1. Introduction

At TCP, we are concerned with the privacy and protection of the Personal Data of those who browse through Our Environments. For this reason, we provide this Privacy Policy, which outlines the rules we follow to process Personal Data, explains the rights that the law grants to the holders of this type of information, and provides the channel through which you can exercise these rights.

Please read this Privacy Policy carefully. If you have any questions about its content, simply contact us through one of the channels listed in this document.

2. Definitions

To help you better understand the content of this document, please consider the following definitions:

“National Data Protection Authority” or “ANPD”: This is the Federal Government body responsible for ensuring and overseeing compliance with the General Data Protection Law (LGPD).

“Controller”: This refers to the individual or legal entity responsible for making decisions regarding the Processing of Personal Data. For the purposes of this Policy, TCP is the Controller of the Personal Data.

“Cookies”: These are small files sent to your browser or devices that store your preferences and other information about how and when Our Environments are visited and how many people access them.

“Personal Data”: Information relating to a natural person that is capable of identifying them directly (such as full name, ID number, or CPF) or indirectly (such as geolocation combined with other information).

“Device”: Any device used to access the internet, such as computers, notebooks, tablets, smartphones, etc.

“Data Protection Officer”: This is the person appointed by TCP to act as a communication channel between us, the Data Subjects, and the National Data Protection Authority.

“Applicable Legislation”: This refers to the set of laws and regulations concerning privacy and the protection of Personal Data, especially the provisions of Law No. 13.709/2018 (“General Data Protection Law” or “LGPD”).

“Our Environments”: This refers to the app, the tcp-partners.com website, tcp-partners.com.br, and their subdomains, managed by TCP.

“Privacy Policy”: This is the document, the Privacy Policy and Personal Data Processing Policy.

“Data Subject”: The individual who interacts with Our Environments and to whom the Personal Data relates.

“Processing”: Any operation performed on Personal Data, such as but not limited to collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation, control, modification, communication, transfer, dissemination, and extraction.

3. Personal Data Processed by TCP

We process your Personal Data according to your interaction with us, which may occur through apps, websites, and portals operated directly by TCP; via email, electronic communication systems, and instant messaging apps (such as WhatsApp and similar); and also via social networks such as Facebook, Instagram, and YouTube.

Important: For certain processing purposes, such as recruitment and selection, third parties may also process Personal Data (e.g., Jobs, etc.), and these third parties have their own privacy policies. It is your responsibility to read and understand the terms and data protection practices of these third parties.

4. Data Update and Accuracy

You are solely responsible for the accuracy, truthfulness, and updating of the Personal Data you provide to TCP. We are not obliged to process the information entrusted to us if we have reason to believe that such Processing may result in a legal violation or that any of Our Environments are being used by you for illegal, unlawful, or immoral purposes.

5. Data Sharing by TCP

TCP shares your Personal Data only in the following circumstances, and when it does, it restricts sharing to what is strictly necessary to fulfill the activities they are intended for, and whenever possible, adopts measures to safeguard the information and observe good practices.

6. How TCP Protects Your Personal Data

Security and Governance Practices: To safeguard your privacy and protect your Personal Data, TCP has a governance program that includes good practice rules, internal policies, and procedures. These establish organizational conditions, training, educational actions, and risk mitigation mechanisms related to the Processing of Personal Data.

7. Data Storage

Storage Location: Personal Data collected is stored in a secure and controlled environment, either on our servers located in Brazil or in cloud computing environments.

Storage Period: We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected or to comply with any legal obligations. This retention period may exceed your direct relationship with TCP, as certain obligations extend over time.

8. Rights Assured to Data Subjects and How to Exercise Them

Even though TCP processes your Personal Data, it remains your data, and it is important that you know that the Applicable Legislation grants several rights concerning them. You can exercise these rights by submitting a request through the contact channels provided at the end of this Privacy Policy.

9. General Information About This Privacy Policy

TCP may change the content of this Privacy Policy at any time, as needed or required for legal compliance, and you should review it whenever you access Our Environments.

10. Contact Channels

If you have any questions regarding this Privacy Policy or to exercise your rights as a Data Subject, you can contact our Data Protection Officer via email at: lgpd@tcp-partners.com