This Privacy Policy applies to individuals who access, sign up to or visit the VOGLER website. It also informs you how you can access and update your Personal Data and exercise your rights in relation to it.

It is important to note that this Privacy Policy is specific to the use of this website. Therefore, it does not apply to third-party websites, social networks, and/or other service providers, which you may access or be redirected to from links provided on our website.

To ensure your security, we recommend that you check the data protection regulations and guidelines of the respective providers and websites accessed.

Please note that VOGLER cannot be held liable for data provided by you to third-party websites, social networks, and/or other providers.

Data processing consists of any and all operations, digital or otherwise, carried out with personal data, which involve the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation, control, modification, communication, transfer, dissemination, or extraction of information.

Personal Data is all information that allows you to be identified. This includes, for example, your name, taxpayer identification (CPF), email, and telephone number, among others.

Sensitive Personal Data consists of personal data related to racial or ethnic origin, religious belief, political opinion, membership in a union or organization of a religious, philosophical, or political nature, data related to health or sexual life, genetic or biometric data, when linked to You.

Access – the possibility of communicating with a device, storage medium, network unit, memory, registry, file, etc., aiming to receive, provide, or delete data.

Storage – the action or result of maintaining or preserving data in a repository.

Filing – the act or effect of keeping data registered even though it has already lost its validity or after its validity has expired.

Review – act or effect of calculating the value of one or more data sets.

Classification – the way of ordering data according to certain established criterion.

Collection – gathering data for a specific purpose.

Communication – the transfer of information relevant to data action policies.

Control – the action or power to regulate, determine, or monitor actions on data.

Dissemination – the act or effect of disclosing, propagating, or multiplying data.

Distribution – the act or effect of making data available according to certain established criteria.

Deletion – the act or effect of excluding or destroying data from the repository.

Extraction – the act of copying or removing data from the repository in which it was found.

Modification – the act or effect of modifying data.

Processing – the act or effect of processing data.

Production – creation of goods and services from data processing.

Receipt – the act of receiving data at the end of a transmission.

Reproduction – copying pre-existing data obtained through any process.

Transfer – changing data from one storage area to another or to a third party.

Transmission – movement of data between two points by means of electrical, electronic, telegraphic, telephone, radioelectric devices, etc.

Use – the act or effect of using data.

If you sign up to or interact on our website, we will be responsible for deciding what actions are taken regarding your information, acting as the Controller of your personal data.

But rest assured, our conduct complies with the provisions of the LGPD and follows the purposes that we inform in this Policy, in a transparent manner.

If you are interested in any information or service offered on our website, depending on the situation, you will need to sign up in order to be identified.

Personal data may be collected in the following situations:

• When submitted by you at the time of your registration, browsing, interaction, and use of our website.
• Automatically through cookies and/or similar technologies.

5.1 See below which personal data we may collect and in each situation:

Registration Data: Full name, email, telephone number, and professional title.

Professional Data: Data submitted by you to participate in the selection process for vacancies made available through our website.

Electronic Records: Logs and Cookies.

Ombudsman Channel: We may request other data from the data subject to check suggestions, complaints, reports, and compliments made through the channel.

Communication: Full name, email, and telephone number.

Personal contact information: Other information may be requested, on our registration forms or when you sign up for our events, in order to segment your interests and direct communications.

Third-party social network information: Any information that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as Instagram or Google). We collect your third-party social network profile information (or parts thereof) whenever you interact with us through a third-party social network. This happens, for example, when you request us to contact you for business purposes and share your contact details (name, telephone number, and email). To learn more about how your information from a third party social network is collected by Vogler or to opt out of sharing such social network information, please visit the website of the specific third party social network.

Cookie Data: Cookies are small text files that are stored on your machine with an access identifier, which record data about your browsing through the pages of the VOGLER website.

Cookies are used to analyze how visitors use our website and aim to improve browsing through pages and target marketing campaigns.

Types of cookies we use:

• Functional

These are essential for the functioning of the website, such as, for example, to control user sessions and ensure a secure login. Without them, our website would not function properly.

• Analytics

The information provided by them allows us to analyze patterns of visitor behavior and their use of the website. This information is used to improve the experience and optimize the website in general.

• Performance

Performance cookies are used to understand and analyze the main performance indexes of the website, which helps us offer a better user experience to visitors.

• Required

Required cookies are absolutely essential for the adequate functioning of the website. These cookies guarantee basic functionality and security features of the website, anonymously.

You can prevent the storage of cookies by setting your permission preferences directly in your browser. If you do not agree to allow cookies, however, some features of the website may be limited during your access.

Keep in mind:

• You are responsible for the veracity of the data provided by you. VOGLER will not be held liable for any damages resulting from false and/or inaccurate information;
• In the event that VOGLER finds that any information provided by you is false, incorrect, outdated, or incomplete, it will have the right to suspend or cancel your registration immediately, without notification, and to refuse any and all use, present or future, of the services that require specific registration;

The data collected is used to provide the various services we make available to you and mainly for the following purposes:

• Identification and access authentication;
• Sending general news and relevant information related to the food sector and new products;
• Sending invitations and registration for events, courses, workshops, webinars, awards, and access to our podcast;
• Sending brochures and e-books;
• Responding to suggestions, questions, complaints, reports, compliments, or queries received through website forms such as “Contact Us” and “Ombudsman;”
• Personalizing and improving your experience, by means such as sending custom content aligned with your interests;
• Participating in selection and recruitment processes;
• Updating registration data for telephone contact and messaging application purposes;
• Preparing reports and statistics, without identifying users;
• Responding to requests made by users.

VOGLER, always based on one of the legal grounds provided in the LGPD, may share some of your information, with your consent, with partner entities for the purposes described in item 5 of this Policy. Certain information may also be shared for the purpose of complying with legal obligations, legitimate interest, or other existing legal basis.

During our relationship, Vogler may share your Personal Data with some entities:

Service providers: We use services from third-party companies to assist in the operation of our business. In these cases, only selected employees will be authorized to access your Personal Data on behalf of Vogler, for the specific tasks requested of them, based on our instructions. Additionally, the providers with whom we share your Personal Data are required to keep it confidential and secure.

Third parties that use your Personal Data for legal reasons or due to a merger/acquisition: We may share your Personal Data with third parties for legal reasons or in the context of a merger or acquisition.

It is important to note that everyone is required to maintain the legality and security standards regarding the personal data shared by us. In order to be transparent with you and guarantee your rights as a data subject, please note how we may share your data:

• For internal operations, such as managing your account, providing customer service, communicating between you and us, understanding user needs, improving the content and services on our website, identifying potential fraud, and taking measures to enforce our Privacy Policy;
• With entities that host and analyze data and service providers that help VOGLER provide services to you;
• For communication services, such as sending emails, WhatsApp messaging, support services, website maintenance, data analysis, event registration system, and customer service.

NOTICE: VOGLER will only share the necessary data and access to information with duly authorized professionals, respecting the principles provided by law and with the guarantee of confidentiality and preservation of privacy, doing so exclusively for the performance of their functions.

7.1 Does VOGLER transfer my data to other countries?

Some of your personal data may be transferred to other countries, such as, for example, when we use cloud computing services for data processing or storage, located outside of Brazil. But do not worry, Vogler also follows all the requirements established in the current legislation in these situations, adopting the best market practices in order to guarantee the protection and privacy of your personal data.

In these cases, we will use the legal bases existing in the Legislation, such as specific contract clauses, which guarantee data protection standards and security measures appropriate to data protection standards and the definitions indicated in this Privacy Policy.

VOGLER does not intentionally request or collect personal data from children and adolescents without the express consent of a parent or guardian. In the event that any records of children and adolescents are detected in our database, they will be deleted as quickly as possible or whenever requested.

To request the deletion of data of children and adolescents, the legal guardian must use the “Contact Us” option through the contact information provided through the Privacy Channel on our website.

All data you provide on the VOGLER portal will be protected and stored using security protocols and software.

The data collected will be stored on our own server or, on occasion, on third-party servers, which may be located in Brazil or overseas, including via cloud computing technology, always in compliance with security and control standards, according to the applicable legislation.

VOGLER emphasizes that no procedure carried out on the Internet is exempt from events that violate information security or unwanted intrusions; however, it undertakes to adopt all appropriate technical and administrative measures to protect your personal data.

In compliance with the provisions of the LGPD, in the event that a security incident occurs with your personal data that involves significant risk or damage to you, we will be contacting you to let you know and we will notify the National Data Protection Authority, whenever necessary and as provided by law.

VOGLER stores your information for as long as you are our customer and/or browse our website using our services, always in compliance with the provisions of the legislation.

Therefore, upon termination of the processing of personal data, except in the cases established by the applicable legislation or by this Privacy Policy, your personal data will be deleted from the database.

We use appropriate measures (as described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information that you have chosen to share in public areas, such as third-party social networks.

People who can access your Personal Data: Your Personal Data will be processed by our employees or authorized agents, provided that they need to have access to such information, depending on the specific purposes for which your Personal Data was collected.

Measures taken in operational environments: We store your Personal Data in operational environments that use security measures to prevent unauthorized access. The transmission of information on the Internet is unfortunately not completely secure and although we do our best to protect your Personal Data, we cannot guarantee the security of data during transmission through our website.

Steps Vogler expects you to take: Your role is critical to keeping your Personal Data secure. When you create an online account, please ensure that you choose a password that is difficult for others to guess. You are responsible for keeping this password confidential for any use of your account. If you use a shared or public computer, never choose to save your username, email address, or password, and ensure that you log out of your account whenever you leave your computer. You should also make use of any privacy settings or controls that we provide on our website.

We have adopted strict policies and procedures that govern how Personal Data is handled at Vogler. These rules are intended to ensure that your Personal Data is handled in an appropriate and lawful manner.

Our security measures are continually monitored and reviewed in line with the latest technological advances and organizational capabilities.

Transparency regarding the processing of your personal data is a priority for Vogler. In addition to the information provided in this Privacy Policy, you may also exercise the rights provided in the General Data Protection Act, including:

• Confirmation of the existence of personal data processing;
• Access to personal data;
• Consent revocation;
• Correction of incomplete, inaccurate, or outdated personal data;
• Removal of personal data processed with your consent or deemed unnecessary, or excessive, or data processed when you believe that some point of the LGPD has not been met;
• Information on the hypotheses and with which companies, partners, and other institutions with which we may share or from which we may receive personal data relating to you;
• Information on the possibility of not providing consent and on the consequences of refusal, where applicable;
• All requests will be processed free of charge and will be subject to a prior assessment of your identity and the feasibility of the service, in order to comply with any obligations that prevent the full fulfillment of the requests of the right holders;
• Revocation of your consent will not affect the processing of personal data carried out previously or under another existing legal basis.

VOGLER may store its users’ data registration history to exercise their rights and may also keep data, even after their request for deletion, when allowed or required by law.

We continuously seek to improve the experience of our users and customers. Therefore, our personal data processing practices may change with the inclusion of new features and services.

We value transparency in the way we process your personal data. Whenever any relevant condition of this Privacy Policy is changed, these changes will be deemed valid, effective, and binding after the new version is published on our website. We recommend that you check the updated version of this Privacy Policy whenever you browse our website.

Whenever you have any questions about this Privacy Policy, even after reading it, or in the event that you need to interact with us on matters involving your personal data, you can do so:

• Through our service channels available at https://vogler.com.br/fale-conosco/, requesting options regarding the privacy of your personal data, whenever available, or;
• By emailing the our Data Control Officer: [email protected].

We are always available to answer your questions and put you in control of your personal data.

You can count on us to keep you informed!

Stephanie de Oliveira Dantas

Data Protection Officer

Updated: 4/11/2024

VOGLER INGREDIENTS LTDA.