Privacy Policy

Last updated on: January 1, 2025

AZZAS 2154 S.A. (“AZZAS 2154”), headquartered at Rua Fernandes Tourinho No. 147, Rooms 1301 to 1304, Belo Horizonte, Minas Gerais, Brazil, ZIP Code 30112-000, registered under CNPJ/MF No. 16.590.234/0001-76, respects your privacy and adopts the best practices to protect your personal data.

This Privacy Policy ("Policy") aims to explain to you, the data subject, how AZZAS 2154 handles the personal data it accesses, what your rights as a data subject are, and how you can exercise them.

The following brands are part of AZZAS 2154: Arezzo, Schutz, Anacapri, Alexandre Birman, Alme, Vans, AR&CO (Reserva, Reserva Mini, Oficina, Reserva Ink, Reserva Go, Reversa and Simples), TROC, ZZ Mall, Carol Bassi, Vicenza, Animale, A Brand, Cris Barros, Fábula, Hering, Dzarm, Off Premium, Animale Oro, Foxton, Farm, Farmrio, Maria Filó, and NV. For more details on how each of these brands handles your personal data, please visit their respective Privacy Policies.

Our responsibility is to take care of your personal data and use it for the purposes described herein. If, after reading, you still have questions, feel free to contact us through the channels indicated in this Policy.

BASIC CONCEPTS – WHAT DO YOU NEED TO KNOW TO UNDERSTAND THIS POLICY?

To make this Policy clearer, some expressions in singular or plural will have the following meanings:

Personal Data or Data: Data related to a natural person that can identify or make the person identifiable within a given context. For example: name, identification document number, address, mobile phone, and email.

Processing: The uses that AZZAS 2154 makes of personal data, including, but not limited to, collection, storage, consultation, sharing, classification, and evaluation of such data.

Data Subject: The person to whom the personal data relates. In the context of this Policy, it can be you, a customer, franchisee, or any other person interacting with AZZAS 2154.

Website: The website of one of the brands under AZZAS 2154.

App: Mobile applications of AZZAS 2154 brands available for download on app stores.

INTERNATIONAL COMPLIANCE AND GENERAL DATA PROTECTION PRINCIPLES

AZZAS 2154 adopts the highest standards of personal data protection, ensuring compliance with major international data protection regulations. These regulations require that personal data processing activities be conducted in accordance with fundamental principles such as transparency, minimization, and security.

At AZZAS 2154, these principles guide all our operations, ensuring that the personal data of our customers, employees, franchisees, and other stakeholders are processed lawfully, fairly, and transparently, with stringent measures in place to guarantee the integrity and confidentiality of such information.

Our Policy is designed to be applied uniformly across all countries in which we operate, ensuring that the same principles are respected regardless of location. The Policy covers our general practices and commitments but also includes specific Annexes for regions or countries with additional legal requirements.

These Annexes, appended at the end of the Policy, ensure that all requirements are met while maintaining a consistent global approach to data protection.

For more details, please see the annexes at the end of this policy for each region or country:

Turkey

European Economic Area, Switzerland, and the United Kingdom

United States

Australia

Argentina

Colombia

Ecuador

Peru

Uruguay

Chile

Japan

United Arab Emirates

Panama

FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA?

The types of data we collect depend on how you interact with us and the brand you are interested in. We collect and use some of your personal data when, for example, you visit, create, or access your account, make a purchase in a physical store, or express interest in becoming one of our franchisees.

Below, you can find some examples of the data collected and the purposes for which they are used. Depending on your relationship and interaction with us, different data may be collected for different purposes.

Source	Types of Data Collected	Purpose
Customers
Browsing on the website	Browsing data: data collected via cookies or device IDs, including IP, date and time of access, geographic location, browser type, visit duration, and pages visited.	Access logs: We have a legal obligation to store some of your information (such as your IP, date, and time of access) to potentially provide it to authorities.
Browsing on the website	Browsing data: data collected through cookies or device IDs, including IP address, date and time of access, geographic location, browser type, visit duration, and pages visited. Data about the access device: model, manufacturer, operating system, telecom operator, browser type, connection speed.	Security: We use this data to monitor items stored in your shopping cart, prevent fraudulent activities, and improve website security. Analytics: The data may be used to understand your browsing behavior and how the website is used, improving your user experience. Collected data is used in an aggregated and anonymized form whenever possible. Advertising: The data may be used to display online advertisements for products that may interest you based on your browsing data.
Data you provide in website forms	Full name, identification document number, email, date of birth, phone, address.	Registration: When you fill out the registration form, we use your data to register you in the AZZAS 2154 database. Communications and advertising: We may use such data to send communications and advertisements via email, phone, messaging apps, mail, or direct mail.
	Full name, email, phone.	Transactional communication: We may use the data to send transactional communications about your purchase, such as payment confirmation or delivery tracking.
	Full name, email.	Newsletter: If you sign up, we will use your email to send you our latest releases, news, and promotions.
	Full name, email, phone, ZIP code, geolocation.	Availability notification: When a product is unavailable on the website and you choose to be notified when it is back in stock, we will use your data to inform you accordingly. Your phone number will only be used if you prefer to be contacted this way, and your ZIP code or geolocation if you wish to check whether a nearby store has the product in stock.
Registration in physical stores	Full name, ID number, email, date of birth, phone, address.	Registration: Before you make a purchase in our physical stores, we may request this data to register you, offer better services, and streamline future purchases.
Payment for products	Full name, email, phone, ID number, and banking data (card number, cardholder's name, expiration date, and CVV).	Payment processing: We will use this data to process your purchase payment. The credit card numbers provided will be recorded directly in the card issuer's database, meaning we do not access this information. If you choose to save your card for future purchases, the provided data will be stored in a payment gateway, a partner company that meets appropriate security standards.
Delivery of products	Full name, phone, address, ID number.	Delivery: We use this data to send the purchased products to the registered address when you select this delivery option.
Request for exchange or return	Full name, email, phone, ID number, address, order number.	Exchange and return: If you request an exchange or return of a product, we will use this data to process your request.
Customer support (chat, email, phone, WhatsApp, social media, etc.)	Full name, email, phone, ID number, address, date of birth, order number, as well as complaints, suggestions, or questions submitted.	Contact and support: If you contact us via the website chat, email, phone, social media, or third-party platforms, we will use the indicated data to address your inquiry.
Loyalty programs	Full name, email, phone, ID number, date of birth, purchase history.	Cashback: If applicable, we may use the data to return part of the purchase value as a bonus for you to use in a future purchase of the respective brand. Loyalty program: We may use the data to provide benefits, introduce new products, and offer exclusive deals.
Gift card	Full name, email, phone, ID number, address.	Vale-presente: caso aplicável, Gift card: If applicable, we may use the data if you want to gift someone with a gift card from one of our brands or to process the redemption of a gift card you may receive.
Physical store monitoring	IImages captured by security cameras.	Monitoring and security: We use the images to monitor and ensure security in our physical stores.
Surveys	Full name, email, opinion.	Surveys: We may use the data to conduct opinion surveys to understand our customer base, improve our products, services, and customer service.
Social media communication	Name, social media account.	Communication: We may use the data for actions aimed at increasing the visibility of our brands, such as through posts or reposts of photos in which one of our brands is mentioned.
Franchisees and Resellers
Preliminary evaluation of franchisees	Full name, email, brand of interest, capital range, ZIP code, age, profession.	Evaluation: If you want to become one of our franchisees, you can express your interest by submitting some data, which will be analyzed to evaluate your profile initially and contact you. Additional data may be processed later depending on the evaluation results.
Approval and communication with resellers	Full name, email, phone, ZIP code, store information.	Approval: The data may be processed to allow you to become a reseller of one of our brands, if applicable. Communication: The data may be processed for us to send product invoices, as well as evaluation and satisfaction surveys related to the brands.
Influencers
Communication with influencers	Full name, ID number, address, email, phone, social media profile.	Contact: The data may be used to establish direct contact for partnerships, sending catalogs, and other materials. Relationship: The data may be used to send products and gift cards from the brands.
Store creation on our platforms	Full name, email, phone, social media profile.	Registration: If you want to partner with us and sell our products on our platforms, some data may be requested to analyze your registration for store creation. Additionally, your contact data may be used to send messages with updates and new information.
Applicant
Data you provide to us in forms on the website	Name, email, and phone.	Offer job opportunities and information.

COOKIES

Cookies are small files that may be installed and collect information about your browser or device. They allow us to understand how and when the website was visited, as well as how many people access it. Cookies can be useful, for example, to adapt the website to fit your screen, better understand your preferences, and offer you products through personalized campaigns and content.

Depending on the applicable legislation in your region, we may use cookies for specific purposes as indicated below:

Essential Cookies: These are cookies strictly necessary to provide our products and services and to ensure our website functions properly, guaranteeing secure navigation, the correct sizing of website content, and compliance with our legal obligations.

Advertising Cookies: These cookies are used to target content and advertisements according to your profile and preferences. They help you see more relevant and interesting ads during your browsing experience.

Statistical Cookies: These provide information about your browsing behavior and how the website is being used. The data collected is aggregated, and our goal is to better understand our audience to offer more interesting content, services, and products to website visitors.

If you want to know which cookies are installed on your device in general or wish to delete or restrict them, use your browser's settings. You will find more detailed instructions by clicking the links below. For information about other browsers, visit the developer’s website.

Please note that if you block the use of cookies, we cannot guarantee the proper functioning of all website applications, and you may not be able to access certain products and services. Additionally, some features and pages may not function as intended.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

To offer our products and services in the best possible way, we rely on the support of other companies in our operations. Therefore, in some cases, we need to share data with third parties, as described below:

AZZAS 2154 Group Brands: Your data may be shared among the brands and companies within the AZZAS 2154 group, which comply with this Policy. This sharing is primarily done to analyze data and understand your profile, enabling us to provide personalized and tailored experiences, send brand content that aligns with you, support development activities for new products, and other purposes.

Suppliers and Partners: We rely on the assistance of suppliers and partners who may process personal data. The information is shared solely for the purposes of the services provided. We always seek to evaluate our suppliers and partners and establish contractual obligations with them to protect personal data and minimize risks for data subjects. These suppliers and partners include, for example, advertising agencies, logistics companies, payment gateways, data hosting servers, and companies that assist us in managing our websites and apps.

Public Authorities: Your data may be shared with public authorities to comply with current legislation. If a judge or an authority with legal competence requires us to share certain personal data for an investigation, for instance, we are obligated to comply. We oppose any abuse of authority and will always defend the privacy and protection of data subjects when we deem an order abusive.

Social Media: Our websites may allow you to register using third-party mechanisms, such as your social media profile. Thus, some data may be shared with these third parties to grant you access. In these cases, it is essential that you review the specific data protection practices of these third parties.

Rights Protection: We reserve the right to share any personal data we deem necessary to comply with a legal obligation or to protect our rights, employees, clients, and third parties.

Other Countries: We may transfer your data to other countries, such as for storage purposes on servers located abroad. We establish robust contractual obligations with the third parties receiving this data to protect personal data and ensure the privacy of data subjects.

INTERNATIONAL DATA TRANSFERS

AZZAS 2154, in compliance with major international data protection regulations, adopts strict measures to ensure the security of personal data transferred internationally. We recognize the importance of protecting personal data in all jurisdictions where we operate and, therefore, implement specific safeguards as required by each applicable legislation.

HOW LONG ARE YOUR PERSONAL DATA STORED?

AZZAS 2154 follows internal rules for retaining and disposing of personal data, including guidelines for determining the appropriate retention period for each type of personal data collected, taking into account its nature, the necessity for collection, and the purpose for which it will be processed.

Personal data is stored only for as long as necessary to fulfill the purposes for which it was collected, unless there is another reason for its retention, such as the need to comply with legal, regulatory, contractual, or other obligations.

HOW DO WE PROTECT PERSONAL DATA?

AZZAS 2154 is committed to safeguarding your personal data and using it for lawful purposes as described in this Policy. To ensure your privacy and protect your personal data, we adopt security practices that align with industry standards, including encryption techniques, access controls, monitoring of suspicious activities, and other information security systems.

We work diligently to preserve your privacy and protect your personal data. However, we cannot guarantee total security. Unauthorized third-party access to your account, hardware or software failures beyond AZZAS 2154's control, and other factors may compromise the security of your personal data. Your active role is critical in maintaining a safe environment for everyone. You can help by adopting good security practices for your account and data, as outlined below:

We recommend that you always stay vigilant to protect your information by avoiding the use of simple or obvious passwords and by not sharing them with others. When using the site on public devices, it is essential to ensure your session is logged out. Additionally, it is very important to always use original software and keep it updated to avoid the risk of breaches.

AZZAS 2154 is not responsible for purchases made outside official channels or for issues caused by disruptions in your network connection. The prerequisite for making a purchase on our websites and apps is having a successful internet connection.

If you identify or suspect anything that compromises the security of your data, please contact us immediately.

WHAT ARE YOUR RIGHTS AS A PERSONAL DATA SUBJECT?

You have a range of rights concerning your personal data, which may vary according to the applicable legislation in your location. We recommend that you read the Annexes of this Policy to understand the specifics of these rights.

In general, these rights include:

Confirmation, Access, and Portability: This allows you to verify whether we process your personal data and, if so, request a copy of the personal data we hold about you.

Correction: This allows you to request the correction of your incomplete, inaccurate, or outdated personal data.

Anonymization, Blocking, or Deletion: This allows you to request that we (a) anonymize your data; (b) block your data, temporarily suspending the ability to process it; and (c) delete your data.

Information About Sharing: You have the right to know which public and private entities we share your data with.

Information About the Option Not to Consent: You have the right to receive clear and complete information about the option and consequences of not providing consent, if it is requested.

Withdrawal of Consent: You have the right to withdraw your consent regarding processing activities based on your consent. However, this will not affect the legality of any processing conducted before the withdrawal. If you withdraw your consent, we may not be able to provide certain communications or services to you, but we will inform you when this occurs.

Objection: The applicable law may authorize the processing of personal data without your consent. If you disagree with such processing, you may object to it in certain cases.s.

Privacy Portal. You can exercise the rights detailed above through the Privacy Portal (https://www.somagrupo.com.br/conheca-a-soma/privacidade/).

Account Deletion. You can delete your account in any of our apps or websites at any time. To do this, contact us at privacy@farmrio.com.

CONTACT

If you have any questions, comments, or requests regarding your personal data, please contact our Data Protection Officer (DPO):

Data Protection Officer (DPO): Baptista Luz Advogados
Responsible Person: Fernando Bousso
Mailing Address: Rua Ramos Batista 444, 2nd Floor, Vila Olímpia, São Paulo/SP, Brazil, ZIP Code 04552-020

Email: privacidade@somagrupo.com.br

CHANGES TO THE PRIVACY POLICY

As we are always seeking to improve our products and services, this Policy may undergo updates. Therefore, we recommend that you periodically visit this page to stay informed about any changes. If significant modifications occur, we will notify you through the contact channels we have on record, in compliance with the requirements of the applicable legislation.

ANNEX - TURKEY

Last updated on: January 1, 2025

The following provisions apply to data subjects located in Turkey and must be read in conjunction with our Privacy Policy.

When operating in Turkey, AZZAZ 2154 complies with local regulations, including but not limited to the Personal Data Protection Law No. 6698 (Kişisel Verilerin Korunması Kanunu or KVKK).

FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

We use your data for the purposes described in Section 3 of our Privacy Policy. We process your personal data only when we have a valid legal basis, such as:

Performance of a contract: To fulfill a contract with you or as necessary for the performance of a contract, for example, to process purchase orders, make deliveries, provide customer support related to purchased products, and manage product returns and exchanges.

Compliance with legal obligations: To meet the requirements of applicable laws, both locally and globally.

Consent: With your prior and informed consent, in specific situations that are properly disclosed to you.

Legitimate interests: To meet our legitimate interests, provided such processing does not violate your rights and freedoms. Specifically, we may process your personal data to:

Protect you, us, or third parties from threats (such as security and fraud prevention);

Manage and conduct our business operations, including quality control, consolidated reporting, and customer service;

Understand and improve our business or our relationships with customers in general.

INTERNATIONAL DATA TRANSFERS

As specified in Section 6 of the Privacy Policy, we may perform international transfers of personal data. In such cases, we will conduct international data transfers in compliance with the KVKK. To ensure security, we only transfer data to countries with adequate protection levels, with the data subject's consent, or through protection agreements.

WHAT ARE YOUR RIGHTS?

In addition to the rights provided in Section 9 of the Privacy Policy, local law grants specific rights regarding personal data, including:

Right to object to automated decisions: You have the right to contest outcomes derived solely from automated data processing if these outcomes may negatively impact you.

Right to compensation for damages: If the processing of your personal data has caused harm, you have the right to request compensation. You also have the right to file a complaint with the local data protection authority.

You can exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - EUROPEAN ECONOMIC AREA, SWITZERLAND, AND THE UNITED KINGDOM

Last updated on: January 1, 2025

The following provisions apply to individuals located in the European Economic Area (EU member countries, Liechtenstein, Norway, or Iceland), the United Kingdom, and Switzerland and should be read in conjunction with our Privacy Policy.

When operating in these regions, AZZAZ 2154 is subject to local laws, including but not limited to the following:

General Data Protection Regulation (GDPR);

UK Data Protection Act, in combination with the UK GDPR;

Swiss Federal Data Protection Act (Bundesgesetz über den Datenschutz).

FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

We use your data for the purposes described in Section 3 of our Privacy Policy. We process your personal data only when we have a valid legal basis, such as:

Contract performance: to fulfill a contract with you or as necessary for the execution of a contract, for example, processing purchase orders, making deliveries, providing customer support related to purchased products, and managing product returns and exchanges.

Compliance with legal obligations: to meet the requirements of applicable laws that apply to us.

Consent: with your prior and informed consent, in specific situations.

Legitimate interests: to pursue our legitimate interests, provided that such processing does not override your rights and freedoms. In particular, we may process your personal data to:

Protect you, us, or third parties against threats (such as security and fraud prevention);

Manage and conduct our business operations, including quality control, consolidated reporting, and customer service;

Understand and improve our business or our relationships with customers in general.

INTERNATIONAL DATA TRANSFERS

As specified in Section 6 of our Privacy Policy, due to the nature of our operations, we may engage in international transfers of personal data. In such cases, we will take commercially reasonable measures to protect these data, including entering into Standard Contractual Clauses approved by the European Commission.

AUTOMATED DECISION-MAKING AND PROFILE CREATION

We use automated tools for profile creation and analysis for product development and business intelligence purposes. These analyses help us understand and improve our products, as well as better meet the needs of our customers and consumers. We also apply these tools for security and fraud prevention purposes.

We will not make automated decisions that significantly affect you, except in the following cases: when the decision is essential for fulfilling a contract with you; when we have your explicit consent; or when applicable law requires the use of this technology.

WHAT ARE YOUR RIGHTS?

In addition to the rights provided in Section 9 of our Privacy Policy, local law guarantees specific rights regarding personal data, including:

Right to restrict processing: You have the right to temporarily limit the use of your data under certain conditions.

Right to data portability: You can transfer your personal data to another controller in a structured, machine-readable format.

Right not to be subject to automated decisions: You have the right to avoid automated decisions that may significantly affect you.

Right to information: You have the right to receive clear and accessible information about how your personal data is processed.

You also have the right to lodge a complaint with the local data protection authority.

You can exercise your rights through the contact channels provided in the Privacy Policy.

ANNEX - UNITED STATES

Last updated on: January 1, 2025

The following provisions apply to residents of the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana. These provisions should be read in conjunction with the Privacy Policy.

WHAT ARE THE SOURCES OF PERSONAL DATA WE COLLECT?

We collect the categories of personal data mentioned in item 3 of the Privacy Policy, both directly and indirectly, whenever you interact with our platforms. Directly, you provide us with your personal information when you fill out and submit any form available on this site. Indirectly, we collect data automatically as you navigate the platforms, such as information about your online behavior and the use of our platform features.

Additionally, we may obtain your personal information from third parties with whom we work, either in relation to the services we provide or the functioning of the site and our other interaction platforms with you.

WHAT ARE YOUR RIGHTS?

In addition to the rights provided in item 9 of the Privacy Policy, local law grants specific rights concerning personal data.

In particular, to the extent permitted by applicable law, you have the following rights:

Rights for users residing in California:

Right to opt-out of the sharing of your personal data for behavioral advertising.

Right to request the limitation or disclosure of your personal data only to what is necessary to perform the services or provide the goods, as reasonably expected by an average consumer. Please note that certain exceptions described in the law may apply, such as when the collection and processing of data are necessary to verify or maintain the quality or security of our service.

Right to opt-out of the sale of your personal data, if applicable. Please note that we do not engage in any activities involving the sale of personal data.

Rights for users residing in Virginia, Colorado, Connecticut, Texas, Oregon, and Montana:

Right to opt-out of the processing of your personal data for targeted advertising or profiling for decisions that produce legal or similarly significant effects on you.

Right to freely give, deny, or withdraw your consent for the processing of your personal data.

Please note that certain exceptions provided by law may apply, including but not limited to situations where the collection and processing of your personal data are necessary to provide a product or service specifically requested by you.

Rights for users residing in Utah:

Right to opt-out of the use of your personal data for targeted advertising; and

Right to opt-out of the use of your personal data..

You can exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - AUSTRALIA

Last updated on: January 1, 2025

The following provisions apply to individuals located in Australia and should be read in conjunction with our Privacy Policy.

By operating in Australia, AZZAZ 2154 is bound by local legislation, including, but not limited to, the Privacy Act 1988 (Australian Privacy Principles or APPs).

DIRECT MARKETING

We will not use or disclose your personal information for direct marketing purposes, except in the following situations:

(a) if you have consented to receiving marketing materials;

(b) if there is a reasonable expectation that we will use your personal data for this purpose; or

(c) if we believe that you may be interested in the marketing material and that it would be impractical to obtain your prior consent.

In any of these cases, we will ensure that our direct marketing communications include a clear option for you to easily opt-out of receiving future messages of this type.

WHAT ARE YOUR RIGHTS?

In addition to the rights provided in item 9 of the Privacy Policy, local law grants specific rights regarding personal data, including:

Right to know the recipients of data transfers: You may request information about third parties, both domestic and international, to whom your personal data has been transferred.

Right to object to automated decisions: You have the right to challenge results obtained solely through automated data processing if these results could have negative impacts on you.

You can exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - ARGENTINA

Last updated on: January 1, 2025

The following provisions apply to individuals located in Argentina and must be read in conjunction with our Privacy Policy.

When operating in Argentina, AZZAZ 2154 complies with local regulations, including, but not limited to, the Personal Data Protection Law (Ley de Protección de Datos Personales - Law No. 25,326).

FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

We process your data for the purposes described in Section 3 of our Privacy Policy. We handle your personal data only when we have a valid legal basis, such as:

Contract performance: to fulfill a contract with you or as necessary for the execution of a contract, for example, to process purchase orders, carry out deliveries, provide customer support related to purchased products, and manage product returns and exchanges.

Compliance with legal obligations: to meet the requirements of applicable laws.

Consent: with your prior and explicit consent.

Legitimate interests: to pursue our legitimate interests or those of third parties.

WHAT ARE YOUR RIGHTS?

In addition to the rights outlined in Section 9 of the Privacy Policy, local law grants specific rights concerning personal data, including:

Right of access: You have the right to request information about the personal data we hold about you. This includes the right to know whether we are processing your data and which personal data is being collected. You may request a copy of your personal data in our possession at no additional cost once per year.

Right not to be subjected to automated decisions: You have the right not to be subjected to automated decisions based solely on the processing of your personal data, such as profiling or decisions that affect your legal or contractual conditions.

If you believe your rights are not being respected, you may contact the National Authority for the Protection of Personal Data (DNPDP) to file a complaint. Additionally, you have the right to seek remedies through the judicial system if you disagree with decisions made by the competent authority or our company.

You can exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - COLOMBIA

Last updated on: January 1, 2025

The following provisions apply to individuals located in Colombia and must be read in conjunction with our Privacy Policy.

When operating in Colombia, AZZAZ 2154 is subject to local regulations, including but not limited to Law No. 1581 of 2012.

WHAT ARE YOUR RIGHTS?

In addition to the rights provided in item 9 of the Privacy Policy, local law grants specific rights concerning personal data, including:

Right to Object: You have the right to object to the processing of your personal data in certain situations, particularly when the processing is carried out for direct marketing purposes or when the data is processed without an appropriate legal basis. In any case where you disagree with the use of your data, you may exercise this right and request that we refrain from using your information.

If you believe that your rights have not been respected, you can file a complaint directly with the Superintendency of Industry and Commerce (SIC), the authority responsible for data protection in Colombia, or seek a judicial resolution.

You may exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - ECUADOR

Last updated on: January 1, 2025

The following provisions apply to data subjects located in Ecuador and should be read in conjunction with our Privacy Policy.

When operating in Ecuador, AZZAZ 2154 complies with local legislation, including but not limited to the Organic Law on the Protection of Personal Data.

WHAT ARE YOUR RIGHTS?

In addition to the rights outlined in item 9 of the Privacy Policy, local law ensures specific rights regarding personal data, including:

Right to deletion: You may request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected or when the processing is no longer legitimate.

Right to data portability: If desired, you have the right to transfer your personal data to another organization or provider in a structured, commonly used format, allowing greater control over your information. This applies when the processing of your data is based on consent or a contract and is technically feasible.

Right to restriction of processing: In certain situations, you may limit the processing of your personal data. This may occur, for example, if you contest the accuracy of your data or if you object to the processing while awaiting an assessment of its legality.

Right not to be subject to automated decisions: You have the right not to be subject to automated decisions that could significantly affect your rights, such as those based on automated profiling or that result in direct legal impacts. If you are affected by this type of decision, you have the right to challenge it.

If you believe your rights are being violated, you have the right to file a complaint with Ecuador’s data protection authority, the National Council for the Protection of Personal Data (CNPD).

You may exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - PERU

Last updated on: January 1, 2025

The following provisions apply to individuals located in Peru and should be read in conjunction with our Privacy Policy.

When operating in Peru, AZZAZ 2154 is subject to local legislation, including, but not limited to, the Peruvian Personal Data Protection Law (Law No. 29,733).

WHAT ARE YOUR RIGHTS?

In addition to the rights outlined in Section 9 of the Privacy Policy, local law provides specific rights regarding personal data, including:

Right of Access: You have the right to access the personal information we hold about you, including details about how your data is collected, stored, used, and shared. You may request a copy of your personal data at any time, free of charge, except for legally established exceptions.

Right to Restriction of Processing: In certain situations, you may restrict the processing of your personal data. This may occur, for example, if you contest the accuracy of your data or object to its processing, while we review the legality of the processing.

If you believe that your data protection rights are being violated or not adequately respected, you have the right to file a complaint with the Peruvian National Authority for Personal Data Protection (ANPDP).

You may exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - URUGUAY

Last updated on: January 1, 2025

The following provisions apply to individuals located in Uruguay and should be read in conjunction with our Privacy Policy.

When operating in Uruguay, AZZAZ 2154 is subject to local legislation, including but not limited to Law No. 18.331.

WHAT ARE YOUR RIGHTS?

In addition to the rights outlined in Section 9 of the Privacy Policy, local law grants specific rights regarding personal data, including:

Right to object: You have the right to object to the processing of your personal data, particularly when the processing is based on a legitimate interest that is not sufficiently relevant in relation to your rights and freedoms.

If you believe that your data protection rights have been violated, or if you consider that we are processing your personal data improperly, you have the right to file a complaint with the Regulatory and Supervisory Unit for Personal Data (URCDP), the national authority responsible for data protection in Uruguay.

You can exercise your rights through the contact channels indicated in the Privacy Policy.

ANNEX - JAPAN

Last updated on: January 1, 2025

The following provisions apply to individuals located in Japan and should be read in conjunction with our Privacy Policy.

WHAT ARE YOUR RIGHTS?

In addition to the rights outlined in Section 9 of the Privacy Policy, local law provides specific rights regarding personal data, including:

Right of Access: You have the right to access the personal data we hold about you.

Right of Rectification: You have the right to rectify any personal data that is incorrect, inaccurate, or outdated.

Right of Erasure: You may request the deletion of your personal data if it is being processed in violation of applicable law.

Right to Cease Sharing: You may request the cessation of sharing your personal data if such sharing is in violation of applicable law.

You can exercise your rights through the contact channels provided in the Privacy Policy.

ANNEX - UNITED ARAB EMIRATES

Last updated on: January 1, 2025

The following provisions apply to individuals located in the United Arab Emirates and should be read in conjunction with our Privacy Policy.

WHAT ARE YOUR RIGHTS?

Applicable legislation provides a range of rights aimed at ensuring greater control over your personal data and promoting a culture of transparency and accountability in data processing practices.

Below are the main rights guaranteed by the applicable laws:

Right to Rectification: You have the right to rectify any personal data that is incorrect, inaccurate, or outdated.

Right to Erasure or Restriction: You can request the deletion or restriction of the use of your personal data.

You can exercise your rights through the contact channels provided in the Privacy Policy.

ANNEX - PANAMA

Last updated on: January 1, 2025

The following provisions apply to data subjects located in Panama and must be read in conjunction with our Privacy Policy.

WHAT ARE YOUR RIGHTS?

Applicable laws guarantee a series of rights to ensure that you have greater control over your personal data, promoting a culture of transparency and accountability in the handling of this information.

You have the right to be informed about your ability to revoke consent at any time if you no longer wish for your data to be processed.

You may exercise your rights through the contact channels indicated in the Privacy Policy.