PRIVACY POLICY

Mineral Trade Ltda.
Headquarters: Rua Fernando de Noronha, 142, 2nd floor, Jardim Guadalajara, Vila Velha, Espírito Santo, Brazil, ZIP Code 29.109-040
CNPJ: 66.519.590/0001-71

This Notice aims to demonstrate our commitment to safeguarding your privacy and protecting your Personal Data, establishing the rules regarding its Processing, as well as explaining your rights and how to exercise them.

Please read this Notice carefully and, if you still have questions, feel free to contact us through the Customer Service Channels provided here.

For a better understanding of this Notice, the following definitions should be considered:

Algorithm: A set of rules that provides a sequence of operations capable of solving a specific problem or performing a task.

Notice: This Privacy Notice.

Cookies: Small files sent to your browser or devices that store your preferences and other information about how and when Our Environments are visited, as well as the number of people who access them.

Personal Data: Data relating to an identified or identifiable natural person. For example: name, email, ID number, personal preferences, IP address, geolocation.

Sensitive Personal Data: Any data regarding racial or ethnic origin, religious belief, political opinion, union membership or membership in a religious, philosophical, or political organization, data concerning health or sexual life, genetic or biometric data, when linked to a natural person.

Data Protection Officer (DPO): The person appointed by Mineral Trade to act as the communication channel between us, the Personal Data Subjects, and the National Data Protection Authority — Agência Nacional de Proteção de Dados (ANPD).

Applicable Legislation: All legislation concerning privacy and the protection of Personal Data, especially Law No. 13.709/2018 (General Data Protection Law — Lei Geral de Proteção de Dados Pessoais – LGPD).

Our Environments: Refers to the website www.mineraltrade.com and its subdomains ("Platform").

Personal Data Subject: You — the natural person to whom the Personal Data refers, whether as a user of the Platform and/or a service provider.

International Data Transfer: The transfer of personal data to a foreign country or to an international organization of which the country is a member.

Processing: Any operation performed with Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.

How we process Data. Personal Data may be processed when you interact with Our Environments.

Update and Accuracy of Data. You are solely responsible for the accuracy, truthfulness, and updating of the Data you provide to us. We are not obligated to process your Data if there are reasons to believe that such processing may result in a violation of any applicable law, or if you are using our environments for any illegal or illicit purposes.

Database. The database formed through the collection of Data is our property and under our responsibility. Its use, access, and sharing, when necessary, will occur within the limits and purposes described in this Notice.

We do not use any type of solely automated decision-making that may affect your interests.

To improve your browsing and experience on the Mineral Trade Platform, we use Cookies.

Purposes of Processing. The use of Cookies in Our online Environments aims to enhance your experience in terms of performance and usability, remembering your preferences and repeated visits. Below are the main purposes, according to the categories of Cookies presented to you:

Functionality: We use functional Cookies for user authentication, to provide the basic services requested by you, and to record personal preferences related to our site, such as name and language.

Analytics: We use analytical Cookies for statistical purposes to implement improvements in advertisements and in our platform, aiming to enhance your experience.

How long do we process Cookies? There are two types of Cookies that may be used in Our Environments:

Session Cookies: Temporary; they remain on your device until you end your browsing session or stop using Our Environments.

Persistent Cookies: Remain on your device until deleted (the duration depends on the Cookie's "lifetime" and your browser settings).

How to manage Cookies in your browser. You can configure your Cookie preferences directly in your browser. Instructions for disabling or deleting Cookies can be found in the help pages for each browser (Firefox, Chrome, Edge, Safari, Opera).

Data Sharing Scenarios. The Data processed and activity logs may be shared:

With competent judicial, administrative, or governmental authorities whenever there is a legal requirement, request, or order.

With service providers or partner companies to facilitate, provide, or perform activities related to Our Environments.

With marketing and advertising companies to deliver promotions and information tailored to your profile.

Automatically, in the event of corporate transactions such as mergers, acquisitions, or incorporation of Mineral Trade.

If you have any questions about who we share your Personal Data with, contact us through the Customer Service Channels listed at the end of this Notice.

Data Anonymization. For market intelligence research, press communications, and advertising, Data will be shared in anonymized form, preventing your identification.

Security and Governance Practices. To safeguard your privacy and protect your Data, we maintain a governance program with best practices, internal policies, procedures, training, educational actions, and mechanisms for supervision and risk mitigation related to Personal Data Processing.

Access, proportionality, and relevance. Internally, Personal Data is accessed only by authorized professionals, respecting principles of proportionality, necessity, and relevance, along with confidentiality commitments. In the event of individual data breaches or unauthorized access that may cause you significant harm or risk, we may promote direct conciliation under Article 52, §7 of the Lei Geral de Proteção de Dados Pessoais, with your consent.

Adoption of good practices. You are also responsible for keeping your Data confidential. Sharing passwords or access credentials violates this Notice and may compromise the security of your Data and Our Environments. If you identify or suspect any security breach, contact our Data Protection Officer through the Customer Service Channels.

External links. When using the Platform, you may be directed to other sites or platforms that may collect your Data and have their own privacy policies. It is your responsibility to read and accept or reject those policies. We are not responsible for third-party privacy policies or content.

Processing by third parties under our direction. We carefully evaluate our partners and service providers and establish contractual obligations regarding confidentiality, information security, and Data protection.

Storage location. We store your personal data and activity logs on our own servers or on servers of carefully selected partners. We adopt strict technical and administrative security measures to ensure your data remains secure, accessible only to authorized individuals, and protected against improper alterations.

If your data is stored on servers located outside Brazil, this may constitute an international data transfer, in which case the rules under International Data Transfer apply.

Retention period. We store Data only for as long as necessary to fulfill the purposes for which it was processed or to comply with legal, regulatory, or rights-preservation obligations.

Data disposal. Once the retention period and legal requirements expire, Data will be deleted using secure disposal methods or anonymized for statistical purposes.

To enable and improve our operations, some of our resources and servers — as well as those of our partners — are located outside Brazil, resulting in international data transfers for the following purposes:

We ensure that all transfers comply with applicable legislation and only transfer personal data to partners that demonstrate compliance with relevant laws, maintaining protection levels equal to or stricter than those required by Brazilian law.

We maintain contracts requiring strict data protection and information security standards. These contracts ensure your personal data is kept confidential and processed only for the purposes indicated above.

You have several rights under applicable legislation, which may be exercised by submitting a request to our Data Protection Officer through the Customer Service Channel. Your rights include:

(i) Confirmation and access: Request confirmation of Processing and access to your Data, including copies of records.

(ii) Correction: Request correction of incomplete, inaccurate, or outdated Data.

(iii) Anonymization, blocking, or deletion: Request anonymization, temporary suspension of Processing, or deletion of your Data.

(iv) Portability: Request your Data in a structured, interoperable format for transfer to a third party.

(v) Information about sharing: Request information about third parties with whom we share your Data.

(vi) Withdrawal of consent: Withdraw consent for specific purposes (without affecting prior lawful Processing).

(vii) Objection: Object to Processing if you disagree with a purpose.

(viii) Review: Request review of decisions based solely on automated Processing.

(ix) Access to contractual clauses: If your data is transferred internationally based on contractual clauses, you may request access to them (subject to trade secrets).

Verification. For your security, we may request additional information to confirm your identity.

Refusal. We may refuse requests that violate our intellectual property, trade secrets, or legal/regulatory obligations, or when Data must be retained for defense in disputes.

Response time. We commit to responding within a reasonable timeframe and in accordance with applicable law.

Petition to ANPD. You may petition the ANPD if you believe your rights were violated or your request was not properly addressed.

Changes and updates. You acknowledge our right to modify this Notice at any time. If relevant updates occur, you will be notified through your contact information or our official channels.

Severability. If any part of this Notice is deemed unenforceable, the remaining provisions remain in full effect.

Customer Service Channels. For questions or to exercise your rights, contact us at: contact@mineraltrade.com

Applicable law. This Notice is governed by Brazilian law, in Portuguese.