CONFIDENTIAL CHANNEL TERMS OF USE 

• INTRODUCTION
  
  

These Terms of Use (“Terms of Use” or “Terms”) govern the relationship between you (“Manifest”) and Associação Aliança de Misericórdia (“Aliança” or “us”), a civil society organization, under CNPJ nº 04.186.468/0001-73, with regard to the use, of any nature and/or form, of the website www.aliancasocial.org and contact channels related to the Whistleblowing Channel (“Whistleblower Channel” or “Channel”) .

These Terms must be read in conjunction with the website's Privacy Policy (“Privacy Policy” or “Policy”), which is available at www.aliancasocial.org/canalconfidencial. This is because, for you to access and use the Reporting Channel (as will be detailed below), Aliança may carry out activities of processing personal data, which are described in the Policy.

If you do not agree with any of the provisions of these Terms, we ask that you do not use the Reporting Channel. The use of the Denouncement Channel, in whole or in part, implies immediate acceptance of these Terms. In addition, you cannot excuse yourself from the Terms by claiming ignorance of their conditions, including any changes to their provisions. For these reasons, we recommend that you read them carefully.

• COMPLAINT CHANNEL DESCRIPTION AND PURPOSE
  
  

This is an exclusive channel of Aliança for safe and, if desired, anonymous communication of conduct considered inappropriate or that violate ethical principles and standards of conduct and/or current legislation, for capturing and recording manifestations related to the compliance of Aliança's activities .

Thus, the Denouncement Channel allows you to present your concerns, complaints or denouncements in relation to the activities carried out by Aliança employees in the exercise of their work duties.

• TO REGISTER A REPORT
  
  

To use the Reporting Channel, the Protestant must be connected to the internet and access the website www.aliancasocial.org. The Channel allows the registration of reports on improper conduct, non-compliance with the Code of Conduct and Relationship, as well as the Bylaws, the Internal Regulations, the policies, management guidelines of the Cooperative, the rules or laws that govern our activities, which must be registered.

It is possible for the manifestation to be registered anonymously, in which no personal data identifying the Manifest will be requested, or in an identified form, in which his personal data will be requested. In all situations, the information you send us will be treated in an absolutely confidential manner and security measures will be applied in the verification of the facts.

During registration, the Manifestation must describe the reasons and suspicions that led him to the Channel, including a description of the situation, the people and witnesses involved, the date of occurrence (be it past, present or future), the place, the cause or reason, as well as possible evidence related to the specific case, such as images, videos, voice recordings or documents (if any). Evidence can be attached by you, in the appropriate place, as indicated on the website.

Then, the complaint will be analyzed and classified, and Aliança will verify the origin of the information provided by the Complainant, adopting, whenever necessary, corrective and disciplinary measures, referring to the identified irregularities.

• CHANNEL ACCESS AND USE
  
  

By accessing the website and using the Denouncement Channel, the Manifest immediately expresses his full and unreserved acceptance of the Terms of Use. Likewise, the Manifest undertakes to observe and respect the laws and contracts in force, using the Channel only for lawful purposes and respecting any rights of third parties.

The content of reports and statements filled in and sent through the Reporting Channel is the sole and exclusive responsibility of the Manifestation. Aliança is not responsible for any damage resulting from reports registered by third parties.

• INTELLECTUAL PROPERTY
  
  

All of Aliança's intellectual property rights are reserved, as well as all trademarks, logos, trade names, layouts, graphics and interface design, images, illustrations, photographs, presentations, videos, sound and audio content, computer programs, database, transmission files and any other information or works protected by applicable law.

Any acts or contributions tending to modify the characteristics, expansion, alteration or incorporation of any programs to the Alliance's systems are prohibited. Any and all forms of reproduction of the Denouncement Channel, in whole or in part, permanent, temporary or provisional, free of charge or onerous, under any modalities, forms or titles is expressly prohibited.

• APPLICABLE LAW AND JURISDICTION
  
  

The Manifest agrees with the application of Brazilian laws to any dispute related to these Terms. The Manifest also agrees with the election of the jurisdiction of the Judicial District of the City of São Paulo, State of São Paulo, to resolve any dispute related to these Terms of Use, expressly waiving any other, however privileged it may be.

TERMS OF CONSENT - LGPD

This document aims to record the free, informed and unequivocal manifestation by which the legal representative or the Holder of Personal Data agrees with the processing of their personal data for a specific purpose, in accordance with Law No. Personal (LGPD).

The Holder or Legal Representative of the Holder consents and agrees that the  ASSOCIAÇÃO ALLIANÇA DE MISERICÓRDIA, CNPJ nº 04.186.468/0001-73, headquartered in the City of São Paulo, Rua Avanhandava, 616, Bela Vista, CEP 01306-000, telephone +55 (11) 3120-9191, e-mail ouvidoria@aliancasocial.org , hereinafter referred to as Controller, make decisions regarding the treatment of its own personal data or your personal data, in addition to the data of the person for whom it is responsible, as well as carry out the processing of such personal data, involving operations such as those referring to the collection , production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction.

PERSONAL DATA COLLECTED

The Controller is authorized to make decisions regarding the treatment and to process the following personal data of the Holder:

• Personal data of the demonstrator: email;
  
  

• Personal data of the accused and third parties: data from the accused and third parties may be collected from the report voluntarily registered by the Manifestation, including data such as name, position and place of work, e-mail. It is also possible that the Manifestation provides other personal data during the description of the incident, as described in the item below.
  
  

• Information provided in the statement: is information provided by the Manifestation when filling out and registering the report, including the type of manifestation (e.g., referring to abuse of power, physical aggression, sponsorship or favoritism, moral or sexual harassment, destruction, damage or theft of assets, discrimination, use or trafficking of prohibited substances, corruption, financial or accounting fraud, operational fraud, leakage or misuse of information, violation of legal rules, non-compliance with internal policies and procedures), place of manifestation, report and description about the occurrence, relevant evidence and documentation (e.g. images, videos, voice recordings, documents).

PURPOSES OF DATA PROCESSING

Personal data will be processed for purposes related to the receipt, evaluation and investigation of the complaint, which includes conducting any investigations that prove necessary, according to the content, nature and seriousness of the report, as well as the fulfillment of legal obligations or regulatory and adoption of legal measures, when necessary;

The processing of the personal data listed in this term has the following purposes:

• Regarding the Manifestation: the treatment aims to allow the identification and contact between Aliança and the Manifestation for clarification of doubts, collection of additional information and progress of the investigations of the report. Data may also be processed for compliance with legal or regulatory obligations, regular exercise of rights and statistical analysis (anonymized). Enable fundraising campaigns;

• In relation to the accused and third parties: The purpose of the treatment is to verify the reported facts and take action, in accordance with the applicable legislation. The data may also be processed for the purposes of complying with legal or regulatory obligations, regular exercise of rights and statistical analysis (in anonymized form).
  
  

DATA SHARING

The Controller is authorized to share the Holder's personal data with other data processing agents, if necessary for the purposes listed in this term, subject to the principles and guarantees established by Law No. 13,709/2018.

DATA SECURITY

The Controller is responsible for maintaining security, technical and administrative measures capable of protecting personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate or unlawful treatment.

Pursuant to art. 48 of Law No. 13.709/2018, the Parent Company will notify the Holder and the National Data Protection Authority (ANPD) of the occurrence of a security incident that may pose a risk or relevant damage to the Holder.

TERMINATION OF DATA PROCESSING

The Controller will be able to keep and process the Holder's personal data for the entire period in which they are relevant to the scope of the purposes listed in this term. Anonymized personal data, without the possibility of association with the individual, may be kept for an indefinite period.

The Holder may request via email or correspondence to the Controller, at any time, that the non-anonymized personal data of the Holder be deleted. The Holder is aware that it may be impracticable for the Controller to continue providing products or services to the Holder after the elimination of personal data.

HOLDER'S RIGHTS

The Holder has the right to obtain from the Controller, in relation to the data processed by him, at any time and upon request: I – confirmation of the existence of treatment; II – access to data; III – correction of incomplete, inaccurate or outdated data; IV – anonymization, blocking or deletion of data that is unnecessary, excessive or treated in violation of the provisions of Law No. 13,709/2018; V – portability of data to another service or product provider, upon express request and observing commercial and industrial secrets, in accordance with the regulation of the controlling body; V – portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets; VI – deletion of personal data processed with the consent of the holder, except in the hypotheses provided for in art. 16 of Law No. 13,709/2018; VII – information from public and private entities with which the controller carried out shared use of data; VIII – information on the possibility of not providing consent and on the consequences of the refusal; IX – revocation of consent, pursuant to § 5 of art. 8 of Law No. 13,709/2018.

RIGHT TO REVOK CONSENT

This consent may be revoked by the Holder, at any time, upon request via email (ouvidoria@aliancasocial.org) or by correspondence to the Controller, cf. indicated on the first page of this document.