Welcome to the VENNDORA platform! The following Privacy Policy is based on our principles and values. We take your privacy very seriously and therefore protect your personal data.

This Privacy and Data Protection Policy describes our policies on information that may be associated with or allow the identification of a person (Personal Data) and information that does not relate to a person and/or cannot be used to identify a person ( Non-Personal Data) in relation to the website.

As a condition for accessing and using the VENNDORA platform and its functionalities, you declare that you have read the rules in this document in full and carefully, being fully aware of and in accordance with them.

DEFINITIONS

1. a) Costumer: term used to designate people who purchase tickets for events on sale by the Event Producer.
2. b) Controller of the Personal Data: natural or legal person, public or private, who is responsible for decisions regarding the processing of personal data.
3. c) Cookies: files whose purpose is to identify a computer and obtain access data, such as navigated pages or links clicked, thus allowing to customize their navigation, according to the user's profile.
4. d) Personal Data: information related to an identified or identifiable natural person.
5. e) Non-Personal Data: any information that does not relate to a person and/or cannot be used to identify a person.
6. f) Personal Data Operator: natural or legal person, public or private, who processes personal data on behalf of the Controller.
7. g) Event Producer: term used to designate people (individuals or legal entities) who create their own events through the VENNDORA platform and disseminate them to Costumers.
8. h) Participants: term used to designate people who enjoy the tickets purchased by Costumers. If Costumer purchase tickets in their own name, they will also be Participants. On the other hand, if the Costumer purchases tickets for the benefit of third parties, these will only be considered Participants, not Costumer.
9. i) VENNDORA Platform: designates the technological platform available to the Event Producers and Venues, in order to sell tickets, create and enroll events, collection of contributions for events and management of participants, accessible at the electronic address https://www.venndora.com
10. j) Processing of Personal Data: any operation carried out with personal data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction.
11. k) User: term used to designate, when referred to together, Event Producer, Costumer and people who browse the VENNDORA platform.
12. Obtaining personal and non-personal information

1.1. When using the VENNDORA platform, some information will be collected, including personal data. VENNDORA will collect such information on its own behalf or on behalf of the Event Producer, which uses the VENNDORA platform to create, manage and publicize its own event. This distinction is important to differentiate the situations in which VENNDORA acts as controller or operator of personal data.

1.2. VENNDORA will collect personal data from all users whenever they voluntarily provide such information, for example, when browsing or using the VENNDORA platform or any of its functionalities, or when contacting VENNDORA. The personal data we may collect includes: name, date of birth, email address, mailing address, password, telephone number and contact preferences, among others necessary to achieve the purposes set out in this Policy.

1.3. In addition to the aforementioned information, the user may provide other types of information, such as payment data, geolocation information, behavior when using the application or its products, and information regarding the computing device used to browse or use the VENNDORA platform, such as: IP addresses, browser type and language, Internet service provider, referring and exit pages, operating system, date and time information, clickstream data, device manufacturer, carrier, model, networks WiFi and phone number.

1.4. VENNDORA may also obtain non-personal information and information about user activities on the VENNDORA platform. Such information may be aggregated and used to help VENNDORA provide information to the Event Producers and understand which parts of the products and services attract the most interest from Costumers. Aggregated data is considered non-personal information for purposes of this Privacy Policy.

1.4.1. If VENNDORA combines non-personal information with personal information, the combined information will be treated as personal information as long as that information remains combined. 1.4.1.1. If the combined information is considered sensitive, that is, capable of revealing data related to racial or ethnic origin, religious conviction, political opinion, membership of a union or organization of a religious, philosophical or political nature, data referring to health or sex life, genetic or biometric data, the processing of this information will only be carried out with the consent of the holder. Such information will be stored securely and will not be shared with third parties, except after anonymization process.

1.5. VENNDORA may collect additional information from Event Producers, such as financial information, in order to guarantee certain payments and issuance of Invoice.

1.6. VENNDORA may collect additional information from Costumers, for example, when purchasing paid tickets, in which case the user will provide personal financial data (eg credit card number and expiration date, billing address, etc.). 1.6.1. Event Producers may, in their sole discretion, configure their event page to collect other personal information from Costumers. In these cases, VENNDORA as operator of personal data, will not interfere in the data processing process carried out by the Event Producers, nor in what personal data will be collected or how it will be used by it.

1.6.2. Personal data collected on behalf of the Event Producers is available to them. In this way, the Event Producers, as controllers of personal data, are responsible for the treatment operations they carry out on this data, such as sharing, analysis, storage, among others.

1.6.3. VENNDORA has a specific document (“Data Processing Agreement”), which establishes its rights and obligations, as an Operator of personal data, regarding the processing operations carried out on behalf of the Event Producers.

1.6.4. Holders of personal data must exercise the rights provided for in item “7” of this document before the Event Producers, and VENNDORA may operationalize such requests in certain cases.

1.7. VENNDORA may also obtain information from its users from different sources, such as third-party websites, banking institutions, payment processors, and other companies or credit protection agencies. In this activity, the rules contained in the applicable legislation will be observed.

1.8. For the purposes of the provisions of Law No. 13,709/2018 (“General Law for the Protection of Personal Data”), VENNDORA may act both as controller of personal data (e.g.: recommends)

2. Use of personal information

2.1. Personal data will be used in a manner consistent with the provisions of this Privacy Policy, with the aim of providing, developing and improving the services provided or products offered, including those to be created.

2.2. VENNDORA will use personal data in the following ways:
a) internal and managerial purposes, such as auditing, data analysis and research to improve products, services and communications with customers, and generating statistical analysis with respect to the use of our services, including consumption trends;

1. b) send notices and important notifications, such as announcements about purchases, changes in terms, conditions and policies. As this information is important for interacting with VENNDORA, the user cannot choose not to receive this type of communication, since it is inherent to the use of the VENNDORA platform;
2. c) improve security and improve VENNDORA 's services and offers, as well as analyze and solve technical problems, in addition to identifying and curbing fraud in the use of the VENNDORA platform;
3. d) send advertising, as well as other promotional materials aimed at marketing our services and news to users, which includes digital campaigns (such as targeted marketing on social networks and notifications) and non-digital campaigns (such as broadcasting, billboards, pamphlets , between others). 2.2.1. VENNDORA will process personal data based on the following legal hypotheses: compliance with a legal obligation, execution of a contract, regular exercise of rights, fulfillment of legitimate interests. The legal basis for processing may vary depending on the activity carried out.

2.3. VENNDORA allows Organizers to use the VENNDORA platform and its functionalities to get in touch with Costumers and other users regarding their events. This tool works like a standard e-mail box, where the Event Producer can enter recipients automatically (through e-mail lists associated with their events hosted on the VENNDORA platform) or manually (through e-mail lists collected outside the VENNDORA platform) and then send them. Notices will be sent by the sender info@venndora.com

2.3.1. The Event Producer is solely responsible for the content and sending of these communications, and it is also up to the Event Producer to cease such sending whenever requested by the recipient. The Event Producer is also responsible for processing the personal data of the recipients of these communications.

2.3.2. The Costumer is aware that unsubscribing from an Event Producer's email list does not prevent the receipt of communications sent by another Event Producer through the VENNDORA platform. To this end, Costumers must block the sender info@venndora.com. in their email provider.

2.4. If VENNDORA uses any personal data in a manner different from those established in this Privacy Policy, the user will be previously informed about this new use, before or on the date on which the personal data is received.

3. Sharing of Personal Information

3.1. VENNDORA does not sell its users' personal data to third parties, but there are situations in which VENNDORA may disclose, transfer or share personal data with third parties, as provided in this document regulated by United States legislation.

3.2. VENNDORA may sell or buy other companies or assets. In case of sale, merger, reorganization, dissolution of the company or other similar corporate transaction, personal data may form part of the shared or transferred intangible assets.

3.2.1. VENNDORA may share personal data with companies of the same economic group, with the following purposes: (i) the development of new products and services; (ii) offering products and services that best meet the interests of users; (iii) generation of statistical and aggregated data about the use of products and services and user profiles.

3.3. VENNDORA may share the personal data of its users with contractors and service providers who process such data on behalf of VENNDORA, in order to perform certain functions related to VENNDORA 's activities, such as, but not limited to, marketing agencies, providers database service providers, disaster recovery and backup service providers, email service providers, payment processors, and others.

3.4. VENNDORA may share its users' information with police or judicial authorities, competent public authorities or other third parties, inside and outside of the United Sates if required by applicable law, by judicial decision and by request of authorities, or if necessary to respond to legal proceedings or to participate in any litigation or disputes of any nature.

3.4.1. In these situations, VENNDORA will cooperate with the competent authorities to the extent that, at its discretion, it deems necessary and appropriate in relation to any investigation of illicit acts, infringements of industrial or intellectual property rights, or other activity that is illegal or that may expose VENNDORA or its users to any legal liability or to impose risks on them, except for cases of secrecy of information contained in the applicable legislation.

3.5. VENNDORA 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 VENNDORA or third parties.

4. Storage of personal information

4.1. The personal information collected by VENNDORA will be stored in reliable cloud services, provided by partners that may be located in United States or in other countries, such as Brazil (BRA) and in countries of the European Union.

4.1.1. When contracting these services, VENNDORA will look for companies that employ a high level of security in the storage of your information, establishing contracts that do not violate the privacy definitions set forth in this Policy.

4.2. VENNDORA only stores user information for the period necessary for the purposes set out in the Terms of Use and in this Privacy Policy, always respecting the data retention period determined by applicable law.

4.2.1. If the user requests the deletion of his account, the personal information provided during the use of the VENNDORA platform will be anonymized or permanently deleted, unless such information is necessary for the fulfillment of a legal obligation by VENNDORA, fulfillment of legitimate interests, or for the regular exercise of rights in judicial, administrative or arbitration proceedings.

4.3. VENNDORA uses its best efforts to respect and protect users' personal information against loss, theft or any form of misuse, as well as against unauthorized access, disclosure, alteration and destruction.

4.3.1. VENNDORA will process personal data with a high degree of security, implementing the best practices in use in the industry for data protection, such as encryption techniques, monitoring and periodic security tests, firewall, among others. However, it is not possible to completely guarantee the non-occurrence of interceptions and violations of systems and databases, since the internet has its security structure in permanent improvement.

4.3.2. In the event of an information security incident that results in the destruction, loss, alteration, unauthorized access, or leakage of personal data, VENNDORA will immediately assess the risks to civil liberties and fundamental rights of the holders of personal data. Communication to data subjects or to the National Data Protection Authority will be carried out depending on the specific case, after assessing the risks mentioned.

5. International data transfer

5.1. VENNDORA may carry out international data transfers to other countries, such as the Brazil and European Union countries, in order to carry out some of the activities involved in the services provided to users, as well as to be able to obtain information that may contribute to the improvement and security of our services.

5.2. In the event of sharing with partners located in other countries, we contractually establish that the partner has a data protection and information security standard compatible with this privacy policy, so that data is always protected in these terms.

6. User rights

6.1. Users may request VENNDORA, in an easy and accessible way, through our web form on the Privacy Portal or by e-mail info@tktwave.com: (i) confirmation of the existence of processing of personal data; (ii) access to personal data; (iii) the correction of incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion of unnecessary or excessive data; (v) data portability, within legal limits.

6.2. If a user initiates a request for the deletion of data owned by him, VENNDORA will be authorized to delete or anonymize the requester's personal data, even if this means removing his availability for the Event Producer on the VENNDORA platform. However, personal data may still be available in the Event Producer’s own databases if they were transmitted to the Event Producer before VENNDORA received or took action regarding deletion or anonymization.

7. Use of the VENNDORA platform by minors and incapable persons

7.1. When registering on the VENNDORA platform, the user expressly guarantees that he is fully capable, under the terms of current legislation, to exercise and enjoy all the Services. Furthermore, Users under 18 (eighteen) years of age must obtain the express consent of their parents, guardians or legal representatives to use the VENNDORA platform and its functionalities, in accordance with the provisions of the Terms of Use and Privacy Policy.

7.2. Parents, guardians or legal representatives will also be fully responsible in the case of access to the VENNDORA platform by children and adolescents, without proper prior authorization. It is up to them to be fully responsible for overseeing the activities and conduct of the respective minors under their guardianship, as well as being aware of the completeness of these Terms.

8. Cookies and other technologies

8.1. VENNDORA has its own policy on the use of cookies and other similar tracking technologies, called the “Cookies Policy”.

9. General Provisions

9.1. When browsing the VENNDORA platform and using its functionalities, users accept all the provisions of this Privacy Policy and other legal policies that are in force on the access date. Therefore, it is recommended that users stay up to date.

9.2. This Privacy Policy is subject to constant improvement and improvement. Thus, VENNDORA reserves the right to modify it at any time, according to the purpose of the VENNDORA platform, such as for adequacy and legal compliance with a provision of law or rule that has equivalent legal force, and it is up to users to verify it whenever access the VENNDORA platform.

9.3. Any tolerance for any violation of the terms and conditions contained in this domain will be considered mere liberality and will not be interpreted as novation, invoked precedent, waiver of rights, tacit amendment of contractual terms, acquired right or contractual amendment.

9.4. If any provision of this Policy is deemed inapplicable or without effect, the rest of the rules continue to be in force, without the need for a judicial measure that declares such assertion. The terms described herein will be interpreted according to United States legislation.

9.5. Communication between VENNDORA and the user must be carried out through the service channels indicated and made available on the VENNDORA platform, especially through the email address info@venndora.com.

9.6. The jurisdiction of the Florida State, is elected to resolve any doubts arising from this Agreement, excluding any other jurisdiction, however privileged it may be.

COOKIES POLICY

Welcome to the VENNDORA platform! The following 'Cookies Policy' is based on our principles and values. We take your privacy very seriously and therefore protect your personal data.

Our website uses 'cookies' to improve performance, ensure security, enhance your browsing experience so that we can offer a more personalized navigation.

The information obtained through cookies does not allow the identification of personal data of the user and, therefore, is treated by VENNDORA as non-personal information, however, if there is any change in the applicable legislation and these data become considered personal information, VENNDORA will observe the relevant legislation. This policy provides the main information related to the use of cookies on our website.

DEFINITIONS

1. a) Local storage: industry standard technology that allows a website or app to store and retrieve data from a user's computer, mobile device, or other device.
2. b) Device identifier: codes that enable the identification of a mobile device, whether persistently or temporarily, such as Advertising ID or Operating System ID.
3. c) Pixel tag: small blocks of code on a web page that allow them to perform actions such as reading and storing cookies and transmitting information to VENNDORA. The resulting connection may include information such as a device's IP address, the time a person viewed the pixel, an identifier associated with the browser or device, and the type of browser in use.
4. d) VENNDORA platform: designates the technological platform available to event organizers and venues, facilitating the sale of tickets, event registration, event contribution billing, and participant management, accessible at the electronic address https://www.venndora.com.
5. 
   e) Personal data treatment: any operation carried out with personal data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of the information, modification, communication, transfer, dissemination, or extraction.

Considerations about cookies

1.1. Cookies are files that contain an identifier (a sequence of letters and numbers) sent by a server to a specific browser that stores it. The identifier is then sent back to the server whenever the browser attempts to access a page from the server.

1.2. Cookies can be 'persistent' or 'session-based.' A persistent cookie will be stored by a browser and remain valid until its expiration date, unless deleted by the user before this date. A session cookie, on the other hand, will expire at the end of a user's browsing session, when the browser is closed.

1.3. VENNDORA treats information obtained through cookies and other technologies as non-personal information. However, to the extent that IP address or similar identifiers are considered personal information under applicable law, VENNDORA will treat such identifiers as personal information.

2. Use of cookies

2.1. VENNDORA uses cookies and other technologies for the following purposes:
a) Authentication: indicates that the user is logged in, in order to provide appropriate features and understand how the user uses and accesses the VENNDORA platform;

1. b) Advertising and measurement: helps to analyze browsing behavior, to deliver and measure ads, make them more relevant, and analyze the content and use of products and services;
2. c) Security and integrity: helps to maintain the security of services, providing support or activating security features and helping to detect activities that violate our legal policies;
3. 
   d) Features and services: helps to provide products and services and personalized content;
4. 
   e) Performance: helps to provide the best possible experience, such as helping to route traffic between servers and realizing how quickly the service is loaded for different people. Occasionally, information may be stored in the browser or device so that the features in use load.

2.2. The user can manage their cookie preferences and other similar technologies from their browser or device settings, by rejecting or deleting certain cookies and technologies. However, this may compromise the provision of services or prevent the functioning of certain features that they integrate. Below, we list some URLs where the user can manage such preferences:

- https://support.google.com/chrome/answer/95647 (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- https://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/pt-br/guide/safari/sfri11471/mac (Safari);
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

3. Third-party cookies

3.1. The service providers used by VENNDORA may use cookies and other technologies of their own to identify the browser and device used, in order to offer targeted advertising of VENNDORA when the user accesses third-party websites or apps. These third parties may also provide VENNDORA with information about the performance of marketing campaigns developed.

4. Tracking Technologies

4.1. VENNDORA may use other tracking technologies, such as web beacons (sometimes called 'tracking pixels,' 'pixel tags,' or 'clear gifs'). These technologies also help Organizers learn more about interest in certain events. In many cases, these technologies rely on cookies to function properly.

4.2. VENNDORA may use a click-through URL linked to platform content. By clicking on one of these URLs, users may have personal data processed, based on VENNDORA 's legitimate interest, to understand interest in certain topics and evaluate the effectiveness of communications with users.

5. General Provisions

5.1. By browsing the VENNDORA platform and using its features, users accept all the provisions in this Policy and other legal policies that are in force on the date of access. Therefore, it is recommended that users keep themselves updated.

5.2. This Cookie Policy is subject to constant improvement and refinement. Therefore, VENNDORA reserves the right to modify it at any time, according to the purpose of the VENNDORA platform, as well as for compliance and legal conformity of dispositions of laws or equivalent legal norms, and it is the responsibility of users to check it whenever accessing the VENNDORA platform.

5.3. Any tolerance for any violation of the terms and conditions contained in this domain will be considered mere liberality and will not be interpreted as novation, invoked precedent, waiver of rights, tacit amendment of contractual terms, acquired right or contractual amendment.

5.4. If any provision of this Policy is deemed inapplicable or without effect, the rest of the rules continue to be in force, without the need for a judicial measure that declares such assertion. The terms described herein will be interpreted according to Brazilian legislation.

5.5. Communication between VENNDORA and the user must be carried out through the service channels indicated and made available on the VENNDORA platform, especially through the email address info@venndora.com

5.6. The jurisdiction of the Florida State, is elected to resolve any doubts arising from this Agreement, excluding any other jurisdiction, however privileged it may be.