INTRODUCTION

This website is operated by TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA (TOBACCO HOUSE INDUSTRY AND COMMERCE LTD). Please read these terms and conditions (the “Terms of Use”) carefully. By accessing the website, you agree with the latter. If you do not agree with being bound to these terms of use, you shouldn’t access or view this website.

For the better understanding of these terms of use, we have utilized some definitions. The terms “TOBACCO HOUSE”, “we”, “us” and “our” are used to refer to Tobacco House Indústria e Comércio Ltda.

These terms of use contain seven sections, including its introduction. The other sections below contain a caveat related specifically to our privacy policy, our cookies policy, information to external links contained in this website, general and corporate information These terms of use (including the caveat related to financial information) can be accessed from any page of this website.

Any questions or complaints you may have related to this website must be addressed through the tab “CONTACT US” found in it.

PRIVACY POLICY

The present Privacy Policy conducts the treatment of personal data that you (“USER”) shares with the TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. (henceforth denominated “TOBACCO HOUSE”) as you utilize the products, services, functionalities and/or digital tools (jointly, “SERVICES”) available to the USERS by TOBACCO HOUSE through its institutional website https://tobhouse.com or through any other website, app and/or digital platform owned by TOBACCO HOUSE (jointly, “APPS”).

Through the exercise of its activities, TOBACCO HOUSE collects a variety of information about people with whom it interacts as a part of the conduction of its business and may utilize them as described in the present PRIVACY POLICY. We, the people of TOBACCO HOUSE, reiterate our commitment with our USERS and our concern with the privacy and protection of their personal data. In the case of doubts regarding this PRIVACY POLICY, contact us through the means indicated by the end of this tool.

I. GATHERING OF PERSONAL DATA

1.1. Through the exercise of its SERVICES, the TOBACCO HOUSE requests and obtain personal data from its USERS. Essentially, the personal data are sent by the USERS as they make contact through the sending of messages or e-mails to the informed addresses of our electronic addresses.

1.2. Having in mind the purpose of its SERVICES offered, personal data like name, address, CPF (Individual Taxpayer Registration), phone number, ID and e-mail for contacting, amongst others, may be required for the total operation of the SERVICES. The USER, as of now, consents with the gathering and treatment of this data for the reasons informed in the present PRIVACY POLICY.

1.3. The personal data informed can be stored in servers and will only be provided to third parties according to the Law and/or through court order. By utilizing the SERVICES, the USER expressly agrees with this storage and eventual necessity of provision of data.

1.4. The data collected by TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. are stored under the strictest information security practices in the database. The DATABASE is rigorously supervised and protected, so that only qualified staff, that are contractually bound to the duties of secrecy and confidentiality, have access to it. The TOBACCO HOUSE will make the best effort to guarantee that the information will always be treated according to what’s established in the present PRIVACY POLICY. However, the TOBACCO HOUSE cannot guarantee that the data protection and its security will never be violated. IN SUCH CIRCUMSTANCES, THE USER CONSENTS THAT THE TOBACCO HOUSE CANNOT BE HELD ACCOUNTABLE FOR THE PRACTICE OF NON-AUTHORIZED ACTS OF THIRD PARTIES THAT PROMOTE THE INTERCEPTION, ELIMINATION, ALTERATION, MODIFICATION OR MANIPULATION OF THE PERSONAL DATA CONTENT AND OTHER INFORMATION AND MATERIALS MADE AVAILABLE BY THE USERS.

1.5 In the performance of its activities, the TOBACCO HOUSE does not carry out personal data treatment of minors. If the TOBACCO HOUSE identifies data pertaining a minor, it will be deleted immediately.

II. PERSONAL DATA PROCESSING

2.1. For the implementation of the SERVICES, the TOBACCO HOUSE won’t share, lend, or exchange personal data of the USERS with third parties for marketing or commercial purposes.

2.2. While exercising its activities, the TOBACCO HOUSE shares information to third parties, in the following scenarios: (i) Taxation, audit or any other authorities, when we believe, we are legally bound to do so and/or to help avoid frauds, protect the personal safety of employees or third parties; (ii) service providers, such as external consultants and professional consultants (including advocacy offices, auditors or accountants), technical support functions and IT consultants that execute tests and jobs for the TOBACCO HOUSE; (iii) compliance with legal obligations: The TOBACCO HOUSE can share information if necessary to fulfill all and any legal determination, be it judicial or administrative, and the TOBACCO HOUSE will notify the USER about what information will be shared. By agreeing with the present PRIVACY POLICY, the USER expressively agrees with such operations, that may, in some cases, consist in the transfer of data. Under these conditions, the TOBACCO HOUSE adopts all technical means necessary to guarantee the personal data’s safety.

2.4. The TOBACCO HOUSE values the privacy of its USERS and utilizes personal data made available by them for the following purposes:

• The exercise of diverse products, services and/or digital tools hired and available to the USERS of TOBACCO HOUSE through the APPLICATIONS. To fulfill this purpose the personal data made available by the USERS can be shared with partners in the manner described by the present PRIVACY POLICY.
• Getting in contact with the USERS to confirm the information that may have been received and request the sending of information that may still be pending so that the TOBACCO HOUSE may exercise its SERVICES accordingly.

2.5. In case of order stemming from public authority requiring the access to TOBACCO HOUSE’s stored data, the respective USER owner of such data will be notified so that they may adopt the defensive measured they see fit.

III. THIRD-PARTY SYSTEMS AND APPLICATIONS

3.1. The TOBACCO HOUSE is not responsible for the treatment of personal data made by third parties due to the usage of systems, apps, websites and general platforms of their own. The treatment realized by third parties are ruled by their respective Privacy Policies.

3.2. The USERS will be responsible, before utilizing the systems, apps, websites, and general platforms of any of TOBACCO HOUSE’s partners, to attentively read the respective PRIVACY POLICY, being aware that the TOBACCO HOUSE is not responsible for the personal data treatment eventually conducted by its partners or by any third party.

IV. THE TRUTH AND UPDATES OF THE DATA

4.1. The USERS guarantee the data provided are real and current, undertaking to update them whenever there is any modification to them.

4.2. The USERS may access, correct or update their data at any moment, as well as request the definitive exclusion of their data from the servers of TOBACCO HOUSE or exercise any of the other rights determined within the article 18 of the Brazilian Law nº 13.709/18 through the Service Channel indicated on item IV of this PRIVACY POLICY. Being aware that at the hypothesis of data removal, they will no longer be able to access the features and services made available.

V. INFORMATION SECURITY

5.1. The TOBACCO HOUSE has technical and organizational security measures in force, adequate in order to (i) protect against the non-authorized access to stored data and the security copies made; and (ii) prevent alterations, divulgation and/or non-authorized elimination of information stored by the TOBACCO HOUSE.

5.2. We restrict the access to information to people that may need this information to provide the necessary support to the USERS, or guarantee the better operation of our services, products and/or legal tools. These individuals are bound to the duty of confidentiality and subject to disciplinary punishment, including the cancellation of service contracts and legal action in case of non-compliance of this obligation.

5.3. If you suspect the improper use, loss or denied access to your personal information, the USER must get in contact immediately with TOBACCO HOUSE through the service channel or directly with the company’s human rights department.

VI. SERVICE CHANNEL

6.1. To exercise any of your rights or if you have QUESTIONS or complaints about this PRIVACY POLICY, please contact us through the phone number +55 (51) 3704-5086, or e-mail tobaccohouse@tobhouse.com or through correspondence forwarded to the TOBACCO HOUSE’s human rights department, at Rio Pardinho, s/n – Interior. CEP/ZIP: 96856-000, Santa Cruz do Sul, RS, Brazil.

TERMS OF USE - GENERAL

1. This website is offered at no charge, without any guarantee, unless specifically established. The information contained in this general information only.

2. Except when specifically mentioned in this website, the TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. is not responsible for the content or use of any internet page, or any message received or sent by you.

3. All copyright ownership, trademarks and other intellectual property rights used in this website are property of TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. and/or of its licensors. You do not acquire any right in the website other than limited right of using the website according to the terms and conditions here presented. You cannot offer the purchase, sell, or distribute by any means, any part of this website or its content. However, you are authorized to print or download information and content from this website for personal use only, not commercial.

4. You must not use this website for illegal reasons and, specially, you agree that you will not send, copy, post or let any posting that is defamatory, obscene, or abusive, indecent or in violation of anyone’s privacy. You agree with not sending any unsolicited promotional material our advertising, spam or similar content or any amount of messages that may interfere with the performance of this website or on the enjoyment of this website for other visitors.

5. The TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. Reserves itself to the right of, at any given moment and no prior notice, to better, modify, alter or discontinue permanently all or part of this website and of restricting or prohibiting the access to it.

6. Through the present tool, you agree in indemnify the TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. for any costs, compensations, losses, and damages (including legal expenses) incurred by or conceded against the TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. through misuse of the website or the failure to follow these terms.

7. If you were to not follow these terms, the TOBACCO HOUSE INDÚSTRIA E COMÉRCIO LTDA. can as an option, suspend or block your access to this website and refuse to give you access to it.

8. If any part of these terms of usage are considered unfeasible under the law, all the other terms of usage will not be affected.

9. These terms of usage conduct our relationship with you and represent our integrated accordance.

10. These terms and conditions and the content of this website are ruled by the Brazilian legislation.