Privacy Policy & Terms of Use

INTRODUCTION AND PRIVACY COMMITMENT

GOOXXY BRASIL S.A., a private legal entity, registered with the CNPJ under No. 33.971.496/0001-08, headquartered at Rodovia Coronel-Polícia Militar Nelson Tranchesi, No. 2036, Itaqui, Itapevi/SP, hereinafter referred to as (“GOOXXY”), prioritizes transparency, security, and the protection of data processed within the scope of its operations. This Privacy Policy describes how data is collected, used, stored, shared, and protected in the context of using the RECOLOCA digital platform, including the website, app, and other official channels.

By using our services, the user declares full awareness of and agreement with the terms established herein, as well as with the platform Terms of Use, which must be interpreted jointly and complementarily. By browsing or using this RECOLOCA digital platform, website, app, and other official channels, in any form whatsoever, you ("user") acknowledge that you have read, understood, and agreed to all terms and conditions established herein, automatically binding yourself to the applicable clauses.

The provisions set forth herein may be updated at any time, and periodic review of this document is recommended. If you do not agree with the terms below, immediately stop browsing and no longer use the platform. GOOXXY recommends that the User print this document, the Terms established herein, and read them carefully.

GOOXXY is committed to transparency, privacy, and data security for its customers throughout every interaction with our RECOLOCA digital platform, website, app, and other channels and third-party agents. To help you better understand what information we collect and how we use, store, or delete it, we detail our Privacy Policy below. Customers’ registration data is not disclosed to third parties, except when necessary to provide a service, for billing, or for participation in promotions requested by customers. Your personal data is essential for complying with legal obligations and ensuring that your experience with us is always personalized.

To facilitate understanding of our Privacy Policy, we present a summary:

• Personal data: information related to an identified or identifiable natural person.
• Data subject: Natural person to whom the personal data being processed refers.
• Processing: Any operation carried out with personal data, such as collection, production, reception, classification, use, access, processing, filing, storage, deletion, among others.
• Controller: Legal entity responsible for decisions regarding personal data processing (GOOXXY).
• Processor: Natural or legal person that processes personal data on behalf of the controller.

TECHNICAL DEFINITIONS

I. GOOXXY’S ROLE IN PROCESSING

GOOXXY acts predominantly as:

• Data Controller: When it processes information from its own customers and platform users for internally defined purposes.
• Data Processor: In specific cases linked to contracts with business partners, where processing takes place under external guidelines.

II. SCOPE OF DATA COLLECTION

Although GOOXXY operates predominantly in business-to-business (B2B) commercial relationships, personal data processing occurs insofar as such information relates to natural persons who represent, are part of, or act on behalf of client companies, such as administrators, employees, representatives, or platform users.

II.1. Information Provided by the User

II.2. Data generated through platform use

During use of the platform, additional data may be generated and processed, including, but not limited to:

• history of negotiations carried out;
• records of orders, invoices, returns, and commercial transactions;
• records of communications carried out through the platform;
• interactions with available features and tools.

II.3. Automatically Collected Data

III. PURPOSE OF PROCESSING

Personal data processing by GOOXXY has legitimate and specific purposes:

• Operations: Contract execution, order management, logistics, and deliveries.
• Communication: Transaction intermediation and technical support for customers.
• Security: Fraud prevention and assurance of system integrity.
• Compliance: Fulfillment of legal, regulatory, and tax obligations.
• Development: Improvement of user experience and institutional marketing.

IV. LEGAL BASES (Brazilian General Data Protection Law - 13,709/2018 - Brazil)

We process your data strictly based on the hypotheses provided by the LGPD:

• Performance of Contract: When necessary to provide platform services.
• Compliance with Legal Obligation: To meet requirements from authorities and applicable rules.
• Legitimate Interest: To support and promote GOOXXY’s activities, while respecting the data subject’s rights.
• Consent: When specifically requested for defined purposes

V. SHARING DATA WITH THIRD PARTIES

Sharing occurs strategically and securely with:

• Business Partners: Industries, retailers, and logistics operators essential to the supply chain.
• Financial Sector: Banking institutions and payment gateways.
• Technology Providers: Cloud computing companies, CRM, analytics and marketing tools (Google, Meta, etc.).
• Public Authorities: When there is a legal obligation or court request.

VI. INTERNATIONAL TRANSFER

GOOXXY may use technological infrastructure (such as cloud servers) located outside the national territory. In these situations, we ensure that receiving countries have an adequate level of protection or that contracts follow standard LGPD compliance clauses.

VII. COOKIES, TECHNOLOGIES, SECURITY, AND GOVERNANCE

Cookies are used only to recognize recurring visitors and improve the purchasing experience. Cookies are small data files transferred from a website to your computer’s disk and do not store personal data. Throughout this entire process, we keep your information in absolute confidentiality. It is worth noting that your data is recorded by GOOXXY automatically, without human handling, and users can manage cookies through their browser. We adopt excellent security standards to mitigate risks of unauthorized access and data incidents:

• Use of encryption and secure communication protocols.
• Strict access control for internal systems.
• Continuous security monitoring and good corporate governance practices.

VIII. USER RESPONSIBILITIES

The user declares and guarantees that all information provided to GOOXXY is true, complete, and up to date, and is solely responsible for maintaining and correcting such data. The user undertakes to preserve the confidentiality of their access credentials, including login and password, and is fully responsible for all activities carried out in their account. Improper, fraudulent, or non-compliant use with applicable law or the Terms of Use may result in account suspension or termination, without prejudice to applicable legal measures.

IX. OFFICIAL COMMUNICATION AND VALID CHANNELS

GOOXXY may establish communications with users through several means, including phone calls and instant messaging apps, which will have a merely informational and non-binding nature. For formal and legal purposes, only communications made through the platform itself, by GOOXXY institutional emails, or by formal documents issued by the company will be considered official communications. GOOXXY is not responsible for any mistaken interpretations, distortions, or losses arising from the use of informal communication channels.

X. DATA SUBJECT RIGHTS

In respect of the legislation, the data subject may request at any time:

1. Confirmation of processing and access to data.
2. Correction of incomplete or outdated data.
3. Anonymization, blocking, or deletion of unnecessary data.
4. Portability of data to another service provider.
5. Revocation of previously granted consent.

XI. ACCOUNT TERMINATION AND DATA DESTINATION

The user may request termination of their account at any time. GOOXXY may terminate or suspend the account in cases of contractual breach, improper use of the platform, or by legal determination. After account termination, data may be:

• deleted, when there is no legal basis for retention; or
• securely retained, when necessary to comply with legal obligations, exercise rights, or prevent fraud.

XII. RETENTION PERIOD

Data is stored for the time strictly necessary for:

• Fulfillment of commercial and contractual purposes.
• Compliance with statutory limitation periods.
• Regular exercise of rights in judicial or administrative proceedings.

XIII. AUTOMATED DECISIONS AND PROFILING

GOOXXY may use data for behavioral analysis and improvement of the user experience, including recommendations and feature optimization. If automated decisions are used that impact the data subject’s rights, the data subject may request review, pursuant to applicable law.

XIV. GENERAL PROVISIONS

The data protection officer is the person chosen by GOOXXY to act as the communication channel between the controller, data subjects, and the Brazilian National Data Protection Authority (ANPD). Any questions may be sent to privacidade@gooxxy.com. Our platform is not intended for individuals under 18 years of age This Privacy Policy shall be governed, interpreted, and enforced in accordance with the laws of the Federative Republic of Brazil, especially Law No. 13,709/2018 (Brazilian General Data Protection Law – LGPD), with the court of the user’s domicile elected to resolve any disputes arising from it, except for any specific provisions set forth in the Terms of Use.