Privacy Policy

This Privacy Policy explains how W4IMPACT NEGÓCIOS E IMPACTO LTDA., registered with the Brazilian National Register of Legal Entities (CNPJ/MF) under No. 66.762.368/0001-03, with registered office at Avenida Presidente Juscelino Kubitschek, 510, sala 92, Vila Nova Conceição, São Paulo/SP, CEP 04543-906, the company responsible for operating ÁVORA (“ÁVORA”, “we”, “us” or “our”), collects, uses, stores, shares and protects personal data.

This Policy also sets out, in a transparent manner, the rights you have in relation to your personal data and how you may exercise them.

This Policy applies to individuals who interact with ÁVORA, including, as the case may be:

• visitors to and users of our digital channels
• individuals who express interest in joining ÁVORA
• applicants and members of the Club
• guests and participants in events and experiences
• mentors, experts, speakers and other participants in the community
• representatives of companies, brands and partners
• individuals who receive our communications, invitations or content
• suppliers and service providers
• individuals who otherwise contact or have a relationship with ÁVORA

When you use our channels, attend events, apply for admission, become a member or interact with us, your personal data may be processed in accordance with this Policy and applicable law.

We recommend that you read this Policy carefully. We may also provide specific privacy notices in certain situations, particularly where there is a specific purpose or form of processing.

To facilitate the understanding of this Policy:

“Personal data” information relating to an identified or identifiable natural person, such as name, email address, telephone number, job title or other data that allows that person to be identified.

“Processing” any operation performed on personal data, including collection, access, use, storage, organization, sharing, alteration and erasure.

“Controller” the natural or legal person responsible for decisions concerning the processing of personal data.

“Data subject” the natural person to whom the personal data relate.

“LGPD” Brazilian Federal Law No. 13,709/2018 (Lei Geral de Proteção de Dados Pessoais, the Brazilian General Personal Data Protection Law), as subsequently amended.

Depending on how you interact with ÁVORA, we may collect different categories of data, including:

Our website uses cookies and similar technologies in two categories:

• Necessary: they keep the website working and secure and store your cookie choice. This choice is saved in your browser's local storage for up to 12 months. They do not depend on consent.
• Measurement (optional): Google Analytics 4, loaded through Google Tag Manager, both provided by Google, measures in aggregate how the website is used: pages visited, language, clicks on buttons and links, scrolling, starting and submitting forms, device and browser type and the approximate origin of the visit. These cookies (such as _ga and _ga_*) are only enabled if you click Accept in the cookie notice.

We never send Google your name, email, phone number or the content of messages and applications filled in on the website. The use of data for advertising and personalised ads remains disabled.

You can accept or decline measurement in the notice shown on your first visit and change your choice at any time under Cookie preferences, in the website footer. Declining does not prevent you from using any page or form. You can also delete or block cookies in your browser settings.

Measurement cookies are processed on the basis of your consent, which you may withdraw at any time. Google acts as the processor of this data and may process it outside Brazil, as described in the international transfer section of this Policy. Measurement data is kept for the retention period configured in Google Analytics.

We may process your personal data for purposes such as:

• reviewing and managing applications to ÁVORA
• conducting the member admission and curation process
• managing your membership of the Club
• providing benefits, experiences, gatherings and content
• organizing events and managing registrations and attendance
• facilitating connections and networking opportunities among members
• carrying out matchmaking and professional connection initiatives, where applicable
• sending invitations, information and communications relating to ÁVORA
• communicating news, experiences and opportunities relevant to the community
• managing payments and obligations relating to membership
• developing and improving our services, experiences and community
• complying with legal and regulatory obligations
• preventing fraud, abuse and security incidents
• protecting our rights and legitimate interests
• exercising or defending rights in judicial, administrative or arbitration proceedings

We will not use your personal data for purposes incompatible with those set out in this Policy or with the applicable legal bases.

ÁVORA will always process personal data on the basis of one of the legal bases provided for in applicable law, according to the specific purpose of the processing.

• performance of a contract or of procedures related to entering into a contract
• compliance with a legal or regulatory obligation
• regular exercise of rights
• legitimate interest, where applicable and provided that the rights and freedoms of the data subject are respected
• consent, where required
• credit protection, where applicable
• other legal bases provided for in the legislation in force

Where processing is based on consent, you may withdraw it in accordance with applicable law.

Withdrawal of consent does not invalidate processing lawfully carried out prior to such withdrawal.

ÁVORA may share personal data only when necessary for a specified and legitimate purpose that is compatible with this Policy, subject to the respective legal basis. Sharing will be limited to the categories of data necessary for each purpose and to the third parties directly involved.

The categories of recipients and the data that may be shared are as follows:

ÁVORA does not sell its members' personal data.

ÁVORA will not make available to third parties, for their own independent use, profile information, preferences or other personal information beyond what is necessary for the specific and legally authorized purpose. Where the purpose requires an individualized disclosure that is not covered by an authorization or another applicable legal basis, ÁVORA will request the specific approval of the data subject.

ÁVORA's proposition involves connecting women leaders, entrepreneurs, executives, professionals, experts and other members of its community.

To make this possible, certain professional or profile information may be used to facilitate connections, gatherings, introductions and matchmaking initiatives. The use and disclosure of such information will be limited to what is necessary for the intended connection.

Where a connection requires personal data to be presented to another member or third party who does not have access to such information, ÁVORA, where a specific authorization is required, will obtain the data subject's prior agreement, clearly indicating what information will be shared and with whom.

These connections will be made in accordance with the community's features and rules and do not constitute a recommendation, endorsement, or commercial or professional guarantee on the part of ÁVORA.

Each member is responsible for independently assessing any opportunity, business, engagement or relationship arising from a connection made within the community.

We may use your contact details to send:

• administrative communications
• information about your membership
• invitations to events and experiences
• information about community activities
• content relating to ÁVORA
• surveys and requests for feedback
• institutional or commercial communications, where permitted by applicable law

Where a communication is subject to consent, we will request the corresponding authorization.

You may unsubscribe from marketing communications at any time, without prejudice to receiving essential communications relating to your membership or to the provision of the services.

ÁVORA may make photographic, audiovisual and audio recordings during events, gatherings, experiences and other activities.

The use of image and voice will be handled on a case-by-case basis, in accordance with the terms of the specific authorization presented for the respective situation and with applicable law.

Where there is a specific authorization for the use of image and/or voice, the recordings may be used exclusively within the limits, purposes, channels and period, if any, indicated in the authorization.

Participation in a given event does not, in itself, imply a general or unrestricted authorization for the use of image, voice or content. Where authorization is required, ÁVORA will request specific consent, stating the intended use.

We adopt reasonable technical, administrative and organizational measures to protect personal data against unauthorized access and against accidental or unlawful destruction, loss, alteration, communication or disclosure.

Despite the efforts employed, no electronic system is completely secure. Accordingly, we cannot guarantee the absolute security of the data.

In the event of a security incident that may pose a relevant risk or harm to data subjects, we will take the appropriate measures in accordance with applicable law.

Data retention will take into account the purpose of the processing, the need to retain the data and the applicable legal and contractual obligations. For reference, the following periods or criteria will apply:

Once retention is no longer necessary, the data will be erased or anonymized, where technically feasible and unless their retention is permitted or required by law.

Some technology providers used by ÁVORA may be located outside Brazil or use international infrastructure. Where an international transfer takes place, the requirements and safeguards provided for in applicable Brazilian law will be observed.

Depending on the services actually contracted by ÁVORA, transfers may involve categories such as registration data, communication data, technical browsing data, event participation data and information required for payments or technology support.

The destination countries, the specific providers and the legal mechanism used for each transfer will depend on the infrastructure and services actually contracted at the time of processing. ÁVORA will keep this information up to date and may make it available to the data subject upon request through the privacy channel indicated in this Policy or by means of a specific privacy notice.

Where applicable, international transfer mechanisms permitted under Brazilian law will be used, subject to the safeguards and guarantees required for the protection of personal data.

On the website, Google Analytics and Google Tag Manager, provided by Google, may process technical browsing data outside Brazil, only for visitors who accepted measurement cookies.

You may exercise the following rights:

• confirmation of the existence of processing
• access to your personal data
• correction of incomplete, inaccurate or out-of-date data
• anonymization, blocking or erasure of unnecessary data or data processed in non-compliance with the law
• portability, where applicable
• information about the sharing that has taken place
• information about the possibility of not giving consent and the consequences of refusal
• withdrawal of consent
• objection to certain processing, where applicable
• other rights provided for by law

Requests may be subject to verification of the data subject's identity and to the limitations provided for by law.

The simplest way to make a request is the My data page, at www.avoraclub.com.br/en/meus-dados: choose what you need (access, correction, deletion, unsubscribe or another request), receive a confirmation by email, and get a reply within 15 days.

To request information, exercise your rights or clarify any questions concerning the processing of your personal data, please contact ÁVORA's Data Protection Officer (DPO):

Data Protection Officer (DPO) email: contato@avoraclub.com.br

Upon receiving a request, we may ask for additional information to confirm the identity of the data subject and ensure the security of the data.

ÁVORA may update this Privacy Policy periodically to reflect changes in its practices, services or technologies or in applicable law.

The most recent version will be available on ÁVORA's official channels.

Where a change is material and significantly expands the purposes, forms of use or instances of sharing of personal data, ÁVORA will notify data subjects in advance through the available contact channels, whenever legally possible and before commencing the new processing or sharing, except where prior notice is not required or is rendered unfeasible by legal requirement.

For questions, requests or matters relating to privacy and personal data protection:

ÁVORA (W4IMPACT NEGÓCIOS E IMPACTO LTDA.)

CNPJ: 66.762.368/0001-03

Av. Presidente Juscelino Kubitschek, 510, sala 92

Vila Nova Conceição, São Paulo/SP

CEP 04543-906

Email: contato@avoraclub.com.br

By registering, applying for membership, taking part in certain activities or using ÁVORA's channels, you declare that you have had access to this Privacy Policy and are aware of its provisions.

Where a given processing activity requires consent, such consent will be requested in a specific, free, informed and unambiguous manner, in accordance with applicable law. Authorizations relating to the disclosure of profile information, networking, image, voice or other personal information that depend on consent will be handled specifically, indicating, where applicable, the purpose, the information involved, the recipients and the period or conditions of use.