INTRODUCTION

Alephee Privacy Policy was created to demonstrate our commitment to always treat personal data with security, privacy, and transparency. This Privacy Policy describes the personal data we collect, how it is used, stored, and shared, and your rights in relation to that data.

Aleph Solutions Informatic is part of the Aleph Solutions LLC holding company based in the USA, and this policy extends to all companies, as well as their affiliates or subsidiaries. The practices described in this Privacy Policy apply to the processing of personal data in Brazil and are subject to applicable local laws, with an emphasis on the current Law No. 13,709/2018 (General Data Protection Law or "LGPD")

INFORMATION WE COLLECT

From the beginning of the interaction with Alephee, the following information may be collected, stored, and used:

1- Data provided by the owner: a) Company data: Company name, Trade name, CNPJ, IE, Address, Neighborhood, City, State, Zip code, Website, Phone b) User data: First name, Last name, Mobile phone, Email c) Company representative data: First name, Last name, Mobile phone, Email, CPF d) Financial representative data: First name, Last name, Mobile phone, Email e) Witness data (for contract signing): First name, Last name, Mobile phone, Email, CPF f) Bank details: Bank, Branch, and Account number g) Data about the use of the platform: Includes data about the opening of a ticket, type of product or service related to your support request, contact or authentication data, and the content of your communications with us, including phone recordings and/or emails.

2- Data collected automatically. We may collect and store the following data automatically: a) Information about the devices you use to access the services, such as your IP address, operating system, geolocation information, and device identifier. b) Log data and information about your visits and services, including the referral source, duration of visit, page visits, and site navigation paths (such as date and time associated with your use, pages and files viewed, searches and other actions taken). c) Browsing data, i.e., data about how you use and interact with our services, which may include dates when you used the services and your browsing activities. We also collect information about the performance of the services, including metrics related to the delivery of emails and other communications you send through the Services. d) Data from the information contained in any communication you send us by email or through our website, including the content and metadata of the communication.

3- Data we collect from other sources. a) Information about commercial transactions made on platforms/marketplaces that are connected to Alephee for online sales operations. b) Credit information obtained from credit risk databases and/or publicly available sources, in accordance with applicable law. c) Data used for identity validation, obtained from secure and reliable sources, such as public agencies, service providers, or business partners we work with. d) We may collect data from other sources, such as public databases, data from public profiles on social networks, and credit protection entities.

4- How we use the information

1. a) Provide the contracted service.
2. b) Identify each user.
3. c) Customize our services.
4. d) Send statements, invoices, payment reminders, as well as collect your payments.
5. e) Send commercial and usability communications from Aleph Solutions.
6. f) Manage risks and detect, prevent, and/or remedy fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies, contracts, or terms of use.
7. g) Notify you of any changes to our products and services.
8. h) Reinforce our security and protection procedures, with the aim of providing a safer
9. i) Carry out internal operations, including support, problem resolution, data analysis, testing, research, and statistics.
10. j) Provide information about other services and/or products we offer, like those already contracted by you.
11. k) Evaluate or understand the effectiveness of the advertising we offer, to provide you with relevant advertising.
12. l) If necessary, to establish, exercise, and defend rights in legal, administrative, or arbitration proceedings.
13. m) Comply with legal or regulatory obligations, or as required by a judicial proceeding, by any competent law enforcement or governmental agency, or claiming competence over Alephee.
14. n) For other purposes for which we provide specific notice at the time of collection, or otherwise, as authorized or required by law.

5- Sharing Information. Protecting your privacy is very important to Alephee, therefore, we do not sell or trade information that identifies our users. Alephee may share your information with any company within our holding and its subsidiaries, including employees, executives, professional consultants, agents, suppliers, or subcontractors as necessary for the purposes described below:

a) Aleph Solutions LLC Subsidiary Companies: Aleph Solutions LLC's subsidiaries may share personal data collected from the provision of the Services with each other to operate, perform, improve, understand, personalize, support, advertise our Services,
and prevent fraud.
b) Third-party service providers: We work with third-party service providers to help us operate, perform, improve, understand, personalize, support, and advertise our Services. When we share data with external service providers, we require that they use your data in accordance with our instructions and terms or with your express consent, as appropriate. We have signed contracts that include confidentiality and data privacy policies.
c) Credit protection entities: We may share your registration data with entities dedicated to reducing credit risk and protecting businesses and individuals against fraud to validate the information provided by you.
d) Regulatory bodies, judicial or administrative authorities: We may share your personal information to provide competent authorities with all information requested in relation to the Holder and the operations carried out on the Sites. Additionally, we may share your personal data with public authorities or private entities to combat fraud and abuse in the use of the Services, to investigate alleged violations of the law or to combat any other suspicion of non-compliance with our policies and contracts.
e) Transfer of assets: If an Aleph Solutions LLC subsidiary is reorganized or sold and all or substantially all of its assets are transferred to a new owner, your personal information may be transferred to the buyer regardless of your authorization to ensure continuity of services.
f) With the customer's authorization: In other cases, not previously provided for, for the purpose of sharing personal data and information, we send a notification with information about such exchange to request the customer's consent, for a specific purpose.

6- Transfer of personal data outside the country

The information we collect may be stored, processed, and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy.

7- Interactions with Third-Party Sites

Alephee includes links to third-party websites. We do not have control or responsibility for the privacy policies and practices of third-party websites. We recommend that customers consult the respective privacy policies of such sites to properly inform themselves about the use of their information by other sites or tools.

8- How Long We Keep Information. We will store personal information only for as long as is necessary to fulfill the purpose for which it was collected, comply with legal or regulatory requirements, or during the statutory period of possible legal or contractual liabilities.

9- Individuals whose personal data is processed by Alephee can request information about their data by emailing us at soporte@alephee.com, and we will consider the request in accordance with applicable laws. Such requests may include:

• Confirmation of the existence of personal data processing.
• Access to personal data, as provided for by applicable law.
• Correction of incomplete, inaccurate, or outdated data.
• Data portability.
• Deletion of data processed based on the individual's consent or when the data is unnecessary, excessive, or processed in breach of applicable law.
• Request for information about data sharing. Please note that this Privacy Policy describes Alephee's personal data sharing activities. To receive more information about how we share your data, please contact us.
• Withdrawal of consent, when applicable. For security reasons, we can only respond to such requests with confirmation of the individual's identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the Cardholder. Please note that, as mentioned earlier, in most of the products and services we offer, Alephee acts as a data processor, in accordance with the instructions of our clients. If you are a consumer and want to exercise your rights about personal data that Alephee processes as a data processor, you should contact the client using the Services.
  
  

10- Security

The personal data processed by Alephee is protected by physical, technical, and organizational security measures to reduce the risks of loss, misuse, and unauthorized access, disclosure, and alteration, such as firewalls and data encryption, physical access controls to data centers, and access authorization controls to information.

11- Cookies and tracking technologies

We and our partners may use various technologies to automatically collect and store data about the use of the Services. These technologies include cookies, pixels, web beacons, and SDKs. We use the information collected through these technologies to optimize and personalize your browsing experience, direct advertising campaigns, develop and enforce security features and fraud prevention procedures, among other possible uses.

12- Privacy policy changes

We reserve the right to change this privacy policy at any time. In the event of any changes, clients will receive notification for review and decision on the continuation of the services provided. Continued access to Alephee will constitute acceptance of the changes.