Privacy Policy

Be Growth Brasil Internet S/A – This privacy policy was created to inform the users of its services about the company’s commitment to always handle their personal data securely, privately, and transparently.

This privacy policy describes the personal data we collect, how it is used, stored, and shared, as well as your rights concerning these data. We recommend that you read it carefully.

Introduction

Be Growth aims to share information and commercial offers that interest users by making them available to everyone and raising awareness of products and services that best suit their reality based on their needs and preferences.

Be Growth complies with international and national safety standards and regulations for data storage, protection, privacy, and transmission.

By using the services, the user confirms that they have read, understood, and accepted the terms and policies applicable to the Be Growth service, including this privacy policy, and commits to complying with them, acknowledging that the data controller responsible for your personal data, the company responsible for decisions related to the processing of your personal data, is BE GROWTH BRASIL INTERNET S.A, a company registered with CNPJ/MF under number 36.563.402/0001-41, located at Av. Afonso Pena, nº 3351, Serra, Belo Horizonte – MG, CEP: 30.130-008.

If, after reading this privacy policy, you have any questions, complaints, wish to exercise your rights regarding your personal data, or contact Be Growth regarding this matter, you can contact us via our service channels or reach out to our Data Protection Officer (DPO), Gabriel Delgado, at the email compliance@begrowth.com.br

1. Scope

This privacy policy applies to all users of Be Growth. We collect your personal data whenever:

• You fill out the registration form on the company’s website;
• You participate in surveys or campaigns offered by Be Growth;
• You report a problem to Be Growth and request the company to provide a solution;
• You browse the Be Growth website – https://begrowth.com.br/
• You contact us through our service channels;

This privacy policy also applies to other forms of personal data collection by Be Growth that enable the provision or improvement of our services. For example, we may collect information through partners or related to our technologies.

The practices described in this privacy policy apply only to the processing of your personal data in Brazil, and they are subject to local laws, particularly Law No. 13.709/2018 (the General Data Protection Law, or “LGPD”).

2. What Personal Data Be Growth Collects

By using the services of Be Growth, you provide us with and we collect certain personal data from you. As soon as you interact with Be Growth, we collect your personal data. In some cases, you provide your personal data directly to Be Growth, but we may also collect data from you automatically.

Additionally, we also receive some personal data from partners we hire for specific purposes to comply with legal obligations or applicable regulations, among others that are later described.

By accepting the terms of this privacy policy, you expressly consent to providing only truthful, up-to-date, and accurate personal data, and you will not modify your identity or personal data in any way when using our products or services. You are solely responsible for any false, outdated, or inaccurate information you provide directly to Be Growth.

These are the personal data Be Growth processes, categorized:

Personal data that the data subject may provide and disclose:

• Personal identification: name, email address, and CPF (Brazilian Individual Taxpayer Registry);
• Personal data: age, marital status, and gender;
• Family status: who you live with;
• Education;
• Work situation: whether you are self-employed, unemployed, an employee, or retired;
• Consumption habits;
• Financial situation: whether you are insolvent or have financial constraints;

Personal data we collect from third parties:

• Registration data such as: name, date of birth, CPF, phone number, and address;
• Data on financial restrictions, such as insolvency, overdue amounts, and due dates;
• Credit history data;
• Credit bureau score;
• Information about overdue or maturing debts, joint liabilities, and guarantees;

Browsing and device information:

• IP address of the mobile device used;
• Interactions made and usage patterns of the website;
• Technical data such as URL, network connection, service provider, and device details;
• Cookies;
• Device characteristics, such as ID, operating system, browser, and model;
• Location data from the device, if you have consented to collect it;
• Application usage log data;
• Date and time of application usage;
• Browsing data that reflect the areas visited;

Personal data generated from the use of our services:

• Service contract data;
• Contract data of credit operations with partners, such as personal loans, negotiation of overdue amounts, and debt agreements;
• Credit history;
• Customer service history;

3. How Be Growth Uses Your Personal Data

Be Growth uses your personal data to provide and recommend the best products for you.

Be Growth is constantly committed to implementing physical, technical, and administrative security measures in processing your personal data in accordance with industry best practices. We aim to protect your data from unauthorized access, accidental or unlawful destruction, loss, alteration, or any inappropriate or unlawful processing.

Below, we detail the purposes for which we use your personal data:

Personal data provided by the data subject

Purposes:

• Accurate identification of the user, ensuring greater security and protection for the users themselves;
• Access to services and products offered by Be Growth;
• Analyzing the user profile to offer and recommend the best products and information according to their real needs and reality;
• Identification, verification, and validation of the requirements for using the services provided by Be Growth;
• Responding to requests and inquiries;
• Contacting via phone, email, SMS, WhatsApp, or other communication means, including sending notifications or push notifications about the use of Be Growth services;
• Improving the services offered by Be Growth, including combining information with contracted products to offer new products and services;
• Marketing, customer acquisition, market research, opinion surveys, and promotion of products and services from our partners, including sending offers and information about products, services, features, content, news, and other events that are relevant to maintaining the relationship;
• Credit protection, including credit granting and credit limit increase;
• Prevention and resolution of technical or security issues;
• Investigations and actions related to preventing and combating illegal activities, fraud, and financial crimes, and ensuring the safety of Be Growth customers and the financial system;
• Cooperation or compliance with court orders, competent authorities, or regulatory bodies;
• Compliance with laws or regulations;
• Solving questions raised based on data, clarifying doubts, correcting problems, and improving the system to enhance the user experience of Be Growth.

Personal data collected from third parties

Purposes:

• Improving our products and services;
• Marketing, customer acquisition, market research, and opinion surveys;
• Credit protection, including credit granting and credit limit increase;
• Prevention and resolution of technical or security issues;
• Investigations and actions related to preventing and combating illegal activities, fraud, and financial crimes, and ensuring the safety of Be Growth customers and the financial system;
• Compliance with laws or regulations, keeping your registration information up to date, or complying with legal and/or regulatory obligations that apply to Be Growth.

Browsing and device information

Purposes:

• Providing services, presenting products, and improving the usage and experience of the Be Growth website;
• Introducing new products and services, and offering products that may interest you;
• Recommending new services, products, or features, including services provided by other partners that may interest you;
• Displaying advertisements, either on our site, social media, or third-party websites;
• Creating statistics, surveys, reports, and behavioral research on the use of services or products;
• Credit protection, including credit granting and credit limit increase;
• Prevention and resolution of technical or security issues;
• Investigations and actions related to preventing and combating illegal activities, fraud, and financial crimes, and ensuring the safety of Be Growth customers and the financial system;
• Compliance with court orders, competent authorities, or regulatory bodies;
• Compliance with laws or regulations;

Personal data generated from the use of our partners’ products and services

Purposes:

• Providing services and offering contracted products;
• Improving the services provided by Be Growth, including combining information with contracted products to offer new products and services;
• Developing new products and services offered by partner companies of Be Growth and producing new information to innovate or develop new products;
• Improving models and services, as well as Be Growth products, through related tests;
• Marketing, customer acquisition, market research, opinion surveys, and promoting products and services from our partners, including sending offers and information about products, services, features, content, news, and other events relevant to maintaining the relationship;
• Credit protection, including credit granting and credit limit increase;
• Prevention and resolution of technical or security issues, and monitoring the usage and performance of Be Growth services and products;
• Investigations and actions related to preventing and combating illegal activities, fraud, and financial crimes, and ensuring the safety of Be Growth customers and the financial system;
• Cooperation or compliance with court orders, competent authorities, or regulatory bodies;
• Compliance with laws or regulations.

Public data

Purposes:

• Presenting products and services offered by Be Growth on social media, websites, apps, or institutional and advertising materials;
• Credit protection, including credit granting and credit limit increase;
• Investigations and actions related to preventing and combating illegal activities, fraud, and financial crimes, and ensuring the safety of Be Growth customers and the financial system;
• Regular exercise of Be Growth‘s rights;
• Compliance with laws and/or regulations applicable to Be Growth.

4. Sharing Personal Data

Be Growth may share your data if you give permission. Your data may be shared with companies within the Be Growth financial group, third-party partners, and authorities or regulators for various purposes, as needed. Sharing occurs strictly within the scope of our business and purposes, as well as in compliance with applicable laws.

Below, we have outlined a summary of the types of service providers with whom we share your personal data, categorized:

Business partners, service providers, and other third parties

Purposes for sharing:

• Improving our services and website, and operating new products or services;
• Contacting you via phone, email, SMS, WhatsApp, push notifications, or other communication means;
• Assisting in developing and providing our services;
• Marketing, customer acquisition, market research, opinion surveys, and promoting our products and services;
• Credit protection, including credit granting and credit limit increase;
• Prevention and resolution of technical or security issues;
• Investigations and actions related to preventing and combating illegal activities, fraud, and financial crimes, and ensuring the safety of Be Growth customers and the financial system;
• Regular exercise of Be Growth‘s rights;
• Compliance with court orders, competent authorities, or regulatory bodies;
• Compliance with laws or regulations.

Authorities and regulatory bodies

Purposes for sharing:

• Investigations and actions related to preventing and combating illegal activities, fraud, and financial crimes, and ensuring the safety of Be Growth customers and the financial system;
• Regular exercise of Be Growth‘s rights, including presenting documents in judicial or administrative proceedings, if necessary;
• Compliance with court orders, competent authorities, or regulatory bodies;
• Compliance with laws or regulations.

Additionally, while browsing our website, you may navigate to third-party websites or applications. When you access a third-party website or application, that third party’s privacy policies and terms of use govern their data privacy practices. We cannot control or be held responsible for the privacy policies and content of third parties. Please carefully read the applicable privacy policies to understand how they collect and process your data.

5. Retention and Deletion of Your Personal Data

As long as you are a customer or potential customer of Be Growth or its partners and use our services, and for the entire time Be Growth retains your personal data, they will be kept in a secure and controlled environment.

Where applicable, and even after you stop using Be Growth or its partners’ services, we may retain your personal data for an additional period to comply with legal obligations or for the regular exercise of Be Growth‘s rights, or for as long as necessary under the legal basis justifying the data retention. If there is no legal basis for retaining the data, they will be deleted from Be Growth‘s database.

6. Your Rights as a Data Subject

With the enactment of the LGPD (General Data Protection Law), as a data subject, you can exercise your rights against data controllers, such as Be Growth.

We provide the following detailed mechanisms so that you can clearly and transparently understand how to exercise your rights, and our team is ready to respond to your requests.

Confirmation of the existence of personal data processing

Being a user of Be Growth‘s services means we process your personal data, even if that processing is limited to securely storing your personal data in a controlled environment. In this regard, you can request Be Growth to confirm whether we process your personal data.

Access to personal data

You can request Be Growth to disclose and provide the personal data it holds about you.

Rectification of incomplete, incorrect, or outdated personal data

If you find that your personal data is incomplete, incorrect, or outdated, you can request Be Growth to correct or update it. To do so, you must provide documentation proving the correct and updated form of your personal data.

Anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in violation of the LGPD

If any personal data is processed unnecessarily, excessively, or in violation of the LGPD, you can request Be Growth to anonymize, block, or delete the data, provided that the excess, needlessness, or illegality is verified.

Deletion of personal data processed with consent

If you have given consent for the processing of your personal data for specific purposes, you can request the deletion of such personal data at any time.

Information about companies with whom Be Growth has shared or received your personal data

You can request Be Growth to inform you of the third parties with whom it has shared or received your personal data.

Information about not providing consent and the consequences

If your consent is required for using or providing a product or service, you can ask Be Growth to clarify whether it is possible to provide the product or service without your consent to process your personal data, or what the consequences will be if you do not provide consent.

Revocation of consent

If you have given consent for the processing of your personal data, you can request the revocation of this permission. Revocation of consent may result in your inability to use some features offered by Be Growth or even in the termination of services, but it does not prevent (i) the use of anonymized data, and (ii) the processing of data based on other legal grounds under the LGPD.

Automated Decisions

You can request a review of decisions made solely based on the automated processing of your personal data that affect your interests and request information about the criteria for such decisions. Due to business secrecy, confidentiality, and the preservation of competition, Be Growth will not disclose how these automated systems work.

7. Activity Log / Collected Data

We may record activities performed when you use our website, creating logs (records of activities on websites, apps, and services) containing: IP address, actions you performed on the service, the date and time the action was performed, and device details such as operating system version, browser, and location.

We may also use our own or third-party technologies to track the activities you perform when using our website, such as:

Cookies: These are web files that temporarily store what you browse online. Be Growth uses cookies on its website and also receives information from its partners regarding cookies placed on their respective websites. Cookies may be used for various purposes, such as remembering you and your preferences, storing information about your activity on the website you visit, or gathering data that can be used to present personalized content.

You may modify your acceptance or rejection of cookies in your browser settings at any time, noting that by refusing navigation cookies, some features of Be Growth may be impaired.

We have enabled third-party cookies on our website. The privacy policies are governed by the privacy policies and terms of use of these third parties, so we cannot control or be held responsible for the privacy policies and content of these third parties. Therefore, we emphasize that you can block cookies at any time by activating the setting in your internet browser, and restricting cookies depends on your browser’s settings and restrictions. You can also delete existing cookies through your internet browser settings. If you choose to disable cookies, you can continue browsing websites, but some features may no longer work.

Web beacon: A web beacon is a technology that allows tracking who visits a specific web page by identifying behavior across different websites or web servers.

Google Adsense Cookie Dart: Be Growth displays ads provided by the GOOGLE ADSENSE network. Google uses cookies to display ads on websites that display its ads. The DART Cookie enables the display of ads based on user preferences and browsing behavior. Users may opt-out of the DART Cookie by visiting the Google Ad and Content Network Privacy Policy page. If the user does not accept Google’s cookies and wishes to disable them, they can simply visit Google’s official page to manage how Google uses cookies in its ad networks: http://www.google.com/ads/preferences/

Analytics Tools: These tools may collect data on how you visit the website, including which pages and when you visit them, other websites you have previously visited, and so on.

We do not intend to collect information from individuals under 18 years old. If you have any questions about your child’s privacy rights related to our services, or if you believe your child may have provided personal data on our website, please contact us through our data protection officer. We will remove such information from our records within a reasonable time frame.

All technologies we use will always comply with the terms of this privacy policy.

8. International Transfer of Personal Data

Some or all of your personal data may be transferred abroad, for example, when Be Growth stores them on cloud servers located outside of Brazil. For this, Be Growth complies with all applicable legal requirements and applies the best security and privacy practices to ensure the integrity and confidentiality of your personal data.

9. Security Measures

Be Growth uses various security measures to ensure the integrity of your personal data, such as the security standards used by the industry in the collection and storage of personal data.

We handle the security of your personal data with extreme care, using industry-approved standards and best practices. We have a highly qualified team responsible for ensuring that Be Growth applies the best security practices, including:

• Multi-factor authentication for access to data;
• Code security to enable automation and ensure a quick and effective response to security events in a technological environment;
• Use of encryption in the storage, transfer, and use of data to ensure data integrity;
• Continuous monitoring of the environment;
• Continuous security analysis and testing of our systems, carried out by internal and external teams;
• Regular audits.

10. Consent

Throughout this privacy policy, we have informed you that certain personal data will only be collected with your consent by Be Growth. Accordingly, such personal data can only be processed with permission and for the purposes described here.

By reading this privacy policy and clicking the option described at the end, you agree to the processing of your personal data in the ways indicated here.

It is important to remember that processing your personal data is necessary for us to provide our services to you. If you have any questions about the terms explained here, we are available through our service channels to assist you.

11. Additional Information

Be Growth does not send emails to its users requesting payments or the confirmation of personal data. If you receive such an email, we recommend ignoring it.

Be Growth may share your personal data with partner companies to recommend and offer you the best-suited products for your needs or to provide the products and/or services requested by the user.

Articles on the Be Growth website may contain embedded content from other websites, such as videos, images, articles, etc. Embedded content from other websites behaves in exactly the same way as if the visitor were visiting the other website. These sites may collect data about you, use cookies, embed third-party tracking, and monitor your interaction with the embedded content, including tracking your interaction with the embedded content if you have an account and are logged into that site.

12. Changes to This Privacy Policy

Be Growth may modify this privacy policy at any time. Whenever significant changes are made to the terms of this privacy policy, the changes will become effective and binding on you when the new version is published on our website or sent to you by email.

We always value transparency: whenever a significant change is made, we will notify you on our page. By continuing to use our products and services after a privacy policy change, you accept the new terms, although you can always express your disagreement through our service channels if applicable.

13. Contacting the DPO

According to Law No. 13.709/2018, Be Growth is considered the “controller” of your personal data. If, after reading this privacy policy, you still have questions or need to contact us regarding your personal data, you can contact our Data Protection Officer:

• Person Responsible (DPO): Gabriel Delgado
• Email: compliance@begrowth.com.br
• Address: Av. Afonso Pena, nº 3351, Serra, Belo Horizonte – MG, CEP: 30.130-008.
• Responsibilities: Law No. 13.709/2018, Article 41, Paragraph 2

We are always available to clarify your questions.