We, JARFEL MONTAGEM DE MÁQUINAS E EQUIPAMENTOS INDUSTRIAIS LTDA. and Sahara Tecnologia Máquinas e Equipamentos Ltda. (together, “JARFEL // SAHARA” or “we”), are committed to safeguarding your privacy and protecting your data. The purpose of this document is to clarify what information is collected from users of our websites – https://jarfel.com.br, https://sahara.com.br, and https://grupoaguilar.com.br – and their respective services (“You”) and how this data is used.

To provide our services, JARFEL // SAHARA collects various data and information through its website, applications, systems, the device on which these are installed or used, and any synchronized devices, aiming primarily to offer you an increasingly better experience.

JARFEL // SAHARA recognizes that your privacy is very important, and therefore we take all possible measures to protect it. Accordingly, this Privacy Policy (“Policy”) aims to inform You how Your information and personal data will be collected, used, shared, and stored through our websites and respective services.

This document is an integral part of our Website Terms of Use, which provides an overview of our platform.

This Privacy Policy applies when you use our Services involving both online and offline data collection, including Personal Data collected through our various services and channels, such as websites, applications, third-party Social Media, Customer Service, points of sale, and events.

Our users may, in certain cases, choose the types of data we collect, use, and share, as described in this Privacy Policy. Your acceptance of our Policy will occur when You register on our platform to use one of the aforementioned services. Such acceptance will take place at the moment You affirmatively agree to the use of Your data for each of the purposes described herein. This will indicate that You are aware of and fully agree with how we will use Your information and data.

If You choose not to provide the Personal Data necessary to use our products or services (which we will indicate when applicable), or if You do not agree with this Policy, we will be unable to provide You with our products and/or services. If You disagree with this Policy, please do not proceed with registration or use our services. However, please inform us of Your disagreement so that we can clarify or improve it.

This document is written in a simple and accessible manner, including several examples of data collection and use, precisely so You can read and understand how we use Your data to offer You a safe and comfortable experience when using the services we provide.

This Policy is divided as follows to facilitate Your understanding:

1. What are the sources of personal data?
2. What types of data does JARFEL // SAHARA collect?
3. With whom does JARFEL // SAHARA share your data?
4. International data transfer
5. What are the rights of data subjects?
6. How long will the data be stored?
7. How does Information Security work at JARFEL // SAHARA?
8. How to contact the Data Protection Officer (DPO) of JARFEL // SAHARA?
9. Changes to the Policy

1 – What are the sources of personal data?

The amount and type of information collected by JARFEL // SAHARA vary according to how You use our services. We will collect different data depending on whether You are visiting our website, using our software, using the services of clients of our software, or using JARFEL or Sahara services. To make these definitions and differences more accessible, we divide user data collection into four parts so You can understand what specifically applies to You. This Policy applies to Personal Data we collect from or about You through the following sources:

• JARFEL // SAHARA Websites: Consumer-focused websites operated by or for JARFEL // SAHARA, including websites we operate under our own domains/URLs and minisites we maintain on third-party Social Networks such as Facebook, Instagram, LinkedIn, TikTok, Twitter, Blog, YouTube, WhatsApp, Pinterest, and Telegram.
• JARFEL // SAHARA Mobile Sites/Apps: Consumer-focused websites or mobile applications operated by or for JARFEL // SAHARA, such as smartphone apps.
• Interactions with Ads: Interactions with our advertisements (for example, if You interact with one or more of our ads on a third-party site, we may receive information about that interaction).
• Data Created by Us: During our interactions with You, we may create Personal Data about You (for example, but not limited to, records of Your purchases on our sites and records of Your interactions with our content and emails).
• Events: Events held and organized by JARFEL // SAHARA, as well as events where JARFEL // SAHARA participates as a sponsor or exhibitor. We also store information regarding all contacts previously made with our users, regardless of the type of user. Such information includes content downloaded from our pages and email interactions, such as opens and clicks.

By clicking the social media sharing buttons available on our pages, the user publishes content through their profile on the selected network. JARFEL // SAHARA does not have access to users’ login or passwords for these networks, nor will it publish content on behalf of the user without their action.

It is worth noting that all data we collect is used solely to provide our services. Therefore, all your data and information are treated as confidential, and we will only use them for the purposes described here and authorized by You, primarily so You can fully use our services and to continually improve Your experience as a user. See Section 2 for what applies to You.

1.2. What are the Legal Bases for data collection?

We rely only on legal bases authorized by law for data collection, such as but not limited to consent, legitimate interest, and proper execution of contracts entered into. When the legal basis for collection is not consent, we always comply with current legislation and respect the individual rights and freedoms of data subjects.

What types of data does JARFEL // SAHARA collect?

2.1. Website Visitors
If You simply visit our websites, we collect your browsing data. When You visit our site, a “cookie” is placed in your browser via software such as Google Analytics and RD Station to identify how many times You return to our address.

“Cookies” are identifiers we transfer to Your browser or device that allow us to recognize Your browser or device and inform us how and when pages and features on our Services are visited and how many people access them.

We also use cookies and browsing data such as URLs (Uniform Resource Locators) to collect information about the date and time of Your visit and the solutions and information You searched for and viewed. Like most technology companies, we automatically collect this personal data and store it in log files whenever You visit our site or access Your account on our network.

We may use session cookies (which expire after closing the browser) and persistent cookies (which remain on Your computer until You delete them) to provide a more personalized and interactive experience on our site. Persistent cookies can be removed by following the instructions in Your internet browser’s help file.

You may choose to limit, refuse, or disable cookies through Your browser settings.

However, by doing so, some areas of our website may not function properly, which may prevent You from benefiting from some of our features.

Again, this Privacy Policy does not cover the use of cookies by third parties, and we are not responsible for their privacy policies and practices. Please note that cookies placed by third parties may continue to monitor Your online activities even after You have left our Services.

2.2. JARFEL // SAHARA Leads
If You interact with our materials and content, in addition to the browsing data mentioned above for Visitors, we will collect data about Your visits to our pages and other information You choose to share with us through Your interactions with our forms, landing pages, emails, and WhatsApp contact, for example.

To offer content and materials relevant to Your interests, it is often necessary to cross-reference data we collect from You so that our marketing efforts are directed toward what You expect to receive from us. We guarantee that this cross-referencing is not done in a discriminatory manner and does not violate any of Your individual rights or freedoms. Furthermore, You may, at any time, request to change or remove such data processing permissions through our Help Center.

Considering all these points, some possible uses of Your data may occur. We recommend You read the examples below:

• Your email is used to send the material or information You requested by filling out a form. It may also be used to send newsletters related to topics such as machinery, human resources, general technology, customer success, and announcements of new free materials or new products from JARFEL // SAHARA and partners. However, You may unsubscribe at any time;
• Sending You messages regarding support or service, such as alerts, notifications, and updates;
• Communicating with You about products, services, promotions, news, updates, events, and other topics You may be interested in; and
• Conducting targeted advertising based on Your preferences, interests, and other collected information.

2.3. Users of JARFEL // SAHARA Websites and Services
If You use any of our services and/or products, we will collect the following categories and types of personal data: contact data (name, email, and phone number), location data (country, state, and city), professional profile data (position, company name and sector, number of employees in the company, academic background, and years of experience), billing data (name, CPF, CNPJ, address, credit card), and marketing data (Your marketing preferences and information about Your CRM).

If You register using Your Facebook/Google account, we will collect the publicly accessible personal data on Your social network profile, such as name and profile picture. Providing Your email is optional and can be set at registration. To integrate with the offered services, we may collect all data publicly accessible through Facebook/Google to our system, including information about Your ads, materials and content You interacted with, number of clicks received, and information about visitors to Your websites available on that platform.

For access registration to services and/or products under a free trial, the following data are collected:

• Contact data (name, email, and phone number)
• Professional profile data (position, company, company sector, number of employees)

For contracting our services and/or products, the following data are collected:

• Contact data (name, email, and phone number)
• Professional profile data (position, company, company sector, number of employees)
• Location data (country, state, and city)
• Billing and invoicing data (legal name or trade name, CNPJ or CPF, legal representative and their CPF, headquarters address, credit card details when payment is by this method, options regarding Simples Nacional tax regime, additional data for issuing invoices, and payment currency for international clients).

2.4. Users of JARFEL // SAHARA Clients’ Websites

JARFEL // SAHARA provides its clients with software and websites for courses and video training or landing pages. It is important to note that JARFEL // SAHARA collects data and analyzes these videos. These data belong to JARFEL // SAHARA, who use, disclose, and protect them according to their respective privacy policies. The clients are responsible for obtaining consent directly from their users and, with this consent, collecting, managing, and processing confidential information. If You have any questions about how Your data is being managed, we recommend contacting the company providing services to You.

2.5. JARFEL // SAHARA Clients

If You are a client of JARFEL // SAHARA, in addition to the browsing data mentioned under Visitors, with Your consent, we will collect Your registration and professional data such as name, CPF/NIF, email, company, password, country, and photo, and billing data (name, CPF, address, credit card) if the course You enroll in is paid. Occasionally, some information may be requested through direct contact from JARFEL // SAHARA via email or phone. If You use Your Facebook/Gmail account to integrate with the offered services, we may also collect publicly accessible personal data provided by Facebook, such as name, photo, and email. If You register on the JARFEL // SAHARA platform using Your Gmail email account, we will collect publicly accessible personal data provided by Gmail, such as name, email, and profile photo.

2.6. Participants in JARFEL // SAHARA Events

If You participate in any event held by JARFEL, such as Sahara Tecnologia, IND Brasileira, or Grupo Aguilar, necessary data to confirm Your registration (such as name, location data, company where You work, and residence location) will be collected via a third-party ticketing platform. Your email data collected at our events will be shared with our Marketing team to send You content and updates related to the event’s topics. You can request changes to these preferences at any time through our Help Center.

We (I) assume no responsibility, of any kind and under any title, regarding any Content on the Websites, Services provided, or any information supplied by or through the Websites,
and (II) do not guarantee that the Website or any Services or Content thereof will be uninterrupted or error-free, that defects will be corrected, or that the Websites, the server on which they are hosted, or any system connected thereto, are free from viruses or other harmful components.

1. Who Does JARFEL // SAHARA Share Your Data With?
   As an online platform, JARFEL // SAHARA may operate together with other companies across a wide range of activities, including providing location features, advertisers, sponsors, and business partners, both online and offline, as well as tools for promotion and performance analytics.
   Thus, we reserve the right to share your information—including location data, registration data, and interest data—with the companies listed below, whenever possible, in an anonymous manner to maximize your privacy protection.

We do not rent, sell, or transfer your personal data to anyone except for the partner companies listed below. We may share your personal data in the following cases:

Advertisers
You may occasionally receive personalized ads, content, and links directly from JARFEL // SAHARA based on your interests and behaviors on our platform or other services you interact with.
To that end, data may be shared among Google, RD STATION, and the targeted advertising platform, mainly unique identifiers, IP addresses, cookies, and other information collected from your browser, which may be used to measure the effectiveness of online advertising. You can always opt out of this advertising by contacting us through our Help Center.

Our Partners
We hire other companies to perform work on our behalf and need to share your personal data with them to provide products and services to you. For example, we use data hosting services to store our database and payment services to process billing information for products you purchase. Our Partners are authorized only to use personal data for the specific purposes for which they were contracted and will not use your personal data for any other purposes beyond the provision of services contractually agreed upon.

Statistics
Data stored by JARFEL // SAHARA may be used for statistical purposes (analytics). This data is aggregated to provide a macro-level analysis and does not seek to identify or make identifiable the data subjects but only to better understand how users access the platforms the company uses, aiming to improve service delivery and customize products more aligned with users’ interests.

Social Media Profiles or Other Submissions
Registering on JARFEL // SAHARA platforms allows you to sign in using your Facebook or Gmail account, whereby certain data from your Facebook and Gmail accounts may be shared with RD. Therefore, when logging in this way, please review the publicly accessible personal data authorized by these platforms so you can decide what you want to share with us. We do not control the privacy policies and practices of any other third-party sites or services, so if you register using your social media profile, please be aware of this.

To Protect and Enforce JARFEL // SAHARA’s Rights
We reserve the right to access, read, preserve, and disclose any data we believe is necessary to comply with a legal obligation or court order; enforce or apply our agreements and others; or protect the rights, property, or safety of JARFEL // SAHARA, our employees, our users, or others.

1. International Data Transfer
   JARFEL // SAHARA collects and transfers personal data collected in Brazil or other continents to JARFEL // SAHARA Partners involved in the processing of personal data. These transfers only involve Partner companies of JARFEL // SAHARA that have demonstrated compliance or are in the process of complying with the GDPR and the applicable Brazilian data protection laws.

JARFEL // SAHARA is headquartered in Brazil, and the data we collect is governed by Brazilian law. By accessing or using the services of JARFEL // SAHARA or by providing personal data to us, you agree to the processing and transfer of such data to Brazil and to other countries.

5. What are the data subjects’ rights?

You may choose not to disclose your data to us, but please note that some of these data may be necessary to register on our platforms or use certain features and products we offer. Regardless, you always have rights regarding privacy and the protection of your personal data. We not only care about the security of this data, but also ensure that you are fully aware of your rights.

Below is a summary of your rights under the Brazilian General Data Protection Law (LGPD), other Brazilian data protection laws, and the General Data Protection Regulation (GDPR):

1. Right of Access
   You have the right to request and receive a copy of the personal data we hold about you.
2. Right to Rectification
   You may request correction or updating of your personal data at any time if you find any inaccuracies.
3. Right to Erasure
   You can request the deletion of your personal data from our platform. All collected data will be deleted from our servers upon your request or when no longer necessary, unless we are required to retain them for legal or rights protection reasons.
4. Right to Confirm Processing
   You have the right to confirm whether we are processing any of your personal data.
5. Right to Block or Delete Data
   You may request to block or delete data that is excessive, unnecessary, or processed in violation of the law.
6. Right to Know with Whom Your Data is Shared
   You may ask which public or private entities your data has been shared with.
7. Right to Restrict Processing
   You may ask us to suspend processing of your personal data in certain scenarios.
8. Right to Review Automated Decisions
   You have the right to request a human review of decisions made solely based on automated processing that affect your interests.
9. Right to Object to Processing
   You may object to the processing of your personal data in specific situations, such as for direct marketing purposes.
10. Right to an Explanation of the Data Collection Logic
    You have the right to receive information on how and why your data is being collected and processed.
11. Right to Information on the Possibility of Denying Consent
    You are entitled to be informed that you may deny consent and what the consequences might be.
12. Right to Withdraw Consent
    You may withdraw your consent at any time. Note that withdrawing consent does not affect the legality of prior processing. However, it may prevent us from delivering certain products or services.

We may ask for specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your data is not disclosed to unauthorized individuals.

Legitimate requests will be answered within 5 business days, but if your request is complex or if you’ve submitted multiple requests, we will keep you informed of the progress.

If you have any questions about your rights or how to exercise them, feel free to contact us via our Help Center.

6. How long will JARFEL // SAHARA store your data?

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to comply with any legal, contractual, or regulatory obligations or requests from competent authorities.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your data and whether we can achieve those purposes through other means, as well as applicable legal requirements.

If you use our products and services, your account information will be retained for as long as your account remains active. If you request cancellation, your information will be deleted within 60 days of account cancellation.

If you are a lead of JARFEL // SAHARA, the information regarding your interactions with us will be stored for up to 30 (thirty) years. Likewise, if you request the deletion of your data and/or account, JARFEL // SAHARA will retain the data for 72 (seventy-two) hours after your deletion request.

7. How does Information Security work at JARFEL // SAHARA

Your account is protected by a password for your privacy and security. If you access your account through a third-party website or service, you may have additional or different login protections through that site or service. You must prevent and avoid unauthorized third-party access to your account and personal data by properly selecting and securing your password and/or other login mechanisms and limiting access to your computer or device and browser, logging out after accessing your account.

To ensure your privacy and the protection of your personal data, JARFEL // SAHARA adopts the best information security and secure development practices available in the market. We design products and services that promote the protection of your data and allow you to manage your information directly.

In line with this, we implement encryption for passwords and other critical information, TLS for data transfer between applications, use of cloud services with certifications and security seals such as ISO 27001, SOC 1 and SOC 2/SSAE 16/ISAE 3402, and PCI DSS, 24/7 system monitoring, edge firewalls with IDS (Intrusion Detection System) functionalities, anti-malware, anti-phishing, content control, and VPN.

We strive to protect the privacy of your account and other personal data we store in our systems, but unfortunately, we cannot guarantee complete security. Unauthorized account access, hardware or software failures, and other factors may compromise the security of your personal data at any time. Therefore, we ask for your help in maintaining a secure environment for everyone.

In addition to following good security practices for your account and data, if you identify or become aware of anything that compromises the security of your data, you can consult our FAQ [here] or contact us through the available support channels.

8. How to Contact the DPO of JARFEL // SAHARA

JARFEL // SAHARA is both the Controller and Processor of the personal data submitted to us by you in accordance with this Privacy Policy. In this regard, and to ensure compliance with the highest standards of data protection laws in Brazil and worldwide, we have appointed a Data Protection Officer (DPO), who is the representative of JARFEL // SAHARA responsible for overseeing all matters related to this Privacy Policy and data protection.

If you believe that your personal information has been used in a manner inconsistent with this Privacy Policy or your preferences, or if you have any other questions, comments, or suggestions related to this Privacy Policy, you may contact our DPO at the following addresses:

Address:
SP-098 – Rod. Mogi Bertioga, Nº 1080 – km 61.5 – Vila Moraes,
Mogi das Cruzes – SP, 08766-500, Brazil
Phone: +55 (11) 2171-1900 | 2943-6955 | 4726-3733
Email: dpo@jarfel.com.br / dpo@sahara.com.br

9. Changes to This Privacy Policy

As we are constantly striving to improve our services, this Privacy Policy may be updated from time to time. Therefore, we recommend that you periodically visit this page to stay informed about any changes. If any significant changes are made that require new consent from you, we will publish the update and request your renewed consent.