We take your information very seriously. Therefore, this document describes how we will treat (collect, store, process, share, transfer, or in any way use) the information that we have access to due to your visit to the ATENAS institutional website (https://atenas.ag), as well as the privacy practices adopted to safeguard such information.

IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY POLICY OR ABOUT THE ATENAS WEBSITE, before using it, please contact us through our Contact Channels.

If you DO NOT agree with all the terms of this Privacy Policy, you SHOULD NOT access, use, or remain on the Atenas website.

If you have any questions about the processing of your data or wish to exercise your rights, please contact the data protection officer of Atenas through the contact channel expressed in this Policy.

PRESENTATION

Which data does this document refer to? This Privacy Policy concerns information that can identify or allow the identification of a natural person, such as name, email, phone number ("personal data").

Who is responsible for processing your personal data? The controller responsible for processing your personal data is DQ Ativação LDA., a private legal entity, headquartered at Rua de Baixo de São Pedro, nº 37, Angra do Heroísmo, Ilha Terceira, Angra do Heroísmo, Portugal ZIP code 9700-025, registered with NIF under no. 519361610, and branch under no. 08.875.583/0002-97, located at Rua Ribeirão Claro, nº 59, Vila Olímpia, São Paulo/SP, ZIP code 04549-060 ("Atenas").

HOW DO WE OBTAIN (COLLECT) YOUR DATA?

We do not collect or process any personal data of yours due to your visit to the ATENAS institutional website.

PURPOSE OF DATA PROCESSING

For what purposes may personal data be used? Personal data may be used ("Authorized Uses") for the following purposes:
regular exercise of rights, including in judicial, administrative or arbitration processes;
identification and prevention of potential security threats;
cross-referencing them and/or enriching them with other data already in Atenas' possession, or which may be obtained and included in our systems;
improving the products, services, and algorithms of Atenas;
creating new services, products, and functionalities, as well as directing advertisements to data subjects and third parties;
including data among Atenas' assets for any and all commercial purposes, including for corporate restructuring purposes, such as merger, division, or incorporation, or any other form of asset disposal.

The eventual use of personal data for purposes that do not comply with this prerogative will be done with prior notification to You, whenever possible and reasonable.

What is the legitimacy of the processing? The legal bases legitimizing the processing of your personal data are: enforcement of the legal relationship between the parties, compliance with legal obligations, authorizations granted by you in terms of this Privacy Policy, eventual regular exercise of rights in judicial, administrative or arbitration processes, and also the legitimate interest of Atenas.

SHARING AND TRANSFER OF DATA

With whom do we share your information? We will not share your data with any commercial partners, except in cases where it is necessary to share with third parties responsible for providing services necessary for the operation of the site, such as technology suppliers, etc.

International Transfers. Your data may be processed by Atenas' providers, who will ensure their security and confidentiality, and who may be located in Brazil or abroad. In the latter case, there will be an international transfer of data, which will be necessary to enable your access to the Site.

How long will we keep your data? The personal data provided will be kept while the contractual relationship is maintained, its deletion is not requested by you, and it should not be deleted because it is necessary (a) for compliance with a legal obligation or (b) for the formulation, exercise, and defense of claims. If You withdraw your consent or exercise the right to deletion, your personal data will be kept blocked for the legally established periods to meet potential liabilities arising from their processing.

What are your rights? Data Subjects may exercise their rights to confirm the existence of processing, access, rectification, anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data, deletion, in cases where data portability is possible, information from public and private entities with which data sharing was carried out, as well as request limitation or opposition to data processing (in which case the use of services will be limited or prevented) and review of automated individual decisions, by sending a request to the contact address above.

You may exercise your rights against Atenas by sending a request to Atenas' Data Protection Officer (Cleide Rodrigues) at Email: [email protected].

Data subjects may, in any case, lodge a complaint with the National Data Protection Authority, especially when they are not satisfied with the exercise of their rights.

Exclusão dos Dados. Os dados pessoais serão excluídos das bases de dados da Atenas mediante (a) requisição dos titulares dos dados pessoais ou (b) quando estes não forem mais necessários para os Usos Autorizados, salvo se houver qualquer outra razão, base legal ou contratual, para a sua manutenção, como (b.i) eventual obrigação legal de retenção de dados pessoais, (bii) necessidade de preservação destes para resguardo de direitos, (b.iii) interesses legítimos da Kontik ou (b.iv) em razão de ordem judicial.

Therefore, ATENAS RESERVES THE RIGHT TO ACCESS, READ, PRESERVE, AND DISCLOSE ANY DATA NECESSARY TO: COMPLY WITH A LEGAL OBLIGATION OR A COURT ORDER ISSUED BY COMPETENT AUTHORITIES; ENFORCE AND APPLY ANY AGREEMENTS MADE WITH YOU (IF APPLICABLE); PROTECT THE RIGHTS, PROPERTY, AND SAFETY OF ATENAS AND/OR ITS PARTNERS, AND THEIR RESPECTIVE REPRESENTATIVES, SERVICE PROVIDERS, EMPLOYEES, AND USERS.

OTHER INFORMATION

The Parties undertake to follow privacy rules, data protection, confidentiality, or information security requirements, in accordance with best practices and applicable laws, with the aim of ensuring the confidentiality and proper use of data and non-disclosure, except as authorized by this Privacy Policy or relevant legislation.

Under no circumstances will Atenas or any of its partners or suppliers be liable for any offense, negligence, contractual breach or other civil or criminal offense that may be caused by You, being entirely your responsibility to bear all damages, monetary or otherwise, arising from your indirect, direct, or incidental actions, with the Controller's right of recourse for such situations.

Atenas always seeks to maintain technical, physical, and administrative security measures to provide reasonable protection for personal data against loss, misuse, unauthorized access, disclosure, and alteration. Although Atenas maintains these measures, you should keep your information secure and only use secure environments and equipment to make the necessary connections.

Atenas may, as needed, periodically adapt this Privacy Policy.

Depending on the interactions you perform on the site, it is possible that services or products provided directly by third parties may be contracted. In this case, you will be subject to the terms and conditions of this third party. Atenas has no influence on the establishment of these terms and policies. If you decide to use third-party services and applications, you do so at your own risk.

This Privacy Policy is governed by the Laws of the Federative Republic of Brazil.

Last updated: 01/12/2025