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Privacy
Policy

Our commitment to transparency in the processing of personal data, in compliance with the Brazilian General Data Protection Law (LGPD — Federal Law 13,709/2018).

1. Introduction

At NAPRO Eletrônica Industrial Ltda, your privacy and security are priorities, and we are committed to transparency in the processing of personal data belonging to our users and customers.

Our data privacy policy aims to demonstrate our commitment and respect for the information entrusted to us.

By using our services, you understand that we will collect and use your personal information in the ways described in this Policy, in accordance with Brazilian data protection rules (LGPD, Federal Law 13,709/2018), consumer protection provisions of Federal Law 8,078/1990, and other applicable Brazilian legislation.

Our privacy policy explains how NAPRO collects, processes/uses, protects and shares the personal data shared with us by you, the use and transfer of information of users, customers or other persons who access or use our website https://www.napro.com.br and the applications PCSCAN3000, PCSCAN7000, PCTRUCK, NAPROSCAN on any platform where they are available.

Accordingly, NAPRO Eletrônica Industrial Ltda, hereinafter referred to simply as "NAPRO ELETRÔNICA", registered under CNPJ/MF No. 57.816.183/0001-35, in the role of Data Controller, is bound by the provisions of this Privacy Policy.

2. Definitions

Controller: a natural or legal person, under public or private law, responsible for decisions regarding the processing of personal data (LGPD, art. 5, VI).

Processor: a natural or legal person, under public or private law, that processes personal data on behalf of the Controller (LGPD, art. 5, VII).

Personal Data: any information relating to an identified or identifiable natural person.

Sensitive Personal Data: personal data concerning racial or ethnic origin, religious belief, political opinion, trade union or religious, philosophical or political organization membership, health or sexual life data, genetic or biometric data, when linked to a natural person.

Data Protection Officer (DPO): person designated by the Controller and Processor to act as a communication channel between the Controller, Data Subjects and the National Data Protection Authority.

ANPD: National Data Protection Authority — body responsible for overseeing compliance with the LGPD in Brazil.

Data Subject(s): natural person to whom the personal data being processed refers.

Processing: any operation or set of operations performed on personal data, by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, comparison, restriction, erasure or destruction.

3. Information We Collect About You

We process your personal data based on your consent. Consent is the free, informed and unambiguous expression by which you authorize NAPRO ELETRÔNICA to process your data.

In accordance with the LGPD, your data will only be collected, processed and stored with prior and express consent.

We collect information voluntarily entered through our electronic forms (website), social media, e-mails or any other electronic or physical means by which you contact us.

In addition to voluntarily provided data, the NAPRO ELETRÔNICA website may automatically collect technical browsing data, such as: IP address, browser type and version, pages visited, time spent and device identifiers, through cookies and traffic analysis tools.

4. Personal Data Provided by the User

We collect all personal data voluntarily entered or submitted by you. Depending on the purpose of the contact or engagement, data collected may include:

Identification and contact data: full name, e-mail, phone, job title and company.

Fiscal and commercial data: tax registration number, company name, billing address and delivery address — collected when necessary for issuing tax documents and fulfilling the supply contract.

Technical browsing data: IP address, cookies, session data and website usage data.

Technical support-related data: information provided by the user when opening support tickets, including descriptions of equipment and usage situations, which may occasionally contain references to personal data.

NAPRO ELETRÔNICA does not collect sensitive personal data (as defined in LGPD art. 5, II) in its standard interactions with customers and website users.

NAPRO ELETRÔNICA may also collect data necessary for the performance of contracted services, always in compliance with article 7 of LGPD (Law 13,709/2018).

5. Withdrawal of Consent

At any time and at no cost, you may withdraw your consent by contacting us through our Ombudsman or by phone at +55 (11) 4391-7000.

6. Data Sharing

NAPRO ELETRÔNICA may share your data with other Controllers located within Brazilian territory in the following circumstances:

With partner companies and suppliers in the development and provision of services aimed at serving its customers;

With authorities, governmental entities or other institutional third parties, to protect the interests of NAPRO ELETRÔNICA in any type of conflict, including legal actions and administrative proceedings;

Upon court order or at the request of administrative authorities with legal competence to require it.

7. International Data Transfers

The NAPRO ELETRÔNICA website uses third-party services that may process data on servers located outside Brazil, including, among others: Google Analytics (traffic analysis), Google Fonts (font loading) and CDN (Content Delivery Network) services for performance optimization.

These transfers are carried out pursuant to article 33 of the LGPD, with appropriate safeguards as required by law, including standard contractual clauses and supplier compliance certifications. We recommend reading the privacy policies of the respective services to understand their practices.

8. Purposes and Legal Bases — Why and How We Process Your Data

NAPRO ELETRÔNICA processes your personal data on the following legal bases provided for in the LGPD (art. 7):

Consent (art. 7, I): for sending commercial communications and newsletters, when you expressly authorize it.

Performance of a contract (art. 7, V): to process purchase orders, issue invoices, carry out deliveries and provide contracted technical support.

Compliance with a legal obligation (art. 7, II): to fulfill tax, labor and regulatory obligations imposed by Brazilian legislation.

Legitimate interest (art. 7, IX): to respond to enquiries and requests, prevent fraud, ensure system security and improve services, always within the reasonable expectation of the data subject and without prejudice to their rights and fundamental freedoms.

9. Your Privacy Rights

In order to preserve your privacy, NAPRO ELETRÔNICA will not share your personal data with any unauthorized third party. Under the LGPD (art. 18), you have the following rights:

Right to know: confirmation of the existence of processing and its purpose.

Right of access: request a copy of the personal information we hold about you.

Right to rectification: request correction of incomplete, inaccurate or outdated data.

Right to data portability: request the transfer of your personal data to another service or product provider, upon express request, in an interoperable format, as regulated by the ANPD.

Right to object: object to the processing of your personal data and withdraw your consent.

Right to erasure: request the deletion of your personal information, provided there is no legal or regulatory obligation to retain it.

Right to be free from discrimination: NAPRO ELETRÔNICA will not discriminate against you for any information or for exercising your privacy rights.

10. Requesting Access or Deletion of Data

To exercise your rights, contact us through the Ombudsman website or by post:

NAPRO Eletrônica Industrial Ltda
Attn: Data Protection Officer — Mr. Claudio
Rua Oneda, 426 — São Bernardo do Campo — SP — ZIP: 09895-280
Phone: +55 (11) 4391-7000

11. How We Protect Your Information

To keep your personal information safe, we use physical, electronic and managerial tools aimed at protecting your privacy, including: data security protections to ensure security, integrity and availability of systems; restriction of physical access to facilities; restriction of access to collected information; monitoring of business partners; and destruction or anonymization of personal information as required by law.

12. Data Retention and Storage

Your personal data will be automatically deleted by NAPRO ELETRÔNICA when the purpose for which it was collected has been fulfilled, or when it is no longer needed to comply with legal obligations. Data processing may be terminated when you request deletion, except for data that must be retained by legal provision.

13. Security Incident Notification

In the event of a security incident that may pose a relevant risk or harm to data subjects, NAPRO ELETRÔNICA will notify the National Data Protection Authority (ANPD) and affected data subjects within a reasonable timeframe, as required by LGPD art. 48, informing the nature of the affected data, the technical and security measures adopted and the actions taken or to be taken to mitigate the effects of the incident.

14. Social Media

NAPRO ELETRÔNICA is present on social media platforms. The processing of data of followers and persons who interact with our pages follows the same guidelines as this Privacy Policy, as well as the terms of use of each social network, previously accepted by the user.

15. Curriculum / Résumé Submission

If you send your résumé to NAPRO ELETRÔNICA, your data will be kept in our talent database for future selection processes, with full respect and confidentiality. You may request deletion of your data at any time.

16. Cookie Technology

NAPRO ELETRÔNICA uses cookies to facilitate use and better adapt its website to the interests and needs of its customers. Cookies may be: necessary (for website operation), performance, session, marketing and persistent. You may revoke cookie authorization at any time through your browser settings.

17. Applicable Law

This Policy was drafted in compliance with Brazilian Federal Law No. 13,709/2018 (General Personal Data Protection Law — LGPD) and other applicable legislation.

18. Updates to this Policy

This Privacy Policy may be updated at any time. We recommend visiting this document periodically to be aware of changes. The current version was updated in May 2026.

19. Contact Us

To exercise your privacy rights or to ask questions about this Policy, contact our Data Protection Officer:

NAPRO Eletrônica Industrial Ltda
Attn: Data Protection Officer — Mr. Claudio
Rua Oneda, 426 — São Bernardo do Campo — SP — ZIP: 09895-280
Phone: +55 (11) 4391-7000
Ombudsman: napro.com.br/ouvidoria.html