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PRIVACY POLICY – FLASH ENGENHARIA

Ver.1.0/2025

  1. OBJECTIVE OF THIS POLICY

FLASH INDUSTRIA E COMERCIO DE PRODUTOS E SISTEMAS ELETROELETRONICOS LTDA, hereinafter referred to as “FLASH ENGENHARIA” (CNPJ No. 04.844.206/0001-59), headquartered at Rua Professora Celia Cangro Marques Mendes, No. 1000 – Alto da Boa Vista – Sorocaba, SP – CEP 18.087-171, acts as the Data Controller for personal data. The company employs its best efforts to provide adequate protection measures in all its operations and to implement consistent, effective, and rigorous policies and procedures. Recognizing the importance of your privacy, we have developed this Policy to inform you regarding the conditions under which we Process and Protect your Personal Data. This Policy also describes your rights and how you can contact us to exercise them or ask any questions regarding the protection of your Personal Data.

The terms of this Policy apply to Users and/or Visitors of the website https://flashengenharia.com.br, also referred to as DIGITAL CHANNELS.

2. ORIGIN OF PERSONAL DATA

FLASH ENGENHARIA collects and processes your Personal Data, which may be provided:

  • I. By the company that contracts FLASH ENGENHARIA‘s services on your behalf; and
  • II. Through the collection of information from other reliable sources.

The information collected by FLASH ENGENHARIA includes:

  • a) For natural persons: name, CPF (Taxpayer ID), RG (ID number), email, marital status, telephone and mobile numbers, address, and date of birth.
  • b) For legal entities: corporate name, CNPJ (Corporate Tax ID), name of the legal representative, RG and CPF of the legal representative, number of employees, revenue, full address, and telephone number.

3. PURPOSES FOR WHICH WE USE PERSONAL DATA

The Personal Data collected by FLASH ENGENHARIA is used to provide its services, ensure they function as expected, improve them, and help enhance the reliability and security of all our services. Specifically, FLASH ENGENHARIA may use your Personal Data for the following purposes:

  • To administer, provide services, and fulfill obligations arising from the services made available by FLASH ENGENHARIA;
  • To inform users about news, services, features, content, benefits, promotions, and other relevant relationship events;
  • To create action plans for the improvement of our services/products;
  • To collaborate with and/or comply with court orders or requests from administrative authorities;
  • Any other purpose that will be communicated to you, if applicable, at the time of data collection.

FLASH ENGENHARIA does not sell or trade information that could identify you.

4. LEGAL BASIS FOR PROCESSING PERSONAL DATA

FLASH ENGENHARIA processes Personal Data as part of the performance and management of our contractual relationship with you and/or with the company contracting our services, in our legitimate interest or that of third parties (provided legal requirements are met), in compliance with certain legal or regulatory obligations, or when necessary for the regular exercise of rights in judicial, administrative, or arbitration proceedings. Your Personal Data may also be processed based on your prior consent, should your consent be requested under certain circumstances.

5. SHARING PERSONAL DATA

The security and confidentiality of your Personal Data are of great importance to us. Therefore, we restrict access to your Personal Data only to our duly authorized professionals who need such knowledge to process your requests or provide the requested service(s).

We will not disclose your Personal Data to unauthorized third parties. However, we may share your Personal Data with entities within the client’s group and with authorized service providers we work with (e.g., Call Centers, relationship agents, BackOffice services, IT and technology consultants, etc.). In such cases, we ensure that your Personal Data is processed only for legitimate, specific, explicit, and informed purposes. Furthermore, we may share Personal Data when we believe, in good faith, that we have an obligation to:

  • I. Comply with a law, regulation, or court order;
  • II. Respond to requests for information made by a regulatory body, police authority, or other public authorities;
  • III. Enforce and/or protect the property or rights of FLASH ENGENHARIA, including investigating fraud and helping to prevent security threats;
  • IV. Protect the legitimate interests of third parties, including the personal safety of FLASH ENGENHARIA employees.

6. STORAGE OF YOUR PERSONAL DATA

We store your Personal Data in our databases in a secure environment, ensuring secrecy and confidentiality, only for the time necessary to fulfill the purposes for which they were collected, observing applicable legal periods and the need for defense in legal proceedings. Once the legal necessity ends, your Personal Data will be deleted using secure disposal methods or anonymized for statistical purposes.

7. INTERNATIONAL TRANSFER OF PERSONAL DATA

As FLASH ENGENHARIA operates in areas aligned with its clients, your Personal Data may eventually be transferred to recipients located outside Brazil authorized to perform services on our behalf. In the event of an international transfer, we will adopt the necessary measures to ensure adequate safeguards for the protection of your Personal Data in accordance with the LGPD.

8. EXERCISING YOUR RIGHTS UNDER THE LGPD

FLASH ENGENHARIA respects the rights you hold as a Data Subject and enables their exercise in accordance with Article 18 of Law No. 13.709/2018. To exercise any of your rights, please refer to Section 12: CONTACT US. To ensure your privacy and as a security/fraud prevention measure, we may request proof of identity before fulfilling your request.

9. SECURITY APPLICABLE TO DATA PROTECTION

We implement the best market practices for technical and administrative security to protect your Personal Data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication, or dissemination, as determined by current legislation.

10. ACCESS AND UPDATES TO OUR PRIVACY POLICY

By accessing the DIGITAL CHANNELS of FLASH ENGENHARIA, you expressly agree to this Policy. You must read and ensure you have understood all conditions established herein. By accepting this Policy, you agree to provide only true, current, and accurate Personal Data. You are solely responsible for any false or inaccurate information provided. Any changes to this Policy will be published as a new version on the DIGITAL CHANNELS, indicating the revision date.

11. APPLICABLE LAW AND JURISDICTION

This Privacy Policy shall be governed, interpreted, and enforced in accordance with Brazilian law. The Forum of the District of Sorocaba is elected to resolve any litigation or controversy involving this document. Outside the State, JUSPRO – Justiça Sem Processo Mediação e Conciliação S/S Ltda. is appointed as the Mediation Chamber to resolve issues involving Data Subjects, pursuant to Art. 52, §7º of the LGPD.

12. CONTACT US REGARDING YOUR LGPD RIGHTS

FLASH ENGENHARIA has appointed Mr. Henrique Rodrigues and Ms. Jessica Rodrigues as the Data Protection Officers (DPO). They will lead the new practices to be implemented from November 2025.

  • Direct Line: (47) 93300-8431 (DPO Manager) | (47) 93300-9607 (DPO Operational)
  • Email: lgpd@flashengenharia.com.br
  • Address for requests: Rua Professora Celia Cangro Marques Mendes, No. 1000 – Alto da Boa Vista – Sorocaba, SP – CEP 18.087-171. (Requests via mail must include a Return Receipt/AR).

13. LAST UPDATE AND PREVIOUS VERSIONS

The last update of this Privacy Policy was performed on December 11, 2025.

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