Agrotools Geospatial management and monitoring of AS Risks

PRIVACY POLICY AND DATA PROTECTION

SUMMARY

PRIVACY POLICY.3
BASIC CONCEPTS: WHAT DO I NEED TO KNOW TO UNDERSTAND THIS POLICY?. 3
HOW DOES AGROTOOLS COLLECT YOUR PERSONAL DATA AND WHAT KIND OF DATA ARE COLLECTED?. 4
COOKIES AND OTHER TECHNOLOGIES: WHY DOES AGROTOOLS USE THEM?. 6
WITH WHOM DOES AGROTOOLS SHARE YOUR PERSONAL INFORMATION?. 7
DOES AGROTOOLS SEND PERSONAL DATA TO OTHER COUNTRIES?. 7
WHAT ARE YOUR RIGHTS AS PERSONAL DATA HOLDER?. 8
FOR HOW LONG WILL PERSONAL DATA BE STORED?. 9
WHAT ARE OUR RESPONSIBILITIES AND HOW DO WE PROTECT YOUR PERSONAL DATA?. 10
HOW TO TALK ABOUT PERSONAL DATA WITH AGROTOOLS?. 10
PRIVACY POLICY CHANGES. 10
Validity of Document Management. 11

1. PRIVACY POLICY

WE FROM AGROTOOLS MANAGEMENT AND GEOSPATIAL RISK MONITORING INC. (“Agrotools” or “us”), registered company in the National Registry of Legal Entities under the number 08.808.179/0001-10 and headquartered at 223 Fidencio Ramos street – set 161, Vila Olimpia, ZIP CODE: 04551-010, São Paulo/SP, we are committed in protect your privacy and protect your personal data. We want to explain to you a little bit more of how we deal with personal data.

Why does Agrotools deal with Personal Data?

Agrotools offers digital and intelligent solutions to the agricultural and agribusiness sector. From technology, we seek to approach distributors, industry, financial agents of producers and landowners in Brazil, favoring the whole chain, including the environment and the final customer. As our activities develop, we process personal data with the deserved respect to security, privacy and expectations of the holder of this information.

When clients interact with us to obtain information about territories in which they relate, or even when we conduct market research on public bases about segments, it is common to collect some personal data of these clients, merchants and landowners for the provision of our services. The same way, for users to interact with our website, it may be necessary to perform registrations, fill forms and provide certain personal data, for example, to browse the client area or to clarify doubts in our contact channels.

These are a few examples that show how our activities depend on personal data. We are very serious about the law enforcement that protects your privacy.

This Privacy Policy describes how your personal data is treated by us. If, after this policy reading, you still have some doubts, feel free to contact us by sending us a message to ajuda@agrotools.com.br

2. BASIC CONCEPTS: WHAT DO I NEED TO KNOW TO UNDERSTAND THIS POLICY?

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

Term	Concept
Privacy Policy or Policy	This is Agrotools Privacy Policy.
Personal Data or Data	Is the data related to an individual, that is able to identify it or make it identifiable inside the determined context. They may be cited as some examples of personal data: name, registered number, ID, address, cell phone and email.
Treatment or Treat	The personal data use made by Agrotools, including, with no limitation, the following activities: collect, storage, consult, use, sharing, classification, reproduction, processing and evaluation of these data.
Legal Base	Are the legal hypotheses that authorize Agrotools to treat personal data. Any and all personal data treatment can only be considered valid if they have foundation on a legal base.
Data Holder or Holder	This is the person to whom the Personal Data relates. In the context of this Policy, this may be a visitor to our website, one of our customers, tradespeople, landowners or partners and company administrators related to agribusiness.
Platform	Refers to Agrotools digital platform, offered product to the clients and that also treats personal data from tradespeople and landowners.
Website	It is the Agrotools website, available at https://agrotools.com.br/.

3. HOW DOES AGROTOOLS COLLECT YOUR PERSONAL DATA AND WHAT KIND OF DATA IS COLLECTED?

The types of Personal Data and the way Agrotools collects them, depend on how you relate with us and why. For example,the Personal Data collected are different in case you are a visitor in our Website, one of our clients or a landowner.

We listed below some situations that we can treat your personal data in the context of our activities.

Clients. In general, our clients are companies that buy feedstock from rural producers and active financial agents in this market. Our platform is destined to these clients so the risk management can be accomplished in your business, socio-environmental compliance and market intelligence. If you are a client, check below the main purposes for which we treat your data.

Origin

Type of used Data

Treatment Purpose

Business Relationship

Registration Dat.

Full name, date of birth, e-mail, ID, registered number.

Support and routine service: for the handling of doubts, clarification, suggestions, critics and improvements or platform crash reporting.

Access management: for the availability and use of the product, as well as for verification and environment correction.

· Traders and landowners. We can access public bases or publicly available including Personal Data from managers and landowners that have relations with the agricultural market or with the agribusiness or receive them straight from our clients when they relate with these people. Our services help to create value, facilitating the access to public information or publicly available to ensure greater conformity in the supply chain. These Data are treated to generate intelligence to our clients and result in the elaboration of analysis reports, mapping and other documents mentioned below. In case you want more information about the data sources treated to these purposes, contact us through the channels indicated on item 9 of this policy.

We indicate below the main purposes for which these data are used:

Origin	Type of used Data
Public sources or public available	Registration Data.Full name, ID and registered number, profession, date of birth, gender, kinkship, social identification number (NIS). Data about priority. Geographic coordinates, address, Incra number, number CAR and environmental infractions.	Production and maintenance of database: to generate and update the geographic database of agents and territories in order to accomplish risk analysis and attendance.
		Various analyses: analysis and socio-environmental monitoring, of impact, of geographic or spatial compliance, multitemporal image, as well as other internal analyses.
		Land valuation report: to value the use of soil, property value and other geographic information sent by the client.
		Market research: collection of relevant information to the market, such as land location and type of business, derivatives exclusively from public bases; and enrichment of databases.

Our clients may access other data by contracting, through our platforms, from other services and reporting options operated by Agrotools partners. These additional signings may involve the treatment of other personal data, that are the responsibility of these partners. In case you have any question related to these partners, contact us through the channels indicated on item 9 of this policy.

· Users of our website. If you are a visitor in our website and seeks to know more about our products and services, contact us or sign up for our selection processes, check how we treat your Data:

Origin	Type of used Data	Treatment purposes
Website Navigation (cookies)	Navigation data: collected data through cookies or IDs device, including IP, access date and time, geographic localization, browser type, duration of visit and visited pages. Access device data: model, manufacturer, operational system, telephone operator, browser type, connection type and speed.	Access log: we have the legal duty to store some of your information (such as your IP, access date and time) to eventually provide them to judicial authorities. Website operation:
Website forms	Registration data: name, e-mail, subject matter and massage.	Talk to us: direct your contact to the responsible sector for getting in contact, as requested.
Gupy (career platform)	Registration data: full name, country of origin, identification document, language and e-mail.	Work with us: you can register on Gupy or log into your account (through this page) to apply for one of our job opportunities.

4. COOKIES AND OTHER TECHNOLOGIES: WHY DOES AGROTOOLS USE THEM?

Cookies are small text files stored in your browser or device (such as cell phone or tablet). Cookies allow us to recognize your preferences to adapt our website to your specific needs. It is through a cookie, for example, we make the content of the website adapt to the size of your screen – can be on a computer or cell phone.

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

· strictly necessary cookies, so our website can work correctly, authenticating logins, for example. It is not possible to refuse these cookies if you want to access the website;

· analysis cookies, to improve the content of the website and its experience as a user, providing information about how it is being used. Identify, for example, how many times the page was visited.

· functionality cookies serve to record the data previously provided, for example, your login information, in order to improve the navigation experience.

It is important to clarify that Agrotools is not responsible if the use of cookies is made by third parties. Be aware, because the cookies from third parties may eventually continue to monitor your activities online even after you have left our site, being recommended that you delete them manually. In case you want to remove the cookies installed on your computer, you can eliminate them manually through the configurations available in your browser, according, for example Google Chrome, Mozilla Firefox, Microsoft Edge ou Safari. Notice, however, that some of the website functionalities may become unavailable after the exclusion of certain cookies.

5. WHO DOES AGROTOOLS SHARE YOUR PERSONAL DATA WITH?

Agrotools work in partnership with a huge number of other companies to enable your activities, offering products and providing services. That way, we can share your Personal Data with these companies in partnership with Agrotools, always searching to preserve as much as possible your privacy and, whenever possible, anonymously. We describe situations where we can share Personal Data:

Our providers. We count on the help of providers that can treat the Personal Data we collect. We always search carefully to evaluate our providers and sign with them contractual obligations to protect Personal Data and information security, with the aim to minimize risks for Data subjects. Among these providers are, for example, the companies responsible for the hosting of certain databases and issuance of invoices.

Analytics. The Data stored by Agrotools may be used for statistical purposes (analytics) so Agrotools can understand who are the people who visit our website and are clients of our products and services. These Data are pseudonymized and don’t seek to identify or make identifiable the holders of Personal Data, but only to understand better how is your access on the Agrotools platform, in order to improve the provision of service and customize more directed products to your interests.

Public Authorities. If an authority with legal competence demands Agrotools to share certain Personal Data, for example, service and regulatory needs, we will need to share this information.

Rights protection. Besides that, we reserve the right to share any Personal Data we believe are necessary to accomplish a legal obligation, apply our terms of use or, still, protect the Agrotools rights, our contributors and clients.

Affiliates. In case, for example, you are interested in our services, we can share your Personal Data with our Affiliates, other companies or reliable people to treat such information to this finality or other legitimate interests. This treatment is always accomplished according to our instructions and in conformity with our Privacy Policy and all other adequate security and confidentiality measures.

In case you have any questions in relation to which are these companies or providers, contact the person in charge (Data Protection Officer), whose contact channels are found on item 9 of this Policy.

6. DOES AGROTOOLS TRANSFER PERSONAL DATA TO OTHER COUNTRIES?

Yes. Although Agrotools is based in Brazil and their services are destined to people located in Brazil, applying Brazilian laws related to the Personal Data protection, the Personal Data we collect can be transferred to other countries. This transfer happens because of the relation with certain providers and Agrotools business partners that may be located in these locations.

These transfers involve some companies that demonstrate to be in conformity or in process of conformity with the applicable laws, and keep a compliance level similar or even more strict than was foreseen in applicable Brazilian legislation.

7. WHAT ARE YOUR RIGHTS AS PERSONAL DATA HOLDER?

The Personal Data are yours and the Brazilian law guarantees you a series of rights related to them. We are committed to the accomplishment of these rights and, this section, are going to explain how you can exercise them with Agrotools. The Brazilian law assure the following rights:

Your rights	Explanation
Confirmation of Treatment and Access	You can request Agrotools for confirmation about the existence of your Personal data treatment so, in a positive case, you can access them, including by requesting copies of records we have about you.
Correction	You can request the correction of Personal Data in case they are incomplete, inaccurate and outdated.
Anonymization, block or elimination	You can request an anonymization of your Personal Data, in a way they can’t be related to you anymore and, therefore, stop being Personal Data; (b) blocking of your Personal Data, suspending temporally your possibility of treating them to certain purposes; and (c) the elimination of your Personal Data, in which case we must erase all your Personal Data with no possibility of reversal.
Portability	You can request Agrotools to supply your Personal Data in a structured and interoperable format aiming your transfer to a third party, as long as this transfer does not violate Agrotools secret business.
Information about the sharing	You have the right to know what are the private and public entities in which Agrotools accomplish shared use of your Personal Data. We will keep, on item 4 of this Policy, a recommendation from our relationship with third parties that might involve Personal Data sharing. In all cases, if you have doubts or want more details, you have the right to request this information. Depending on the case, we can limit the information provided to you in case your divulgation violates the intellectual property or Agrotools business secret.
Information about the possibility of not consenting	You have the right to receive clear and complete information about the possibility and the consequences for not consenting, when it is requested by Agrotools. Your consenting, when necessary, must be free and informed. Therefore, every time we ask your consent, you will be free to deny it – in these cases, it is possible that some services can not be provided.
Revocation of consent	In case you have consented some finality of your Personal Data treatment, you can always choose to revoke your consenting. However, this won’t affect the legality of any treatment previously accomplished to the revocation. If you take away your consent, it is possible we are unable to provide you certain services, but we will warn you when it happens.
Opposition	The law authorizes the treatment of Personal Data even without your consent. In these situations, we only treat your personal Data if we have legitimate reasons for doing so. In case you don’t agree with some finality of your Personal Data treatment, you can introduce opposition, by requesting its interruption.
Automated decision review	You can request the review of the decisions made based on automated treatments accomplished by us, when applicable, as long as respecting Agrotools business secrets.

To accomplish the exercise of any right above, we recommend that the holder get in contact with us by e-mail mentioned on item 9 of this Policy.

For your safety, everytime you show a request to exercise your rights, Agrotools can request some additional information for the purpose of proving your identity, seeking to prevent fraud. We do this to assure the safety and privacy of all, aiming a non- disclosure of Personal Data to not authorized people.

In some cases, Agrotools may have legitimate reasons to stop attending to a request of exercise rights. These situations include, for example, cases where a disclosure of specific information could violate Agrotools business secret or third parties, as well as cases where anonymization, blocking or data elimination requests can’t be attended because of the existence of obligation that Agrotools have to holding data, whether to accomplish legal obligation, regulatory or to enable the defense of Agrotools rights or third parties, including disputes of any kind.

Still, some requests may not be answered immediately, but Agrotools commits itself in answering all requests in a reasonable deadline and always in compliance with applicable law..

8. FOR HOW LONG THE PERSONAL DATA WILL BE STORED?

Agrotools have a Personal Data retention policy aligned to the applicable law. Personal Data are stored only for as long as necessary to accomplish the purposes which they were collected for, unless there is any other reason for its maintenance such as, compliance of any legal obligation, regulatory, contractual, among others, as long as founded on a legal basis. Of course, there is always your right to request the data deletion, according to the previous item.

We Always do a technical analysis to determine the appropriate retention period suitable for any kind of collected Personal Data, considering its nature, collection and purpose needed for which it will be treated. For example, the Data related to IP and date and time of website access are kept for, at least, 6 (six) months.

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

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

We work to protect your privacy and your Personal data, but unfortunately we can’t ensure complete security. Entry or use unauthorized of third parties in your account, hardware or software failures that are not under Agrotools control and other external factors may compromise the security of your Personal Data. That is why your interaction is primordial to maintaining a safe environment for all. You can help us adopt good security practices regarding your account and your Data (such as, do not share your password with third parties), and in case you identify or take notice of something that compromises the safety of your Data, please contact us through the contact information indicated below.

Links to third parties websites. Our Websites may display ads, links or any content that directs you to third parties websites, usually companies which we are related to or maintain partnerships. Agrotools can’t control nor be responsible for the privacy practices and the content of these third parties. We suggest you read the warnings and privacy policy of these companies, once they may differ from our policies.

10. HOW TO TALK ABOUT PERSONAL DATA WITH AGROTOOLS?

If you want to exercise some right, or understand that your data has been used in an incompatible way with this Policy, or, even, if you still have doubts, comments or suggestions related to this Policy, contact us. We have someone in charge (Data Protection Officer – DPO) who is available at the following contact addresses:

In charge (DPO): André Marques

Mailing Address: 811, Paraibuna St, Zip Code 12245 -020, Jd. São Dimas, São José dos Campos/SP.

Contact email: DPO@agrotools.com.br

11. PRIVACY POLICY CHANGES

As we are always trying to improve our products and services, this Privacy Policy may go through updates to reflect the improvements made. This way, we recommend a periodic visit to this page so you can have the knowledge about affected modifications. If relevant changes are made, we will communicate with you.

Version history: V1.0

12. Validity of Document Management

The document is valid from 10/01/2021

The owner of this document is the Information Security Management System, that must verify the need to update the document at least once a year. The document must be approved by the CIO.

CIO

Rafael Gomes