The MedSystems Group takes your privacy seriously and ensures the security and data protection of all its partners, suppliers and users of the http://grupomedsystems.com.br/ website.

This Privacy Policy is intended to inform you about how we use and disclose information collected from your visits to our website and from messages we exchange with you, and applies only to information collected through this website.

By accessing the website, sending communications or providing any type of personal data, you declare that you are aware of the terms set forth herein and agree to the privacy policy, which describes the purposes and forms of processing of your personal data made available on the website.

This Privacy Policy provides an overview of our privacy practices and the choices you can make, as well as rights you can exercise in relation to Personal Data processed by us. If you have any questions about our use of Personal Data, please contact [email protected].

Our privacy policy has been drawn up in full compliance with current legislation and may be updated as a result of regulatory changes, which is why we invite all our clients and users to consult and access this section from time to time.

Section 1 — Definitions

For the purposes of this Privacy Policy:

• Personal Data: means any information that directly or indirectly identifies or can identify a natural person, such as name, CPF, date of birth, IP address, among others;
• Sensitive Personal Data: means any information that reveals, in relation to a natural person, racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data concerning health or sex life, genetic or biometric data;
• Processing of Personal Data: means any operation carried out with regard to Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or, alternatively, making available, harmonization or association, restriction, erasure or destruction. Any other operation provided for under the terms of the applicable legislation is also considered to be the Processing of Personal Data;
• Data Protection Laws: means all legal provisions regulating the Processing of Personal Data, including, but not limited to, Law No. 13,709/18, the General Personal Data Protection Law (“LGPD”).

Section 2 — Purpose of Using Personal Data

We collect and use Personal Data to manage your relationship with us and improve our service, personalizing your experience according to your preferences. Examples of how we use data include:

• Enable you to contact the website;
• Confirm or correct the information we have about you;
• Send information that we believe may be of interest to you;
• Personalize your experience using the website;
• Contact us through the telephone number and/or email address provided. We may contact you by voice message, through automatic dialing equipment, by text messages (SMS), by e-mail, or by any other means of communication that your device is capable of receiving, in accordance with the law and for reasonable business purposes.

In addition, the Personal Data provided may also be used as we deem necessary or appropriate: (a) under Data Protection Laws; (b) to meet the requirements of legal process; (c) to comply with a court order, regulatory decision or decision of competent authorities, including authorities outside your country of residence; (d) to enforce our Terms and Conditions of Use; (e) to protect our operations; (f) to protect our, your or any third party’s rights, privacy or safety; (g) to detect and prevent fraud; (h) to enable us to use available remedies or limit damages that we may suffer; and (i) in other ways permitted by law.

Section 3 – Failure to provide Personal Data

There is no obligation to share the Personal Data we request. However, if you choose not to share it, in some cases we will not be able to provide you with full access to the website, some specialized features or be able to provide the necessary assistance to you.

If you agree to provide personal data when using the website, in order to safeguard and protect the rights of third parties, you must only provide your personal data.

Section 4 — Data Collected

The general public will be able to browse the website without having to register or submit any Personal Data. However, some of the website’s functionalities may require registration and submission of Personal Data.

When contacting the website, we may collect:

• Contact details: name, surname, telephone number, address, city, state and e-mail address;
• Information submitted: information you send via the form (questions, complaints, suggestions, criticisms, compliments, etc.).

When browsing the website in general, we may collect:

• Location data: geolocation data when you access the website;
• Preferences: information about your preferences and interests in relation to products/services (when you tell us what they are or when we deduce them from what we know about you);
• Website browsing data: information about your visits and activities, including the content (and any advertisements) you view and interact with, information about the browser and device you are using, your IP address, your location, the address of the website from which you arrived. Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons and embedded web links. To find out more, read how we use Automatic Data Collection Tools in section 7 below;
• Anonymous or aggregated data: anonymous responses to surveys or anonymous and aggregated information about how the website is enjoyed. During our operations, in certain cases, we apply a de-identification or pseudonymization process to your data so that it is reasonably unlikely to identify you through the use of this data with available technology;
• Other information we may collect: information that does not specifically reveal your identity or is not directly related to an individual, such as browser and device information; website usage data; and information collected through cookies, pixel tags and other technologies.
• We do not collect Sensitive Personal Data.

In accordance with the provisions of art. 15, heading and paragraphs, of Federal Law No. 12,965/2014 (“Brazilian Civil Rights Framework for the Internet”), user access logs will be collected and stored for at least six months.

Section 5 — Sharing Personal Data with third parties

We may share your Personal Data with the partner company(ies) you select or choose to send your data, queries, questions, etc., as well as with service providers or partners to manage or support certain aspects of our business operations on our behalf.

These service providers or partners may be located in the United States, Argentina, Brazil or other global locations, including servers for homologation and production, and providers of hosting and data storage services, fraud management, customer support, sales on our behalf, order fulfillment, content personalization, advertising and marketing activities (including digital and personalized advertising) and IT services, for example.

We may also share your Personal Data with third parties who will help us manage the website or in the event of any reorganization, merger, sale, joint venture, assignment, transfer or conveyance of all or part of our business, assets or capital (including those relating to bankruptcy or similar proceedings).

Please note that this Privacy Policy does not apply to any third-party applications, products, services, websites or social media features that may be offered or accessed through our website. Accessing these links will cause you to leave our website and may result in the collection or sharing of information with third parties. We do not control, endorse or make any representations about third party websites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any website with which you interact before permitting the collection and use of your Personal Data.

Section 6 — International Data Transfers

Personal data and information of other kinds collected by us may be transferred to or accessed by entities belonging to the corporate group of the partner companies internationally in accordance with this Privacy Policy.

Section 7 — Automatic Collection of Personal Data

By visiting this website, you are aware that it may store or retrieve information in your browser, mainly in the form of cookies, which are text files sent by the website to the user’s device and stored there, with information related to browsing the website. This information may be about you, your preferences or your device and is mainly used to make the website work as you expect. The information generally does not identify you directly and can offer you a more personalized internet experience.

In accordance with this Privacy Policy, we, our service providers and our partners may, with your consent, collect your Personal Data in various ways, including:

Through the browser or device: some information is collected by most browsers or automatically through internet access devices, such as the type of computer, screen resolution, name and version of the operating system, model and manufacturer of the device, language, type and version of the internet browser you are using. We may use this information to ensure that the website functions properly.

• Use of cookies: information about your use of the website may be collected by third parties using cookies. Cookies are pieces of information stored directly on the device you are using. Cookies allow the collection of information such as browser type, time spent on the website, pages visited, language preferences, and other anonymous traffic data. We and our service providers use information for security protection, to facilitate navigation, display information more efficiently, and personalize your experience when using the website, as well as for online tracking. We also collect statistical information about the use of the website for continuous improvement of our design and functionality.
• Use of pixel tags and other similar technologies: pixel tags (also known as web beacons and invisible GIFs) may be used to track the actions of website users (including email recipients), measure the success of our marketing campaigns and collect statistical data on website usage and response rates, and for other unspecified purposes. We may contract with behavioral advertising companies to obtain reports on the website’s advertisements across the internet. To do this, these companies use cookies, pixel tags and other technologies to collect information about your use, or the use of other users, of our website and third-party websites. We are not responsible for pixel tags, cookies and other similar technologies used by third parties.

If you do not wish to have your information collected through cookies, you can exercise the option to reject the transfer of a specific cookie (or cookies) from a given website to your device.

The settings you choose may affect your browsing experience and the functionalities that require the use of cookies. In this regard, we disclaim any liability for the consequences arising from the limited functioning of the website caused by the deactivation of cookies on your device (inability to set or read a cookie).

Section 8 — User Rights

You may, at any time, request: (i) confirmation that your Personal Data is being processed; (ii) access to your Personal Data; (iii) corrections to incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the provisions of the law; (v) portability of Personal Data to another service provider, provided that this does not affect our industrial and commercial secrets; (vi) deletion of Personal Data processed with your consent, to the extent permitted by law; (vii) information on the entities to which your Personal Data has been shared; (viii) information on the possibility of not providing consent and on the consequences of refusing to do so; and (ix) revocation of consent.

Your requests will be handled with special care so that we can ensure the effectiveness of your rights. You may be asked to provide proof of your identity in order to ensure that Personal Data is only shared with its owner and your request will be answered within thirty (30) days by our Data Security Department.

You should bear in mind that, in the cases defined by article 11, item II of the General Data Protection Act, your request may not be fulfilled, in compliance with legal provisions.

Section 9 — Personal Data Security

The website undertakes to apply technical and organizational measures to protect personal data from unauthorized access and from situations of destruction, loss, alteration, communication or dissemination of such data.

The website uses a security certificate that guarantees that personal data is treated in a secure and confidential manner, so that any transmission of data between the server and the user, and in feedback, takes place in a fully encrypted manner.

However, the website disclaims liability for the sole fault of third parties, such as in the event of an attack by hackers or crackers, or the sole fault of the user, such as in the event that they themselves transfer their data to a third party. The website also undertakes to notify the user within an appropriate period of time in the event of any type of breach of the security of their personal data which may cause a high risk to their personal rights and freedoms.

We have adopted the technical and organizational measures provided for by the Data Protection Laws appropriate for the protection of Personal Data in our organization, however, if you have reason to believe that your interaction with us has ceased to be secure (for example, if you believe that the security of any of your accounts has been compromised), please notify us immediately.

Section 10 — Hypertext links to other websites and social media platforms

The website may, from time to time, contain hypertext links that will redirect you to websites in the networks of our partners, advertisers or suppliers. If you click on one of these links to any of these websites, please remember that each website has its own privacy practices and that we are not responsible for these policies. Please consult these policies before submitting any Personal Data to these websites.

We are not responsible for the collection, use and disclosure policies and practices (including data protection practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other software developer or application provider, social media store, operating system, wireless internet service provider or device manufacturer, including any Personal Data you disclose to other organizations through the applications, in connection with such applications, or posted on our social media pages. We recommend that you inform yourself about the privacy policy of each website you visit or service provider you use.

Section 11 — Updates to this Privacy Policy

If we modify our Privacy Policy, we will publish the new text on the website, with the updated revision date. We may change this Privacy Policy at any time. If there is a significant change in the terms of this Privacy Policy, we may inform you through the contact information we have in our database or by notifying you on our website.

We remind you that we are committed to not processing your Personal Data in a manner incompatible with the purposes described above, unless otherwise required by law or court order.

Your use of the website after the changes means that you have accepted the revised Privacy Policies. If, after reading the revised version, you do not agree with its terms, please terminate access to the website.

Section 12 — Controller of Personal Data

If you wish to exercise any of the rights provided for, including withdrawing your consent, in this Privacy Policy and/or in the Data Protection Laws, or to resolve any queries relating to the Processing of your Personal Data, please contact us at [email protected].

Section 13 — Applicable law and jurisdiction

For the resolution of disputes arising from this instrument, Brazilian law shall apply in full, and any disputes shall be submitted to the courts of the capital city of São Paulo, State of São Paulo.