Legal

DRUMWAVE PRIVACY POLICY

DrumWave (“We” or “Us”) understands the importance and the obligation to respect the privacy and to ensure the security of the personal data of all the website’s Users, as well as candidates to our job vacancies and representatives of our clients and business partners (or “You”). For that reason, all the data is processed in conformity with the applicable privacy and data protection laws and the best practices.

This Privacy Policy (“Policy”) must be read with attention because it describes how your personal data is processed by Us.

It important to mention that this Policy does not apply to services offered by third parties, therefore, in case any content presented in the website forwards You, through an external link, to other websites, we recommend a cautious analysis of their respective privacy policies.

1. Categories of data subjects and processed personal data

We may process information of the following categories of data subjects on our website: users of the website, registrants of our events, representatives of clients and business partners and candidates for job vacancies at DrumWave.

The following data is processed:

General identification and contact data: name, e-mail, telephone and company.
Professional and academic data: professional history, academic history, general and specific competences, intended role, past and intended salary.
Navigation data: IP, navigation service provider, network connection, device’s operational system, interactions, device ID and geolocation, when authorized in your device.

2. Purposed of the processing of personal data

We process the personal data above for the following purposes:

General identification and contact data: process your registration for our events; manage relationship with customers and business partners; and process applications for job vacancies at DrumWave and carry out selection and recruitment processes for new employees.
Professional and academic data: process applications for job vacancies at DrumWave and carry out selection and recruitment processes for new employees.
Navigation data: obtain anonymous statistics on usage in order to continually improve access and content of the website; and generate website usage indicators.

3. Lawful Basis

We use the following lawful basis to justify the processing of personal data, according to the purposes mentioned above:

Process your registration for our events: performance of a contract
Manage relationships with customers and business partners: performance of a

contract
Process applications for job vacancies at DrumWave and carry out selection and recruitment processes for new employees: preliminary procedures for the performance of a contract
Obtaining anonymous statistics on usage in order to continually improve access and content of the website: legitimate interest.
Generate website usage indicators: legitimate interest.

4. Are cookies used?

Cookies are small text files that are stored in your browser or on your device and that are triggered when You access most websites available on the internet, including ours.

Cookies are used to allow the website to function correctly, evaluate possible usage problems and obtain performance metrics to improve content, for example. On our website, we may use the following categories of cookies:

Strictly necessary cookies: they are essential for the website to function, to ensure its security and adequate performance. Although they are necessary, You can disable them directly in your browser, but it is important to remember that this may compromise your experience and impair the functioning of the website.

Performance cookies: collect information about your behavior while browsing our website, such as the pages that are accessed and the time of visit, allowing us to improve the quality of our website and its content.
Advertising/targeting cookies: Advertising cookies are set on our website by our partners and may be used to build a profile of your interests and show You advertisements that are relevant to You on other websites.

Remember that some browsers automatically accept cookies, but You can change this setting to refuse cookies by accessing the “Help” feature in your browser’s toolbar.

5. With whom may my data be shared?

DrumWave may share your personal data with third parties that have adequate security and confidentiality standards to protect them, for the following purposes:

Companies of the same economic group as DrumWave: we may share your data to process your application for job vacancies at DrumWave and carry out selection and recruitment processes for new employees, as well as to conduct market research.
Business partners, service providers and other third parties: personal data may be shared with companies that work with DrumWave to enable and improve our services, such as legal service providers, selection and recruitment, cloud data storage and network services.
New businesses: in the continuous development of our business, processes of acquisition, sale and merger of companies, subsidiaries and other businesses may occur. In this transfer or change of business models, personal data and other information processed by DrumWave may be shared with involved or interested third parties, and transferred to investors and potential buyers, by itself or by third parties designated by them, for (i) carrying out audits and due diligence; and (ii) enabling the execution and conclusion of investments or corporate operations.
Government Authorities: your data may be shared with authorities to comply with legal or regulatory obligations and in the event of defense or request in judicial, administrative or arbitration proceedings.

In other cases, not provided for above, if personal data is to be shared, we will send You a notification with information regarding such sharing, requesting your consent.

6. Is my data transferred internationally?

Your personal data may be the object of international transfer for storage on cloud computing servers and when shared between companies of the same economic group as

DrumWave. Whenever your personal data is transmitted to another country, we will adopt measures to protect it, observing the applicable legislation.

7. How is my data protected?

DrumWave adopts technical and organizational measures to protect your data in the most complete way possible, guaranteeing the confidentiality, integrity and availability of your information based on the strictest standards practiced in the market. For example, the website is hosted in IBM’s hybrid cloud, which guarantees greater security and the traceability of your data.

Furthermore, international information security standards and practices are used, including double-factor authentication for account access; encryption for data in transit, ensuring the integrity of information; continuous monitoring of our environments; continuous analysis and testing of information security in our systems, carried out by internal and external teams, including carrying out periodic audits.

8. For how long will my data be stored?

Your personal data will be stored for the necessary period to fulfill the purposes for which it was collected, comply with legal or regulatory obligations and exercise rights in judicial, administrative or arbitration proceedings.

9. What are my rights and how may I exercise them?

As a data subject, You have the following rights:

• Confirm the existence of the processing of your personal data;
• Access data processed by DrumWave;
• Correct incomplete, inaccurate or outdated data;
• Request the anonymization, blocking or deletion of unnecessary, excessive or
• processed data that does not comply with the LGPD;
• Expressly request data portability to another service or product provider;
• Request the deletion of data obtained via consent, when applicable;
• Request information about the public or private entities with which DrumWave shares your data;
• When consent motivates collection, request information about the possibility of not
• providing it and the consequences of such denial;
• Request the review of decisions made solely based on automated processing of personal data; and
• Revoke your consent, whenever it is the lawful basis used for any processing activity carried out by DrumWave.

If You intend to exercise any of the rights listed above, please contact our DPO using the e- mail [email protected]. Your request will be analyzed and, if it is legitimate and reasonable, it will be responded within the legal deadline. In addition, to correctly fulfill your request, we will adopt the necessary procedures to confirm your identity.

Such rights are not absolute and may be waived if they conflict with other guarantees provided by law, such as confidentiality of information or DrumWave’s business secrets, legal retention obligations, need for storage for defense in lawsuits, or other legitimate reasons that justify refusal.

10. How do I contact DrumWave?

In Brazil, we are identified as:

DrumWave Brasil Tecnologia Ltda.
National Registry of Legal Persons: 34.791.805/0001-12 Address: Faria Lima Avenue, 1888, Room 918 – Pinheiros São Paulo/SP, Brazil

In the United Stated, we are identified as:

DrumWave, Inc.
148 Castro Street
Mountain View, California 94041 USA

11. Changes in this Policy

Any changes in this Privacy Policy will be made directly on our website. Therefore, we ask You to periodically access this document to be aware of any and all changes. Significant changes will always be reported more prominently.