COSTAO DO SANTINHO PRIVACY POLICY

Last Updated on 01/05/2024

I. COSTAO DO SANTINHO and YOU

For us at Costao do Santinho, privacy, security, and transparency are very important pillars, so we emphasize our commitment to adopting best practices to ensure the integrity and confidentiality of everyone's personal data. By accepting this privacy policy, you agree with what we present in this document regarding how Costao do Santinho collects, stores, processes, and uses each of the data provided or captured from our customers, visitors, and employees. Additionally, you give Costao do Santinho full and general authorization to continue using your personal data under this privacy policy, meeting all the requirements of law no. 13,709/2018 - General Data Protection Law.

II. TERMS

Whenever the terms “Costao do Santinho”, “we”, “ours” or “Organization” are used, it is understood that we are referring to Costao do Santinho TURISMO E LAZER LTDA, located at Estrada Vereador Onildo Lemos, 2505, Ingleses, Florianópolis/SC, ZIP code: 88.058-700. Now, when this policy refers to “you”, “customer”, “your”, “yours” or “employee”, we are referring to you. When referring to “Personal Data”, it means any information that can identify or make an individual identifiable.

III. APPLICATION OF THIS POLICY

This privacy policy applies to: a) customers of Costao do Santinho: contractors and users of our services and products (individuals or legal entities);

b) prospects of Costao do Santinho: people approached by Costao do Santinho or who have already requested service contracting and have not yet become customers;

c) apartment owners at Costao do Santinho;

d) members of Costao do Santinho Vacation Club, people who purchased the Vacation Club title;

e) prospects of Costao do Santinho Vacation Club: guests and participants of actions and drawings who have not yet acquired the title of Costao do Santinho Vacation Club;

f) job applicants at Costao do Santinho;

Costao do Santinho will collect your data whenever you: a) Access and navigate the website www.costao.com.br, blogs, or related pages; b) Use the Costao do Santinho mobile app; c) Contract or use our services; d) Contact us through our service channels; e) Be invited or participate in the Costao do Santinho Vacation Club Program; f) Become an apartment owner at Costao do Santinho; g) Use SPA services; h) Apply for job vacancies on our website; i) Participate in programs and activities requiring information or prior authorization; j) Subscribe to Costao do Santinho newsletters or promotions; k) Participate in surveys or promotions conducted by Costao do Santinho.

IV. DATA COLLECTED BY COSTAO DO SANTINHO

Costao do Santinho collects and processes four types of information: a) information actively entered by you when registering; b) data collected automatically when accessing the website, app, or web pages, such as the identification of the commercial establishment used, IP with date and time of connection, among others; c) Public data provided by you and information made public by you, as well as mentions or interactions with Costao do Santinho, such as testimonials about Costao do Santinho posted on profiles, review sites, and social media pages, including images and videos; d) Transaction data, i.e., information about negotiations conducted, executed or not, access to our systems, service usage data, and customer service history; Regarding the information you provide, Costao do Santinho collects everything actively entered, such as full name, email, gender, date of birth, CPF, affiliation, nationality, profession, declared income, phone, city, state, and biometric data, such as document photos, among others. As for automatically collected data, it is possible to collect information about access device characteristics, browser, IP (with date and time), IP origin, geolocation data, click information, accessed pages, subsequent pages accessed after leaving the Pages, or any search term entered on the sites or referring to these, among others. This collection is done using technologies such as cookies, pixel, tags, caches, beacons, and local shared objects, used to enhance the User's browsing experience on the Pages according to their habits and preferences. It is noteworthy that it is possible to disable, through your internet browser settings, the automatic collection of information through some technologies, such as cookies and caches. However, the User should be aware that if these technologies are disabled, some features offered by the site, which depend on processing the mentioned data, may not function correctly. V. SHARING OF INFORMATION The collected information may be shared by the organization with: a) other partner companies when necessary for the proper provision of services targeted by their activities; b) to protect the organization's interests in any type of conflict; c) by court decision or request from a competent authority. Furthermore, we clarify that your information may also be shared with companies providing technological and operational infrastructure necessary for Costao do Santinho's activities, such as payment intermediaries and information storage service providers. You can access, update and add your data, and you can also request the deletion of your data collected by Costao do Santinho by contacting via email tic@costao.com.br. We will make efforts to respond to you as quickly as possible, respecting the storage periods established by the law. VI. HOW COSTAO USES THE DATA COLLECTED Costao do Santinho uses the collected data to fulfill legal or regulatory requirements, to deliver services, and to personalize your experience. It also uses it for fraud prevention and to ensure your security in identification and authentication processes, market and opinion research, dissemination of products and services provided by Costao do Santinho on social networks, websites, or institutional and advertising materials. The collected information aims to establish a contractual relationship with the management, administration, provision, expansion, and improvement of services provided and the Pages to the User, adapting them to their preferences and tastes, as well as creating new services and products to be offered to Users. It is worth noting that when you contact Costao do Santinho providing your data, all captured information will be maintained in a secure and controlled environment and may continue to be stored for an additional period to ensure Costao do Santinho's rights in legal or aforementioned situations. Additionally, the collected information may be used for advertising purposes, such as sending information about brands, products, Costao do Santinho promotions, as well as publicizing events, or conducting purchase satisfaction surveys, with the consent of the data subject for such. If you no longer wish to receive promotional information from the organization, you can contact the organization via email at tic@costao.com.br at any time. Legal Basis: In these cases, data processing is authorized by item I of article 7 of Law no. 13,709/2018, the General Data Protection Law (“General Data Protection Law – LGPD”). VII. HOW, WHEN, AND WITH WHOM COSTAO SHARES YOUR INFORMATION We share personal data with third parties to expand communication resources with you and our partners, as well as to comply with applicable laws and regulations, to protect our rights, and to comply with court orders. Costao do Santinho may also obtain publicly available personal data from the organization's partners, including social networks. However, Costao do Santinho will observe the authorization limitations granted by data subjects to the respective partners. The organization works in partnership with various companies. Therefore, information collected through the Pages may be shared in the following cases: a) With other companies, constituted or operating in any country, committed to using the information for the same purposes indicated in this Policy; b) With partner companies, in the development of the organization's commercial activities; c) To protect the organization's interests in any type of conflict, including legal actions; d) In the case of transactions and corporate changes involving Costao do Santinho, in which case the transfer of information will be necessary for the continuity of services; e) By court order or request from administrative authorities that have legal competence to request it. Costao do Santinho makes the best efforts to preserve the privacy of Users' data. However, no website is entirely secure, and the organization cannot fully guarantee that all information that travels on the pages will not be subject to unauthorized access perpetrated using methods developed to improperly obtain information. For this reason, we encourage users to take appropriate measures to protect themselves, such as keeping all usernames and passwords confidential. Furthermore, when you use our app or browse our websites, you may be redirected to third-party sites or apps, and whenever this happens, the privacy practices will be governed by those third parties' privacy policies and terms of use. Since we cannot be responsible for third-party privacy practices and content, we advise careful reading of the applicable privacy policies to understand how they collect and process your data. VIII. HOW COSTAO DO SANTINHO PROTECTS YOUR INFORMATION The organization will store the collected information on its Pages on its servers or those it has contracted. Costao do Santinho uses reasonable market means and legally required methods to preserve the privacy of data collected on its Pages. Therefore, it adopts the following precautions, in compliance with the security standard guidelines established by Decree no. 8,771/2016, such as: a) using standard and market methods to encrypt and anonymize collected data; b) protecting against unauthorized access to its systems; c) only granting access to where collected information is stored to previously authorized persons. Those who contact the information commit to maintaining confidentiality and aligning with the guidelines of this policy; otherwise, non-compliance will result in civil liability according to applicable legislation. IX. YOUR RIGHTS: With the enforcement of the General Data Protection Law - LGPD, you, as the holder of your personal data, have the right to confirm whether Costao do Santinho processes Personal Data concerning you. Moreover, Costao do Santinho guarantees you the right to access the Personal Data you provided us or that we maintain about you. Additionally, we ensure the following rights: a) Correction of incomplete, inaccurate, or outdated data; b) Privacy and blocking or deletion of unnecessary, excessive, or non-compliant data with the legislation; c) Deletion of data processed with User consent; d) Obtaining information about public or private entities with which the organization shared your data; e) Requesting clarification about how Costao do Santinho processes your Personal Data; f) Revocation of consent and the possibility of not providing consent and the consequences of such refusal. These rights may be exercised through a request for subsequent evaluation and adoption of further actions by Costao do Santinho. If you require any assistance to exercise your rights, you can contact Costao do Santinho as directed in this Policy. You are aware that the deletion of essential information for account management with Costao do Santinho will result in the termination of your registration, with the consequent cancellation of the services then being provided. Costao do Santinho will make every effort to fulfill such requests in the shortest possible time. However, even in case of a deletion request, the minimum information storage period for users of Internet applications, as determined by Brazilian legislation, will be respected. Costao do Santinho is committed to ensuring that Personal Data processing complies with the legislation and respects the rights and interests of personal data holders. The exercise of the rights mentioned above should be made through the email tic@costao.com.br, and your request will be analyzed by those responsible for privacy and personal data protection at Costao do Santinho. X. CHANGES AND UPDATES TO THIS PRIVACY POLICY Costao do Santinho reserves the right to change this Privacy Policy at any time and as many times as necessary, aiming to provide you with greater security, convenience and to improve your experience more and more. Every time a relevant condition of this Privacy Policy is changed, this modification will be validated and effectuated after the new version is posted on our website and/or sent to you by email. We value transparency, so whenever a relevant change is made, we will send a notice to you indicating the updated current version. By continuing to use our products and services after a change in the Privacy Policy, you agree to the new terms. However, you can always express your disagreement through our service channels, if applicable. In cases where changes to this Privacy Policy result in changes to personal data processing practices that require your consent, Costao do Santinho will adopt the measures provided to request your acceptance. It is noteworthy that it is essential to access our Policy periodically. To facilitate this, we indicate at the beginning of the document the date of the last update. XI. REVOCATION If at any time, for any reason, you do not agree with the maintenance of your Personal Data, know that this authorization may be revoked at any time. In general, revocation, however, will only be applicable to the future use of Personal Data. You can revoke your consent by email to Costao do Santinho. XII. LEGISLATION AND JURISDICTION This Policy will be governed, interpreted, and executed following Brazilian Laws, particularly Law no. 13,709/2018, with the jurisdiction of the Capital of Santa Catarina being competent to resolve any doubt arising from this document.

Costao do Santinho wants you to be at ease! If you have any questions or concerns about this Privacy Policy, our data collection and use practices, or a possible breach or privacy violation, you should contact us via email at tic@costao.com.br or atendimento@costao.com.br