect the personal data sent to us, both during transmission and while in our possession. We also review our collection, storage, and processing practices, including physical security measures.
Thus, the personal data collected by the systems operated by us are protected in order to continuously enhance the security and reliability of our services. In turn, Alares companies have the following security measures as protocol:
- Authorize access only to pre-established individuals to the location where the collected information is stored;
- Store the collected information on their Pages on their own servers or servers contracted by them;
- Use standard market methods to encrypt the collected data;
- Have protection against unauthorized access to their systems, such as information systems with authentication and restricted access, anonymized databases (where possible), and use of information security solutions such as firewalls, antivirus, antispam, intrusion detection and prevention systems (IDS/IPS), and web filters.
- Those who access the information commit to maintaining confidentiality. Breach of confidentiality may result in civil liability, and the responsible party may be held accountable under Brazilian law.
Although we make the best efforts to preserve your privacy and protect your personal data, no data transmission is entirely secure and is always susceptible to information security incidents. In the remote event of incidents of this nature, Alares will ensure the adoption of all appropriate measures to remedy the consequences of the event, always ensuring due transparency to the data subject.
Therefore, we kindly ask for your help in maintaining a secure environment for everyone by keeping all usernames and passwords confidential, using passwords that are difficult to clone, and adopting good security practices regarding your account and your data.
If you identify or become aware of anything compromising the security of your data, please contact us via email at: dpo@alaresinternet.com.br.
GET IN TOUCH WITH US
If you wish to obtain information, clarify doubts, make requests, or provide suggestions regarding the processing of personal data carried out by Alares, you can contact our Privacy department at the following contact address: dpo@alaresinternet.com.br.
COOKIES POLICY
WHAT IS COOKIES?
A cookie is a small file that is installed on your device when you visit a digital environment. This file enables the automated collection of information in certain situations, aiming to fulfill various purposes. Therefore, many cookies are essential to maintain the proper and secure functioning of the website, as well as to enable the offering of products and services on the website, which may or may not be personalized for you.
Cookies can be installed by the server of the website you visit or by partners of that website. The server of a website can only use the cookies that it installed itself and does not have access to other information found on your computer or mobile device. Cookies are stored in the browser folder on your device
WHAT ARE COOKIES USED FOR?
The use of cookies is common on any website nowadays, and their use does not harm the devices (computers, smartphones, tablets, etc.) on which they are stored.
- Cookies allow our website to remember information about your visit, your preferred language, your location, the recurrence of your sessions, and other variables that we consider relevant to make your experience much more interactive.
- Cookies are used to enhance your experience, both in terms of performance and usability, as the content provided is tailored to your needs and expectations.
- Cookies can also be used to compile anonymous and aggregated statistics that allow us to understand how users use and interact with our website, as well as to improve its structure and content. Since they are anonymous statistics, we cannot identify you personally through this data.
COOKIES CATEGORIES
Cookies generally facilitate interaction between you and the website, making it faster and easier to navigate between different parts of a site. Some of these cookies are necessary because without them, the site would be unable to function properly. Others are not necessary but may be convenient for you, as they can, for example, remember your username and language preferences. This means you won’t have to enter the same information every time you visit a particular website.
The categories for defining cookies are diverse and can stem from different perspectives. In this document, we will present the categories that are most frequently used on the internet. It is worth noting that the same cookie can be included in more than one category. Below are the cookie categories defined according to the National Data Protection Authority – ANPD:
I. MANAGER RESPONSIBILITY
- First-party cookies: These are cookies used by the site or application you are visiting. First-party cookies cannot be used to track activity on a site other than the original site where they were placed. These types of cookies may include information such as login credentials, items in the shopping cart, or your preferred language.
- Third-party cookies: These are cookies created by a website different from the one you are visiting. They are functionalities from other sites that are incorporated into a page you are accessing, such as displaying ads.
II. NECESSITY
- Necessary cookies: Essential for the operation of the web page or for the provision of our services.
- Non-necessary cookies: Do not fall under the definition of necessary cookies and disabling them does not prevent the operation of the site or application or the use of our services. Examples of non-necessary cookies include those used to track preferences, measure page performance, as well as display ads or other embedded content.
III. PURPOSE
- Analytical or performance cookies: Enable the collection of data about how you use the site, which pages you visit most frequently, the occurrence of errors, and/or information about the site or application’s performance itself.
- Functionality cookies: Used to provide basic services and can remember your preferences, such as username, region, or language.
- Advertising cookies: Used to collect information for the purpose of displaying personalized ads to you based on your browsing habits.
IV. INFORMATION RETENTION PERIOD
- Session or temporary cookies: Designed to collect and store information while you access a website. This type of cookie is discarded after you close the browser used. We may store information that is relevant only for providing the service requested by you or for a specific temporary purpose, such as saving the list of products or services you wish to purchase in a shopping website.
- Persistent cookies: Data collected through these cookies is stored and can be accessed and processed for a period defined by us.
WHAT TYPES OF COOKIES DO WE USE?
We aim to transparently explain how, when, and why we use cookies. Therefore, we employ this feature for the purposes outlined below:
| Cookies Types | Name | Purpose | Storage duration |
| Performance Cookies | _ga | Provided by Google Analytics (tag present in GTM) | 2 years |
| _gat | 1 minute | ||
| _gid | 24 hours | ||
| _utma | 2 years from creation/update | ||
| _utmc | End of browser session | ||
| _utmz | 6 months from creation/update | ||
| _trf.src | Store the reference of the user’s visit origin to the website. | 1 year | |
| rdtrk | Store the list of all pages that the visitor accessed within your domain, even before conversion (only for accounts with access to Lead Tracking). | 1 year | |
| Advertising Cookies | 1P_JAR | Store access information and personalize ads. | 1 month |
| AID | Store user activities on Google across different devices, including for advertising purposes. | 1,5 year | |
| Third Party Cookies | APISID | Used by Google to store user preferences. | 2 years |
| DV | Build a user interest profile and display Google ads in a relevant and personalized manner. | minutes | |
| HSID | Used by Google to store user preferences. | 2 years | |
| NID | Remember your preferences and other information (preferred language, number of search results, activation of Google SafeSearch filter). | 6 months | |
| OTZ | Traffic information more geared towards Google Analytics. | 1 month | |
| SAPISID | Used by Google to store user preferences. | 2 years | |
| SEARCH_SAMESITE | Build a user interest profile and display Google ads in a relevant and personalized manner. | 6 months | |
| SID | Used by Google to store user preferences. | 2 years | |
| SIDCC | Security cookie to protect user data against unauthorized access. | 1 year | |
| SSID | Security cookie to protect user data against unauthorized access. | 2 years | |
| _Secure-1PAPISID | Building user interest profiles and displaying Google ads in a relevant and personalized manner. | 2 years | |
| _Secure-1PSID | Building user interest profiles and displaying Google ads in a relevant and personalized manner. | 2 years | |
| _Secure-1PSID | Building user interest profiles and displaying Google ads in a relevant and personalized manner. | 2 years | |
| _Secure-3PAPISID | Building user interest profiles and displaying Google ads in a relevant and personalized manner. | 2 years | |
| _Secure-3PSID | Building user interest profiles and displaying Google ads in a relevant and personalized manner. | 2 years | |
| _Secure-3PSIDCC | Building user interest profiles and displaying Google ads in a relevant and personalized manner. | 2 years | |
| Funcionality Cookies | citycode | Building user interest profiles and displaying Google ads in a relevant and personalized manner. | 1 day |
| citycode | Store and manage the city chosen by the user. | 1 day | |
| moove_gdpr_popup | This cookie is used to save your cookie setting preferences. | 1 dia | |
| moove_gdpr_popup | This cookie is used to save your cookie setting preferences. | 1 day |
When accessing our website, you consent to the use of necessary cookies for the operation of our site and may authorize or refuse the use of unnecessary cookies, in accordance with this Policy. If you do not agree to the use of cookies, you may:
- Adjust your browser settings to not allow the use of unnecessary cookies; or
- Not access our website. Please note that disabling the use of cookies may impact your experience while browsing our website.
IS IT POSSIBLE TO CONTROL OR DELETE COOKIES?
Most internet browsers are set to automatically accept cookies, but there are various ways to manage cookies. You can change settings to block the use of cookies or alert you when a cookie is being sent to your device, for example. It’s important to inform you that by disabling cookies, you may not be able to visit certain areas of a page or may not receive personalized information when visiting a page on the Alares website. If you use different devices to access our website (computer, smartphone, tablet, etc.), you should ensure that each browser on different devices is adjusted to meet your cookie preferences.
You can modify your browser to disable cookies. This is very easy to do. Please note: if you disable cookies, your username and password will no longer be stored on any site. Below are step-by-step instructions for:
FIREFOX:
- Open Firefox.
- At the top of the Firefox window, click the “Firefox” button, then select “Options.”
- Select the “Privacy” panel.
- Set “Firefox will:” to “Use custom settings for history.”
- Uncheck the option “Accept cookies from sites” to disable cookies.
- Click “OK” to close the Options window.
INTERNET EXPLORER:
- Open Internet Explorer.
- Click the “Tools” button and click “Internet Options.”
- Click the “Privacy” tab, then click “Settings,” move the control up to block all cookies, and click “OK.”
GOOGLE CHROME:
- Open Google Chrome.
- Click the wrench icon.
- Select “Settings.”
- Near the bottom of the page, click “Show advanced settings.”
- In the “Privacy” section, click “Content settings.”
- To disable cookies, select “Block sites from setting any data.”
SAFARI:
- Choose “Preferences” from the toolbar and click “Privacy” (You can find the toolbar that looks like a gear, above and to the right in the Safari window.)
- In the “Block cookies” section, you can specify whether and when Safari should accept cookies from sites.
- To see an explanation of the options, click the help button (question mark).
- If you want to see which sites store cookies on your computer, click details.
CONTACT
For any questions or doubts regarding this cookie policy, you can contact us via email at: dpo@alaresinternet.com.br or if you prefer to learn more about us and how we protect your data, please refer to our Privacy Policy.