1. INTRODUCTION
This Privacy and Data Protection Policy aims to demonstrate its commitment to the protection of the privacy and personal data of its customers, partners and employees, pursuant to Federal Law No. 13.709/18 – General Data Protection Law – LGPD – which deals with the protection of personal data and its future amendments, being supervised and implemented by the public administration body responsible for complying with the LGPD in the country – Autoridade Nacional de Defesa de Dados – ANPD. This Policy also describes how and for what purpose personal information is collected and used. This Policy applies to all Holders who have their data processed, directly or indirectly, by the fog® Group and must be followed by all its employees, customers and service providers, without exception, under penalty of the application of the indicated sanctions in this Policy.

2. RIGHTS OF DATA HOLDERS
The fog® Group ensures the Personal Data Holders the following rights, in the form of the LGPD:

1. Protection and secrecy of the processed Personal Data;
2. Confirmation of the existence of processing of your Personal Data;
3. Access to your processed Personal Data;
4. Correction of any incomplete, inaccurate or out-of-date Personal Data;
5. Anonymization, blocking or deletion of Personal Data that is unnecessary, excessive or treated in breach of the provisions of the LGPD;
6. Portability of Personal Data to another service or product provider, upon express request by the Holder, in accordance with the regulations of the national authority, observing commercial and industrial secrets;
7. Elimination of Personal Data processed with the consent of the Holder, except in the event of need for maintenance by the fog® Group under the terms of this policy and art. 16, of the LGPD;
8. Information about public and private entities with which Personal Data has been shared;
9. Information about the possibility of not providing consent and the consequences of the refusal; It is
10.Revocation of consent, when this is the legal basis for the processing of Personal Data.

Any questions about the rights of the Holders may be addressed to the fog® Group, in the person of its DPO, through the contact addresses indicated in this Policy.

3. PROCESSING AND DISCLOSURE OF PERSONAL DATA
The fog® Group, its collaborators, representatives and service providers will only treat the Personal Data strictly necessary for the activities performed, being certain that all treatment must be duly communicated to the Data Holders, accompanied by:
(i) the purpose for which such Data will be processed;
(ii)the legal basis for its treatment, in the form of the LGPD;
(iii) the identification and contact information of the fog® Group, when Data Controller; It is
(iv) express reference and indication of the means of access to this Privacy and Data Protection Policy.

Grupo fog® may disclose the Personal Data processed to third parties only in the following situations and within the limits of the Law:
(v)With its collaborators/employees, when necessary to achieve the purpose of data processing;
(vi) With service providers, when necessary for the provision of related services; It is
(vii) When necessary as a result of legal obligation, determination of competent authority, or court decision.

Grupo fog® may also disclose Personal Data, as necessary, in order to defend itself against third-party claims or allegations, or for the purpose of protecting the safety and rights of its collaborators/employees, customers and/or
service providers.

If there is a need for unplanned disclosure of Personal Data to any third party, Grupo fog® will communicate such disclosure to the respective Holders, unless the communication is in any way restricted or prohibited by law or by court decision. The Personal Data processed under the terms of this Policy will be deleted within a maximum period of 6 (six) months after the end of its processing by the fog® Group, unless the legislation in force requires its conservation for a longer period.

4. CONTACT
Any doubts, questions, communications or requests related to the processing of Personal Data by the fog® Group or its Service Providers may be directed to the department through the following channels:

E-mail: [email protected]
letter addressed to “fog® branding”, at address: Rua Pe Anchieta, 2050 Sl 1907 Bigorrilho CEP 80730-000 Curitiba – PR

5. DISCLOSURE AND COMPLIANCE WITH THE PRIVACY POLICY AND PERSONAL DATA PROTECTION
This Personal Data Protection and Privacy Policy must be kept available for access and/or consultation by all Data Holders, at any time, with the exposure of information about its availability and the
Company contact information in an easily visible location on the fog® Group websites.

The Service Providers, customers and employees/employees of the fog® Group declare that they are fully aware of the terms of this Policy, and undertake to comply with it, as well as all provisions of the Law, being fully responsible for any violations of the Holders’ rights of Data.