Our Privacy Policy

1. Objective

AZIMUTH, the trade name of Ascent Business Consulting, was created to provide individuals and organizations with solutions in their life design, marketing, sales, and financial areas. Since its inception it's been our goal to serve worldwide and multiculturally, offering a fully digital set of solutions through a digital platform. Today, We propose fully digital solutions, with agility and quality, being thoroughly committed to ensuring the security and protection of your personal data.

As a result, we have prepared this Privacy Policy to explain, in a simple and objective way, what information is collected from you, why we collect it, whether we share it and with whom, as well as what your rights are as a data subject, and how to exercise them with Azimuth, in order to demonstrate our commitment to processing your personal data securely. privacy and transparency.

Below, we will present the name of the controller of your personal data, responsible for ensuring the security, respect for purpose and transparency of your personal information:

AZIMUTH Life Design. (Ascent Business Consulting) CNPJ nº 31.124.578/0001-83Address – Av. Paulista, 1471- Bela Vista, São Paulo/SP, CEP 01311-927 – Brazil

2. Comprehensiveness

This Privacy Notice applies to individuals who interact with Azimuth's services, including, but not limited to:

2.1 Azimuth Prospects: natural persons prospected or who have already requested the contracting of one of our and/or our partners' services or products, but who have not become an Azimuth customer so far.

2.2 Azimuth's customers: natural persons, either for themselves or for their legal entity, who effectively contract, use or access one or more of Azimuth's services or products.

2.3 Business Partner: natural persons with a publicly-held company (CNPJ) who refer customers to Azimuth.

2.4 Applicants for job vacancies at Azimuth: natural persons who apply for the job vacancies open at Azimuth.

2.5 Suppliers/service providers: natural persons who legally represent the companies that provide services/products to Azimuth.

3. What personal data does Azimuth collect?

In order to respect your privacy, we understand that any and all Processing of Personal Data must be limited to the minimum necessary, relevant, and proportionate to allow the intended purpose to be carried out.

Therefore, the Personal Data we collect about you will vary according to the relationship you choose to establish with us, i.e., customer, consumer, supplier, service provider, visitor, partner, among others.

Below, grouped into categories, we present the main personal data processed by us:

3.1 Identification information: such as your name, CPF, CNPJ, date of birth, parentage, dependents, digital certificate data, marital status, and gender, among others.

3.2 Information that helps us contact you: such as home address, zip code, landline or mobile phone, WhatsApp, personal and/or professional emails;

3.3 Information on the property to be pledged or to be financed: zip code, city, state, street, neighborhood, number, type of property, if the property given as collateral is the same as the one in which you reside, if the property is paid off, financing amount, among others;

3.4 Financial information: such as declared income and proof, family income, credit history, intended loan amount, appraised value of the property, number of installments, among others;

3.5 Professional information: such as profession, place of work, type of work (CLT, service provider, self-employed, etc.), position, professional history, academic qualification, among others;

3.6 Behavioral information: such as consumer or professional profile, credit score, among others;

3.7 Sensitive personal data: Facial recognition for signing contracts, only in specific cases.

3.8 Attributes associated with your electronic devices: such as access provider, operating system, browser (type, version, enabled options and installed plug-ins), video settings (size/resolution and number of colors), date and time of access and pages viewed through cookies;

3.9 Information from third parties: information shared by third parties with Azimuth, such as information from Credit Bureaus, which presents registration, behavioral and financial data; and

3.10 General data: i.e. the content that you send to us of your own free will, such as testimonials referring to Azimuth posted on profiles and pages on social networks, together with your name and image (including profile pictures).

4. Como coletamos seus dados pessoais?

As informações que tratamos a seu respeito podem ter sido fornecidas diretamente por você à Azimuth ou de forma indireta, quando obtemos por terceiros, de fontes pública ou mesmo coletadas de forma automática através de nosso site, Plataforma ou outros canais, conforme abaixo se indica.

FORNECIDAS DIRETAMENTE POR VOCÊ

Desde o início de sua interação conosco, você voluntariamente nos disponibiliza informações a seu respeito, por exemplo, quando nos contata por meio das redes sociais ou dos nossos canais de atendimento, quando do acesso para conhecer nossos produtos e serviços ofertados, ou, ainda, quando você se cadastra para participar de our selection process.

PROVIDED BY THIRD PARTIES

In specific cases, we may also receive some Personal Data from you through third parties. For example, from our team of consultants, from a partner specialized in recruitment and selection, our service providers and suppliers, or we may receive information from financial institutions, securitization companies, banking partners, and credit bureaus

AUTOMATICALLY

In some situations, we may also collect Personal Data automatically from the devices you use to access our website and platforms, such as the IP address of the device used to access Azimuth's services or products; technical data, such as URL, network connection, and provider information; timestamps of actions. This information helps us to generate access statistics and, thus, get to know our audience better. This is important so that we can improve it more and more and adapt it to the widest possible audience. Some of this data may be collected through cookies or similar technologies, as we will explain in a separate topic.

PUBLICLY AVAILABLE

We may also collect publicly available information from you, including, but not limited to, databases of public agencies (e.g., the IRS).

5. Why we process your personal data

Personal Data is processed by Azimuth for various purposes. Below are the main cases in which we will process your information:

5.1 Perform a contract you have entered into with us or carry out pre-contractual due diligence - When you are a party to a contract with Azimuth, or represent a company in a contract, we will process your Personal Data for the analysis of service and/or loan requests, property valuation, delinquent collections, loan cancellation, Sending the contract for digital signature, conducting due diligence, among others. In addition, the data will be processed to maintain our business relationships with customers, partners, suppliers, and others, as well as to ensure the execution of the desired operation and enable purchase and service contracts;

5.2 Credit protection, granting, and analysis – we may process your Personal Data to carry out credit analysis and, if necessary, we may also consult additional Personal Data about you with third-party partners, credit bureaux and other public information;

5.3 Prevent fraud and ensure your security - We may process your personal data to ensure the security of your (and third parties) and to prevent and combat identification fraud, in particular during your loan application, where we will take steps to confirm and authenticate your identity;

5.4 Comply with our legal or regulatory obligations - Your personal data may be used to comply with our obligations under the law and/or regulations of government agencies and orders or requests from tax authorities, the Judiciary, and/or other competent authority, such as providing income reports to the customer, issuing invoices to suppliers, notification of assignment of credit, for the investigation of complaints and complaints;

5.5 Exercise rights in judicial, administrative, or arbitration claims - Even after the termination of your relationship with us, we may process some of your Personal Data to exercise our rights guaranteed by law, including as evidence in judicial, administrative or arbitration proceedings;

5.6 Enable activities necessary for our Organization - Based on our legitimate interest, we may also process your Personal Data in activities such as consulting third parties, to better adapt the products and/or services available; preparing reports on the region of the users and operations carried out, in order to personalize the services, products, and benefits offered, as well as the communication, the dissemination of these to our customers and potential customers, as well as for the management and use of cookies; 5.7 Advertising - We may use your Personal Data to create audience segmentations and thus more appropriately promote updated content from Azimuth's marketing and remarketing campaigns. In this case, the option to exclude registration from our database will always be available at the end of each communication we forward, providing the possibility of choosing to receive information such as offers and news about our latest trends;

5.8 Prospecting – When you interact with us, through our numerous channels (online form, interaction with advertising campaigns, among others) to request loan simulation or even to answer questions and find out more information about our products and services, our specialized team will contact you in the way that best suits you, that is, by email, by phone, by WhatsApp or other means of communication; and

5.9 Recruitment and selection - We advertise our vacancies on specialized websites, we also receive resumes through recruitment consultancy and through our LinkedIn. In these situations, we will process your personal data to analyze your resume, verify your skills, curriculum information and whether or not you meet the specific requirements of the position for which you have applied, as well as to follow up on the selection process, when applicable, in situations such as contact by phone or email and scheduling interviews.

A Azimuth também poderá tratar dados pessoais por meio de autorização concedida por você, para as finalidades onde verificarmos necessário a autorização, com base na legislação aplicável.

6. What are Cookies and how do we use them?

Cookies are text files that may be stored on your electronic devices when you visit our website. Azimuth uses this tool for different purposes, such as generating access statistics and improving your experience in our interfaces/domains, among others. Aggregated into groups, below we list the types of cookies used and their purposes:

Type of Cookie - What do they do?

Necessary/Essential - These are essential cookies to enable the proper functioning of our website, as well as to allow you to make use of all available features.

Performance/Analytics - These are cookies that help us understand how visitors interact with our website by providing information about the areas visited, the time spent on the site, and any problems encountered.

Functional - These are cookies that allow us to remember your previous choices, such as language navigation. They are responsible for providing a personalized experience.

Marketing/Advertising - These are cookies used to provide you with more content that is relevant and specific to your interests. They can also be used to display advertising with a greater target or to limit the number of ads it is served. They also allow the measurement of the effectiveness of a launched campaign

However, you do not have to worry, as cookies do not damage your equipment and/or electronic device and can be easily disabled by setting your browser to refuse cookies. In these cases, the platforms may not operate properly, or cause too much delay in loading the content.

For more information on how to manage cookies in browsers, we provide the links below:

Internet explorer
Mozilla Firefox
Google Chrome
Safari
Microsoft Edge
Opera Help

You may also choose to block the use of Google Analytics cookies from the following link: https://tools.google.com/dlpage/gaoptout.

Finally, we emphasize that cookies are essential for the normal functioning of our website, and opposition to the use of this tool may result in the disabling of your experience or the suspension of your access.

7. Who does Azimuth share my data with

Your personal data may be shared with some recipients to enable our activities, in which case it will be restricted to the minimum appropriate and necessary for the fulfillment of any of the specific purposes previously informed to you, such as:

i. To inquire about your information in the Credit Information System (SCR) database;

ii. For the valuation of your property as collateral;

iii. With institutions responsible for collecting the credit resulting from default;

iv. With financial institutions, securitization, and banking;

v. With business partners and suppliers, in the development and provision of services aimed at you, provided that they are duly approved by Azimuth's security processes;

vi. With third-party partners, who support us in campaigns and other advertising and prospecting actions;

vii. With service and/or infrastructure providers and third parties that contribute to Azimuth's activities, provided that they are duly approved by the security processes;

viii. In order to comply with legal obligations to which we are subject, we may have to share data with public authorities or official bodies, upon request or express legal provision;

ix. In the case of corporate transactions and changes, corporate transactions, such as Mergers, Acquisitions and Incorporation;

x. With companies that make up the Azimuth group; and

xi. With external law firms, to act in extrajudicial, judicial, administrative or arbitration demands or proceedings.

In any case, the sharing of personal data will comply with all applicable laws and rules, always seeking to ensure the security of the data and the technical standards employed in the market.

When we share your personal data with partners, we use contractual instruments to ensure that any third party that receives it guarantees them adequate protection.

In situations where the sharing is with a third party located outside Brazil, in addition to ensuring the security and protection of personal data through a contract, Azimuth will use one of the legal hypotheses of international transfer.

8. How long does Azimuth store my data?

We store your personal data in a secure and controlled environment for as long as you have a relationship with us, in compliance with the guidelines on security standards set forth in applicable regulations.

It is possible that your Personal Data will be kept for an additional period after the cancellation/termination of your relationship with us, for the purposes of complying with legal or regulatory obligations, audits, for the regular exercise of rights in administrative, judicial or arbitration claims.

To determine the retention period for your personal data, we rely on the following criteria:

i. Whether we have a legal, contractual or other obligation to retain personal data, or whether it is necessary for the purposes of investigation or litigation; and

ii. Whether they are necessary to maintain accurate business and financial records.

Your Personal Data may be deleted immediately if requested unless the retention is expressly authorized by law or contract. See item 9.

9. How we protect your data and how you can protect it too

We have implemented all the security measures within our reach to protect your personal data from unauthorized access and from accidental or unlawful destruction, loss, alteration, communication or dissemination.

All personal data collected is only accessed by professionals and

duly authorized partner companies, respecting the principles of proportionality, necessity and relevance to the objectives of our business, in addition to the commitment to confidentiality and preservation of your privacy. In addition to these organizational and governance measures, we have adopted several other technical measures that ensure even greater security for your personal data.

When you use our platforms, it is necessary to carry out the authentication process at each login by means of a password. It is your responsibility to ensure your password and/or authentication service, not passing on your login credentials to third parties. This technology also aims to prevent information from being transmitted to or accessed by unauthorized third parties.

In the event of any type of security incident that may generate relevant risk or damage to our data subjects, we will notify those affected and the National Data Protection Authority about the incident, in accordance with the provisions of the General Data Protection Law.

10. What are your rights as a data subject and how to exercise them?

We pride ourselves on being a company that takes the rights of personal data subjects seriously. Therefore, we ensure that the rights over your personal data provided for by law (art. 18, Federal Law No. 13,709/2018) can be fully exercised, respecting the applicable limits, through the e-mail address juridico@Azimuth.com.br, the following rights:

i. Access to data - you may request access to your personal data stored by Azimuth, as well as information about possible sharing with third parties.

II. Correction - If the personal data is incorrect, incomplete or out of date, you may make a request for correction or update.

iii. Deletion of data processed on the basis of consent - data provided with consent may be subject to deletion. However, it is possible that, even after the deletion request, some personal data will remain stored, due to legal obligations or for the protection of our interests or those of our customers.

iv. opposition - you may oppose the processing of your personal data by Azimuth, based on one of the hypotheses of waiver of consent, in case of non-compliance with the provisions of the LGPD;

V. Portability - In order for you to exercise the portability of your personal data, we may provide you with a copy of your personal data in a commonly readable format.

vi. information about sharing - you can find out which public and private entities Azimuth shares your Personal Data with.

vii. information about the possibility of not consenting - you have the right to receive clear and complete information about the possibility and consequences of not providing consent when it is requested by Azimuth.

viii. Revocation of consent - if you have consented to any purpose of processing your Personal Data, you can always choose to withdraw your consent. However, it is possible that in some exceptions Azimuth will be unable to provide you with certain services, but we will notify you when this occurs;

IX. Automated decision-making – You may request the review of automated decisions that affect your interests, including decisions aimed at defining your personal, professional, consumer, and credit profile or aspects of your personality; and

X. Anonymization, Blocking, or Deletion – You may request the anonymization, blocking, or deletion of data that is unnecessary, excessive, or that may have been processed in violation of the law.

For your security, whenever you submit a request to exercise your rights, Azimuth may request some additional information and/or documents so that we can prove your identity, seeking to prevent fraud.

In specific circumstances, it is possible that your request will not be fulfilled. In these cases, we will explain the reasons that justified the non-attendance.

Requests involving personal data and/or documents of other data subjects will not be answered, except through power of attorney, parental authority or other hypothesis that authorizes the exercise of the right of another holder by you.

Finally, we are committed to responding to all requests within a reasonable time and always in compliance with applicable law.

To exercise your rights, you can contact us by email at info@azimuth.global

11. Changes to our Privacy Policy

Azimuth reserves the right to modify this Notice at any time, especially to adapt it to any changes made to our website, either by providing new functionalities or by suppressing or modifying existing ones.

12. Legal regulation

Law No. 13,709, of August 14, 2018 – General Data Protection Law.

13. Contact Azimuth's Legal Department

Name: Galantini e Associados Contact: info@Azimuth.com.br