Privacy Policy - Origem Energia

At Origem Energia, data privacy and security are fundamental to our relationship with you, thus we always keep upto date to ensure the highest security standards.

This Privacy Policy is committed to protecting the registration data of visitors to the Origem Energia website, as well as establishing the rules for collecting, using and transferring customer information orinformationof any third partywho may access or use our website, in accordance with the laws in force, in the way oftransparency and clarity towards you and the market in general.

By using our services, you understand that your personal information will be collected and used in the ways described in this Privacy Policy, under the rules of the General Data Protection Law (LGPD – Federal Law 13,709/2018) and other applicable rules of the Brazilian legal system.

Thus, Origem Energia S.A., recorded inthe National Register of Legal Entities (CNPJ) under number 32.021.201/0001-61, in the role of Data Controller, is bound by the provisions of this Privacy Policy.



Special Note for Children and Teenagers

Please, do not register on our website, if you are under 18 years of age.



About the application and validity of this policy

This Policy applies to the Origem Energia website and becomes effective as of the date provided in the footer of this document.



1. What data do we collect about you and for what purpose?

For the execution of our services and improvement of your user experience, our website collects and uses some of your personal data.



What do we collect?

Registration Data

• Full Name
• Birth Date
• Email
• Phone number
• Address / Zip Code
• State
• Education



Why do we collect your data?

(i) For identification purposes;
(ii) To fulfill the obligations arising from the use of our services;
(iii) To expand our relationship by keeping you up to date about news, website features, content and other events we consider relevant to you.



2. When we collect your data.

We only collect your data when you visit and use our website.



3. How we utilize your data.

Some sections of the Origem Energia website, such as the “Work with us” / “Be part of Origiem Energia” include contact forms for submitting personal data. Origem Energia assures that such data is necessary for service provision and will only be used to contact users of the website, not being passed on to third parties.

Technologies used:
- Cookies: You can, at your discretion, managepreferences for cookies from your browser or device settings, if you want to block them.This may cause certain website featureswe offer to be limited;
- Google Analytics: To record non-identifiable browsing data for analysis;

By using the Origem Energia website or providing your personal data in the forms available herein, you are fully aware of the terms of this Privacy Policy, in addition to knowing your rights and how to exercise them. At any time and at no cost, you may withdraw your consent.



4. What are your rights and how can you manage your data?

Origem Energia assuresits users of their rights in accordance with what is provided for in article 18 of the General Data Protection Law.

In the event thatyou wish to exercise your rights and clarify any concerns about the Origem Energia website data sharing policy, please contact our Legal team via email at juridico@origemenergia.com.

Thus, you may, at any time, free of charge, exercise your rights via the aforementioned email, as follows:
- To confirm the existence of the treatment, to amend your personal data when incomplete, inaccurate or outdated;
- To request the deletion of your data, unless legally required otherwise;
- To request limited use of your data;
- To request the correction of your data;
- To express your objection and/or withdraw consent to the use of your personal data, in such instances where we use your consent to process your data;
- To request portability of your data, through a registration data report which Origem Energia handles about you;
- You have the right to receive your personal data in a simplified format;
- You can revoke your consent, by disallowing the processing of your data.



5. How and for how long will your data be stored?

Your personal data collected by Origem Energia will be utilized and storedfor the required time period until theservice or the provisions, described in this Privacy Policy, have been accomplished regarding the rights of the data subject as well as those of the controllers.

In a general sense, your collected data will remain stored for as long as the contractual relationship between you and Origem Energia may last.
Upon the conclusion of the personal data storage period, these will be deleted from our database or anonymized, except in the instances provided for in article 16 of the General Data Protection Law, i.e.:

I- Compliance with legal or regulatory obligation by the controller;
II- Study by a research body, and whenever feasible, guaranteed anonymization of personal data;
III- transfer to a third party, subject to data processing requirements set out in this Law; or
IV-Exclusive use by the controller, its access to any third party is prohibited, provided that the data is anonymized.To specific, personal information about you, essential to the fulfillment of legal, judicial and administrative determinations and/or to the exercise of the right of defense in judicial and administrative proceedings will be withheld, despite the deletion of other data.
The storage of data collected by Origin Energia reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions able to guarantee the confidentiality, integrity and inviolability of your data. Moreover, we also apply risk-appropriate security measures and access control to stored information.



6. What do we do to keep your data safe?

To keep your personal information safe, we use physical, electronic and managerial tools aimed at protecting your privacy.

We apply these tools based on the nature of the personal data collected, the context and purpose of the processingand the risks that any violations would generate for the rights and freedoms of the data subject whose data has been collected and processed.

Among the adopted measures, we highlight the following:
• Only authorized persons have access to your personal data;
• Access to your personal data is made only after a commitment to confidentiality;
• Your personal data is stored in a secure and suitable environment.

Origem Energia is committed to adopting the best practices to avoid security incidents. However, it is necessary to point out that no web page is entirely safe and risk-free. It is possible that, despite all our security protocols, problems that are solely the fault of third parties may occur, such as cyber-attacks by hackers, or else, due to negligence or recklessness by the user/client himself.

In the event of security incidents that may generate relevant risk or damage to you or any of our users/clients, we will notify those affected and the National Data Protection Authority about what has occurred, in line with the provisions of the General Data Protection Law.



7. With whom can your data be shared?

In order to preserve your privacy, Origem Energia will not share your personal data with any unauthorized third parties.

Check below the list of stakeholders with whom your data may be shared after your prior authorization:
- With competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, requisition or court order;
- For the purposes of market intelligence research, disclosure of data to the press and advertising. In such cases, the data provided by you will be shared anonymously, i.e. in a way that does not allow your identification.

Origem Energia ensures to only send necessary personal data to carry out the service, in accordance with good practices and with the legitimate purpose of the data treatment, along with what is provided for in contractual clauses aimed at protecting your data.



8. International data transfer

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. Under these conditions, at any rate, your personal data will be subject to the General Data Protection Lawand other Brazilian data protection legislation. Origem Energia is, in that regard, committed to always adopting efficient cyber security and data protection standards, while puttingforththe best effortsto guarantee and comply with legislative requirements. By browsing our site you are subject to this Privacy Policy, and the purposes described in this statement.

It is worth emphasizing that, in order to preserve your privacy; Origem Energia will not share your personal data with any unauthorized third party. In the cases in which there is such a possibility, Origem Energia ensures that it only sends personal data necessary to carry out the servicein accordance with good practices and with the legitimate purpose of the data treatment, along with what is provided for in contractual clauses aimed at protecting your data.



9. Cookies or browsing data

Origem Energia makes use of cookies, small text files sent and stored on your computer. These small files are used to recognize, track and store your browsing experience on the internet.

In short, cookies are used to improve user experience. By accessing our website, you declare that you know and accept browsing data collection with the use of cookies on your device. You may, at any time and at no cost, change permissions, block or refuse cookies. However, revoking consent to certain cookies may make it impossible for some features of the platform to function correctly.

In order for you to be able to simply and intuitively manage your cookies preferences from your browser, you can use one of the links below:
• For more information on “Private Browsing” and managing cookies in the Firefox browser, click here;
• For more information on browsing “Incognito Mode” and managing cookies in the Chrome browser, click here;
• For more information on “Private Browsing” and managing cookies in the Internet Explorer browser, click here;
• For more information on “Private Browsing” and managing cookies in Safari, click here;
• For more information on “Private Browsing” and managing cookies in the Opera browser, click here.



10. Amendment of this Privacy Policy

The current version of this Privacy Policy was formulated and last updated on October 27, 2021. Origin Energia reserves the right to modify this Privacy Policy at any time, mainly due to the adequacy of any changes made on our website or in the legislative scope. Therefore, we recommend that you review it frequently.

Any changes will be effective as of their publication on our website and we will always notify you of the changes.

By using our services and providing your personal data after such modifications, you consent to them.



11. Responsibility

Origem Energia provides for the liability of agents who act in the data treatment processes, in accordance with articles 42 to 45 of the General Data Protection Law.

We undertake to keep this Privacy Policy updated, observing its provisions and ensuring compliance.

In addition, we are also committed to seeking technical and organizational conditions that are suitable to the protection of the entire data treatment process.

In case the National Data Protection Authority requires the adoption of measures regarding the processing of data carried out by Origem Energia, it is our commitment to comply with them accordingly.



11.1 Disclaimer

While Origem Energia adopts high security standards in order to avoid incidents, there is no web page that is entirely risk-free. Therefore, OrigemEnergia is not responsible for:

I – Any consequences arising from negligence, recklessness or a user’s malpracticeregarding their individual data. We guarantee and are only responsible for the security of the data processing procedures and the fulfillment of the purposes described in this instrument. We emphasize that the responsibility for the confidentiality of access data lies with the user;
II – Malicious actions by third parties, such as hacker attacks, unless proven guilty or deliberate conduct by Origem Energia. In the event of security incidents that may cause relevant risk or damage to you or any of our users/clients, we will notify those affected, as well as the National Data Protection Authority, while complying withthe necessary measures;
III – Inaccuracy of the information entered by the user/client in the records necessary for the utilization of the Origem Energia services, any consequences resulting from false information, or information supplied in bad faith are entirely the responsibility of the user/client.



12. Information about this policy

This Policy will be interpreted in accordance with Brazilian legislation, in the Portuguese language, and the court of your domicile will be chosen to settle any dispute involving this document, except for specific objection of personal, territorial or functional competence by applicable legislation.

If you do not have a domicile in Brazil, you are subject toBrazilian legislation, agreeing, therefore that in case of litigation to be resolved, the action must be filed in the Court of the City of Rio de Janeiro, State of Rio de Janeiro.

For any questions about the present contents of the Privacy Policy of Origem Energia, you may contact us at juridico@origemenergia.com.



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