Policy Privacy

1. general information and definitions

Macler Chemical Products Ltd. values the privacy of its customers, employees and suppliers. This policy reaffirms its commitment to protect your privacy and personal data in accordance with the Data Protection Act and other applicable laws, and describes how your privacy is protected throughout the information life cycle, from handling, storage, transport and disposal. This policy applies to all customers, employees, suppliers and all those who are in any way related to Macler Produtos Químicos Ltda.

1.1. definitions

• Holder: natural person to whom the personal data that is the subject of processing relates; • Personal Data: any information relating to an identified or identifiable natural person. Sensitive Personal Data: personal data concerning racial or ethnic origin, religious belief, political opinion, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data. Processing: any operation performed with personal data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of the information, modification, communication, transfer, dissemination or extraction; Controller: a natural or legal person, governed by public or private law, who is responsible for decisions regarding the processing of personal data; • Operator: a natural or legal person, governed by public or private law, who performs the processing of personal data on behalf of the controller; • Purpose: the goal, the purpose to be achieved from each processing of personal information. • Legal bases: legal grounds that make it legitimate to process personal data for a particular purpose. • Consent: free, informed, and unequivocal manifestation by which the data subject agrees with the processing of his/her personal data for a specific purpose; • Duty Officer: person appointed by the controller and operator to act as a communication channel between the controller, the data holders and the National Data Protection Authority (ANPD); • Cloud: cloud computing is the provision of computing services, including servers, storage, databases, networking, software, analytics and intelligence, over the Internet (“the cloud”) By using the services provided by Macler Chemical Products Ltd., the Cardholder declares to have full and express capacity to accept the terms and conditions of this Privacy Policy for all legal purposes. In case the Holder does not agree, even partially, with the terms and conditions contained in this Privacy Policy, he shall not access and/or use the services offered by Macler Produtos Químicos Ltda.

2. COLLECTION AND USES OF PERSONAL INFORMATION

The Holder is aware that he provides information on a conscious and voluntary basis. The Personal Data requested will be kept confidential and will be used only for the purpose that motivated the registration, according to the Table of Purposes.

3. TRANSFERS OF DATA TO OPERATORS

Macler Chemical Products Ltd. does not share Personal Data collected with any other company without your express consent. However Macler Chemical Products Ltd. may transfer Personal Data collected to third party operators in the following situations and within the limits required and authorized by Law: • With suppliers and partners for the execution of services contracted with Macler Chemical Products Ltd. (such as information technology, accounting, among others); • With companies and individuals contracted to perform certain activities and services on behalf of Macler Produtos Químicos Ltda; For administrative purposes such as research, planning, service development, security and risk management. When required as a result of a legal obligation, a determination by a competent authority, or a court order. In the event that we transfer Personal Data to third parties, we take contractual safeguards to ensure that such data is used in accordance with the purposes for which it was collected and in accordance with all applicable privacy and data protection laws.

4. DISCLOSURE OF YOUR DATA

Under certain circumstances, Macler Chemical Products Ltd. may disclose personal data, to government agencies, consultants and other third parties for the purpose of complying with applicable law or with a court order or a court subpoena, or if Macler Chemical Products Ltd. believes in good faith that such action is necessary to: • Comply with a law requiring such disclosure; Investigate, prevent, or take action regarding suspected or actual illegal activities or to cooperate with government agencies or to protect national security; Performing its contracts; Investigate and defend against any claims or allegations from third parties; • Protecting the security or integrity of the services (for example, sharing with companies that are experiencing similar threats); Perform or protect the rights, property, and safety of Macler Produtos Químicos Ltda; • To protect the rights and personal safety of its employees, customers or the public; • In the event of the sale, purchase, merger, reorganization, liquidation or dissolution of Macler Produtos Químicos Ltda. Macler Chemical Products Ltd. will make the respective Holders aware of any legal demands that result in the disclosure of personal information, unless this disclosure is prohibited by law or prohibited by a court order, or even if the request is emergency.

5. SECURITY OF PERSONAL INFORMATION

All Personal Data will be stored in databases maintained in the cloud by service providers hired by Macler Chemical Products Ltd., which are in accordance with current data legislation. Macler Chemical Products Ltd. and its suppliers follow the best Information Security practices to protect the privacy, security and integrity of your Personal Data, preventing eventual damages due to the treatment of this data. Although Macler Chemical Products Ltd. uses security measures and monitors its system to check for vulnerabilities and attacks to protect your Personal Data against unauthorized disclosure, misuse, or alteration, the Data Subject understands and agrees that there is no guarantee that the information cannot be accessed, disclosed, altered, or destroyed by violation of any of the physical, technical, or administrative safeguards.

6. RETENTION OF DATA

Macler Chemical Products Ltd. holds all data provided, including sensitive personal data, for as long as the registration is active and as needed to perform its services. Macler Chemicals Ltd will retain your Personal Data and keep your data stored until you request deletion, or in accordance with the periods described in the Table of Purposes. Macler Chemical Products Ltd. may keep your personal data after receiving your request for deletion or after the time limits in the Table of Purposes if necessary to comply with legal obligations, resolve disputes, maintain security, prevent fraud and abuse, and enforce contracts.

7. LEGAL BASIS FOR PROCESSING

The processing of Personal Data occurs only in situations in which it is legally authorized or with the express and unequivocal consent of the Holder. Each data processing is supported by a legal basis defined by the General Data Protection Act and are specified in the Table of Purposes. If you have any questions about the legal basis for the collection, processing and storage of your personal data, please contact the Data Controller via the channel described in the Contact section.

8. RIGHT TO ACCESS AND CONTROL YOUR PERSONAL DATA

In addition to clearly demonstrating in the Table of Purposes what data are processed, their purpose and legal basis, Macler Chemical Products Ltd offers means for the Holder to control their personal data, these being: Requesting information: The Holder may request whether their data is handled by Macler Chemical Products Ltd. and what this data is. Requesting alteration or correction: the Holder can request the adjustment of some of his/her personal data. Request deletion: the Holder may request the deletion of his/her personal data. These will be deleted if they are not necessary for compliance with legal obligations. The Holder may make the requests listed above by contacting our Data Controller through the channel described in the Contact section, and these requests will be considered if they comply with applicable laws.

9. Political & Policy Reviews

If Macler Chemical Products Ltd. changes this Privacy Policy, such changes will be posted conspicuously on the Macler Produtos Químicos Ltda website. This Policy is effective from November 1, 2021. In case the Holder has any questions regarding the privacy policies, please contact Macler Produtos Químicos Ltda, through the channel described in the Contact Us item.

10. CONTACT

Macler Chemical Products Ltd. has appointed Larissa Kuehn as Data Controller. The Data Subject may contact her at macler@macler.com.br.

11. PURPOSE CHART