PRIVACY POLICY

Atualizado em 24 Maio 2021

APEK INTERNATIONAL LLC, (“Apek”), EIN: 35-2609627, a legal entity governed by private law, responsible for the operation of the “Skedway” platform, scheduling platform rooms, workstations, cabinets and parking spaces, available to registered users (“Users”). This Data Privacy Guide can be revised at any time due to new technical and regulatory demands, as well as changes in the scope of infrastructure, security, systems, employees and processes, Group activities and/or regulatory demands, and whenever the business continuity tests result in situations considered inadequate / ineffective.

The solution for scheduling rooms, workstations and parking spaces is available through Apek's proprietary platform: https://skedway.com (“Platform”). The Platform will be made available to Users registered and belonging to the company contracting the Apek services (“Partner”). Through this Privacy Policy ("Policy"), Apek presents essential information on the way that Users' personal data will be used and processed.

The collection, use and sharing of personal data of Apek Users will be subject to this Privacy Policy and its updates. When accessing the Platform, the User must read this Policy. If you want to contact Apek, just send an email to: legal@skedway.com or through the link https://apek.atlassian.net/servicedesk/customer/portals.

1. Provide, operate, and maintain our website

Purpose of this Privacy Policy: Apek takes the measures that are within its power to protect the privacy of the User, in compliance with the legislation in force. This Privacy Policy details the way Apek performs the collection, storage, use, sharing and disclosure of Users' personal data, as well as clearly outlines the measures taken to ensure the protection of the collected data.

Moment of data collection: Users' personal data are collected when entered voluntarily by the User in the Platform or through the integration of Office 365 or G Suite, depending on how the contract is carried out by the partner organization.

Personal data of Users collected by Apek:

a) Name;

b) E-mail;

c) Photo (if made available by the User or by the system database indicated by the Partner for integration with the Platform, such as Office 365 or G Suite);

d) Complete location of the Partner;

e) Business phone; and

f) Personal phone.

Personal data of Users collected during the use of the Platform:

a) User IP address;

b) Accesses containing name, registered e-mail and time made by the User on the Platform;

c) Pages and screens accessed by the User on the Platform;

d) Dates and times of each User action on the Platform;

e) Schedules made by the User with his IP address;

f) Publications made by the User and log of these publications;

g) Customized settings by the User on the Platform;

h) Information on reservations made through the Platform; and

i) Information on participation in meetings scheduled through the Platform

Apek's responsibility for the information provided: Apek is not responsible for the veracity or lack of it in the information provided by the User, as well as for its outdation. It is the responsibility of the User to provide them accurately or update them.

Purposes of data collection from Users:

User data is used for the following purposes:

a) Properly identify them on the Platform;

b) Schedule rooms, workstations, cabinets and parking spaces in the Partner's Parking for the User and according to their preferences;

c) To adequately respond to requests and doubts in order to meet the Users' rights;

d) Organize the available calendar of rooms, workstations, cupboards and parking spaces of the Client;

e) Provide the services and fulfill the obligations arising from Apek's services, as contracted with the Client;

f) Maintain the updated Users' registry for the purposes of contacting Apek by e-mail and on the Platform;

g) Inform the administrator User about news, features and other events relevant to maintaining the relationship with Apek, through notifications and communications made by the Platform and by e-mail;

h) Protect Apek and the rights and obligations related to the use of the Platform, in accordance with the provisions of Brazilian law;

i) Collaborate and / or comply with a court order or request by an administrative authority;

j) Provide tools for the User to cancel the receipt of Apek's communications and messages;

k) Collect and analyze anonymous data from Google Analytics for parameterization and creation of metrics;

l) Share the data collected with Apek's partners to maintain the Apek's Service Platform;

Notifications to Users: In the event of any change in the purposes for which we use User data, they will be notified, under the terms described in this Privacy Policy.

The personal information of the administrating Users may be used to send important notices and notifications regarding, for example, the operation of Apek's purchase conditions and services, and also the conditions and policies of use and privacy.

The services offered and by Apek are dynamic and may have new features that may require the collection of new information. If your personal data is substantially different or we significantly change how we use your data, we will send you a notification and may even modify this Privacy Policy. The notification will be made when the User next accesses the Platform or by e-mail.

2. Data Sharing and Disclosure

In order to carry out the purposes described above and operate the Platform, when necessary, Apek may share the personal data of its Users with service providers, partners, regulatory bodies or judicial authorities. We emphasize that we do not sell personal data.

Sharing with service providers takes place so that Apek can provide the services made available through its Platform, which process personal data in accordance with Apek's instructions. Sharing takes place for the following purposes: intermediation of payments and cloud storage.

Apek may also share personal data with judicial, police or governmental authorities, in the following cases: court orders or requests, administrative requests or due to legal or regulatory obligations.

Users' personal data may also be shared with other companies in the same group as Apek, which operate at the same level of information security and privacy, such as affiliates, affiliates, controlled companies and controllers. This sharing may occur for the development of new products and for the management of its current services.

3. Data Security

Security measures: Apek follows the commonly used security standards and uses its best efforts to ensure the safety of its Users and to respect and protect their personal information against loss, theft or other forms of misuse and unauthorized access. Some of the measures adopted by the Apek team are: encryption of passwords and Usernames in the Apek database, complex custom password policy and monitoring of the environment to detect improper login attempts.

Access to data: Apek guarantees that they use the limited access policy, that is, the data and personal information of Users are limited only to those whose function requires contact with personal data.

Password confidentiality: Apek recommends that Users keep their access passwords for the Platform and the Application under complete confidentiality, avoiding their disclosure to third parties. Suspected data breach: in the case of suspected breach of personal data, Apek undertakes to notify Users and who may have been affected and to track all activities carried out in the last period since the last suspicion.

4. The Rights of Personal Data Holders

Rights: The User may exercise his rights in relation to the data collected by contacting him via email legal@skedway.com or through the link https://apek.atlassian.net/servicedesk/customer/portals.

Only identifiable data is liable to exercise such rights.

User rights include:

a) Right of access: allows the User to know and obtain information about the personal data subject to processing;

b) Right of rectification or exclusion: allows the correction of errors and the modification of inaccurate and incomplete data;

c) Right of cancellation: allows the exclusion of inappropriate or excessive data;

d) Right of opposition: the User's right to prevent the processing of their personal data or to cease processing in progress;

e) Right to restrict processing: involves marking personal data stored to restrict its future processing;

f) Data portability: provision of User data that is subject to processing so that it can be transferred to another controller without hindrance; and

g) Right to withdraw the consent given at any time.

Apek reserves the right to use all lawful means necessary to verify the identity of those who request the exercise of rights in order to prove that they are, in fact, the respective data subjects. In addition, whenever any of the requests described above are made, Apek will analyze the need or possibility of maintaining the personal data of Users in order to comply with legal or regulatory obligations on their part.

We remind you that, in some cases, the exercise of Users' rights will depend on joint analysis with Contractor.

5. Retention and Exclusion of Personal Data

Retention of User data: Apek will keep the User's personal data in order to fulfill the purposes for which we collect them, including for the purpose of complying with legal and regulatory obligations. Apek also periodically deletes personal data from inactive Users.

Display, rectification, ratification or deletion of personal data: The User can request the display, rectification or ratification of his personal data, through the service tools provided by Apek. If you wish to request the deletion of your personal data collected and registered by Apek, you can also contact us via email legal@skedway.com or through the link https://apek.atlassian.net/servicedesk/customer/portals.

6. International Transfer

Users' personal data may be transferred to other countries due to the cloud storage services contracted by Apek. In these cases, Apek only contracts with suppliers who also comply with current legislation and have the best market practices with regard to privacy and data protection.

7. Modifications to the Terms of this Policy

This Privacy Policy may be changed at any time, according to the purpose or need, such as for adequacy and legal compliance of a provision of law or rule that has equivalent legal force, the current version being always the most recent.

The new Policy will come into force 5 (five) days after being published on the Platform. Within the informed period, the User must inform Apek, through one of its service channels, if he does not agree with the amended terms. If there is no manifestation within the stipulated period, or if the User continues to use Apek's services, it will be understood that the User has accepted the new Policy and the contract will continue to bind the parties.

8. Applicable legislation and venue of election

All items in this Policy are governed by the laws in force in the Federative Republic of Brazil. For all matters relating to interpretation, compliance or any other question related to this Policy, the parties agree and expressly elect the Central Forum of the District of São Paulo.

The User declares to have read, understood and accepted all the rules, conditions and obligations established in this Privacy Policy.

São Paulo / SP, date of acceptance, access and use of the Platform and other applications.