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PRIVACY POLICY

VOTORANTIM PARTICIPAÇÕES S. A.

The present Policy regulates the general conditions for the collection, use, storage, handling and protection of data on sites, platforms and Internet applications of Votorantim Participações S. A. and its subsidiaries or direct and/or indirect affiliates (VPAR), in accordance with Act 12.965/2014 (Brazilian Civil Rights Framework for the Internet).

On using VPAR sites, platforms or applications of the Internet you agree expressly and entirely with this Privacy Policy.

THE ACCEPTANCE OF THIS POLICY IS ESSENTIAL FOR THE USE OF THE SERVICES AND FUNCTIONS OF VPAR SITES, PLATFORMS AND INTERNET APPLICATIONS.

I – DATA COLLECTION

VPAR is fully committed to the privacy of the information that may be collected on its sites, platforms and Internet applications.

VPAR´s fundamental managing principle is based on the good moral character and reputation of its professionals and it pledges itself to guarantee, to the maximum extent, its ethical and transparent conduct in handling the information of users of its sites, platforms and Internet applications.

The collection of data on the VPAR sites, platforms and Internet applications is carried out with the following aims:

a. To be highly efficient in the provision of its services and providing the adequate support to carry out its corporate objective;

b. To match the appearance and content to the user´s preferences in order to provide him or her with the fastest , most user friendly and efficient access;

c. To authenticate accesses;

d. To seek adequate security for the services offered and means of identification in the case of improper or illegal uses;

e. To resolve problems and create notification related to the use of VPAR sites, platforms and Internet applications;

f. To keep users informed about the services, alterations in the Terms of Use or in the Privacy Policy, updates or improvements to the VPAR sites, platforms and Internet applications, or also on the status of their accounts and operations;

g. To publicize promotional actions on the VPAR sites, platforms and Internet applications or other VPAR initiatives, always providing ways allowing the user to cancel the receipt of promotional e-mails (opt out);

h. To publicize promotional actions of partner companies that adopt privacy protection measures similar to the present policy, with the prior consent of the user;

i. To check statistical information.

II –COLLECTED DATA

To carry out the above objectives, the VPAR sites, platforms and Internet applications may collect some data based on information:

a. That the user himself or herself has freely provided, through the creation of accounts or the insertion of references related to the user in any context of the VPAR sites, platforms and Internet applications;

b. In the way the user navigates the VPAR sites, platforms and Internet applications, as well as on the registration of access and general interactions on the VPAR sites, platforms and Internet applications. This kind of information may include data:

a. On the device and systems/navigators that the user uses to access the VPAR sites, platforms and Internet applications, including the Internet protocol address (IP number);

b. Likely to identify all and any use and interaction in the context of the VPAR sites, platforms and Internet applications;

c. Relating to the time of each action by the user on the VPAR sites, platforms and Internet applications (date and time);

d. Relating to the location of the user.

e. Provided by external tools or platforms provided by partners and related to the navigator or user account (cookies or anonymous identification methods).

III - STORING, HANDLING AND PROTECTION OF DATA

The data collected through the VPAR sites, platforms and Internet applications is stored, handled and protected through the best practices of hosting, processing, backup and cryptography, according to its respective critical level.

The collected data is maintained in secret.

However, the user should take note that no Internet security system is guaranteed against undesirable invasions, and VPAR´s commitment is limited to the adoption of recommended protection measures, according to the current state of the technique.

Due to the structural features of the Internet, the data collected may be stored or handled abroad.

IV – DATA SHARING

The VPAR sites, platforms and Internet applications only share data: (i) with other companies that are members of the same economic group or controlled by VPAR; (ii) in the circumstances foreseen in this clause; or (iii) with the prior authorization of the user.

The VPAR sites, platforms and Internet applications may use outsourced service providers for the storage or handling of data, providing a contract that assures its secrecy and confidentiality is adopted.

The VPAR sites, platforms and Internet applications may also share data with third parties through a legal order or application by the public prosecutor´s office, police or administrative authority within the terms of article 15, paragraph 3, of Act 12.965/14, or, also, if necessary to comply with any other government law or regulation.

V - MANAGEMENT, CORRECTION AND EXCLUSION OF DATA

VPAR is not responsible for the content or correction, veracity, authenticity, completeness and updating of the data provided by users of its sites, platforms or Internet applications, even in the case of any undue use of information published by users or frauds arising from the abuse of passwords.

It is the exclusive responsibility of the user to provide only information that is correct, true, authentic, complete and up to date, as well as to ensure the secrecy of his/her password, when applicable, and not to divulge it to third parties.

VPAR has an attendance channel for users and to denounce false/incorrect data published on its sites, platforms and Internet applications through the electronic address denuncias@vpar.com.br . This channel can also be used to send any complaints or allegations.

At the express request of the user, via an e-mail sent to denuncias@vpar.com.br , VPAR may exclude from its sites, platforms and Internet applications personal data related to the applicant, closing his/her account/profile, when applicable, except in the case where it is obliged to maintain registrations or data foreseen in law or through a legal order, application by the public prosecutor´s office, police or administrative authority within the terms of article art. 7, X, of Act 12.965/14.

VI – RIGHT OF EDITING AND EXCLUSION OF CONTENT

The VPAR sites, platforms and Internet applications reserve the right to edit or even exclude any content published by users that is not in conformance with the law, its Privacy Policy or Terms of Use.

However, this condition does not mean that VPAR is obliged, except within the terms of art. 15, paragraph 3 of Act 12.965/14, where requests for editing or removal are usually made through a legal order or application by the public prosecutor´s office, police or administrative authority.

VII - SPAM

The VPAR sites, platforms and Internet applications will make the best efforts to avoid the sending of unsolicited e-mails.

Cooperate by sending complaints to denuncias@vpar.com.br should you receive any unsolicited or potential invasive e-mail in the name of VPAR.

VIII - LINKS

The VPAR sites, platforms and Internet applications may contain connections and links to other Internet sites.

VPAR is not responsible for the content, the Terms of Use or Privacy Policy of the sites whose links are published on the VPAR sites, platforms and Internet applications.

IX – ALTERATIONS IN POLICY

The present Privacy Policy may be altered at any time.

The alterations in this Privacy Policy will be announced and highlighted on the VPAR sites, platforms and Internet applications.

X – APPLICABLE LAW AND COMPETENT COURT

Any interpretation of the present Privacy Policy will be based on Brazilian law .

Any law suits related to this Privacy Policy will be dealt with exclusively by the District Court (Foro da Comarca) of São Paulo, São Paulo state, Brazil.

July 2014.