Bordallo Pinheiro USA Corpoation ("Bordallo Pinheiro”, “Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website bordallopinheiro.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.

• In email, text, and other electronic messages between you and this Website.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");

• that is about you but individually does not identify you; and/or

• about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

• From third parties, for example, our business partners.

Information You Provide to Us. The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may

choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Website or any products or services we offer or provide though it.

• To allow you to participate in interactive features on our Website.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Bordallo Pinheiro’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Bordallo Pinheiro about our Website users is among the assets transferred.

• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of sale and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bordallo Pinheiro, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Promotional Offers from the Company. If you do not wish to have your email address or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to usa@bordallopinheiro.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to usa@bordallopinheiro.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to usa@bordallopinheiro.com or write us at: Vista Alegre USA Corpoation, 41 Madison Avenue, 9th Floor, New York, New York 10010.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

usa@bordallopinheiro.com

or via our toll-free number:

1-(888) 506-0526

2.2 Third Parties

Grupo Vista Alegre may also communicate to other third parties not qualified as subcontractors under Article 4, paragraph 8 of the GDPR.

These entities are subject to confidentiality and all of them have undertaken to ensure the processing of personal data according to GDPR. Grupo Vista Alegre communicates data to other recipients, in detail:

3. DATA COLLECTION CHANNELS

Grupo Vista Alegre may collect data directly (directly from the Customer) or indirectly (through subcontractors, partner entities or third parties). Collection may be carried out by the following channels:

• Direct collection: in person, by telephone, by e-mail and through the Website;

• Indirect collection: through partners or companies of the Grupo and official entities.

4. GENERAL PRINCIPLES APPLICABLE TO THE TREATMENT OF CUSTOMER DATA

Grupo Vista Alegre undertakes to ensure that the Customer data it processes is:

• Collected for specific, objective and legitimate purposes and no further processing contrary to those purposes;

• Processed lawfully, fairly and transparently in respect to the Customer;

• Adequate, justified and limited to what is necessary in relation to the purposes for which they have been collected;

• Accurate and up-to-date, whenever necessary, and the necessary measures taken to ensure that data which are inaccurate or no longer up-to-date (in terms of the purposes for which are processed) are erased or corrected without delay;

• Kept in such a way as to allow identification of the Customer only during the period necessary for the purposes that the data is processed;

• Processed in such a way as to ensure its security, including protection against unauthorized or unlawful processing and against their loss, destruction or unforeseen damage, with suitable technical and organizational measures being taken.

Data processing carried out by Grupo Vista Alegre is permitted and legitimate when at least one of the following situations occurs:

• The User has given free, positive, explicit and unequivocal consent to the processing of Customer Data for one or more specific purposes;

• Processing is necessary to carry out a contract to which the Customer is a party, or for pre-contractual procedures upon the Customer's request;

• Processing is necessary to comply with a legal obligation to which the Grupo Vista Alegre is subject;

• Processing is necessary in order to protect the vital interests of the Customer or another individual;

• Processing is necessary for the purposes of the legitimate interests pursued by Grupo Vista Alegre or a third party (unless the interests or fundamental rights and freedoms of the Customers prevail and require protection of personal data).

Grupo Vista Alegre undertakes to ensure that the processing of Customer Data is carried out only under the conditions listed above and in compliance with the aforementioned principles. Where the processing of Customer Data is carried out by Grupo Vista Alegre based on consent, the Customer has the right to revoke their consent at any time. The revocation of consent, however, does not compromise the legality of the processing carried out by Grupo Vista Alegre based on the consent previously given by the Customer. The period of time during which data is stored and maintained varies according to the purpose for which the information is processed, being filled only for the time necessary to fulfil the purposes for which they are processed, taking into account the Data Retention Policy approved by Grupo Vista Alegre. There are legal requirements which require the retention of data for a minimum period of time. Thus, whenever there is no specific legal obligation, the data shall be stored and retained only for the minimum period of time necessary for the purposes for which they were collected or subsequently processed and that, upon expiry, they shall be deleted.

5. USE AND PURPOSES OF PROCESSING CUSTOMER DATA

In general terms, Grupo Vista Alegre uses Custom Data for the following purposes:

• Customer contact management;

• Billing and collection from the Customer;

• Customer registration on Grupo Vista Alegre’s websites;

• Allowing access to restricted areas of the websites of Grupo Vista Alegre, according to previously established terms;

• Ensure that the website meets the Customer’s needs, through development and publication of suitable contents matching the interests and requests expressed by the Customer, improving search capabilities and platform functionalities as well as obtaining the associated or statistic information regarding the type of Customer profile (analysis of consumption profiles);

• Information/Contact requests;

• Presence in social networks;

• Newsletters and Mailing;

• Events;

• Planning and organization of events, meetings, and fairs;

• Providing you with services;

• Managing and maintaining our contractual relationships;

• For accounting and tax purposes;

• For marketing and business development;

• Compliance with applicable legal and regulatory requirements;

• Establishing, exercising or defending legal rights;

• Responding to requests and communications from competent authorities;

• Recruitment and business development;

• Website Customer Relationships, including:

o Sending communications or details of our services;

o Contacting you for feedback on our services;

o Contacting you for market research or research purposes.

• Voucher acquisition and management;

• Management and response to a budget;

• Inform the Customer, upon request, about new products and services available on the Website, special offers and campaigns, updated information about Grupo Vista Alegre’s activity and in terms of marketing purposes of this company and its brands, through any means of communication, including electronic means;

• Participation in campaigns to collect contacts or competitions on Grupo Vista Alegre’s social networks;

• Subscription to loyalty programs of Grupo Vista Alegre (“Cartão Private” and “Clube Colecionadores”) that allows access to specific campaigns of the brand;

• Sending satisfaction questionnaires;

• Recording conversations in the Web chat;

• Recording telephone calls made when requesting or providing information on products or services and their commercial and usage conditions, as well as any contractual relationship, both during the contract elaboration phase and during its term.

Grupo Vista Alegre may combine Usability Information with anonymous demographic information for research purposes and it may use the results to provide more relevant content on the Website. With your consent, in certain restricted areas of the Website, Grupo Vista Alegre may combine Personal Data with Usability Information to provide you with more personalized content.

6. BASIS OF LAWFULNESS FOR PROCESSING SOCIAL DATA

The processing of your personal data has the following purposes:

7. TECHNICAL, ORGANIZATIONAL AND SAFETY MEASURES IMPLEMENTED

In order to ensure the security of Customer Data and maximum confidentiality, Grupo Vista Alegre handles the information provided to us in an absolutely

confidential manner, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated as necessary, as well as with the terms and conditions provided by law. In view of the nature, scope, context and purposes of data processing, as well as the risks arising from processing for the Customer’s rights and freedoms, Grupo Vista Alegre undertakes to apply, both when defining the means of processing and when processing itself, the necessary and appropriate technical and organizational measures to protect Customer Data and to comply with legal requirements. It further undertakes to ensure that, by default, only data that are necessary for each specific purpose of processing are handled and that such data are not made available without human intervention to an indefinite number of persons. The communication between the Customer’s device and the website of Grupo Vista Alegre is made through secure channels and communications using the HTTPS protocol and SSL security standard. Nevertheless, in terms of general measures, Grupo Vista Alegre adopts the following:

• Regular audits to identify the effectiveness of technical and organizational measures implemented;

• Awareness raising and training of staff involved in data processing operations;

• Pseudonymization and encryption of personal data;

• Mechanisms capable of ensuring ongoing confidentiality, availability and resilience of information systems;

• Mechanisms to ensure that information systems are rapidly re-established and personal data can be accessed in the event of a physical or technical incident. In the event of an incident of personal data breach, Grupo Vista Alegre undertakes to adopt all measures provided for in article 33 and 34 of the GDPR.

8. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Personal data collected and subject to processing are stored in databases suitable for that purpose. The personal data is kept, according to its purpose, in compliance with the applicable legal deadlines. In cases where no legal deadline applies in regards to keeping and storing personal data, such data will only be stored and kept for the appropriate period and to the extent necessary, given the purposes for which they were collected,

unless, at any time, the subject of the personal data, within the limits of the law, exercises their rights of opposition, erasure or withdrawal of consent.

9. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

Grupo Vista Alegre may transfer your personal data to recipients in countries outside the European Union, which may have different levels of protection in terms personal data. Consequently, Grupo Vista Alegre is concerned with adopting adequate measures to ensure the safe transfer of the Customer Data, whenever there is a transfer to a third country, whose level of protection of its personal data is different from that of the country where the personal data are collected. Grupo Vista Alegre undertakes to ensure that transfers of Customer Data to countries outside the European Union comply with the applicable legal provisions, in particular in terms of determining the suitability of such country in terms of data protection and the requirements applicable to such transfers.

10. USE OF COOKIES

When you visit our website, small text files (Cookies) are created and saved on your computer disk. These text files will enable a more personalized and efficient browsing experience. Each time you visit the Website, your internet browser sends these cookies back to the Website, allowing it to recognize and memorize your identity and your usage preferences. These Cookies will only be installed with your express consent, to be collected when presenting the cookies banner in the pages of the companies of Grupo Vista Alegre, except in cases in which they are strictly necessary for Websites to function. The information about the cookies that we use on the websites, including their purpose, categories, duration and to whom they belong to, can be found in our Cookies Policy available here. In addition, you may at any time manage your preferences regarding the collection of cookies in the preference manager available here.

11. THIRD-PARTY TOOLS INTEGRATED INTO THE WEBSITE

Facebook and Instagram:

On our Websites there is interactivity with Facebook and Instagram, through a connection to the servers of these social media. This will allow us to identify the website the User is visiting and possibly store other data, such as the IP address. If the User has their Facebook and/or Instagram session started, data will be associated with their accounts. To prevent this from happening, the User must log out of Facebook and Instagram before visiting the website. Information regarding the data processing carried out by these social media is available at: https://www.facebook.com/about/privacy/ https://help.instagram.com/519522125107875

12. Use of Social Media for Marketing Purposes

In order to meet our customers’ needs in the best possible way and to provide more personalized services, Grupo Visabeira may share Customer Data with social media, including Facebook, to allow the presentation of personalized advertisements which better meet the subject’s interests. As such social media may use the Customer Data to pursue its own interests. The information regarding data processing by these social media is available at:

https://www.facebook.com/about/privacy/

https://help.instagram.com/519522125107875

13. CUSTOMERS’ RIGHTS (DATA SUBJECTS)

13.1. RIGHT TO INFORMATION

13.1.1. Information provided to the Customer by Grupo Vista Alegre (when data are gathered directly from the Customer):

• The identity and the contact details of the responsible for the processing and, where applicable, his/her representative;

• The contact details of the Data Protection Officer;

• The purposes for processing personal data as well as, where applicable, the legal reasons for processing;

• If data processing is based on legitimate interests of the Grupo Vista Alegre or a third party, indication of such interests;

• Where applicable, the recipients or categories of recipients of the personal data;

• Where applicable, indication whether personal data will be transferred to a third country or an international organization and the existence or not of an adjustment decision adopted by the European Commission or reference to suitable transfer safeguards;

• Period of time to retain personal data;

• The right to request permission to access personal data from Grupo Vista Alegre, as well as its correction, deletion or limitations, the right to oppose its processing as well as the right to access data;

• If data processing is based on the User’s consent, the right to withdraw it at any time, without compromising the lawful process of the processing carried out based on the consent previously given;

• The right to present a complaint with the CNPD (National Commission for Data Protection) or any other supervisory authority;

• Indicating whether communication of personal data represents a legal or contractual obligation or a necessary requirement to sign a contract, as well as whether the data subject is obliged to provide personal data and the possible consequences of not doing so;

• Where applicable, the existence of automated decisions, including profiling, and information concerning the basic concept, as well as the relevance and the expected consequences of such processing for the data subject.

13.1.2. When the collection of Customer Data is not carried out directly by Grupo Vista Alegre with the Customer, besides the information aforementioned, the Customer shall also be informed as to the categories of personal data subject to processing, as well as about the source of the data and possibly, whether they come from publicly available sources. In case Grupo Vista Alegre intends to further process the Customer Data for a purpose other than the one for which data were collected, prior to this processing, Grupo Vista Alegre shall provide the Customer with information regarding this purpose, as well as any other relevant information, as mentioned above.

13.2. Procedures and measures implemented in order to comply with the right to information. The information referred to in 13.1 shall be provided in writing (including electronic means) by Grupo Vista Alegre to the Customer prior to the processing of the personal data concerned. Under applicable law, Grupo Vista Alegre shall not be obliged to provide the Customer with the information referred to 13.1. if the Customer is already aware of it. The information is provided by Grupo Vista Alegre free of charge.

14. RIGHT OF ACCESS TO PERSONAL DATA

Grupo Vista Alegre shall provide means for the Customer to access his/her Personal Data. The Customer has the right to obtain confirmation from Grupo Vista Alegre as to whether personal data concerning him/her are being processed and, if so, the right to access his or her personal data as well as the following information:

• The purpose of the data processing;

• The categories of personal data concerned;

• The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or those which belong to international organizations;

• The right to be informed as to the guarantees in terms of the transfer of data to third countries or international organizations;

• The period for retaining personal data;

• The right to request Grupo Vista Alegre to correct, erasure or limit the processing of personal data, or the right to prevent such processing;

• The right to file a complaint with the CNPD or other supervisory authority;

• The information available on the source of such data, if it has not been collected from the Customer;

• The existence of automated decisions, including profiling, information regarding the underlying logic, as well as the importance of expected consequences of such processing for the data subject. Upon request, Grupo Vista Alegre shall provide the User, free of charge, with a copy of the Customer Data that is being processed. The provision of other copies requested by the Customer may entail administrative costs.

15. RIGHT TO CORRECT PERSONAL DATA

Customers have the right to request, at any time, the correction of their Personal Data as well as the right to complement their personal data, even if through an additional declaration. In case data are corrected, Grupo Vista Alegre shall communicate this

information to each recipient to whom the data have been transmitted, unless such communication is deemed impossible or involves a disproportionate effort for Grupo Vista Alegre.

16. RIGHT TO DELETION OF PERSONAL DATA (“RIGHT TO BE FORGOTTEN”)

The customer has the right to obtain from Grupo Visabeira, the deletion of his/her personal data when one of the following reasons should occur:

• Customer Data is no longer necessary for the purpose it was collected or processed;

• The Customer withdraws the consent on which the data processing is based and there is no other legal ground for said processing;

• If the Customer objects to the processing under the right to object and there are no overriding legitimate interests justifying processing;

• In case there is no lawful basis justifying processing;

• In case Customer Data must be erased for compliance with the legal obligation which Grupo Vista Alegre is subject to. Under applicable legal terms, Grupo Vista Alegre shall not be obliged to delete Customer Data if processing is necessary to comply with a legal obligation which Grupo Visabeira is subject to or for the purposes of asserting, exercising or defending a Grupo Vista Alegre’s right in a legal proceeding. In case of data deletion, Grupo Vista Alegre shall notify this information to each recipient/entity to whom the data have been transmitted, unless such notification is deemed impossible or involves a disproportionate effort for Grupo Vista Alegre. In case Grupo Vista Alegre has made public the Customer Data and it is obliged to delete it pursuant to the right of such deletion, Grupo Vista Alegre undertakes to ensure that reasonable measures, including those of a technical nature, taking into consideration the available technology and the costs of their implementation, are taken to inform those responsible for the actual processing of personal data that the Customer has requested them to delete the links to such personal data, as well as the copies or reproductions thereof.

17. RIGHT TO LIMITATION OF PROCESSING OF PERSONAL DATA

The Customer has the right to obtain, from Grupo Vista Alegre, the limitation of the processing of his or her personal data if one of the following applies:

• If you contest the accuracy of the personal data, for a period that allows Grupo Vista Alegre to verify its accuracy;

• If the processing is unlawful and the Customer opposes to the deletion of the data, requesting, in return, the limitation of its use;

• If Grupo Vista Alegre no longer needs Customer Data for processing purposes, but such data is required by the customer for the purposes of asserting, exercising or defending a right in legal proceedings;

• If the Customer has objected to processing, until it is ascertained that the legitimate grounds of Grupo Vista Alegre prevail over those of the User. When Customer Data is subject to limitation, it may, with the exception of storage, only be processed with the consent of the User or for the purpose of asserting, exercising or defending a right in legal proceedings, defending the rights of another natural or legal person, or for reasons of public interest as provided by law. Customers who have obtained the limitation of the processing of their data in the aforementioned cases shall be informed by Grupo Vista Alegre before the limitation of processing is cancelled. In case of limitation of data processing, Grupo Vista Alegre shall inform each recipient to whom the data have been disclosed, unless such communication is deemed impossible or involves a disproportionate effort for Grupo Vista Alegre.

18. RIGHT TO PORTABILITY OF PERSONAL DATA

The Customer shall have the right to receive the personal data concerning him/her which have been provided to Grupo Vista Alegre, under a structured, commonly used and machine readable format, as well as the right to forward such data to another processing officer, if:

• Processing is based on consent or on a contract to which the Customer is a party;

• Processing is automated. The right of portability does not include inferred data or derived data, i.e., personal data that are generated by Grupo Vista Alegre as a result of the analysis of the data undergoing processing.

The Customer has the right to have his/her personal data transmitted directly between processing officers, whenever it is technically possible.

19. RIGHT TO OBJECT TO PROCESSING

The Customer has the right to, at any time, for reasons related to his/her particular situation, object to his/her personal data processing, and which is based on exercising the legitimate interests pursued by Grupo Vista Alegre, or when processing is carried out for purposes other than those for which the personal data were collected, including profiling, or when the personal data are processed for statistical purposes. Grupo Vista Alegre will cancel the processing of Customer data unless there are urgent and legitimate grounds for such processing which override the interests, rights and freedom of the Customer, or for the purposes of asserting, exercising or defending a right of Grupo Vista Alegre in a legal proceeding. When the Customer data are processed for direct marketing purposes, the Customer shall have the right to, at any time, object to his/her data processing, for the aforementioned purposes, including profiling, as long as related to direct marketing. In the event that the Customer objects to the processing of his/her data for the purposes of direct marketing, Grupo Vista Alegre shall cease processing data for such purposes. The Customer shall also have the right not to be subject to any decision taken solely on the basis of automated processing, including profiling, which produces legal effects, or which affects him/her significantly, unless the decision:

• Is necessary for the conclusion or the execution of a contract between the Customer and Grupo vista Alegre;

• Is authorized by legislation to which Grupo Vista Alegre is subject; or

• Is based on the Customer’s explicit consent.

20. PROCEDURES FOR EXERCISING CUSTOMER RIGHTS

The right of access, the right of correction, the right of deletion, the right of limitation, the right of portability and the right to object may be exercised by the Customer by contacting the Privacy Department by e-mail rgpd@vistaalegre.com For further information please contact the Data Protection Officer of Grupo Vista Alegre at dpo@vistaalegre.com or by letter addressed to the DPO of Grupo Vista Alegre: Lugar da Vista Alegre, 3830-292 Ílhavo - Portugal.

Grupo Vista Alegre shall respond in writing (including by electronic means) to a Customer’s request within one month from receipt of the request, except in cases of particular complexity, where such period may be extended to two months. If requests submitted by the Customer are unjustified or excessive, in particular due to their repetitive characteristics, Grupo Vista Alegre reserves the right to charge administrative costs or refuse to comply with the request.

21. CHANGES TO PRIVACY POLICY

Grupo Vista Alegre reserves the right to change this Privacy Policy at any time. We encourage you to read this document regularly.

22. RIGHT TO FILE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You can always file a complaint with the competent supervisory authority to protect personal data. In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados, located at Av. D. Carlos I, 134 - 1.º 1200-651 Lisboa, with the telephone number (+351) 213928400 and e-mail: geral@cnpd.pt.