1. Who does this Policy apply to?

This Privacy Policy, also referred to as the “Policy”, applies to those who access or register in our application and to those who use it in any other way.

Our application will be referred to as the “app”, “MARKET4U app”, “application” or “MARKET4U application”. Whenever the terms “MARKET4U”, “we”, “us” or “our” are used, we are referring to MARKET4U. Likewise, whenever the terms “you”, “your” or “user” are used, we are referring to you. Whenever the terms “operators of our technology” or “operators of our business model” are used, we are referring to the Franchisees of the MARKET4U Franchise Network.

2. Who controls the processing of personal data?

The controller is the natural or legal person that makes decisions regarding the processing of personal data.

When you access or register in our application, MARKET4U acts as the controller of the processing of your personal data, operating in accordance with applicable law and as described in this Policy.

3. What data is collected?

3.1 Data you provide to us

When you create an account to become a MARKET4U user, we may obtain a range of information about you, such as:

a) Profile data

This data includes your name, CPF (Brazilian individual taxpayer registry number), email address, address, phone number and preferences.

To create your registration in the MARKET4U Application, you may also use your social media account. For example, when using Facebook to register, you will allow MARKET4U to access personal information in your Facebook account, such as your name and email address, if you have registered them on Facebook. The information we obtain in this case is the same and depends on your privacy settings with the social networking service.

b) Payment data

When making a purchase or placing an order in the MARKET4U app, you must make the payment directly in the application.

When choosing your payment method, you may provide us with your payment data, such as credit card data and data related to partner payment methods. However, you can rest assured: your online payment information is stored by MARKET4U only in anonymized form, limited to the last four digits of the card, so we do not have access to your complete financial data.

c) Location data

To correctly identify the MARKET4U point of sale where you are making your purchase, or so that one of our partners can deliver your order or provide a service, we also need you to provide us with your location.

This location may be provided through the address you enter manually in the application, or through the location obtained from your device via GPS and mobile networks, including cell towers, Wi-Fi and other location methods, and confirmed by you.

For purposes of Law No. 12,965 of 2014 (Brazilian Internet Civil Rights Framework), or any law that may replace it, the location provided will be considered registration data.

3.2 Data generated while using the services

a) Data from your devices

We may automatically collect information about the devices from which you access MARKET4U, such as IP addresses, browser type and language, Internet Service Provider (ISP), operating system, date and time information, device manufacturer, carrier, model, device version, application version, operating system version, device advertising identifier (IDFA), device accessibility information and Wi-Fi networks.

b) Transactional data and data about your use

We collect data about your interactions with our application, including date and time of access, sequence of interactions with the application, searches and views. We may also collect transactional data related to your use of our services, such as order details, order date and time, amount charged and payment method.

c) Communication data

We intermediate communication between users, operators of our technology and partner establishments through our application. For example, we allow users, couriers and partner establishments to send messages through chat or anonymized phone calls. To provide this service, MARKET4U receives certain data relating to calls, texts or other communications, including the date and time of the communications and the content of the communications.

d) Audio and video

For security and monitoring of our points of sale, MARKET4U carries out audio and video monitoring. This monitoring is activated by an intelligence and computer vision system and, from that point onward, is operated remotely by an operator linked to MARKET4U.

3.3 Non-personal information

We may also obtain non-personal information, meaning data that does not allow direct association with any specific person. Examples of non-personal data include aggregated purchases, orders and the locations where MARKET4U points of sale exist by region.

4. How do we use this data?

4.1 Providing our services

We may use the data collected to provide, maintain, improve and personalize our products and services intended for you, whether existing or to be created.

This processing includes the use of data to create and update your account; allow order deliveries or the provision of services by our partners; personalize your account; and provide necessary internal operations.

We may also use your personal data for internal purposes, such as auditing, data analysis and research to improve products, services and customer communications, as well as to generate statistical analyses regarding the use of our services, including consumer trends.

4.2 Non-commercial communications

From time to time, we may use your personal data to send important notices and notifications, such as communications about purchases and changes to deadlines, conditions and policies. Because this information is important for your interaction with MARKET4U, you may not opt out of receiving this type of communication, as it is inherent to the use of the service.

4.3 Support

We will also have access to your information when you request support for issues involving purchases, orders or deliveries, whether through “SAC” or through “Your Account” > “Customer Service Center”.

In this case, we may use information such as your registration data to verify that you are the user who made the purchase or order in question; direct your questions to the support agent; investigate and direct your issue; and monitor and improve our support procedures.

4.4 Payment management

Information security and compliance with financial legislation are major concerns for MARKET4U. For this reason, we store your financial information only in anonymized form, which prevents us from having access to your complete financial data.

In addition, we process your data only for the specified purpose: allowing an online transaction to be carried out and charged to you. Do not worry: MARKET4U will never process your financial and/or banking information in a way that violates applicable compliance rules.

4.5 Security and fraud prevention

We may also use your personal data to improve our security and enhance MARKET4U services and offers intended for you. In this way, we may analyze and resolve technical issues, as well as identify and prevent fraud in the use of our service.

4.6 Monitoring

Our business model requires you to pick up your purchases and pay for them on site. In this regard, audio and video captured by our monitoring system may also be used for your identification, guidance and active collection, by telephone, messaging application or email, if there is any pending purchase in your shopping cart or if our system detects any inconsistency.

The user expressly acknowledges and consents to the use of this feature, allowing the collection of data resulting from monitoring and also granting the licenses and authorizations necessary for the use of their image and voice under the terms of this Privacy Policy. Such data will be stored by MARKET4U on secure servers, respecting users’ privacy and image rights.

All images are automatically destroyed after 20 (twenty) days counted from the date of capture.

The data collected through monitoring will not be shared with third parties, except in the following cases:

1. With agencies, authorities and other public government entities, as well as natural or legal persons of a private nature, in compliance with a legal obligation or court order.
2. With a police authority or a representative of the Public Prosecutor’s Office, regardless of the existence of a specific legal obligation or court order, when, exceptionally, there is a well-founded suspicion of a crime involving violence or serious threat in an emergency circumstance and involving USERS of the application, or when necessary to protect the rights, property or safety of MARKET4U, its users or third parties.
3. In cases involving signs of theft or robbery of products at MARKET4U units, by means of this instrument the user authorizes the responsible company, or a third party acting under its order, to use the user’s personality rights, such as image and voice, for publication and disclosure in media in general, whether written, spoken, televised or electronic, and for dissemination and transmission through any means of communication. This authorization is granted free of charge, for disclosure throughout Brazil and abroad.

4.7 Marketing

We may use your personal data to send advertising, as well as other promotional materials related to the marketing of our services and news to you, including targeted marketing on social media and push notifications.

In addition, we will share only the information strictly necessary for this purpose with MARKET4U partners, for the purpose of developing marketing campaigns that are more relevant to people interested in MARKET4U products, such as your user identification, phone number or email address. MARKET4U will only share data with partners whose privacy policies offer protection levels compatible with those offered by this Policy.

4.8 Promotions

If you participate in a contest, competition or any other type of promotion, we may use the information you provide to administer these programs.

4.9 Various surveys

We may use your data to contact you directly in order to collect feedback that is important for improving our services. In this case, you will be asked whether you wish to participate in the relevant survey, and you may always refuse to help us in our daily improvement efforts.

4.10 Legal and regulatory requests

Your data may be used so that we can address judicial and regulatory claims related to the use of our services.

To make some of the definitions listed above more accessible, we have prepared the table below so that you can better understand what applies specifically to you:

5. How do we use cookies and other technologies?

MARKET4U uses technologies such as cookies, pixel tags, local storage or other identifiers, whether on mobile devices or not, or similar technologies (“cookies and other technologies”), for a variety of functions. These technologies help us authenticate your account, promote and improve MARKET4U services, personalize your experience and evaluate the effectiveness of our communications and advertising.

5.1 What are these technologies?

Cookies are small files stored in your browser, mobile phone or other device.

Pixel tags, also known as clear GIFs, web beacons or pixels, are small blocks of code on a web page that allow the page to perform actions such as reading and storing cookies and transmitting information to MARKET4U. The resulting connection may include information such as a device’s IP address, the time at which a person viewed the pixel, an identifier associated with the browser or device, and the type of browser in use.

Mobile device identifiers are codes that allow your mobile device to be identified, whether persistently or temporarily, such as the Advertising ID or your operating system ID.

5.2 Promoting a personalized experience

MARKET4U and its partners also use cookies and other technologies to remember personal information when you use our Application or the MARKET4U partner network that may use similar technologies. In these cases, our goal is to make your experience with MARKET4U more convenient and personalized.

For example, knowing your first name allows us to welcome you the next time you access the MARKET4U app. Knowing your country and language allows us to provide you with a more personalized and useful shopping experience. Knowing that you purchased a particular product or used a particular service allows us to make your advertising and email communications more relevant to your interests.

Along these lines, we may also use this information to classify users within the MARKET4U network, identifying users based on events performed, such as a first purchase or downloading our application, and based on certain characteristics of their profile, such as users who buy more of a certain food category, make more than 15 purchases per month, or use certain services more frequently.

5.3 Evaluating the effectiveness of our communications and advertising

We also use this information to understand and analyze trends, administer our services, learn about user behavior and obtain demographic information about our user base in general. In some of our email messages, we use a “click-through URL” linked to MARKET4U content. When customers click one of these URLs, users are sent to a different server before arriving at the destination page on our service.

We monitor this click-through data to understand interest in certain topics and evaluate the effectiveness of our communications with customers. If you prefer not to be monitored in this way, do not click on text or links contained in email messages sent by MARKET4U.

Pixel tags allow us to send email messages in formats that users can read and tell us whether the email was opened. We may use this information to reduce or eliminate messages sent to users.

5.4 Third-party technology

In addition to MARKET4U cookies and other technologies, we may allow third parties contracted by MARKET4U to use their own cookies and other technologies to identify your browser and device, so that they may offer you targeted MARKET4U advertising when you access third-party websites or applications.

These third parties may also provide MARKET4U with information about the performance of marketing campaigns developed through the sharing of data with us.

By way of example, some of these companies may use their own cookies and other technologies in MARKET4U services, such as Facebook, Google Analytics and DoubleClick.

6. How is data stored?

6.1 Where is data stored?

The data we collect from you is stored in reliable cloud services provided by partners that may be located in Brazil or in other countries that offer reliable cloud storage services commonly used by technology companies, such as the United States of America (USA), and countries in Latin America and Europe.

When contracting these services, MARKET4U always seeks companies that employ a high level of security in storing your information, establishing contracts that do not violate the privacy definitions set forth in this Policy.

6.2 How long is data stored?

MARKET4U stores your information for the period necessary for the purposes presented in MARKET4U’s Terms and Conditions of Use and in this Privacy Policy, respecting the data retention period determined by applicable law.

If you request deletion of your account, the personal information you provided to MARKET4U during your use of our services will be deleted, except for the purposes permitted by data protection legislation.

In some cases, we may retain your information even if you delete your account, such as in cases of mandatory record retention provided for in applicable laws, including invoices, if there is an unresolved issue related to your account, such as an unresolved complaint or dispute, for the regular exercise of our rights, or if necessary for our legitimate interests, such as fraud prevention and improving the security of our users.

7. Does MARKET4U transfer data to other countries?

MARKET4U may carry out international data transfers to other countries, such as the United States of America and countries in the European Union and Latin America, in order to perform some of the activities involved in the services provided to you.

In any case involving sharing with partners or service providers located in other countries, we contractually establish that the partner must have a data protection and information security standard compatible with this Policy and applicable law.

8. How is data shared?

MARKET4U, like any technology company, operates in partnership with a number of other companies to offer its Services. Accordingly, we may share your Personal Data with these companies, always seeking to preserve your privacy as much as possible and, whenever possible, in anonymized form.

Below, we describe situations in which we may share your Personal Data:

8.1 Service providers

For data processing purposes on behalf of MARKET4U, we may share data with third-party service providers. In this case, the data will be processed in a way that protects your privacy, and these companies will have a contractual duty of protection compatible with applicable law and with the terms of this MARKET4U Privacy Policy.

We may use the services of these companies to facilitate our service, provide the MARKET4U service on our behalf and perform service-related activities, including service maintenance; database management; computer systems and cloud storage providers; customer service center; and advertising agencies.

Regarding payment for your purchases in our application, if you choose to pay directly online, we may share your payment data with payment processing companies with which we work. This sharing is carried out exclusively to enable the purchase made by you.

These companies or individuals have access to your personal information, restricted to what is necessary, only to perform activities requested by MARKET4U, and are required not to use or disclose such information for any other purpose.

8.2 MARKET4U partner establishments

When placing an order or making a purchase from one of our partners through our application, we may share some of your information with that partner establishment, as well as provide data regarding the specific order. The data shared may include name, address and CPF, when requested.

8.3 Business partners

We may share your data with companies engaged in financial or commercial activities with which MARKET4U maintains a collaborative or partnership relationship, in order to offer promotions, products and services from these companies jointly.

In these cases, agreements or contracts are entered into with the objective of protecting the privacy of our users’ personal data and complying with applicable law, so that all appropriate measures to ensure compliance with confidentiality and security standards are taken.

8.4 MARKET4U Group companies

MARKET4U Group companies follow the same personal data protection standard described in this MARKET4U Privacy Policy and comply with the same purposes described in this document. When we share your data with these companies, the same guarantees and care that MARKET4U applies to your data will be replicated by MARKET4U Group companies.

The sharing of data with MARKET4U Group companies will have the following purposes: (a) development of new products, features and services, as well as their improvement and enhancement; (b) offering products and services that better meet your interests; (c) generation of statistical and aggregated data regarding the use of our products and services and user profiles; (d) marketing, prospecting, market and opinion research and promotion of products and services; and (e) investigations and measures to prevent and combat unlawful acts and fraud.

8.5 In the event of a change in MARKET4U’s corporate control

In the case of corporate transactions, such as restructuring, merger or sale of MARKET4U assets, of the economic group or part thereof, your data may be transferred, provided that the terms of this Policy are respected.

8.6 Advertising and analytics services

To deliver advertising and promotions suited to you, as well as to improve our services, we may also share your anonymized data with companies specializing in marketing and digital data analysis that offer a level of data protection compatible with this Privacy Policy.

8.7 Order delivery

In order to deliver your order placed within the MARKET4U app, we may share your name and address with our delivery partners.

8.8 Public authorities

MARKET4U may also share your information with police or judicial authorities, competent public authorities or other third parties, inside or outside the country where you reside, if required by applicable law, by court decision or by request from authorities, or if necessary to respond to judicial proceedings or participate in any litigation or disputes of any nature.

In these situations, MARKET4U will cooperate with the competent authorities to the extent required by law.

In addition, MARKET4U reserves the right to share information about its users with third parties when there are sufficient reasons to consider that a user’s activity is suspicious, illegal or harmful to MARKET4U or to third parties.

This right will be used by MARKET4U when it considers it appropriate or necessary to maintain the integrity and security of its service, to comply with its Terms and Conditions of Use, to regularly exercise its rights and to cooperate with law enforcement and compliance with the law, regardless of whether there is a judicial or administrative order to that effect.

9. How do we protect your data?

MARKET4U adopts security, technical and administrative measures capable of protecting personal data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate or unlawful processing.

We use the principles established by law, respecting your privacy and protecting your data throughout our internal processes.

We process your data only with a high degree of security, implementing the best practices used in the industry for data protection, such as encryption techniques, monitoring and periodic security testing.

10. How will we notify you in case of changes to this Policy?

MARKET4U may update this Privacy Policy periodically, and the version in force will always be the most recent version.

If we make any material change to the Policy, we will post a notice in our Application or send an email together with the updated Privacy Policy.

To check the date of the version currently in force, see the “Last updated” date at the beginning of this document.

11. How can you exercise your rights as a personal data subject?

Personal Data belongs to you, and Brazilian law guarantees you a number of rights related to it, including the following:

• Request access to your Personal Data.
• Request information about the sharing of your Personal Data.
• Object to the processing of your Personal Data and/or revoke consent previously given, including by requesting deletion of your Personal Data.

In order to exercise your rights as a personal data subject, MARKET4U provides specific channels for requests through the “SAC” tab or the “Customer Service Center”.

If you have any questions or concerns regarding this MARKET4U Privacy Policy or any practice described here, you may also contact us through our Help page on the Platform. You may contact MARKET4U’s data protection officer by email at [email protected].

12. Amendments

This version of the Privacy Policy was last updated on March 2, 2022.

MARKET4U reserves the right to modify its practices and this Policy at any time and without prior notice, especially to adapt them to developments in the MARKET4U application, whether through the availability of new features or the removal or modification of existing ones.

This Privacy Policy may also be updated as a result of regulatory changes. For this reason, users are invited to review this section periodically.

By using the service after any modifications, you demonstrate your agreement with the new rules. If you disagree with any of the modifications, you must immediately request cancellation of your account and submit your objection to customer service, if you so wish.

13. Applicable law and venue

Brazilian law shall apply in full to the resolution of disputes arising from this instrument.

Any disputes must be brought before the court of the district where the application publisher’s headquarters is located, namely the Central Court of the District of the Metropolitan Region of Curitiba, in the State of Paraná.

14. Confirmation

After reading the conditions of this term, you expressly acknowledge that you have read and understood the rights, obligations and conditions contained herein, and that by clicking the “I have read and accept the Terms of Use and the Privacy Policy” button, you grant MARKET4U the rights established herein.