Privacy Policy and Data Protection of HD FEMININO PERUCAS LTDA, trade name HD MAKE HAIR, a limited company registered with CNPJ/ME under nº 11.925.255/0001-81, headquartered in Porto Alegre, Rio Grande do Sul, at Rua Padre Chagas, 347, 1st floor, CEP 90.570-080, was created to demonstrate HD MAKE HAIR's commitment to the security and privacy of information collected about customers or users of services provided, both online and offline, who are the holders of personal data ('Holder' or simply 'you').

The Policy clarifies the general conditions of collection, use, storage, and other forms of treatment and protection of personal data on HD MAKE HAIR's websites, physical stores, and messaging applications ('Internet Applications'), in accordance with current Brazilian legislation on privacy and personal data protection in Brazil, especially Law nº 13.709/2018, as amended (General Data Protection Law – 'LGPD').

For the purposes of this Policy, HD MAKE HAIR is qualified as a Controller, responsible for the decisions regarding the treatment of personal data. HD MAKE HAIR has appointed a Data Protection Officer to manage a communication channel with you. If you have any questions related to the data processing activities under our responsibility, please send an email addressed to Mr. Diego Oliveira Pereira ('Data Protection Officer') to lgpd@hdmakehair.com.

By using our Internet Applications and physical stores or by signing the Consent Form, you freely, informed, unequivocally, expressly, and fully agree to this Policy. We recommend that you read it carefully.

1. PURPOSE OF COLLECTING PERSONAL DATA

1.1. By learning more about you, our goal is to always offer the best service, including information and promotions that make sense for you. This is how HD MAKE HAIR stays close to you. We are committed to preserving the privacy and security of the data we collect, always respecting the highest ethical and legal principles.

1.2. Data collection is carried out with the following objectives:

• Ensure the effectiveness in providing our services;
• Adapt the appearance, organization, and logistics of our stores, as well as the type and quantity of products we offer to the expectations and interests of the Holders;
• Adapt the appearance and content of our offers, whether via digital means or through physical stores, to the preferences of the Holder, providing faster, more pleasant, personalized, and effective access;
• Authenticate access to our website on the Internet;
• Seek adequate security for the services offered and means of identification in the event of improper or illegal uses;
• Resolve doubts, problems, and formulate notifications related to the use of our Internet Applications;
• Keep Holders informed about services, changes in the Terms of Use or the Privacy and Data Protection Policy, updates or improvements to our website, or the status of their accounts and operations;
• Maintain contact by phone, email, SMS, WhatsApp, notifications, or other means of communication;
• Promote promotional actions in our physical and virtual stores or other HD MAKE HAIR advertising initiatives, always providing means for the Holder to cancel the receipt of emails, messages, notifications, and promotional calls (opt out);
• Determine the effectiveness of our advertising;
• Gather statistical and behavioral pattern information (analytics);
• Adopt measures to ensure compliance, protect our credit, as well as prevent fraud;
• Evaluate the quality of our staff's service;
• Carry out purchase cancellations, refunds, or product exchanges, as provided by current legislation;
• Comply with legal and regulatory obligations, and with contracts signed with the Holders; and exercise HD MAKE HAIR's regular rights.

2. PERSONAL DATA COLLECTED

2.1. To achieve the purposes set out in Clause 1 above, we may collect your personal data in our stores, at events organized by us, or in other physical environments, from information:

• That you provide us voluntarily when using our services, filling out forms and forms, or answering questions from our staff, as well as participating in opinion surveys or interviews;

2.2. Also to achieve the purposes set out in Clause 1 above, our website may collect your personal data from information:

• That you voluntarily provide us by creating accounts or entering references about yourself in any context on our internet environments;
• About how you navigate and access and interact records on our website, including information:
• About the device and systems/browsers you use to access our internet environments, including the Internet protocol address (IP number);
• That can identify all and any use and interaction in the context of our Internet environments, including your shopping habits and general preferences, the products you viewed or searched for, the duration of your visits, and other interaction information with the pages, such as the use of the scroll bar, clicks, tabs, and places where you navigated with the mouse;
• Referring to the moment of each action in our internet environments (date and time);
• Referring to your geolocation;
• Referring to the site you accessed immediately before visiting our sites, platforms, and Internet applications.
• Obtained through cookies, tags, and anonymous identifiers contained in our sites and emails sent to you, used to monitor your interactions, such as, for example, when you received, opened, or clicked on a link in an email sent by us.

2.2.1. In compliance with the duty of transparency, HD MAKE HAIR clarifies that the processing of the personal data referred to in items (b) and (c) of this Clause 2.2. is based on our legitimate interest, to meet the purposes set out in Clause 1 above.

2.3. To meet the purposes set out in Clause 1 above, we may also receive your personal data from third parties from information obtained by:

• Sites, social networks, tools, or external platforms provided by third parties;
• Advertising companies, research or statistical and behavioral pattern analysis (analytics);
• Companies that organize databases;
• Financial, payment, credit, and risk analysis institutions.

2.4. We do not intentionally collect, store, or otherwise process excessive or unnecessary personal data for the provision of our services. Therefore, we ask that you refrain from sharing sensitive personal data with us, such as those related to your racial or ethnic origin, religious belief, political opinion, union membership or affiliation with a religious, philosophical, or political organization, health or sexual life, as well as genetic data.

2.5. Although HD MAKE HAIR has products aimed at the child and youth public, it declares that it does not process any data of Holders who are children without specific and prominent consent given by at least one of the parents or legal guardian. The conclusion of registrations in our physical stores, as well as in our internet environments, is conditioned on proof that this consent has been given.

3. HOW HD MAKE HAIR STORES AND OTHERWISE TREATS AND PROTECTS THESE PERSONAL DATA?

3.1. HD MAKE HAIR keeps the personal data collected from Holders in a controlled and secure environment, aiming to meet specific purposes, as set out in Clauses 1 and 2. Such data are deleted as soon as the purpose of their use by HD MAKE HAIR is achieved, according to Clause 1 above. In the cases authorized by law, HD MAKE HAIR may keep and otherwise treat personal data in its domain.

3.2. The personal data collected are kept confidential, with strict access control, through authentication mechanisms. HD MAKE HAIR also keeps a detailed inventory of access to records and personal data, containing the moment, duration, identity of the employee or designated person, and the accessed file.

3.3. HD MAKE HAIR adopts security, technical and administrative measures to keep all data stored in its inventory secure. Specifically regarding the data collected through our Internet environments, they are stored, processed, and protected using the best hosting, processing, backup, and encryption practices, according to their respective criticality.

3.4. In compliance with the law in force, our Internet environments promote the storage of their respective access records, in a controlled and secure environment, for an indefinite period. At the request of data holders, the access records to Internet applications will be deleted.

3.5. Even so, the Holder should be aware that no Internet security system is guaranteed against unwanted invasions, with HD MAKE HAIR's commitment limited to adopting recommendable protection measures according to the current state of the art.

3.6. Due to the structural characteristics of the Internet, it is possible that the collected data is stored or otherwise processed on third-party servers, located in Brazil or abroad. It is possible that these countries do not have legislation on privacy and personal data protection that guarantees an adequate and similar degree of protection to the Brazilian one. In any case, our partners provide HD MAKE HAIR with contractual guarantees that they adopt security, technical, and administrative measures capable of protecting your data. AWARE OF THIS, YOU CONSENT IN A FREE, INFORMED, UNEQUIVOCAL MANNER THAT HD MAKE HAIR CARRIES OUT INTERNATIONAL DATA TRANSFERS WHENEVER WE DEEM NECESSARY.

4. DATA RELATED TO FINANCIAL TRANSACTIONS

4.1. Data relating to financial transactions are subject to additional security mechanisms aimed at their authenticity, confidentiality, and integrity. Technical resources such as digital certification and encryption are used in this regard. Information that travels through our online buying and selling process is protected by HTTPS (usually, a closed padlock in the browser indicates that the connection is secure).

4.2. The Identification (Login and Password) process is mandatory in all online purchase processes.

4.3. The payment card numbers (credit or debit) provided by the Holder are used exclusively for authorization of purchase and/or payment transactions, being encrypted and masked according to the best market practices.

4.4. HD MAKE HAIR is in compliance with PCI DSS (Payment Card Industry Data Security Standard), a standard of the brands (Visa, MasterCard, and others), which establishes the security model for protecting the credit and debit card data of the Holders, and which applies to both physical stores and the online buying and selling process.

5. SHARING OF PERSONAL DATA

5.1. We only share data: a) with companies that provide transportation services, exclusively to provide the delivery service of the product(s) purchased by the Holder; b) with the entities mentioned in item 2.3 above; c) in the cases provided for in this clause; or d) with the prior consent of the Holder.

5.2. HD MAKE HAIR may use third-party service providers, located in Brazil or abroad for storage and data processing, which will assume the quality of Operators under the terms of the law in force. In this case, these Operators will have committed, by means of a contractual instrument, to treat personal data exclusively according to our lawful instructions, as well as to treat them confidentially. These contracts will also establish the responsibility of these Operators for any damage caused due to the exercise of personal data processing activities.

5.3. HD MAKE HAIR may also share data with third parties upon a court order or request from the National Data Protection Authority (ANPD), the Public Ministry, police, or administrative authority, or if necessary to comply with any other law or government regulation.

6. RIGHTS OF PERSONAL DATA HOLDERS

6.1. In the form and within the limits of the applicable legislation, as the holder of personal data, you may contact us to exercise certain rights, to request:

• the confirmation of the existence of processing of your personal data;
• access to your data;
• the correction of your incomplete, inaccurate, or outdated data;
• the anonymization, blocking, or deletion of your data that is unnecessary, excessive, or processed in non-compliance with the applicable legislation;
• the portability of your data to another service or product provider, in accordance with the ANPD regulations, considering commercial and industrial secrets;
• the deletion of your personal data, except in cases provided for by the applicable legislation;
• information on public and private entities with which HD MAKE HAIR shared your data;
• information on the possibility of you not providing consent and the consequences of your refusal;
• the revocation of your consent when you have provided it, safeguarding the public interest that may justify the continuation of processing or the existence of another legal basis that authorizes it; and
• opposition to any personal data processing based on one of the hypotheses in which your consent is waived, as long as there has been non-compliance with the applicable legislation and safeguarding the public interest that may justify the continuation of processing.

6.2. Your request can be made free of charge through our Data Protection Officer's email: <a href='mailto:lgpd@hdmakehair.com' className='text-blue-500'>lgpd@hdmakehair.com</a>. We will analyze your request and respond as quickly as possible, considering the deadlines and terms provided by the applicable legislation. If it is not possible to meet your request immediately, we will indicate the factual or legal reasons that prevent us from doing so.

6.3. Specifically concerning the rights to confirmation of the existence of processing and access to personal data, mentioned in items 'a' and 'b' of Clause 6.1 above, whenever possible, HD MAKE HAIR will seek to meet them immediately, in a simplified format. When this is not possible, we will provide you within 15 (fifteen) days, counted from the receipt of your request, with a complete statement with the pertinent information. You may choose to receive this information electronically or in printed form.

6.4. HD MAKE HAIR is not responsible for the correction, truthfulness, authenticity, completeness, and updating of the data provided by Holders, nor for the possible misuse of information published by them or for fraud resulting from the violation of personal passwords.

6.5. It is your exclusive responsibility to provide only correct, true, authentic, complete, and updated information, as well as to ensure the confidentiality of your password, when applicable, not disclosing it to third parties.

7. EDITION AND DELETION OF CONTENTS

7.1. Our Internet environments reserve the right to edit or delete any content published by Holders that do not comply with the law, with this Privacy and Data Protection Policy, or our Terms of Use.

7.2. This condition, however, does not constitute an obligation of HD MAKE HAIR, as, as a rule, requests for editing or removal must be made in the form of a court order, request from the ANPD, the Public Ministry, police, or administrative authority.

8. COMMUNICATION POLICY

8.1. Our Internet environments seek to avoid sending unsolicited emails, restricting communications with you to matters that are relevant or of specific interest to you.

8.2. When you make an online purchase, we confirm your order by email and may also contact you through the communication means provided in your registration to confirm the operation performed on our site.

8.3. If you prefer not to receive our promotional information, such as special offers and sales events, you can request your unsubscription through the unsubscribe link contained in the email or message received, or on your registration page, uncheck the option that authorizes the sending of promotional emails and messages (opt out).

8.4. After unsubscription, you may still receive security communications or related to online purchases you have made.

8.5. You should be aware that several fraudsters try to use famous brands to obtain personal information such as passwords and credit card data. HD MAKE HAIR WILL NEVER REQUEST YOUR PASSWORD AND/OR CREDIT/DEBIT CARD DATA THROUGH EMAIL OR TELEPHONE CONTACT. IN THE EVENT OF ANY OTHER SUSPICIOUS BEHAVIOR, SEND YOUR QUESTION OR ALERT BY EMAIL TO lgpd@hdmakehair.com

9. LINKS TO OTHER SITES

9.1. Our Internet environments may contain links or frames to other sites. These links or frames aim to provide additional benefits to the content and services offered to the Holders.

9.2. We clarify that the inclusion of these links in our Internet environments does not mean that HD MAKE HAIR is aware of, agrees with, or is responsible for the content of such links and frames. It is important to emphasize that our goal is to only provide links or frames from reputable and reliable institutions. However, HD MAKE HAIR is not responsible for the information, products, and services obtained by Holders on the referred sites, nor for the commercial practices and privacy policies adopted by these institutions, and cannot be held responsible for any losses and damages or lost profits suffered due to the use of these resources.

10. TERM AND CHANGES

10.1. The functioning of HD MAKE HAIR's Internet environments is for an indefinite period.

10.2. HD MAKE HAIR's Internet environments, in whole or in each of their tabs and sections, can be closed, suspended, or interrupted unilaterally by HD MAKE HAIR, at any time and without prior notice.

11. APPLICABLE LAW AND COMPETENT FORUM

11.1. In the interpretation of this Privacy and Data Protection Policy, Brazilian legislation applies.

11.2. Any disputes related to this Privacy and Data Protection Policy should preferably be resolved extrajudicially. Our Data Protection Officer is available to seek a consensual solution with you. Please send us an email to <a href='mailto:lgpd@hdmakehair.com' className='text-blue-500'>lgpd@hdmakehair.com</a>. If an amicable resolution is not possible, any disputes related to this Privacy and Data Protection Policy will be under the exclusive jurisdiction of the Central Court of Porto Alegre, RS, Brazil, excluding any other court, however privileged it may be.

All content and information contained in HD FEMININO PERUCAS LTDA's Internet environments are protected by laws regulating copyrights, trademarks, and other distinctive signs, and their total or partial reproduction is not permitted.