Privacy Policy

Privacy Policy and Personal Data Protection

This Privacy Policy explains how Eletrofrio Refrigeração Ltda., registered with the CNPJ under no. CNPJ 76.498.179/0001-10, headquartered at Rua João Chede, 1599 – CIC – CEP 81170-220 – Curitiba – PR (“Company”, “we”), processes personal data on its websites and digital channels. By using the main website at https://eletrofrio.com.br/en/ and its subdomains (“Site”), you (“User” or “you”) declare that you have read and understood this Privacy Policy. This Policy was prepared in accordance with Law No. 13,709/2018, the Brazilian General Data Protection Law (“LGPD”), and other applicable rules.

1. Controller and Data Protection Officer (DPO)

Eletrofrio Refrigeração Ltda. is the Controller of the personal data processed under this Policy. The Data Protection Officer (DPO) is responsible for receiving communications from data subjects and from the Brazilian National Data Protection Authority (ANPD).

DPO: João Bezerra
Email for privacy matters: joao.bezerra@eletrofrio.com.br

2. What personal data we collect

We may collect two types of information about you:

2.1. Non-personal information

This is information that does not allow the direct identification of a natural person. In general, it includes:

• Technical access data, such as browser type and version
• Operating system, screen resolution, device language
• Pages visited, browsing time, clicks, traffic source
• Statistical and aggregated information about Site usage

This information may be collected automatically when you browse the Site.

2.2. Personal information

This is information that identifies or may identify a natural person. For example:

• Full name
• Company/organization and job title
• Email
• Phone number
• City, state, country
• Information provided in text fields (“message”)
• Resume data or professional information in “Careers/Work With Us” forms
• IP address and access log data, when linked to an identifiable user

This data may be collected:

• When you fill out contact forms, quote requests, product/service demos, material downloads, newsletters, “Careers/Work With Us”, or similar
• When you communicate with us by email, phone, messaging apps, or other channels
• Automatically, through cookies and similar technologies, as described in this Policy

3. Legal bases and purposes of processing

We process personal data based on the legal bases provided by the LGPD. The main ones are:

3.1. Performance of a contract or preliminary procedures

We use your data to:

• Respond to requests for contact, quotes, and product or service demonstrations
• Send information about proposals, commercial terms, and contracts
• Maintain relationships with customers, partners, and suppliers

3.2. Compliance with legal or regulatory obligations

We may process and store data to:

• Meet tax, accounting, and regulatory obligations
• Respond to requests from public authorities, when applicable

3.3. Legitimate interest

In certain situations, we process data based on legitimate interest, always considering your rights and expectations. For example:

• Improve the Site’s content, usability, and security
• Maintain access logs for security and fraud prevention
• Send institutional communications related to services already contracted
• Produce internal statistics and reports on the use of our channels

When we rely on legitimate interest, we assess the necessity and impact of the processing, always seeking to respect your privacy.

3.4. Consent

In some cases, we will request your consent, especially for:

• Sending marketing communications, newsletters, and promotional materials
• Using certain non-essential cookies (such as marketing or analytics cookies, when required)

When processing is based on consent, you may withdraw it at any time, as described in this Policy.

4. How we use your personal data

We may use your personal data for the following purposes:

• Respond to your messages and requests submitted through the Site’s forms
• Send information about products, services, events, content, and informational materials
• Maintain and improve our services, the Site, and the user experience
• Comply with legal, regulatory, and contractual obligations
• Contact you for support, service, technical questions, or commercial matters
• Perform statistical and performance analyses of the Site
• Protect our rights, prevent fraud, and ensure system security

5. Sharing of personal data

We may share your personal data with suppliers and service providers who help us operate the Site and deliver services, such as:

1. Suppliers and service providers that assist us in operating the Site and providing services, for example:
   • Hosting and cloud computing companies
   • Marketing automation and CRM platforms, such as RD Station
   • Analytics and measurement tools, such as Google Analytics
   • Advertising platforms, such as Google Ads, Meta Ads, LinkedIn Ads, and TikTok Ads
   • Security and anti-spam tools, such as Google reCAPTCHA and Akismet
   • Font and graphic resource services, such as Google Fonts, Adobe Fonts, and Font Awesome
2. Public authorities, when necessary to:
   • Comply with legal or regulatory obligations
   • Respond to court orders, administrative orders, or requests from competent authorities
3. Corporate transactions, in the event of a merger, acquisition, corporate reorganization, or sale of assets.
   • In such cases, the legal successor may access personal data, in compliance with this Policy and the LGPD.

Whenever possible, sharing is carried out under contracts that include data security and confidentiality obligations. We do not sell your personal data.

6. International transfer of data

In particular, some of the suppliers mentioned (such as Google, Meta, LinkedIn, TikTok, RD Station, hosting providers, and font services) may be located in or process data in other countries. In such cases, we seek to adopt measures to ensure that processing is carried out in compliance with the LGPD, including appropriate contractual clauses and compatible security standards.

7. Cookies, analytics, and advertising tools

We use cookies and similar technologies to:

• Enable the Site to function properly
• Remember browsing preferences
• Measure audience and page performance
• Support digital marketing actions and ad personalization

These technologies may be first-party or third-party. In particular, we may use:

• Google Analytics
  Traffic analytics tool that collects information such as pages visited, browsing time, and access source, helping us understand Site usage and improve your experience. Privacy policy: https://policies.google.com/privacy

• Google Ads
  Advertising platform for campaign delivery and measurement, including remarketing and conversion measurement. Cookies may be used to show more relevant ads and measure campaign results. Privacy policy: https://policies.google.com/privacy

• Meta Ads (Facebook/Instagram)
  We use Meta’s pixel and APIs to measure conversions, build audiences, and optimize campaigns on Facebook and Instagram. This data may be combined by Meta with other information it holds. Privacy policy: https://www.facebook.com/policy.php

• LinkedIn Ads
  LinkedIn conversion pixels and tags may be used to measure campaign performance and improve ad targeting on the platform. Privacy policy: https://www.linkedin.com/legal/privacy-policy

• TikTok Ads
  We may use the TikTok pixel to measure conversions and optimize media campaigns on the platform. Privacy policy: https://www.tiktok.com/legal/page/row/privacy-policy

• RD Station
  Marketing automation and relationship tool used to manage forms, lead nurturing, emails, and segmentation. RD Station may use cookies and identify visits to the Site’s pages. Privacy policy: https://legal.rdstation.com/pt/privacy-policy/

Security tools, fonts, and website resources

In addition, the Site may use:

• Google reCAPTCHA
  Service that protects forms against spam and abuse, analyzing browsing interactions to distinguish humans from bots. Privacy policy: https://policies.google.com/privacy

• Akismet
  Anti-spam service for comments and forms (when applicable). Privacy policy: https://akismet.com/privacy/

• Google Fonts and Adobe Fonts
  Third-party hosted font services that may receive technical information such as IP address and browser data to display fonts correctly. Google Fonts privacy policy: https://policies.google.com/privacy. Adobe Fonts privacy policy: https://www.adobe.com/privacy.html

• Font Awesome
  Icon library used to display graphical elements on the Site, which may collect minimal technical data for content delivery. Privacy policy: https://fontawesome.com/privacy

Cookie management

You can manage the use of cookies:

• Through your browser settings, by blocking or deleting cookies

Blocking essential cookies may affect the operation of parts of the Site. Non-essential cookies (such as analytics and marketing cookies) can be disabled without impairing basic access to content.

8. Data retention period

We store your personal data only for as long as necessary to:

• Fulfill the purposes described in this Policy
• Comply with legal or regulatory obligations
• Preserve the Company’s rights in eventual judicial, administrative, or arbitration proceedings

After this period, data may be:

• Securely deleted
• Anonymized for statistical or research purposes

9. Data subject rights

Under the LGPD, you have, among others, the following rights regarding your personal data:

• Confirm whether we process your data
• Request access to the personal data we hold about you
• Request correction of incomplete, inaccurate, or outdated data
• Request anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data
• Request data portability to another service or product provider, when applicable
• Request deletion of personal data processed based on consent
• Obtain information about public and private entities with whom we share personal data
• Withdraw consent, when processing is based on it
• Request review of decisions made solely based on automated processing, if any

To exercise your rights, you may contact our DPO at joao.bezerra@eletrofrio.com.br or through another channel indicated in our official contacts. For security reasons, we may request additional information to confirm your identity before responding to the request.

10. Information security

We adopt technical and organizational security measures aligned with market best practices to protect your personal data against unauthorized access, loss, misuse, alteration, and improper disclosure. Even so, no system is completely immune to incidents. In the event of a security incident that may entail relevant risk or damage to you, we will take the appropriate measures, including, when necessary, notifying the ANPD and affected data subjects, under the LGPD.

11. Data of children and adolescents

Our websites and services are not intended for children. If we identify the processing of personal data of children or adolescents in violation of the law, we will take the necessary measures to stop such processing and, when applicable, delete the data. If you are a parent or legal guardian and believe your child has improperly provided us with personal data, please contact our DPO.

12. Marketing and communications

We may use your contact data to send:

• Newsletters
• Event invitations
• Content, gated materials, and communications about products and services

You can unsubscribe at any time by using the unsubscribe link in the messages or by contacting us through the privacy channel. When communications are based on consent, withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

13. Updates to this Privacy Policy

We may update this Privacy Policy at any time to reflect changes in our personal data processing practices or to meet legal or regulatory requirements.

When there are relevant changes, we may:

• Post a prominent notice on our Site
• Send an email notification, when appropriate

We recommend that you review this page periodically to check the most recent version of this Policy. At the bottom of this page, we will indicate the date of the last update.

14. Contact

If you have questions, comments, or requests related to this Privacy Policy or the processing of personal data, please contact our DPO:

• DPO: João Bezerra
• Email: joao.bezerra@eletrofrio.com.br

Last update: December 6, 2025