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POLICY OF PRIVACY

Learn how Élin Duxus collects, uses, and protects your information. Our Privacy Policy guarantees full transparency and compliance with data protection regulations.

SECTION I — OF GENERAL INFORMATION

This Privacy Policy, hereinafter referred to as POLICY, contains information on the collection, use, storage, processing and protection of the personal data of users and visitors of the Élin Duxus systems, hereinafter referred to as COMPANY, and its electronic address, with the purpose of demonstrating absolute transparency on the subject and informing all interested parties about the types of data that are collected, the reasons for the collection and the way in which users can manage or delete their personal information.
This POLICY applies to all users and visitors of the COMPANY's systems and electronic addresses.
This document was prepared in accordance with the General Personal Data Protection Act (Law 13,709/18), the Internet Civil Framework (Law 12,965/14) (and EU Regulation No. 2016/6790). In addition, the document may be updated at any time by the COMPANY, and users and visitors are invited to consult this section periodically.

SECTION II — OF DATA COLLECTION

The personal data of the user and visitor are collected by the platform as follows:
• When a user and visitor accesses pages from the COMPANY's electronic address: information about interaction and access is collected by the company to ensure a better experience for the user and visitor. This data may concern the keywords used in a search, the sharing of a specific document, comments, page views, profiles, the URL where the user and visitor come from, the browser they use and their access IPs, among others that may be stored and retained;
• When the user creates an account/profile in the COMPANY's systems: information about interaction and access is collected by the company to ensure a better user experience when using the application, in addition to providing an audit trail of user actions; and
• When the user uses the COMPANY's systems support system.
Users and visitors are invited to consult the section of these third parties periodically.
For users of the COMPANY's systems, the conditions and clauses present in the contracts signed with the system contractor must be considered in addition to this POLICY.
Data collection can be carried out using a third-party tool. The following are used at the COMPANY's email addresses:
• Google Analytics.

SECTION III — OF THE DATA COLLECTED

The personal data of the user and visitor collected are as follows:
• For actions related to the company's electronic address, comments, e-mail, traffic information, access time, and other data related to access to addresses are collected.
• For actions related to the COMPANY's systems, all information is collected to audit user actions, such as IP, system changes, date and time of the modifications, in addition to registration information such as e-mail.

SECTION IV — THE USE OF DATA

The purpose of the user and visitor's personal data collected and stored is:
• For actions related to the company's electronic address: to improve the user experience, facilitate access to COMPANY information, promote improvements, assist in business and technical development, present advertisements when applicable, and promote access facilitation and information security.
• For actions related to the COMPANY's systems: provision of audit trails and access logs and actions.

SECTION V — OF THE STORAGE PERIOD

The personal data of the user and visitor are stored by the platform for the period necessary to provide the service or to fulfill the purposes set out in this document.
The data may be removed or anonymized at the user's request, except in cases where the law offers other treatment.
Furthermore, the personal data of users can only be kept after the end of their treatment in the following cases:
I - compliance with a legal or regulatory obligation;
II - study by a research body, guaranteeing, whenever possible, the anonymity of personal data;
III - transfer to a third party, provided that the data processing requirements set out in the law are respected; and
IV - exclusive use of the controller, with no access by a third party, and provided that the data is anonymized.

SECTION VI — ON DATA SECURITY

The COMPANY undertakes to apply technical and organizational measures to protect personal data from unauthorized access and from situations of destruction, loss, alteration, communication or dissemination of such data.
The stored personal data is treated confidentially, within legal limits. However, we may disclose your personal information if we are required by law to do so or in the event of a violation of terms of use.

SECTION VII — DATA SHARING

For data related to the COMPANY's electronic addresses, the sharing of user data occurs only with the third-party traffic analysis tools used by the COMPANY.
For data related to the COMPANY's systems, the auditing tools allow all collected data to be shared with the contracting company through specific permission within the systems.

SECTION VIII — THE TRANSFER OF DATA

Except for information regarding data traffic at the COMPANY's electronic addresses and at the request of a company contracting the COMPANY's systems, there is no sharing of additional data
Throughout the use of the applications, if a user or visitor is redirected to a third-party application or electronic address, they will no longer be governed by this POLICY or the COMPANY's terms of use, which will be exempt from the privacy practices of other sites, and the user and visitors are encouraged to access and read the privacy statements of these destinations.

SECTION IX — OF COOKIES OR BROWSING DATA

Cookies refer to text files sent by the platform to the user and visitor's computer and which are stored there, with information related to browsing the site. This information is related to access data such as place and time of access and is stored by the user and visitor's browser so that the COMPANY's analysts can read them later in order to customize the COMPANY's services.
The user and the visitor must indicate that they know and accept, at all the COMPANY's electronic addresses, that a system for collecting browsing data can be used through the use of cookies.
The persistent cookie remains on the user and visitor's hard drive after the browser is closed and will be used by the browser on subsequent visits to the site. Persistent cookies can be removed by following your browser's instructions. The session cookie, on the other hand, is temporary and disappears after the browser is closed. It is possible to reset your web browser to refuse all cookies, however some features of the platform may not work properly if the ability to accept cookies is disabled.
For company systems, the acceptance of cookies by users is implicit in the hiring of cookies by the employing company.

SECTION X — OF CONSENT

By using the services and providing personal information on the platform, the user is consenting to this POLICY.
The user, upon registering, declares that they know and can exercise their rights to cancel their registration, access and update their personal data, and guarantees the veracity of the information provided by them.
The user has the right to withdraw their consent at any time, so they must contact us using the contact form at the COMPANY's email address.

SECTION XI — OF THE AMENDMENTS

The COMPANY reserves the right to modify this POLICY at any time, so it is recommended that the user and visitor review it frequently.
The changes and clarifications will take effect immediately after their publication on the platform. When changes are made, users will be notified. By using the service or providing personal information after any modifications, the user and visitor demonstrate their agreement with the new rules.
Upon the merger or sale of the platform to another company, user data may be transferred to the new owners so that the services offered remain.

SECTION XII — JURISDICTION FOR CONFLICT RESOLUTION

Brazilian law will be fully applied to the resolution of disputes arising from this instrument.
Any disputes must be submitted to the court of the district where the COMPANY is headquartered.

Élin Duxus is dedicated to providing advanced risk management solutions for the financial sector. We combine innovative technology and technical expertise to deliver tools that ensure security and compliance for our clients.
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