PRIVACY POLICY

AUTOMAB APP

Thanks for choosing Automab! This Privacy Policy is an integral part of the Terms of Use (“Terms”) that govern access to and use of the “Automab” platform (“Platform” or “Service”), a management and automation platform residential, made available and maintained by AUTOMAB TECNOLOGIA LTDA., person private law, registered with the CNPJ under No. 25.350.227/0001-98, with headquartered at Rua Ceará, nº 743, Bairro Umuarama, in the city of Uberlândia, State of Minas Gerais, CEP 38405-315, Brazil.

When accepting the Automab App Terms of Use, you also grant your free and express for us to collect and process your personal data, and all the information necessary for your choice, about how your data are processed, are available in this Privacy Policy.

Access to Platform can be done by the Android and iOS applications (“Applications”), available on the respective App Stores (“Web Platform”). The use of such content portals, even if only to obtain applications from Platform, is subject to the rules of its respective providers, including with regard to the collection and processing of personal data by these websites and systems.

the present Privacy Policy is available for reading and consultation by the User at any time in the Applications and through the link http://www.automab.com.br/html/politica-de-privacidade_en.html.

1. Collected Data and Collection Method

Data provided by the User. To use our Service, you must create an Account on our Platform. All Personal Data provided by you for this registration will be stored by us and associated with your user account (“Account”), including, but not limited to: email address or telephone contact cell.

Data collected by Equipment. Compatible Equipment that are connected by the User on the Platform may collect personal data, in accordance with their functionalities and in accordance with its own Privacy Policy. The data collected in this way, which are entered on the Platform, will be treated in compliance with this Policy, while other data transiting exclusively by third-party equipment, networks or services shall not be Automab's responsibility, being ruled exclusively by the contracts between the User and such third parties.

Data automatically collected by the Platform. Our Service automatically collects some technical information, including but not limited to, the type of device used to access the Service, your connection IP (with date and time of access), your approximate geographic location, the unique identification number of your device (such as MAC Address or IMEI), information about your device usage Service, the software or browser used to access the Service, the operating system and its version of the device used, among others.

Cookies. Automab may also use standard technology to collect information from Users, such as cookies, in order to improve your browsing experience. However, the use of these technologies may be deactivated by the User at any time. time, according to the settings of your access device. Nonetheless, if the User implements such deactivation, we point out that part of the functions offered by the Platform may not function properly.

2. Treatment Purposes

Data necessary for the provision of the Service. The personal data collected by service will be used primarily for the provision of the Service itself. We use this data only for the purposes described in this Policy. As the Platform does not function without most of such data, its collection and treatment are founded especially on such a need.

Data needed for secondary functionality. Some data is collected and used to enable the operation of services ancillary to the Service, such as contact information used to send you information information about the Service, your Account or other relevant news. In addition Furthermore, such data can be used to enable functions that are not mandatory, which includes the specific modules related to the different types of compatible Equipment, which may or may not be connected by the User. The collection and processing of this data is based, in particular, on such need and at the request of the User.

Data collected to comply with legal obligations. We are required by law to retain some basic access log data to our Service, including, but not limited to, the IP address of the originating connection, with date and hour. Such data are kept for a minimum period of 6 months. Ocasionally, other data may also be stored to fulfill obligations cool.

Data collected for Platform improvement and technical support. We can use, for example, technical information collected from your device to facilitate support process and providing technical assistance in the event of a bug or malfunction operation of the Service. We also use the data collected, mainly, but not exclusively, those of use of the Platform and technical information from your device to improve the Platform itself, adding functionality or improving other aspects of it and its navigability.

Targeting of offers and advertising. We may also use the collected data to direct you to offers and advertisements that we think may be of your interest. Such offers and advertisements will, whenever possible, relate to with the Platform or with Automab. You can choose to prevent such communications, when they are made by direct communication and not by systems integrated, opting out of such communications.

Purposes secondary. The Company may use the data collected also for purposes secondary considerations that are not conflicting or excessive in relation to the purposes listed above, including for sale of databases to third parties, always in compliance with Brazilian legislation, based on your legitimate interest, except in cases where the User's legal rights and guarantees prevail.

User as Treatment Controller. In cases where the Platform is used by the User for monitoring and collecting data from third parties, be they family members, children, relatives, spouses, employees, collaborators, subcontractors and any other third party that interacts with the Equipment connected or frequent environments controlled or monitored by such Equipment, THE USER HIMSELF IS, FOR THIS PURPOSE, THE CONTROLLER OF THIS TREATMENT OF THIRD PARTY DATA, with Automab appearing merely as a Treatment Operator. In this case, the purposes of the treatment are defined exclusively by the User, who is responsible for its legitimacy and lawfulness, under the terms of the laws applicable, in particular those on privacy and data protection, do not Automab having interference or responsibility over such purposes for the use of the data. In particular, in this case, the User is SOLELY RESPONSIBLE by obtaining the consent of such third parties or by substantiating such treatment on other applicable legal bases.

3. Data Conservation

Supply of the Service and features. The data collected and used to enable the use of the Platform and its functionalities, including those voluntarily provided by the User, will be maintained as long as the relationship between the User and Automab exists, and without its conservation, it is not possible to make the Platform and its functionalities available.

Offers and publicity. The collected data used for promotional actions, targeting of offers and advertising will be maintained as long as the relationship between the User and Automab, or while, for media specific, the User does not opt-out to opt-out of receiving such communications.

Improvement of the Platform and technical support. The data collected to allow the improvement of the Platform and for technical support service will be maintained for the time necessary to implement or provide the specific assistance requested by the User, and may be permanently deleted or anonymized to compose aggregated database for statistical purposes.

Obligations cool. The data collected and maintained for the purpose of complying with Legal obligations by the Company will be preserved for the period indicated in the Law.

Defense of rights. Eventually certain relevant data, always considering the minimum necessary, may be stored beyond the period described above, with the purpose of defending Automab's rights by legal means or extrajudicial

Supply recording storage service. If the User makes the contract of the Video Cloud Recording service, which consists of storing recordings of security cameras connected to the Platform in cloud service, such as recordings will be kept for up to 30 (thirty) days, in accordance with the determined by the User, who may opt for shorter periods of retention, acting as Controller of such data processing.

4. Security and Confidentiality

Safety logical and organizational. Automab considers all information collected by through the Platform confidentially, guaranteeing that they will be treated and stored in accordance with the provisions of this Policy and with the adoption of the appropriate logical and organizational security measures, according to the degree of data sensitivity and the risks inherent to the activity. Such measures will follow reasonable standards of security and confidentiality using, for example, encryption, secure connections, among others.

Backup and integrity. Automab performs periodic backups of its database, in order to to ensure continuity of service in the event of a failure. Backups will be restored directly by Automab, whenever a violation is identified, unauthorized modification, or loss of data. Backups performed are not intended to restore data deleted, accidentally or not, by Users, so data restoration is not possible in these cases.

Communication and international transfers. In the event of data communication personal data to third parties, whether operators or not, or in the event of international transfers, the Company guarantees that all entities that receive such data will be bound by contractual clauses specific or data confidentiality and security agreements, with the purpose of imposing on such third parties or foreign data recipients the same security, integrity and confidentiality obligations described in this Policy. Additionally, in cases of international data transfer, the Company will make sure that such transfer takes place within the legal hypotheses acceptable for personal data protection standards to be required from the recipient of such data.

5. Communication and Shared Use

Communication to treatment operators. Automab may share the data collected through the Platform with service providers, subcontractors or others suppliers that act, under the direction of Automab, in the processing of data personal data collected through the Platform, as operators of the treatment in order to allow the correct provision of the Platform to the Users.

Communication to third parties. Automab may share the data collected through the Platform with third parties in the situations described below:

• a) With Automab's partner companies, for promotional, advertising and statistics, as indicated in this Policy;
• b) For protection of Automab's interests in any type of conflict, including lawsuits;
• c) At the case of transactions and corporate changes involving Automab, hypothesis in which the transfer of information will be necessary for the continuity of services and delivery of products;
• d) By court order or at the request of authorities administrative bodies that have legal competence for their request; or
• e) Upon request of the User, acting as a Controller of third-party data processing, carried out through the Platform.

Use shared. Automab may make the shared use of data with public entities, at their request, for projects of interest to Automab and/or public interest, and the Company undertakes to provide Users with all relevant information, as provided for in the LGPD, whenever such use shared occur.

6. International Transfers

The data personal data collected while using the Platform may be processed by ourselves or by affiliates or subcontractors. Our company is established in Brazil, but our affiliates, subcontractors or partners may be headquartered or may process data in other countries. In this case, we guarantee that affiliates and subcontractors will also be subject to the obligations of this Policy, as provided in the "Security and Confidentiality” of this document. Therefore, by agreeing to this Policy and the associated Terms of Use, you also agree that your data may be subject to international transfers to affiliates or subcontractors, and declares to be aware of all guarantees applicable to the treatment abroad, in accordance with this Privacy Policy and Terms of Use related.

7. Data Subject Rights

Rights of the Holder. The holder of the personal data collected and processed has the following rights, in accordance with the General Data Protection Act (Law No. 13.709/2018):

• a) Confirmation of the existence of the treatment;
• b) Access to data;
• c) Correction of incomplete, inaccurate or outdated data;
• d) Anonymization, blocking or deletion of unnecessary, excessive data or treated in violation of the provisions of the Law;
• e) Data portability to another service or product provider, Automab's commercial and industrial secrets are protected;
• f) Deletion of data processed with the consent of the holder, except in the cases of legal custody and others provided for by law;
• g) All relevant information, as required by law and made available in this document and in other places accessible to the User;
• h) Withdrawal of consent, when the treatment is based on it.

Shape and exercise conditions. The rights mentioned above will be guaranteed and may be exercised in the exact terms described in the General Law for the Protection of Data.

Exclusion of data. The deletion of data stored by Automab may be requested, under the conditions established by the General Data Protection Law, through the Platform tools or email automab@automab.com.br. The company declares itself committed to making the best efforts to serve all exclusion requests, when applicable, as soon as possible. Such exclusion, when it covers data necessary for the operation of the Service, it will also the Termination of the Terms of Use and the deletion of the User Account. Same in this case, Automab may keep the personal data stored, without subject them to active treatment in order to comply with their legal obligations of data guard.

8. Responsible for the Treatment

Automab as Controller. The treatment of the collected data is carried out by Automab, or by third parties under the guidance of Automab, which is responsible for the legality of the project as a whole, except in the cases mentioned in the “EXCEPTIONS OF LIABILITY” of the Terms of Use or in other cases of exemption from liability provided for in this Policy or the Terms of Use. any and all request, complaint, request for information or exercise of rights by the holder can be made by written message to the address automab@automab.com.br, containing, at a minimum, the following information and documents:

• a) Applicant's complete name
• b) RG and CPF numbers of the applicant;
• c) email address used to register on the Platform;
• d) Copy of the RG and CPF;
• e) Request description.

Ocasionally, other information or documents may be requested for the service of the request, if there is any doubt about the veracity of the information provided or about the identity of the applicant.

User as Controller. In cases where the Platform is used by the User to monitoring and collecting data from third parties, be they family members, children, relatives, spouses, employees, collaborators, subcontractors and any other third party that interacts with the connected Equipment or frequents environments controlled or monitored by such Equipment, THE USER IS, FOR THAT PURPOSE, THE CONTROLLER OF THIS THIRD-PARTY DATA PROCESSING, including Automab merely as a Treatment Operator.

9. General Provisions

Rules General Terms of Use. Applicable to this Privacy Policy are the general rules applicable to the Terms of Use, especially those relating to applicable law, choice of venue, and liability and warranty exceptions.

Modifications. Our service may change from time to time. Therefore, we can modify unilaterally this Privacy Policy at any time. Whenever there is a material change to it, you will be notified through the information contact details provided by you, which must be kept up to date on the “My Account” panel of the Service. In the notification sent, you will have access to the new text of the Privacy Policy, as well as a summary of the changes carried out. Upon such notice, by continuing to use the Service, you automatically agrees to the new terms of the Policy. If you do not agree with changes and want to cancel and delete your account, please send an email to automab@automab.com.br. The updated version of this Policy will always be available at: http://www.automab.com.br/html/politica-de-privacidade_en.html.

10. Contact

If you have questions or requests about this Privacy Policy, our practices, or about our service, please contact us at automab@automab.com.br.

Last Update: 23.04.2019