Privacy Policy

PURPOSE AND SCOPE

We, at AGROTOOLS GESTÃO E MONITORAMENTE GEO-ESPACIAL DE RISCOS SA (“ Agrotools ” or “ we ”), a company registered with the CNPJ/ME under number 08.808.179/0001-10 and headquartered at Rua Hungria, 888, 9º Andar, Conjunto 92, Jardim Europa, São Paulo/SP, CEP 01455-905, are committed to safeguarding your privacy and protecting your personal data. We would like to explain to you a little more about how we treat personal data.

Why does Agrotools process Personal Data?

Agrotools offers digital and intelligence solutions for the agricultural and agribusiness segment. Using technology, we seek to bring distributors, industry, and financial agents closer to producers and landowners in Brazil, benefiting the entire chain, including the environment and the end consumer. In carrying out our activities, we process personal data with respect for the security, privacy, and expectations of the holder of such information.

When customers interact with us to obtain information about the territories they are related to, or even when we conduct market research on public databases about the segment, it is common for us to collect some personal data from these customers, traders and landowners in order to provide our services. Likewise, for users to interact with our website, it may be necessary to register, fill out forms and provide certain personal data, such as, for example, to browse the customer area or to clarify doubts on our contact channels.

These are just a few examples that show how our activities depend on personal data. We take compliance with laws that protect your privacy very seriously.

This Privacy Policy describes how your personal data is handled by us. If, after reading this Policy, you still have questions, feel free to contact us by sending a message to DPO@agrotools.com.br

DEFINITIONS

In order to simplify your reading, we present some useful definitions for your interpretation:

TermConcept
Privacy Policy or PolicyThis is Agrotools Privacy Policy.
Personal Data or DataIt is data relating to a natural person, which is capable of identifying them or making them identifiable within a given context. Some examples of personal data include: name, CPF, ID, address, cell phone number and email.
Treatment or TreatThese are the uses that Agrotools makes of Personal Data, including, without limitation, the following activities: collection, storage, consultation, use, sharing, classification, reproduction, processing and evaluation of this Data.
Legal BasisThese are the legal hypotheses that authorize Agrotools to Process Personal Data. Any and all Processing of Personal Data can only be considered valid if it is based on a legal basis.
Data Subject or HolderThis is the person to whom the Personal Data relates. In the context of this Policy, you may be a visitor to our website, one of our customers, traders and landowners or partners and administrators of companies related to agribusiness.
PlatformIt refers to the Agrotools digital platform, a product offered to customers and which also processes personal data of traders and landowners.
SiteIt is the Agrotools website, available at
https://agrotools.com.br/ .

ROLES AND RESPONSIBILITIES

The types of Personal Data and how Agrotools collects it depend on how you engage with us and why. For example, the Personal Data collected will be different depending on whether you are a visitor to our Website, one of our customers or a landowner.

We list below some situations in which we may process your Personal Data in the context of our activities.

Clients. In general, our clients are companies that purchase raw materials from rural producers and financial agents operating in this market. Our Platform is intended for these clients so that they can carry out risk management in their businesses, socio-environmental compliance and market intelligence. If you are a client, see below the main purposes for which we process your Data:

OriginType of Data usedTreatment Purposes
Business relationshipRegistration data. Full name, date of birth, email, ID and CPF.Routine support and service: to deal with queries, clarifications, suggestions, criticisms and improvements or reporting errors on the Platform.
Access management: to make the product available and use it, as well as to check and correct the environment.

Traders and landowners. We may access public or publicly available databases containing Personal Data of businesspeople and landowners who are related to the agricultural market or agribusiness, or receive them directly from our customers when they interact with these individuals. Our services help create value by facilitating access to public or publicly available information to ensure greater compliance in the supply chain. This Data is processed to generate intelligence for our customers and results in the preparation of analyses, reports, mappings and other documents mentioned below. If you would like more information about the sources of the data processed for these purposes, please contact us through the channels indicated in item 4.7 of this policy. We indicate below the main purposes for using this Data:

OriginType of Data usedTreatment Purposes
Public or publicly available sourcesRegistration data. Full name, ID and CPF, profession, date of birth, gender, kinship, social identification number (NIS).
Property data . Geographic coordinates, address, INCRA number, CAR number and environmental violations.
Database production and maintenance: to generate and update the geographic database of agents and territories so that risk analyses and monitoring can be carried out.
Various analyses: socio-environmental, impact, geographic or spatial compliance, multi-temporal image analyses and monitoring, as well as other internal analyses.
Land Valuation Report: for assessing land use, property value and other geographic information submitted by the client.
Market research: gathering information relevant to the market, such as land location and types of business, derived exclusively from public databases; and enriching the database.

Our customers may access other data by contracting, through our Platforms, other services and reporting options operated by Agrotools partners. These additional contracts may involve the Processing of other Personal Data, which are the responsibility of these Partners. If you have any questions regarding these Partners, please contact us through the channels indicated in item 4.7 of this Policy.

Users of our Website. If you are a visitor to our Website and want to learn more about our products and services, contact us or register for our selection processes, see how we process your Data:

OriginType of Data usedTreatment Purposes
Site Navigation ( cookies )Navigation data: data collected through cookies or device IDs , including IP, date and time of access, geographic location, browser type, duration of visit and pages visited.Access log: we have a legal obligation to store some of your information (such as your IP address, date and time of access) in order to eventually provide it to legal authorities.
Website operation: to enable essential features, such as antivirus software, website responsiveness to desktop/mobile, among other functions.
Data about the access device: model, manufacturer, operating system, telephone operator, browser type, connection type and speed.Analytics: understand browsing behavior and how the website is being used, to improve the user experience. The data collected is aggregated and, whenever possible, anonymized.
Website FormsRegistration data: name, email, subject and message.Contact Us: direct your contact to the department responsible for contacting you, as requested.
Gupy (career platform)Registration data: full name, country of origin, identification document, language and email.Work with us: you can register with Gupy or log in to your account (through this page ) to apply for one of our job opportunities.

PROCEDURES

COOKIES AND OTHER TECHNOLOGIES: WHY DOES AGROTOOLS USE THEM?

Cookies are small text files stored on your browser or device (such as a mobile phone or tablet). Cookies allow us to recognise your preferences to adapt our Website to your specific needs. It is through a cookie, for example, that we make the content of the Website adapt to the size of your screen – whether a computer or a mobile phone.

Cookies usually have an expiration date. Some cookies are automatically deleted when you close your browser (so-called session cookies), while others can be stored on your computer for a longer period of time until you manually delete them (so-called persistent cookies). Agrotools uses the following types of cookies:

  • Strictly necessary cookies, for our Site to function properly, for example authenticating logins. You cannot refuse these cookies if you want to access the Site;
  • Analytical cookies, to improve the content of the Website and your experience as a user, providing information about how it is being used. They identify, for example, how many times a particular page has been visited; and
  • Functionality cookies are used to record previously provided data, such as your login information, in order to improve the browsing experience.It is important to clarify that Agrotools is not responsible for the use of cookies by third parties. Please be aware that third-party cookies may continue to monitor your online activities even after you have left our Website, and it is recommended that you delete them manually.If you wish to remove cookies installed on your computer, you can delete them manually through the settings available in your browser, as per, for example, the instructions for Google Chrome , Mozilla Firefox , Microsoft Edge or Safari . Please note, however, that some of the Site’s features may become unavailable after deleting certain cookies.

WHO DOES AGROTOOLS SHARE YOUR PERSONAL DATA WITH?

Agrotools works in partnership with a number of other companies to facilitate its activities, offer products and provide services. Therefore, we may share your Personal Data with these partner companies of Agrotools, always seeking to preserve your privacy as much as possible and, whenever possible, in an anonymized manner. We describe here situations in which we may share Personal Data:

Our suppliers. We rely on suppliers who may Process Personal Data that we collect. We always seek to carefully evaluate our suppliers and enter into contractual obligations with them regarding the protection of Personal Data and information security, with the aim of minimizing risks for Data Subjects. These suppliers include, for example, companies responsible for hosting certain databases and issuing invoices.
Analytics. The Data stored by Agrotools may be used for statistical purposes ( analytics ), so that Agrotools can understand who are the people who visit our Website and who are customers of our products and services. This Data is pseudonymized and does not seek to identify or make identifiable the Holders of Personal Data, but only to better understand how they access the Agrotools Platform, in order to improve the provision of services and customize products more targeted to their interests.
Public Authorities. If an authority with legal competence requires Agrotools to share certain Personal Data, for example, to meet regulatory needs, we will need to share that information.
Protection of rights. In addition, we reserve the right to share any Personal Data that we believe is necessary to comply with a legal obligation, enforce our Terms of Use, or protect the rights of Agrotools, our employees, and customers.
Affiliates. If, for example, you are interested in our services, we may share your Personal Data with our Affiliates, other trusted companies or individuals to Process such information for this purpose or other legitimate interests. Such Processing is always carried out in accordance with our instructions and in compliance with our Privacy Policy and all other appropriate security and confidentiality measures.

If you have any questions regarding which companies or suppliers these are, please contact the Data Protection Officer , whose contact channels are found in item 4.7 of this Policy.

DOES AGROTOOLS TRANSFER PERSONAL DATA TO OTHER COUNTRIES?

Yes. Although Agrotools is headquartered in Brazil and its services are intended for people located in Brazil, and Brazilian laws regarding the protection of Personal Data apply, the Personal Data we collect may be transferred to other countries. This transfer occurs due to relationships with certain suppliers and business partners of Agrotools, which may be located in these locations.

If we provide any information about you to companies located in other countries, we will take appropriate measures to ensure that these companies protect your information adequately in accordance with this Privacy Policy and the parameters of Brazilian data protection legislation, which may include, for example, entering into standard contractual clauses with third parties or implementing other transfer mechanisms provided for by law to protect your data.

WHAT ARE YOUR RIGHTS AS A PERSONAL DATA SUBJECT?

Personal Data is yours and Brazilian law guarantees you a series of rights related to it. We are committed to complying with these rights and, in this section, we will explain how you can exercise them with Agrotools. Brazilian law guarantees you the following rights:

Your rightsExplanation
Treatment Confirmation and AccessYou can ask Agrotools to confirm whether your Personal Data is being processed so that, if so, you can access it, including by requesting copies of records we have about you.
CorrectionYou may request the correction of your Personal Data if it is incomplete, inaccurate or out of date.
Anonymization, blocking or deletionYou may request (a) the anonymization of your Personal Data, so that it can no longer be related to you and therefore ceases to be Personal Data; (b) the blocking of your Personal Data, temporarily suspending your ability to process it for certain purposes; and (c) the deletion of your Personal Data, in which case we must erase all your Personal Data without the possibility of reversal.
PortabilityYou may request that Agrotools provide your Personal Data in a structured and interoperable format for transfer to a third party, provided that such transfer does not violate Agrotools’ business secrets.
Information about sharingYou have the right to know which public and private entities Agrotools shares your Personal Data with. We will keep, in item 4.2 of this Policy, an indication of our relationships with third parties that may involve the sharing of Personal Data. In any case, if you have questions or want more details, you have the right to request this information from us. Depending on the case, we may limit the information provided to you if its disclosure may violate Agrotools’ intellectual property or trade secret.
Information about the possibility of not consentingYou have the right to receive clear and complete information about the possibility and consequences of not providing consent, when requested by Agrotools. Your consent, when necessary, must be free and informed. Therefore, whenever we ask for your consent, you will be free to withhold it – in such cases, it is possible that some services cannot be provided.
Revocation of consentIf you have consented to any purpose of Processing your Personal Data, you may always choose to revoke your consent. However, this will not affect the lawfulness of any Processing carried out prior to the revocation. If you withdraw your consent, we may be unable to provide you with certain services, but we will notify you when this occurs.
OppositionThe law authorizes the Processing of Personal Data even without your consent. In these situations, we will only process your Personal Data if we have legitimate reasons to do so. If you do not agree with any purpose for the Processing of your Personal Data, you may object, requesting its interruption.
Review of automated decisionsYou can request a review of decisions taken based on automated processing carried out by us, where applicable, as long as Agrotools’ business secrets are respected.

To exercise any of the above rights, we recommend that the Holder contact us via the email mentioned in item 4.7 of this Policy.

For your safety, whenever you submit a request to exercise your rights, Agrotools may request some additional information to verify your identity , seeking to prevent fraud. We do this to ensure the safety and privacy of everyone, aiming to prevent the disclosure of Personal Data to unauthorized persons.

Agrotools may request additional information to verify your identity and prevent fraud. We do this to ensure the security and privacy of everyone, and to prevent the disclosure of Personal Data to unauthorized persons.

In some cases, Agrotools may have legitimate reasons for failing to comply with a request to exercise rights . These situations include, for example, cases where a disclosure of specific information could violate trade secrets of Agrotools or third parties, as well as cases where requests for anonymization, blocking or deletion of data cannot be fulfilled due to the existence of an obligation on Agrotools’ part to retain data, whether to comply with legal or regulatory obligations or to enable the defense of the rights of Agrotools or third parties, including in disputes of any nature.

Furthermore, some requests may not be responded to immediately , but Agrotools is committed to responding to all requests within a reasonable timeframe and always in compliance with applicable legislation.

HOW LONG WILL PERSONAL DATA BE STORED?

Agrotools has a Personal Data retention policy in line with applicable law. Personal Data is stored only for as long as necessary to fulfill the purposes for which it was collected, unless there is any other reason for its retention, such as compliance with any legal, regulatory, contractual obligations, among others, provided that they are based on a Legal Basis.

We always perform a technical analysis to determine the appropriate retention period for each type of Personal Data collected, considering its nature, need for collection and purpose for which it will be processed. For example, Data related to IP and date and time of access to the Website are kept for at least 6 (six) months.

WHAT ARE OUR RESPONSIBILITIES AND HOW DO WE PROTECT YOUR PERSONAL DATA?

Our responsibility is to take care of your Personal Data and use it only for the purposes described in this Policy . And, to protect your Personal Data, we adopt security practices appropriate to our activities, using encryption techniques, record management, access controls and other available information security measures.

We work to protect your privacy and your Personal Data, but unfortunately we cannot guarantee complete security . Unauthorized access or use by third parties to your account, hardware or software failures that are not under Agrotools’ control, and other external factors may compromise the security of your Personal Data. Therefore, your actions are essential to maintaining a safe environment for everyone. You can help us by adopting good security practices in relation to your account and your Data (such as, for example, not sharing your password with third parties), and if you identify or become aware of anything that compromises the security of your Data, please contact us using the contact information provided below.

Links to third-party websites . Our Websites may display advertisements, links or other content that direct you to third-party websites, usually companies with which we are related or have partnerships. Agrotools cannot control and is not responsible for the privacy practices and content of these third parties. We suggest that you read the privacy notices and policies of these companies, as they may differ from our policies.

HOW TO TALK ABOUT PERSONAL DATA WITH AGROTOOLS?

If you wish to exercise any right, or understand that your data has been used in a manner incompatible with this Policy, or if you have any questions, comments or suggestions related to this Policy, please contact us. We have a Data Protection Officer (DPO ) who is available at the following contact addresses:

Responsible Party (DPO) : Baptista Luz Lawyers

Responsible : Fernando Bousso

Address for correspondence : Rua Hungria, 888, 9th Floor, Suite 92, Jardim Europa, São Paulo/SP, ZIP Code 01455-905

Contact email : DPO@agrotools.com.br

CHANGES TO PRIVACY POLICY

As we are always seeking to improve our products and services, this Privacy Policy may be updated to reflect the improvements made. Therefore, we recommend that you visit this page periodically to be aware of any changes made. If any relevant changes are made, we will notify you.

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