External Privacy Notice

1 – WHAT DATA WE USE

Novatrade respects your privacy. Any information you provide to us will be treated with the highest level of care and security and will only be used within the limits set forth in this document.

In the process of “contact” the site, to communicate with Novatrade, we collect your name, telephone number, and e-mail, for example. This information is necessary for us to identify you and make the expected contact possible.

Novatrade may collect information actively entered by you, “User”, at the time of contact, and information collected automatically when using our services, such as, for example, data linked to your connection, such as: IP address, date , time, device used, consumption data and usage habits, among other information.

Thus, there is the treatment of two types of personal data: (a) those provided by the user; and (b) those collected automatically by Novatrade.

(a) Personal data provided by the user: Novatrade collects all personal data actively entered or forwarded by the user when filling out the contact form on the portal. They are: Purpose, Name, Telephone, Company, Position, how did you know Novatrade, E-mail and the message sent.

Regardless of which personal data is actively provided by the user, we will only use those effectively relevant and necessary to achieve the stated purposes;

(b) Data collected automatically: Novatrade also collects a series of information automatically, such as: characteristics of the access device, browser, IP (with date and time), IP origin. For such collection, some standard technologies are used, such as cookies, pixel tags, beacons and local shared objects, which are used with the purpose of improving your browsing experience on our services, according to your habits and your preferences.

Novatrade, as a rule, for the general purposes set forth herein, does not process personal data defined as sensitive by the LGPD, understood as those related to: racial or ethnic origin, religious conviction, political opinion, union or organization affiliation of a religious, philosophical or political nature, data referring to health or sexual life, genetic or biometric data.

2 – HOW WE USE THE DATA

Novatrade uses all information collected by filling out registration, entered by the user on this website or automatically for the following purposes: (i) to fulfill the purpose for which you provided the information; (ii) expand our marketing offers and promote products and services that may be of interest to you; (iii) further customize and improve our products and services; and (iv) preventing fraud and minimizing financial losses, among other cases that may go unconventional.

User information may be used in other services provided directly by Novatrade, respecting the purposes exposed to the User and the authorization previously granted, when there is a legal requirement to collect it.

Novatrade, in some cases, may also process personal data when necessary for the fulfillment of legal or regulatory obligations or regular exercise of rights in judicial, administrative or arbitration proceedings. In addition, Novatrade may also process personal data based on its legitimate interest, always within the limits of its expectations, and never at the expense of its fundamental interests, rights and freedoms.

Additionally, the information collected may, upon prior collection of your authorization, be used for advertising purposes, such as sending communications, news that are of interest to you.

If you feel uncomfortable and no longer wish to receive any advertising newsletters from Novatrade, you can, at any time, contact us by expressing your opposition here: info@novatradebrasil.com.

3 – WITH WHOM WE WILL SHARE THE DATA

Novatrade is committed to presenting new solutions that increase the value of its products and services to offer its Users special marketing opportunities, such as incentives and promotions.

For this purpose, your information may be shared with some of our partner companies, in Brazil and abroad.

For the operationalization of its services, Novatrade uses the partnership with several companies located in Brazil and abroad. Below we present some hypotheses that the sharing of your information may occur: i.

With partner companies and suppliers, in the development and provision of services aimed at the User; ii. With authorities, government entities or other third parties, for the protection of Novatrade’s interests, in any type of conflict, including lawsuits and administrative proceedings; iii. In the case of transactions and corporate changes involving Novatrade, in which case the transfer of information will be necessary for the continuity of the services; or, iv. By court order or by request of administrative authorities that have legal competence for your request. Additionally, it is possible that some of the transfers indicated above take place outside Brazilian territory.

4 – HOW WE KEEP YOUR PERSONAL DATA SAFE

Any information provided by the User will be collected and stored in accordance with the strictest security standards.

To this end, Novatrade adopts several precautions, in compliance with the guidelines on safety standards established in applicable laws and regulations.

Novatrade only authorizes the access of specific people to the place where their personal information is stored, as long as this access is essential to the development of the intended activity; Novatrade guarantees that those agents, internal employees or external partners who process personal data must undertake to maintain the absolute confidentiality of the information accessed, as well as to adopt the best practices for handling this information, as determined in the internal policies and procedures and external;

Novatrade regularly performs backup on the Site. Site activity is checked consistently to protect the information you provide. Sophisticated protection systems are used and activity on our Site is monitored.

Access to collected information is restricted to employees and authorized persons. Those who improperly use this information, in violation of this Privacy and Information Security Policy, will be subject to applicable administrative, disciplinary and legal sanctions.

Although Novatrade uses its best efforts to preserve your privacy and protect your personal data, no transmission of information is completely secure, so Novatrade cannot fully guarantee that all information it receives and/or sends is not target of unauthorized access perpetrated through methods designed to obtain information improperly, such as technical failures, viruses or invasions of the Site’s database.

Anyway, in the remote hypothesis of incidents of this nature, Novatrade guarantees the full effort to remedy the consequences of the event. Novatrade is not responsible for any other website that can be accessed from ours, and there is no link between such addresses.

5 – RETENTION OF COLLECTED INFORMATION

In order to protect the privacy of its users, the personal data processed by Novatrade will be deleted when they are no longer useful for the purposes for which they were collected, or when the user requests their deletion, unless the maintenance of the data is expressly authorized by law or applicable regulation.

User information may be kept for compliance with legal or regulatory obligations, transfer to a third party – provided that the data processing requirements are respected – and exclusive use by Novatrade, including for the exercise of their rights in judicial or administrative proceedings.

6 – USERS’ RIGHTS

In compliance with the applicable regulations, with regard to the processing of personal data, Novatrade respects and guarantees the User the possibility of submitting requests based on the following rights: Confirmation of the existence of processing;

Access to data;

Correction of incomplete, inaccurate or outdated data;

Anonymization, blocking or deletion of unnecessary, excessive or processed 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 Novatrade has shared your 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 above rights may be exercised directly by the User, from the management of registration/contact information, while another part will depend on sending a request to our Data Protection Officer, for further evaluation and adoption of the necessary measures. The channel for receiving requests of this nature will be available through the following email: info@novatradebrasil.com.

Any request to exclude essential information for the management of your registration with Novatrade will imply the termination of your contractual relationship, with the consequent cancellation of the services then provided.

7 – LEGISLATION AND JURISDICTION

This Policy will be interpreted according to Brazilian legislation, in the Portuguese language, especially the LGPD.

8 – CHANGES TO OUR PRIVACY POLICY

Novatrade reserves the right, at its sole discretion, to modify, alter, add or remove portions of this policy at any time. We recommend that you check this policy every time you browse the Novatrade Website.

This Privacy Policy was last changed and posted on our websites on October 25, 2021.

9 – REVIEW AND MAINTENANCE

This International Standard shall be revised annually or when a significant change occurs in the organization.