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Privacy Policy

1. INTRODUCTION

The principle of JERA CAPITAL GESTÃO DE RECURSOS LTDA. (“Jera Capital” or “Management Company”) is the respect for the privacy of the information and personal data (“Data”) provided by you, the Data owner (“Owner”).

Therefore, Jera Capital prepared this Privacy Policy (“Policy”) to describe how it collects, stores and uses your Data, based on Law No. 13709/18, the General Data Protection Law (“LGPD”).

2. WHAT DATA CAN WE COLLECT?

The Data processed by Jera Capital may be provided directly or indirectly by the Holder.

No Data will be used in a discriminatory, abusive, unlawful manner or even for a purpose other than that for which it was collected. Jera Capital will use its best efforts and use technical resources to ensure the integrity and confidentiality of the Data it collects.

2.1. DATA PROVIDED DIRECTLY BY THE HOLDER

You can provide us with your Data directly, for example, but not exhaustively, by (i) sending your resume to participate in a selection process; (ii) contact through our website or through the contact email provided therein; (iv) contractual, labor or corporate relationship with Jera Capital; (v) filling out a registration form; among other ways.

When sending Data to Jera Capital, in any of the cases above or others not listed, it is important that you know that your Data will be stored and processed by the Management Company for the necessary purposes.

2.2. DATA COLLECTED INDIRECTLY

Jera Capital can collect your Data indirectly, for example, by receiving documentation for investment analysis of managed vehicles, such as corporate information of target and investee companies, which contain Data of its employees, directors, officers, partners, shareholders, among others.

Even if this Data reaches Jera Capital indirectly, the Management Company, within the limits of its attributions, does everything possible to ensure that the person responsible for collecting and storing such Data informs the Holder that he/she may eventually share them with third parties.

In addition, Jera Capital cares that its business partners are in compliance with LGPD procedures.

2.3. CONSIDERATIONS ABOUT SENSITIVE PERSONAL DATA

The Management Company’s practice is to collect sensitive personal data for records relating to the health insurance of its employees, as well as medical reports and examinations, when necessary for legal reasons and to protect the employees’ health.

The Management Company keeps all sensitive personal Data strictly for legal purposes with the express consent of the Holders and those responsible for it for a specified period and with restricted access by employees and third parties responsible for processing them.

If Data of this nature is voluntarily provided by a Holder for purposes other than those previously reported, such Data will be processed exceptionally and under provisions of LGPD, and may be immediately discarded if there is no specific purpose for processing them.

2.4. CONSIDERATIONS ABOUT PERSONAL DATA OF CHILDREN AND ADOLESCENTS

Data on children and adolescents is collected specifically for compliance with legal obligations and for the execution of a contract between Jera Capital and its employees and clients. This Data is provided by parents or legal guardians with specific consent and as required by the LGPD.

3. WHAT DO WE DO WITH YOUR DATA?

Depending on the type of relationship you establish with Jera Capital, your Data may be used, but not limited to, for example, (i) due diligence; (ii) compliance with legal and/or regulatory requirements; (iii) carrying out commercial or business practices inherent to the activity of the Management Company and the contract signed with it; among other lawful activities linked to the regular exercise of the activities of Jera Capital, as provided for in our business purpose.

In addition, in order to carry out our third-party asset management activities, it is necessary to share information about the vehicles managed by Jera Capital, its investments and investors with other service providers of these vehicles. Examples are the trustee, in addition to any legal, accounting, payment, controllership, custody, commercial and consulting advisors specializing in administrative, financial, research, security matters, among others (“Service Providers”, see item 5.1 below).

Jera Capital can also use your Data for commercial actions such as forwarding invitations to events and communicating the launch of new products and services.

It should be noted, however, that there will always be the option of not receiving new emails with contacts or commercial information from Jera Capital.

For more specific information about how your Data is used, please contact us through the LGPD Channel, as per item 7 of this Policy.

4. HOW DO WE STORE YOUR DATA?

When your Data is stored on Jera Capital’s own network, it is allocated in specific directories, according to the person responsible for processing it, whose access is segregated by type of function and authenticated by a personal password.

In this sense, the highest standards of technological and physical security are adopted to protect your Data against loss, misuse, unauthorized access, alteration, and destruction.

In the case of offshore investments, if your Data is stored by third parties in national or international territory, compliance with the LGPD by this third party is always evaluated by Jera Capital to ensure that your Data is protected.

Your Data is stored for as long as necessary, according to the storage time defined by Jera Capital for each type of Data, in accordance with the purpose for which it was collected and consented. For information about your Data, simply request it through the LGPD Channel, as per item 7 of this Policy.

5. DATA SHARING

The Data sharing assumptions will depend on the nature of your relationship with Jera Capital. Data will be shared only when necessary for the regular exercise of the activities of the Management Company, as mentioned in this Policy.

5.1. SERVICE PROVIDERS

Eventually, your Data may be shared with service providers, so that Jera Capital can achieve the purpose stated when collecting your Data.

Service providers go through a due diligence process, which includes verification of aspects related to Data processing, so that there is final approval and eventual hiring by Jera Capital.

It is also worth mentioning that the sharing of Data with third parties will always comply with the provisions of this Policy, in addition to the regulations and legislation in force.

5.2. DATA DISCLOSED DUE TO LEGAL MATTERS

In certain circumstances, we may be required to disclose your Data, such as by court order or administrative order, for defense in judicial or administrative proceedings; compliance with applicable law or regulation; protection of Jera Capital’s rights; and fulfillment of different contracts.

In line with the principles of transparency adopted by Jera Capital, depending on the circumstances and whenever allowed, the said disclosure of Data will be communicated to the Holder.

6. YOUR RIGHTS AS DATA HOLDER

You can, at any time and free of charge, request through our LGPD Channel:

(i) confirmation of Data stored by Jera Capital, and access this Data;
(ii) correction of incomplete, inaccurate or outdated Data;
(iii) anonymization, blocking or deletion of unnecessary, excessive or processed Data in violation of the LGPD;
(iv) information about the possibility of not providing your consent for the processing of any of your Data and what are the negative consequences of this action;
(v) that consent to the processing of your Data be revoked;
(vi) deletion of the Data processed with the consent of the Holder;
(vii) information on the entities with which your Data has been shared; and
(viii) any other acts provided for in the LGPD or that may be granted by law or regulation in force.

Jera Capital will always endeavor to respond to your requests, unless this is not possible for legal or regulatory reasons or due to the nature of your relationship with Jera Capital.

In any case, requests will always be answered in a timely, clear, reasoned and cost-free manner, regardless of the possibility of being executed or not.

7. GDPL CHANNEL

You may exercise any rights described in item 6 above or clarify doubts about the processing of your Data by Jera Capital through our LGPD Channel, which can be accessed at www.jeracapitalcom.br/politica-privacidade, which also contains the contact information for the Management Company’s Data Supervisor (DPO): e-mail privacidade@jeracapital.com.br.

Depending on the complexity of the content, your request may be answered immediately or within a maximum of 15 (fifteen) days/ period defined by law.

8. UPDATES TO THIS POLICY

Jera Capital reserves the right to change the way of processing Data, at any time and whenever necessary, to adapt to its activities and better execution of its services. In this case, this Policy will be updated on our website.