Política de Privaciade - HSI Smart Solutions

Privacy and Personal Data Protection Policy

Last updated: September 23, 2026

HSI Smart Solutions values the privacy and protection of the personal data of customers, prospective customers, partners, suppliers, job applicants, visitors, and other users of its websites and digital channels.

This Privacy Policy explains how HSI collects, uses, shares, stores, and protects personal data, as well as the rights of data subjects and how such rights may be exercised.

The processing of personal data carried out by HSI complies with applicable Brazilian legislation, particularly Federal Law No. 13,709/2018 — the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais — LGPD) — and regulations issued by the Brazilian National Data Protection Authority (Autoridade Nacional de Proteção de Dados — ANPD).

1. Who Is the Data Controller

For the activities described in this Policy, HSI generally acts as the controller of personal data.

HSI Smart Solutions

Legal entity name: HSI Informática Industrial Ltda

Brazilian Corporate Taxpayer ID (CNPJ): 68.943.117/0001-42

Address: Rua José Versolato, 111 – 28th floor, suites 2807/2808, São Bernardo do Campo – SP – ZIP Code 09750-730 – Brazil

In certain circumstances, particularly when providing services to customers, HSI may act as a data processor, processing personal data in accordance with the instructions of the respective data controller.

2. Who This Policy Applies To

This Policy applies to the processing of personal data carried out through:

• the hsinet.com.br website and websites or subdomains maintained by HSI;
• contact forms, demo requests, and content download forms;
• registrations for events, webinars, and other activities promoted by HSI;
• commercial and marketing communications;
• interactions with our sales and support channels;
• recruitment and selection processes, where applicable;
• other professional or commercial interactions conducted directly with HSI.

Third-party websites, platforms, and services accessed through links available on HSI channels are subject to their own privacy policies and practices.

3. Personal Data We May Collect

Depending on how individuals interact with HSI, we may process different categories of personal data.

Data provided directly by the data subject may include:

• first and last name;
• email address;
• telephone number;
• company or organization;
• job title or professional role;
• country, state, or city;
• information provided in messages and forms;
• areas of interest;
• information related to commercial requests;
• registrations for events, webinars, or demonstrations;
• communication preferences;
• professional information provided during recruitment processes.

We ask users not to provide sensitive personal data through HSI’s commercial forms unless specifically requested and necessary for a particular purpose.

When users browse our websites, certain technical information may also be collected automatically, including:

• IP address;
• browser type and version;
• operating system;
• device type;
• date and time of access;
• pages visited;
• time spent on pages;
• referral source or referring page;
• interactions performed on the website;
• identifiers associated with cookies and similar technologies.

Such data may be used for technical operation, security, performance analysis, and improvement of our websites.

4. Purposes for Which We Use Personal Data

HSI may process personal data for purposes including:

• responding to contacts, questions, and requests;
• providing information about products, solutions, and services;
• processing requests for demonstrations, meetings, or proposals;
• managing registrations for events, webinars, and activities;
• providing technical materials, white papers, and other content;
• maintaining relationships with customers, partners, and prospective customers;
• managing contracts and commercial relationships;
• providing support and customer service;
• developing and improving our products, services, and content;
• analyzing website performance and usage;
• preventing fraud, abuse, and security incidents;
• protecting the rights and legitimate interests of HSI and third parties;
• complying with legal or regulatory obligations;
• exercising rights in judicial, administrative, or arbitration proceedings;
• conducting recruitment and selection activities;
• sending institutional and commercial communications, where permitted by applicable law.

5. Legal Bases for Processing

The processing of personal data does not necessarily depend on consent.

Depending on the purpose and context, HSI may rely on one or more legal bases provided under the LGPD, including:

• consent of the data subject, where applicable;
• performance of a contract or preliminary procedures related to a contract;
• compliance with a legal or regulatory obligation;
• exercise of rights in judicial, administrative, or arbitration proceedings;
• legitimate interests of HSI or third parties, provided that the interests involved are appropriately balanced against the fundamental rights and freedoms of the data subject;
• other legal bases provided under applicable law.

Where processing is based on consent, the data subject may withdraw such consent at any time through the channels made available by HSI.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal request.

6. Communications and Marketing

HSI may use professional and contact information to communicate information regarding its products, services, technical content, events, webinars, and other subjects related to its areas of business, subject to the applicable legal basis.

Data subjects may request that commercial communications be discontinued at any time.

Marketing emails will generally include an opt-out mechanism such as an “unsubscribe,” “opt out,” or equivalent link.

Even after unsubscribing from commercial communications, HSI may continue to send communications necessary for contract performance, fulfillment of requests, security purposes, legal obligations, or other non-promotional purposes.

7. Cookies and Similar Technologies

Cookies are small files or identifiers stored on or accessed from a user’s device while browsing websites.

HSI may use cookies and similar technologies for different purposes.

Necessary cookies are used to enable essential website functionality, security, operation, and privacy preference management.

Performance and analytics cookies help us understand how visitors use our websites, allowing us to evaluate traffic, performance, navigation patterns, and opportunities for improvement.

Preference cookies may store certain settings or choices made by the user.

Advertising or marketing cookies, where used, may help measure marketing campaigns, understand user interests, and provide more relevant communications.

Where required by applicable law, non-essential cookies will be used in accordance with the choices made by the user through our cookie management mechanism.

Users may change their preferences at any time through the cookie management tool made available on the website or through their browser settings.

Disabling certain cookies may affect some website features or functionality.

8. Sharing of Personal Data

HSI may share personal data, to the extent necessary for the purposes described in this Policy, with:

• hosting and technology infrastructure providers;
• cloud computing providers;
• CRM and sales automation platforms;
• communication and email management platforms;
• website analytics service providers;
• technology security and support providers;
• service providers engaged by HSI;
• commercial partners and manufacturers associated with products or solutions relevant to the data subject’s request, where necessary to fulfill such request;
• consultants, auditors, law firms, and other professional advisors;
• public authorities, regulatory bodies, or courts where required by law or necessary for the exercise of rights.

HSI seeks to share only the data necessary for the specific purpose and to implement appropriate contractual and organizational measures to protect the personal data involved.

9. International Data Transfers

Some providers of technology, infrastructure, storage, analytics, communication, or other services used by HSI may operate servers or business activities outside Brazil.

As a result, personal data may be subject to international data transfers.

Where applicable, HSI will adopt mechanisms permitted under the LGPD and ANPD regulations to ensure an adequate level of protection, including adequacy decisions, standard contractual clauses approved by the ANPD, or other legally permitted mechanisms.

Additional information regarding international transfers carried out by HSI, including their purpose, duration, destination countries, participating processing agents, and safeguards adopted, may be requested through the privacy channel identified in this Policy, subject to applicable legal limitations and the protection of trade and industrial secrets.

10. Data Retention and Deletion

Personal data will be retained only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal, regulatory, contractual, and rights-protection obligations.

Criteria used to determine retention periods may include:

• duration of the relationship with the data subject;
• duration of contracts;
• need for support or customer service;
• history of interactions;
• legal and regulatory obligations;
• applicable limitation periods;
• fraud prevention and security requirements;
• exercise or defense of legal rights.

Once the applicable processing period has ended, personal data may be deleted, anonymized, or retained where there is a lawful basis for continued retention.

11. Personal Data Security

HSI adopts technical, administrative, and organizational measures designed to protect personal data against unauthorized access and accidental or unlawful destruction, loss, alteration, disclosure, or improper processing.

Depending on the circumstances, such measures may include:

• access controls;
• authentication mechanisms;
• permission management;
• infrastructure and system protection;
• backup procedures;
• security monitoring;
• internal procedures;
• supplier management;
• employee awareness and training.

No technological environment is completely free from risk. For this reason, HSI maintains prevention, detection, and response practices appropriate to the nature of its operations.

12. Security Incidents

In the event of a security incident involving personal data, HSI will assess the incident in accordance with applicable legislation and regulations.

Where an incident may result in relevant risk or damage to data subjects, HSI will take the appropriate measures, including, where required, notifying the Brazilian National Data Protection Authority — ANPD — and affected data subjects within the deadlines established by applicable regulations.

HSI may also provide affected data subjects with guidance regarding recommended actions to reduce potential risks arising from the incident.

13. Data Subject Rights

Under the LGPD and applicable regulations, data subjects may exercise rights relating to their personal data.

These may include:

• confirmation as to whether personal data is being processed;
• access to personal data;
• correction of incomplete, inaccurate, or outdated data;
• requesting anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in violation of applicable law;
• data portability, where applicable and regulated;
• information regarding public and private entities with which personal data has been shared;
• information about the possibility of refusing consent and the consequences of such refusal;
• withdrawal of consent;
• deletion of personal data processed on the basis of consent, subject to lawful retention requirements;
• objection to certain processing activities in the circumstances provided by law;
• requesting review of decisions made solely on the basis of automated processing that affect the data subject’s interests, where applicable;
• filing complaints or petitions with the ANPD or consumer protection authorities.

To protect the data subject, HSI may request additional information necessary to verify the identity of the individual submitting the request.

Requests will be reviewed and answered in accordance with the deadlines and conditions established by applicable law.

14. Personal Data of Children and Adolescents

HSI’s websites and commercial services are primarily directed to companies and professionals and are not specifically intended for children or adolescents.

HSI does not intentionally seek to collect children’s personal data through its commercial forms.

If HSI identifies the processing of personal data relating to children or adolescents, it will adopt the measures required under applicable law, particularly considering the best interests of the child or adolescent and the specific requirements applicable to such processing.

15. Recruitment and Selection

When an individual applies for a professional opportunity with HSI, we may process information relating to professional experience, academic background, qualifications, contact details, and other information provided by the applicant.

Such data will primarily be used to evaluate the application, communicate with the applicant, and manage recruitment and selection processes.

Applicant data may be retained during the recruitment process and afterward where there is an applicable legal basis or compatible legitimate interest in considering the applicant for future opportunities, subject to the applicant’s rights.

16. Third-Party Links and Services

Our websites may contain links to websites, platforms, or services operated by third parties.

HSI does not control the privacy practices of these external environments.

We recommend that users review the respective privacy policies before providing personal data to third parties.

17. Changes to This Policy

This Policy may be updated periodically to reflect changes in our processes, technologies, services, legal requirements, or applicable regulations.

The most recent version will always be made available through HSI’s official channels.

Where material changes are made, HSI may adopt additional measures to inform data subjects, where appropriate.

The date of the most recent update will be displayed at the beginning of this document.