Privacy Policy.

1. Data Controller

GENUO TECNOLOGIA EM COMPRAS E SERVIÇOS LTDA
Brazilian Tax ID (CNPJ) 63.360.512/0001-89
Headquarters: Rua 3300, 341, Sala 13 — Centro
Balneário Camboriú/SC · ZIP 88330-272 · Brazil
Contact: contato@genuo.com.br · +55 (47) 3363-3952

2. Data Protection Officer (DPO)

For any matter related to this Policy or exercise of data subject rights: contato@genuo.com.br (with subject "DPO — Data Protection"). The DPO's name and direct contact will be published after formal appointment.

3. What Data We Collect

3.1 Data you provide

Category	Examples	Source
Identification	Full name, corporate email, phone	Form, registration
Professional	Company, position, role	Form, registration
Transactional	Quotes, orders, commercial history	Platform usage
Corporate	Tax ID, legal name, address, homologation documents	Homologation process
Communications	Messages sent via form or platform	Active communication

3.2 Data collected automatically

Category	Examples
Navigation	IP address, browser, OS, pages visited, time on site
Cookies	Session identifiers, language preferences, aggregate analytics
Usage logs	Records of actions on the platform (Genuo Footprint) for audit

4. Processing Purposes

• Service delivery: providing platform features (quotation, homologation, recommendation, audit);
• Communication: responding to requests, sending operational notifications and support;
• Personalization: tailoring content and recommendations to user profile;
• Analytics and improvement: aggregate metrics for product evolution;
• Legal compliance: meeting tax, regulatory, and labor obligations;
• Security: preventing fraud, abuse, and Terms violations;
• Direct marketing: commercial communications with opt-out option.

5. Legal Bases (LGPD art. 7 and 11)

• Contract performance — for delivering contracted services;
• Compliance with legal or regulatory obligation;
• Legitimate interest — for security, product improvement, and direct marketing;
• Consent — when expressly requested;
• Regular exercise of rights in administrative, arbitration, or judicial proceedings.

6. With Whom We Share Your Data

• Technology providers (cloud, infrastructure, email, analytics), under data protection agreements (DPA);
• Registered sellers and buyers, exclusively the data needed to enable intermediated transactions;
• Public authorities, in compliance with legal obligation or court order;
• Commercial partners, only with express consent or under a contract signed by the data subject.

Genuo does not sell personal data.

7. International Transfer

When the service involves international data transfer (e.g., cloud providers in other jurisdictions), Genuo will adopt safeguards provided by applicable law (standard contractual clauses, certifications, or binding corporate rules).

8. Data Subject Rights

You have the right to:

• Confirm the existence of processing;
• Access your data;
• Correct incomplete, inaccurate, or outdated data;
• Request anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data;
• Request portability to another provider;
• Request deletion of data processed based on consent;
• Information about entities with which Genuo has shared your data;
• Information about the possibility of not providing consent and its consequences;
• Withdraw consent;
• File a complaint with the national data protection authority (ANPD in Brazil, or local equivalent).

To exercise these rights, send a request to contato@genuo.com.br. Response within 15 (fifteen) business days.

9. Cookies

The Genuo platform uses cookies for functionality, security, analytics, and personalization. You can manage cookie preferences in your browser settings. Disabling essential cookies may impair the user experience.

10. Information Security

• Encryption in transit (TLS/HTTPS) and at rest where applicable;
• Role-based access control (RBAC);
• Audit trail (Genuo Footprint);
• Continuous security monitoring;
• Periodic team training.

In the event of a security incident that may pose a risk or relevant damage to data subjects, Genuo will notify the competent authority and affected data subjects within a reasonable timeframe.

11. Retention and Disposal

Data is retained for the period necessary to fulfill the purposes for which it was collected, observing applicable legal periods. After that period, data is anonymized or securely deleted.

12. Children and Adolescents

The Genuo platform is intended exclusively for legal entities and their representatives over 18 years old. We do not intentionally collect data from minors.

13. Changes to this Policy

This Policy may be updated periodically. Material changes will be communicated at least 30 (thirty) days before entering into force.

14. Governing Law and Jurisdiction

This Policy is governed by Brazilian law, with emphasis on LGPD (Law No. 13,709/2018). The forum of the District of Balneário Camboriú/SC, Brazil, is elected to resolve disputes.

15. Contact

Email: contato@genuo.com.br
Phone: +55 (47) 3363-3952
Address: Rua 3300, 341, Sala 13 — Centro · Balneário Camboriú/SC · ZIP 88330-272 · Brazil