GDPR

PRIVACY AND PERSONAL DATA PROTECTION POLICY

Version dated November 1st, 2022.

2FUTURE HOLDING LTDA., a limited liability company enrolled with the Brazilian Taxpayers’ Registry of Legal Entities (“CNPJ/ME”) under No. 24.453.143/0001-17 (“2FUTURE”) values privacy, and it is concerned with the rights of the data subjects, it is committed to the personal data protection and it is also committed to offering a suitable level of security to its business model.

2FUTURE is a holding company comprised of inspiring companies of several segments focused on the well-being and on the concern about future generations.

In the development of its activities, while responsible for the processing of personal data, 2FUTURE strictly observes the legal provisions about personal data protection, including (at all times and as applicable), the Constitution of the Federative Republic of Brazil of 1988 (“Brazilian Federal Constitution”), the Act 8.078, dated September 11th, 1990 (“Brazilian Consumer Protection Code”), the Act 10.406, dated January 10th, 2002 (“Brazilian Civil Code”), the Act 12.965, dated Abril 23rd, 2014 (“Brazilian Internet Civil Framework”), the Decree 8.771, dated May 11th, 2016, the Act 13.709, dated August 14th, 2018 (“LGPD”), and remaining sector-specific or general regulation on the subject.

We offer below the practices related to the collection, form of use, storage, processing, sharing and transfer of personal data that take place as a result of the activities carried out by 2FUTURE, specifically as a result of the access and use of the services made available by means of the website accessible at https://2futureholding.com/ (“Website”).

2FUTURE advises the reading of the Privacy and Personal Data Protection Policy and its respective updates (“Privacy Policy” or “Policy”) carefully. In case of modifications to the Privacy Policy, the date of the last amendment, available at the top of this page, is also updated.

In this policy, any individual that uses our Website (“User” or “You”) may verify how their personal data is being processed when inserted in the Website for registration in our newsletter and/or events, sending of email for contact or registration for our openings and opportunities.

The Website is not intended for use by individuals under 18 years old. It is not 2FUTURE's policy or intention to collect and intentionally treat personal data of underaged individuals. Users under 18 years old must not send us information by means of the Website. Eventual information concerning individuals under 18 years old provided through the Website will be disregarded and deleted from our database.

See below the content of our Privacy Policy:

1. What personal data is collected by 2FUTURE?

2. For which purposes are the personal data processed?

3. Which are the data subjects’ rights?

4. Are the personal data shared with third parties?

5. What is the retention period of the personal data?

6. How does 2FUTURE protect the personal data?

7. Does 2FUTURE use Cookies?

8. International Transfer of Personal Data

9. Consent and Acceptance of Data Processing

10. Application of the Privacy Policy

11. Doubts and contact with 2FUTURE

12. Updating of this Privacy Policy

13. Applicable Laws

If you still have any doubts or if you need additional information related to the processing of personal data or if you intend to exercise any of your rights as a data subject, please contact us by means of the following channels:

Email: hello@2futureholding.com

Written Communication: Rua Bandeira Paulista, nº 726, conj. 71, Itaim Bibi, São Paulo – SP, CEP 04532-002.

1. What personal data is collected by 2FUTURE?

Personal data comprehends any information related to an identified or identifiable individual. The subjects of the personal data are the individuals to whom the data refer.

In the exercise of its activity, 2FUTURE collects and treats personal data, particularly the ones necessary for the provision of the services and development of its activity, and it also treats the data it receives from the business relationship established with clients or potential clients, and within the scope of the observance of the applicable legal and regulatory obligations.

When you register on the Website to receive our newsletter and/or participate in events, the User shall provide to 2FUTURE the following personal data:

(i) Name;

(ii) Email address;

(iii) Organization of which theyare a part of;

(iv) Position held in the organization.

When accessing the Website, the following data may also be collected, which will be used by 2FUTURE for browsing analysis: (i) date and time of access; (ii) IP address (Internet Protocol); (iii) access origin; (iv) browser data (name and version of the browser, manufacturer and language); (v) access device data (type of device - desktop, mobile devices, tablet -, operational system and version, screen resolution and language); and (vi) geolocation data (latitude, longitude, City, State). Said data will be stored by 2FUTURE for a period of at least six (06) months.  

2FUTURE makes available on its Website a contact channel, which allows the User to send or request information by means of texts, by information of name, email address and telephone. The User agrees that they are the sole responsible for all messages transmitted through this channel. 2FUTURE will not consider said messages as confidential or secretive, but, in any case, this Privacy Policy is also applicable to them.

The User is responsible for keeping its personal information updated. Whenever their data sustains any changes, said fact must be promptly altered by the User by means of the Website. 2FUTURE does is not responsible for the veracity of the data provided by the User, who is solely responsible for the accuracy of the information.

2. For which purposes are the personal data processed?

The data processing is an operation or series of operations carried out in relation to the personal data by means of manual or automated means, including the collection, storage, use, copy and transfer, amongst others.

2FUTURE is responsible for collecting and processing personal data for the purposes indicated below. In case you have any doubts about the way in which the processing of personal data is carried out, you wish to obtain any explanation about this document or if you wish to exercise any of the rights mentioned in this document, you should contact us by email or written communication sent to our address, both informed in section 11 below.

The User expressly and unequivocally accepts that the data provided by them at the Website may be processed by 2FUTURE, which primary purpose in collecting personal information is to provide the User with a safe, easy, and effective experience. To this end, the personal data may be processed for the following purposes:

(i) to deliver advertisement communication by email, telephone calls, SMS, social communities or any other present or future material or electronic means, which allow a business communication. Said business communication relates to products or services offered by 2FUTURE and the companies it owns, as well as its employees or partners with which a partnership of business promotion has been established. In such cases, third parties will never have access to the User’s data, and the business communication will be made directly by 2FUTURE and will be about products and services concerning the market niche explored by 2FUTURE and by the companies it owns;

(ii) to process orders, requests or any requirements that may be made by the User through any contact channels made available by 2FUTURE;

(iii) to assist the User with information about the newsletter and events promoted, and to provide details about the activities carried out by 2FUTURE;

(iv) to notify the User about the maintenances or updates occurred on the Website or the Privacy Policy;

(v) to carry out the analysis of the behavior of Users in general and other measurements important to provide a quality service at all times;

(vi) to develop forms of data anonymization, which may be used for economic purposes, including the onerous transfer to third parties;

(vii) to observe legal obligations, including judicial orders.

3. Which are the rights of data subjects?

According to the terms of applicable laws on personal data protection, 2FUTURE ensures to the data subject the right of access, rectification, cancellation, portability and opposition of their personal data, by means of a written request addressed to 2FUTURE. The request can be made by email or communication in writing sent to our addresses, both informed in section 11 below.

When the right of access of the data subject damages fundamental rights and legitime interests of individuals, it will be limited.

The supply of copies requested by the data subject may generate administrative costs.

4. Are the personal data shared with third parties?

We may share your personal data with third parties, according to contractual provisions in force, including third parties involved in the provision of the services we offer to clients and Users.

2FUTURE may share the data of Users as follows:

(i) to render viable the supply and the provision of its services in a suitable manner;

(ii) with bodies, authorities and other entities of the public administration, to comply with laws and regulations applicable to the services offered by 2FUTURE;

(iii) with bodies, authorities and other entities of the public administration, in addition to individuals or private legal entities, to comply with legal obligation or judicial order;

(iv) to defend the interests and rights of 2FUTURE or third parties, including judicial and administrative proceedings;

(v) with business partners and employees that provide services to 2FUTURE, which must follow 2FUTURE’s instructions and observe the information's confidentiality; and

(vi) with police authority or members of the Public Prosecution, even if there is no specific legal obligation or judicial order, to protect the rights, property or safety of 2FUTURE, its clients, employees or third parties.

The access to the information collected is restricted to the employees and authorized staff of 2FUTURE. The employees and/or authorized individuals who unduly use said information will be in violation of our Privacy Policy and they will be subject to penalties set forth in our disciplinary proceeding, without exclusion of the remaining suitable legal measures.

5. What is the retention period of the personal data?

2FUTURE stores and keeps your personal data during the period necessary to attain the purposes set forth in this Privacy Policy or during the period that is required by legal norms or applicable laws.

In case the User wishes to do so, they may request to 2FUTURE, via email, that the information collected is excluded from its database.  

In observance of the applicable laws or a judicial order, 2FUTURE may maintain certain data stored for a period of at least six (06) months after the request for its exclusion. Said data will not be anonymized, deleted or destroyed by 2FUTURE before the end of said term.

2FUTURE reserves the right to examine the request and, with observance of the legal term of mandatory maintenance, it shall arrange for the deletion or anonymization of the data, at your exclusive discretion.

6. How does 2FUTURE protect the personal data?

2FUTURE adopts best practices and technical and organizational measures to protect your personal data against destruction, loss, alteration, disclosure and non-authorized access, in addition to any form of unsuitable or illegal processing.

For such purpose, 2FUTURE uses information security techniques, widely accepted in the business community. At any rate, if you have any concerns or suspicion that your personal data are at risk, please contact us immediately.

2FUTURE advises that the User, when accessing the Internet, consults at all times the Privacy Policy of the website they are browsing, verify whether the page is secure and do not offer their data to third parties.

We also respect the confidentiality of your information. Therefore, we do not sell, distribute or in any way make your information commercially available to any third party. 2FUTURE undertakes the commitment to maintaining your information protected according to this Privacy Policy and applicable laws.

7. Does 2FUTURE use Cookies?

The “cookies” are small text files that identify the device of the User in the server of 2FUTURE when accessing our Website. Cookies themselves do not identify the individual User, but only the device used. Cookies are not used to collect personal data.

Furthermore, cookies are used to help the users to browse in websites with efficiency and execute certain functions. Due to its main role to improve the usability or the processes of the Website, deactivating cookies may prevent the Users from using certain tools of the Website.

When accessing the Website, the User authorizes the use of cookies according to this Policy. In case the User does not agree with the use of the cookies in this manner, they shall adjust the settings of their browser to prevent the use. Deactivating the cookies may render the Website less functional, but it will not prevent the browsing.

Types of cookies used by 2FUTURE:

• Primary Cookies: cookies issued by 2FUTURE’s Website domain (https://2futureholding.com) to be used inside its pages and they are generally used to identify the language and local preferences or to facilitate the basic functionality of the Website, as well as to register User’s information upon using the Website for 2FUTURE’s analysis.

• Third Party Cookies: cookies issued and managed by third party companies unrelated to 2FUTURE and the Website, with the intention of monitoring the activity of the User in order to allow the targeted advertisement and understand the profile and behavior of the User for advertisement purposes.

• Session Cookies: temporary cookies which will remain in the cookies file until the User leaves the Website. The information obtained by said cookies is used to analyze standards of web traffic, allowing problem the identification and providing a better browsing experience.

• Persistent Cookies: used to remember the User ‘s preferences when using the Website and they remain in User's desktop or mobile device even after closing the browser or reinitializing. The Persistent Cookies are used by 2FUTURE to analyze the behavior of the User and establish standards, to improve the Website’s functionality. The Persistent Cookies also allow 2FUTURE to offer targeted advertisement and to measure the effectiveness of the website and the functionality of said advertisements.

8. International Transfer of Personal Data

2FUTURE does not treat the data directly for international transfers of personal information between different subsidiaries. However, the personal data may be transferred abroad when stored by 2FUTURE on cloud computer servers located outside Brazil. For such purpose, 2FUTURE observes and adopts the best practices of security and privacy to ensure the protection of the personal data of the subjects, and it is attentive to the local laws in force about the matter.

To ensure the protection of data subjects, in case of an international transfer, 2FUTURE guarantees that it will observe the applicable legal provisions, particularly in relation to the determination of the suitability of said country in relation to the data protection and the requirements applicable to said transfers.

9. Consent and Acceptance of Data Processing

When registering on the Website and clicking on the link “I accept the Privacy Policy”, the User expressly and unrestrictedly declares to agree with this Privacy Policy and also declaring, for all purposes, that it is over 18 years of age, legally capable and responsible for all acts they performed, and data provided to 2FUTURE.

We clarify that the LGPD establishes several legal bases for the processing of personal data. The so-called “legal bases” provided for in the Law would be the foundations, justifications, hypotheses so that a certain data processing is considered lawful and allowed.

The subject’s consent is not the sole legal basis for the personal data processing. It means that 2FUTURE may treat the personal data, even without the subject’s consent, in case there is a legal basis set forth in Law that allows said processing, for example, for the observance of judicial orders.

10. Application of the Privacy Policy:

This Privacy Policy applies to all means of access to the Website, whether by computers or mobile devices.

The terms of this Privacy Policy do not apply to the services offered by other platforms or third-party websites, even if, occasionally, the Website offers a link of access to other platforms and websites.

Therefore, 2FUTURE recommends the careful analysis, by the User, of other websites’ privacy policies, because the content of this Privacy Policy is not applicable to them. The access to platforms or websites that are not owned by 2FUTURE will be voluntary and at the sole discretion of the User.

11. Doubts and Contact with 2FUTURE

In case any doubts remain or in case you need information concerning the personal data processing or if you intend to exercise any of your rights as the data subject, please contact us by means of the following channels:

Email: hello@2futureholding.com

Written Communication: Rua Bandeira Paulista, nº 726, conj. 71, Itaim Bibi, São Paulo – SP, CEP 04532-002.

The response to requests will be provided, as a rule, within a maximum period of fifteen (15) days, except in case of a specifically complex request or several requests. We kindly ask that, when writing to us, you indicate in the subject field “Notification on the use of personal data”.

We clarify that, occasionally, before we respond to a request, we may ask you to provide us with certain information to confirm your identity.

12. Updating of this Privacy Policy

Seeking at all times to improve our services and our relationship with third parties, this Privacy Policy may be updated by 2FUTURE, at any time, aiming at its improvement. The amended Privacy Policy will take effect as of its publication on the Website.

2FUTURE will notify the User about possible material alterations made to this Privacy Policy by means of the electronic address provided by the User and it will make the last version of the Privacy Policy available on the Website, with the date of the last updating.

The User will remain bound to any alterations to the Privacy Policy after its publication, in case they continue to use the Website, the services provided by 2FUTURE through the Website and do not demonstrate interest in unbinding from it.

The User undertakes to frequently consult the Privacy Policy on the Website to keep updated in relation to its terms and conditions.

In case of conflict between this Privacy Policy and possible amendments, the latter will prevail.

13. Applicable Laws

This Privacy Policy will be governed and construed according to the laws of the Federative Republic of Brazil and any disputes arising from it, which cannot be amicably settled by the Parties, must be submitted to the jurisdiction of the Judicial District of São Paulo, State of São Paulo.