Cookie Policy

1. PURPOSE

The purpose of this Policy is to provide transparency to users regarding the processing of Cookies carried out by ATLAS GOVERNANCE ("ATLAS").

2. SCOPE

This document covers all board members, committee members, partners, investors, directors, managers, employees, and interns (collectively, "Employees"), cooperative members, and individuals or legal entities that represent or directly interact with ATLAS ("Third Parties").

3. REFERÊNCIAS

Internal

• PL GSI 001 – Information Security Policy;

• PL CCE 002 – Privacy and Data Protection Policy for Customers, Users, and Candidates.

External

• Brazilian General Data Protection Law (Law No. 13.709/2018);

• ABNT NBR ISO/IEC 27001:2013: ISMS – Requirements;

• ABNT NBR ISO/IEC 27701:2019 – Privacy – Requirements and Guidelines.

4. GLOSSARY

PERSONAL DATA ("PD") – Any and all information related to an identified or identifiable natural person, meaning the concept covers direct information such as name, ID, tax number, and address, as well as indirect information such as location data and other electronic identifiers.

COOKIES – Small files created on your device in order to store browsing information and user preferences, enabling greater customization, agility, and ease of use of the website.

DATA SUBJECT – The natural person to whom the Personal Data being Processed refers.

COOKIE PROCESSING – Any activity carried out with personal data, such as collection, processing, access, storage, and deletion.

5. GENERAL DESCRIPTION OF THE POLICY

This Cookie Policy defines our practices regarding the processing (including collection, storage, use, sharing, and disposal) of Cookies during access to and use of the ATLAS website and its subdomains.

5.1. Why does Atlas use Cookies?

ATLAS uses cookies to understand, protect, operate, customize, and provide our services, as well as to improve the user experience, understand how our services are being accessed and used, remember your choices, rank the popularity of our pages, and assess their effectiveness.

5.2. How are Cookies collected by Atlas?

Atlas automatically collects Cookies considered Necessary, based on its legitimate interest.

The data subject may accept or refuse the collection of Cookies in the other categories, which are considered non-essential for the operation of the website, via the banner that appears on our web page.

If the data subject wishes to manage which Cookies are collected, they may adjust their preferences by accessing the "Options" item on the cookie banner, which will list the categories and specify all cookies collected.

5.3. Which categories of cookies are collected by Atlas?

ATLAS uses Cookies considered Necessary for the operation of the website, in addition to cookies from other categories, whose processing by ATLAS will depend on the data subject's authorization.

The Cookies processed are divided into the following categories:

• Necessary Cookies are those that contribute to the proper functioning of the website and security tools; non-essential categories are not included. Without them, it will not be possible to access the main tools and activities of the site.

• Performance Cookies are those that allow the site to behave in a way that delivers the best possible experience for the user, adjusting to their location, preferred language, etc. The Cookies in this category collected by ATLAS are listed below.

• Functional Cookies are those that adjust the site to its own or third-party services, such as content sharing on social networks, comments, chatbots, among others. The Cookies in this category collected by ATLAS are listed below.

• Marketing Cookies or advertising cookies are those that track visitor navigation and collect data so that the company can provide more relevant ads according to such behavior. The Cookies in this category collected by ATLAS are listed below.

• Statistics or Analytics Cookies are those that translate visitor interactions into detailed reports on user behavior and interaction with the site, anonymously, enabling the improvement of its performance. ATLAS does not currently collect Cookies in this category.

The cookies collected, the purpose of processing, and the retention period are specified in the RL CCE – Cookies Report.

5.4. How to disable Cookies?

The data subject may follow the instructions provided in their browser or device (usually located in "Preferences" or "Settings") to change their cookie settings. However, by disabling the cookie option in your browser or device, the ATLAS website may stop functioning, and the use of the Portal may be compromised.

The data subject may use the anonymous browsing page, an optional browsing setting that allows tracking to be disabled by sites not visited, including statistical analysis services, advertising networks, and social platforms.

5.5. How to revoke consent for cookie collection?

• At any time, the data subject may revoke consent for the use of cookies by adjusting the settings in the banner available on the website.

• The data subject may delete and/or request access to the data collected through the "Opt-out" page.

• It is also possible to clear cookies directly in your browser. In this case, the ATLAS website may stop functioning, and the use of our services may be compromised.

6. SANCTIONS AND PENALTIES

In the event of non-compliance with this Policy, all guidelines set forth in PL CCE 004 – Policy for the Investigation of Reports and Disciplinary Measures shall apply.

7. ROLES AND RESPONSIBILITIES

Senior Management:

• Provide the necessary resources for the planning, implementation, maintenance, and improvement of Privacy management.

Risk and Compliance:

• Manage the collection of cookies and the consent of data subjects;

• Respond to data subject requests;

• Guide compliance with aspects of this Policy regarding data protection and privacy.

8. COOKIES REPORT

Updated on 03/14/2024