PRIVACY POLICY

Updated: February 17, 2025.

AGUAS DE SANTA BARBARA FUTEBOL CLUBE, a private non-economic civil association, regularly registered with the CNPJ/MF under nº 51.378.887/0001-97, with Municipal Registration nº 3.4.02035, with headquarters at Rua Marques do Vale 26, Sala 03, Centro, 18770-000, Aguas de Santa Barbara/SP, Brazil, hereinafter referred to as “ASBFC”, from a perspective of public communication, of protection of the fundamental rights of freedom, privacy and free development of the personality, which guide the association's actions, acts as responsible for the processing of personal data corresponding to natural and legal persons with whom it has or had some kind of bond.

ASBFC intends to offer a clear explanation of when, why, and how it collects and uses the personal data of visitors and users, as well as providing an explanation of the legal rights of visitors and users, based on the provisions of the LGPD (General Data Protection Law). Personal Data) and in Law No. 13,709, of August 14, 2018.

In compliance with the provisions of personal data protection regulations, we inform you that personal data provided as a result of activities or operations carried out with ASBFC will be treated in accordance with its Privacy and Data Protection Policy and through the use and maintenance of technical, physical and administrative security measures to prevent unauthorized third parties from accessing this data.

For this reason, it is recommended that you carefully read this Privacy and Data Protection Policy, as when visiting the ASBFC website or purchasing any license to access ASBFC's content, visitors and users will be agreeing to the terms and conditions set out in this Privacy and Data Protection Policy and with all other notices that may appear on the pages of this website, relevant to said policy.

Before accessing the website or purchasing any license to access ASBFC's content, both the visitor and the user must ensure that they fully understand the association's practices in relation to the collection and use of their personal information.

1. PURPOSE AND DIRECTION TO WHICH THE DATA WILL BE SUBMITTED

ASBFC may collect “personal information” and “non-personal information” about its visitors and users, who, by this instrument, ratify that they have read and accepted this Privacy and Data Protection Policy, expressly authorizing ASBFC to collect and carry out the processing of the data in question as described in this instrument.

Personal information is individually identifiable information and consists of any information that allows an individual to be identified, including, but not limited to, their name, fixed or email address, personal qualifications, registration with CPF/MF or CNPJ/MF, telephone number, other contact details, billing details or any other data that may be sufficient to be linked to this information.

Non-personal information may also be collected about visitors and users whenever they interact with the website. This information includes, but is not limited to, IP addresses, browser details, date and time stamps and referring pages. None of this information can personally identify specific visitors to the ASBFC's website.

Information and data are collected, stored, organized, used, circulated, transmitted, transferred, updated, rectified, suppressed, eliminated and administered in accordance with the nature of the data and the purposes established in this Policy.

ASBFC has access to the data of its customers, employees, sponsors or anyone with whom the association has established or establishes a permanent or occasional relationship.

This data is collected and processed for the following purposes:

(i) Obtain generic statistics to identify the profile of visitors and users, such as their interests, behaviors and demographics to better understand their needs and interests and, thus, offer more relevant content and services and provide a better online experience;

(ii) Improve ASBFC's commercial and promotional initiatives and analyze the pages visited and searches carried out by visitors and users to improve the offer of content and services;

(iii) Resolve any legal issues related to the visitor and user access portal;

(iv) Inform about new products or services and/or changes made to them;

(v) Evaluate the quality of the service and send satisfaction surveys or any other mechanisms to evaluate the quality of services provided by ASBFC;

(vi) Carry out market research and studies on consumption habits, statistical analyzes and reports on the behavior of customers, users and the public that access the different advertising solutions;

(vii) Carry out analyzes and define the profile of customers, users and the public that access different advertising solutions and that allow products and services to be defined more in accordance with their purchasing and contracting preferences;

(viii) Send to physical mail, electronic mail, cell phone or mobile device via text message (SMS and/or MMS) or through any other analogous and/or digital means of communication created or to be created, commercial, advertising or promotional information about products and/or services, events and/or promotions of a commercial or non-commercial nature, in order to promote, invite, direct, execute, inform and, in general, carry out campaigns, promotions or competitions of a commercial or advertising nature, in advance by ASBFC and/or third parties;

(ix) Provide, share, send or deliver your personal data to affiliated, linked or subordinate associations of the association located in Brazil or any other country in the event that such associations request the information for the purposes indicated here;

(x) Allow consultation of third parties who wish to contact the Holder, with the aim of corroborating their information and/or carrying out any of the activities described in this instrument;

(xi) Use the information provided by the Holder in order to contact new potential customers to offer ASBFC products and services;

(xii) Any other activity of a similar nature to those described above that is necessary to develop the corporate purpose of ASBFC;

(xiii) Develop and offer loyalty and benefit programs for customers.

The information requested from visitors and users is necessary to improve and personalize the experience of accessing, browsing, purchasing products and contracting services on the ASBFC website or on its social media.

This information will not be used beyond the hypotheses provided for in this document and any use will always be linked to the guidelines outlined by the ASBFC in this Privacy and Data Protection Policy.

For the processing of personal data of children and adolescents, the procedure will be in accordance with that set out in this Policy in the paragraph relating to their rights.

If personal data is provided, this information will only be used for the purposes indicated here and, therefore, ASBFC will not sell, license, transmit or disclose it, except:

(i) there is express authorization to do so;

(ii) is necessary to enable contractors or agents to provide the services ordered;

(iii) is necessary in order to provide our services and/or products;

(iv) it is necessary to disclose it to entities that provide marketing services on behalf of ASBFC or other entities with which there are joint market agreements;

(v) the information is related to a merger, consolidation, acquisition, divestment or other restructuring process of the company;

(vi) that is required or permitted by law.

ASBFC may outsource the processing of certain functions or information. When the processing of personal or corporate information is actually outsourced, or personal information is provided to third party service providers, the ASBFC warns these third parties of the need to protect this personal information with appropriate security measures, the use of the information for own purposes and it is requested that personal information not be disclosed to others.

2. PERROGATIVES OF PERSONAL DATA

In accordance with current applicable data protection regulations, holders of personal data have the following rights:

(i) Access, understand, update and rectify your Personal Data before the ASBFC or those responsible for processing it. This right may be exercised, among others, for partial, inaccurate, incomplete, fragmented, misleading data, or those whose processing is expressly prohibited or has not been authorized;

(ii) Request proof of the Authorization granted by the ASBFC to process data using any valid means, except in cases where, according to the law, authorization is unnecessary;

(iii) Submit requests to the ASBFC or the person responsible for processing regarding the use made of your Personal Data and that such requests present this information;

(iv) Submit complaints for violations of the Law to the competent bodies, prior to processing the consultation or request before the ASBFC;

(v) Revoke your Authorization and/or request the deletion of your Personal Data from the ASBFC databases when, in the Processing, constitutional and legal principles, rights and guarantees are not respected;

(vi) Know the changes to the terms of this Policy in advance and efficiently to implement the new changes or, failing that, the new information processing policy;

(vii) Have easy access to the text of this Policy and its modifications;

(viii) Access in an easy, simple and free way your Personal Data that is under the control of ASBFC and has been subject to processing, at least once a month, and each time there are significant changes to this policy that motivate new consultations;

(ix) Know the person dependent on or provided by ASBFC to whom complaints, questions and any other request may be made regarding your Personal Data;

(x) In accordance with Article 10, §3, of Law No. 12,965/14 or related legislation in force, the ASBFC informs that it is legally obliged to disclose registration data that informs personal qualifications, affiliation and address to the legally qualified administrative authorities.

These rights may be exercised:

(a) By the holder, who must sufficiently prove his identity through his identification document in the original format;

(b) By the holder's assignees, who must prove this status in the legally established manner;

(c) By the representative and/or attorney of the holder, with prior proof of representation or power of attorney, in the legally established form;

(d) By another person in favor of or for whom the holder has stipulated the aforementioned right, through a written document.

3. RIGHTS OF CHILDREN AND ADOLESCENTS

The ASBFC declares that it does not collect personal data from minors and it is the responsibility of the parents or legal guardian(s) to ensure the privacy of minors, doing everything possible to ensure that they have authorized the collection and use of the minor's personal data.

Likewise, when processing personal data, respect for the prevailing rights of minors will be guaranteed.

4. APPROVAL OF SENSITIVE DATA PROCESSING

If sensitive personal data is collected, the holder may refuse to authorize its processing.

5. PROTECTION OF INFORMATION COLLECTED

ASBFC will seek to maintain the privacy of personal information and access information stored on its servers, committing to use technology that is sufficiently adequate to protect such data, in order to maintain a safe environment, using appropriate tools and controls efficient security of the information collected, always observing the available state of the art, in accordance with the LGPD, and with Law No. 13,709, of August 14, 2018. However, despite the ASBFC's efforts in trying to protect the information of visitors and users, it is unanimous that no security system is absolutely safe. Therefore, ASBFC is exempt from any responsibility for any damages and/or losses resulting from an invasion of its website, its servers and other failures related to the security of the data collected, unless there is intent or fault on the part of ASBFC.

The provisions of the previous item also apply to information relating to financial records. This is because all online credit card purchases are made securely, through third-party service providers and payment gateways that comply with the PCI DSS (Payment Card Industry Data Security Standard).

All personal data of visitors and users will be stored in an automated data archive. Users, when registering with ASBFC, authorize this transfer of their data to the above database.

Financial data (credit or debit card numbers) obtained through online transactions are not stored, nor is information transmitted to third parties, except when ASBFC is legally obliged to do so, with the scope of helping to reduce fraud or to provide a requested service and minimize credit risks.

ASBFC professionals are aware of this Privacy and Data Protection Policy and only qualified and authorized personnel are allowed to access the information collected by ASBFC, under penalty of suffering disciplinary action in case of violation of the rules set out here.

6. INFORMATION SHARING

Once the user has registered on the website, ASBFC will not share personal information, except in the ways established in this Policy. Likewise, personal or non-personal information collected from visitors will not be shared under any circumstances, except for the situations set out in this Policy.

However, it may occur that, due to court orders or legal provisions, ASBFC is compelled to reveal information to competent authorities or third parties under certain circumstances. In these cases, visitors and users are aware and agree that ASBFC provides the requested information, being absolutely exempt from any responsibility for the information that may be revealed.

7. PRODUCTS AND SERVICES

Any product sold or service provided by ASBFC to duly registered customers and sponsors will have all pertinent information, such as, but not limited to, items, specifications, quantity, values, delivery times, validity and duration, in accordance with the clauses, terms and conditions described in the respective product purchase and sale and sponsorship contracts (provision of advertising services on television or streaming channels and social media).

For Public-Private Partnership (PPP) contracts, such instruments will be published according to their respective notices, in accordance with Law No. 12,527/2011 (Access to Information Law).

8. DATA RETENTION

ASBFC will store the personal and non-personal information of visitors and users for an indefinite period of time, retaining user information even after the end of their registration or license.

ASBFC may continue to retain personal information, even after the USER deactivates their Account, ceasing to use any specific services or products, as deemed necessary to comply with any legal or regulatory obligation to which ASBFC is subject, or for the purposes of exercising of any right of the ASBFC in a judicial or extrajudicial proceeding, or in the cases mentioned in Article 16 of Law No. 13,709, of August 14, 2018.

9. CHANGES TO THIS PRIVACY POLICY

This Privacy and Data Protection Policy is subject to constant improvement and improvement to ensure greater transparency and security for visitors and users. Therefore, ASBFC reserves the right to unilaterally modify this instrument at any time.

In case of modification of this Privacy and Data Protection Policy, ASBFC is obliged to inform visitors and users of the content of the modifications made, as provided in § 6 of Article 8 of Law No. 13,709, of August 14, 2018 .

By continuing to access the ASBFC website after the modifications come into effect, visitors and users will automatically agree and accept the content of the modifications made.

10. FINAL PROVISIONS

In case of any doubts regarding this instrument or ASBFC, visitors and users should contact the Customer Service Center by the Contact Form in the homepage.