PRIVACY POLICY - ECG

Protecting each user’s privacy is crucial to the future of business conducted on the Internet and for migration to the real economy on the Internet. FH created this privacy statement to express its firm commitment to each user’s right to privacy. This policy sets out the use practices for personal information on this site

Basic principles on global privacy
FH’s privacy practices reflect the current global principles and standards regarding the handling of personal information. These principles include notices on data use, data use preference, access to data, data integrity, security, continuous transfer and compliance and oversight. The FH submits to the privacy laws of the countries where it does business.

Consent
By using this site, the user agrees to the data collection and information use terms described herein. If FH changes this Privacy Statement, it will post the changes on this website so that the user is always knowledgeable of what information is collected and how it is used.

Periodically, as required by the applicable law, FH may also ask for the user’s explicit consent to process certain data and information collected on this site or provided spontaneously by the user.

Personal data collection and processing
To better serve users and understand their needs and interests, FH collects, exports, and uses personal information with the due consent and proper notice, besides the relevant requirements issued by the data protection authorities, when applicable.

When the user visits the site, FH might record the user’s IP address and use cookies and other Internet technologies (hereinafter Automatic tools and embedded links) to gather general information of visitors and their interests. The technologies used and the information collected are described in detail below.

FH can also harvest and process any information and data provided voluntarily by the user, for example when signing up for events, subscribing to newsletters, participating in online surveys, in discussion forums or groups, or making purchases.

Use and purpose of collected personal data
Information collected aimed at understanding the user’s needs and interests allows FH to provide a consistent, customized experience. The FH uses this information only as described in this Privacy Statement and/or as specified at the time data is collected. FH will not subsequently modify the form of the use of personal data without the user’s express consent, as required by the applicable law.

FH uses the user’s personal data to, among others, keep the user updated about the latest products, software updates and upgrades, security patches, system enhancements, special offers, and other information. This may occasionally include information from other technology companies or business partners concerning products and services that add value to FH products.

Customize the information about FH products and services to meet each user’s specific interests. For example, while visiting the website, such customization allows FH to provide product and service information of special interest to the user.

Offer participation in sweepstakes, contests or other promotional activities carried out on fh.com.br or partner sites. Personal data may be collected to oversee these programs.

Apply questionnaires and conduct research to offer better quality products and services to FH customers and users. The user’s completion of any questionnaires is a voluntary act.

Assist in recruitment queries and meet contractual obligations.

IP Addresses
FH uses IP addresses to help diagnose issues, manage the site, and to gather demographic information. FH can also use IP addresses or other information, such as fh.com.br information the user shares on this site or any previous occasion, or a campaign code, to identify site pages visited and topics interest in order for FH to provide the user with information about relevant products and services. Overall, FH collects these data anonymously and does not connect them to any particular user, unless expressly authorized by such user. When the user visits the site, FH recognizes only the user’s domain name.

FH only collects information related to the user’s visit to FH’s site. FH does not track or collect personal information on the user’s visits to sites of companies or entities outside the FH group.

Automatic tools
In addition to the information provided by the user, FH may also collect information during visits to FH’s site using automated tools, including Web beacons, cookies, embedded links and other tools typically used for data collection. These tools gather certain standard information sent by the user’s browser to FH’s website, such as browser type and language, access times and address of the website that led the user to FH’s page. With these tools, FH can also confirm the receipt of e-mails sent with the recipient’s consent and track other information, such as pages visited on the FH site, whether or not the recipient registers for events offered by FH, in addition to other data collected, unrelated to any particular user.

Embedded links
E-mails FH sends usually contain links intended to direct the user to a relevant area on the Web and, then, redirect them through FH’s servers. The redirection system allows FH to change the destination URL of these links, if necessary, and to determine the effectiveness of marketing initiatives.

In the e-mails, such links also allow FH to determine whether the user clicked on the link contained in the e-mail, and the information of this interaction may be linked to the user’s personal identification. If the user does not want FH to harvest information from the links he or she clicked, all he or she has to do is not click the link contained in the e-mail sent by FH.

Cookies
FH uses cookies to deliver customized content in order for the user not to have to repeatedly enter the password and for FH to customize the information provided to the user according to how the user himself and other users use the site.

E-mail addresses
If the user chooses to provide his or her e-mail to FH, communication will take place by e-mail. FH does divulge the user’s e-mail to companies not belonging to the FH group. The user may, at any time, opt out of receiving further e-mails from FH.

Depending on the user’s e-mail server configuration, user information may be transmitted automatically when he or she e-mails FH.

If the user elects to register to receive third-party services, it is possible some fh.com.br registry information will have to be sent to the service provider, including the user’s e-mail address.

Sharing personal data
As a global company, FH’s site is accessible worldwide. Any information and data supplied voluntarily by the user him or herself in any country may be sent electronically to FH’s server in another country, which may not be the same as the user’s. FH protects the user’s privacy interests around the world, ensuring that its website complies with the principles of data protection described herein.

FH may also share this information with business partners, service providers, agents or other authorized contractors to provide the requested service or transaction, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registrations and providing customer support or providing the user with information about goods and services of interest to him or her.

FH only provides to such third parties the minimum amount of personal data necessary for them to provide services on behalf of FH, and third parties are authorized to use the user’s personal data only for the sole purpose of completing the requested service or transaction.

FH does not sell or lease personal user data to third parties for marketing purposes unless authorized by the user.

There will be circumstances when, whether for strategic or other business reasons, FH decides to sell, buy, merge or otherwise reorganize businesses in some countries. This type of transaction may involve, under the applicable law, the disclosure of personal information to actual or prospective purchasers, or the receipt of such information provided by the sellers. Part of FH’s practice is to seek appropriate protection for information in these types of transactions.

FH can collect and possibly share personal information and any other available information to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to any person’s physical safety, breaches of FH’s Terms of Use or any other legal requirement.

During the visit to FH’s site, the user may be directed to content or functionalities hosted by another vendor, not on the fh.com.br website. This is often done to host special events, such as contests or seminars. When the information is harvested exclusively on behalf of FH, the appropriate FH entity’s privacy statement will be mentioned on the site and govern how the information is used. For other, non-FH sites, the site owner’s privacy policy shall be mentioned. FH’s practice requires such vendors and business partners to handle the information in accordance with FH’s privacy statement.

Personal data security
FH is committed to protecting the personal user data shared with it. FH uses a combination of standard industry technologies, procedures and organizational security measures to protect user’s personal data against unauthorized access, use or disclosure. FH offers online support for security using secure server technology to ensure user data security. There are cutting-edge security arrangements and facilities on FH’s websites to prevent abuse.

FH requires its employees to respect the user’s rights to confidentiality and privacy.

Links to other sites
This site may contain links to other sites. FH is not responsible for the privacy practices or for the content of other sites of companies not belonging to FH.

Opting out from receiving communications
FH communicates with users subscribing FH services regularly by e-mail and may also communicate by phone to respond to customer complaints or investigate suspicious transactions. FH can use the user’s e-mail to confirm the opening of the user’s account, send information about changes in FH products and services and to send notices and other specifications required by law. In general, users cannot opt out of receiving these communications, but they are primarily informational rather than promotional in nature.

FH offers the user the possibility to unsubscribe if he or she does not want to receive other types of communications from FH, such as e-mails or updates about new services and products offered on this site, or if he or she does not want FH to share his or her personal information with third parties. The user may opt out from receiving such notice by e-mailing: relacionamento@fh.com.br to unsubscribe.

Data retention
FH does not retain the user’s personal data longer than necessary in order to meet the purposes for which they were collected or as required by the applicable law and regulations.

Consultations, access and updating personal data
FH needs the user’s help to keep the personal data he or she shares current and accurate. In the case of a registered user, the user him or herself can update by sending an e-mail to relacionamento@fh.com.br

If the user has any question about this privacy statement or would like to further examine the information FH stores about him or her, he or she should contact: relacionamento@fh.com.br