Privacy Policy

This privacy policy is valid as of July 2025.

PRIVACY POLICY — Qualified Steps

Qualified Steps, a private legal entity with headquarters in Lontra, MG, Brazil, takes your privacy seriously and ensures the security and data protection of all its customers, partners, suppliers, and users ("Users" or "you") of the website http://www.qualifiedsteps.com and any other website, Store, or application operated by the Merchant (herein, simply referred to as the "Store").

This Privacy Policy ("Privacy Policy") is intended to inform you about how we use and disclose information collected during your visits to our Store and in messages we exchange with you ("Communications").

BY ACCESSING THE STORE, SENDING COMMUNICATIONS, OR PROVIDING ANY TYPE OF PERSONAL DATA, YOU DECLARE THAT YOU ARE AWARE OF AND AGREE TO THIS PRIVACY POLICY, WHICH DESCRIBES THE PURPOSES AND METHODS OF PROCESSING YOUR PERSONAL DATA THAT YOU MAKE AVAILABLE ON THE STORE.

This Privacy Policy provides an overview of our privacy practices and the choices you can make, as well as the rights you can exercise in relation to the Personal Data we process. If you have any questions about the use of Personal Data, please contact [email protected].

In addition, this Privacy Policy does not apply to any third-party applications, products, services, websites, or social media features that may be offered or accessed through the Store. Accessing these links will cause you to leave the Store and may result in the collection or sharing of information about you by third parties. We do not control, endorse, or make any representations about these third-party websites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any website you interact with before allowing the collection and use of your Personal Data.

If you send us Personal Data relating to other individuals, you declare that you have the authority to do so and have obtained the necessary consent to authorize the use of such information in accordance with this Privacy Policy.

Definitions

For the purposes of this Privacy Policy:

"Personal Data" means any information that, directly or indirectly, identifies or can identify a natural person, such as, for example, name, CPF (Brazilian tax ID), date of birth, IP address, among others;

"Sensitive Personal Data" means any information that reveals, in relation to a natural person, racial or ethnic origin, religious beliefs, political opinions, union membership or membership in a religious, philosophical, or political organization, data related to health or sexual life, or genetic or biometric data;

"Personal Data Processing" means any operation carried out on Personal Data, whether by automatic or non-automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or, alternatively, making available, alignment or combination, restriction, erasure, or destruction. Any other operation provided for under the terms of applicable law is also considered Personal Data Processing;

"Data Protection Laws" means all legal provisions that regulate Personal Data Processing, including, but not limited to, Law No. 13.709/18, the General Data Protection Law ("LGPD").

Use of Personal Data

We collect and use Personal Data to manage your relationship with us and to better serve you when you are purchasing products and/or services on the Store, personalizing and improving your experience. Examples of how we use the data include:

• Enabling you to purchase products and/or services on the Store;

• To confirm or correct the information we have about you;

• To send information we believe to be of interest to you;

• To personalize your experience of using the Store;

• To personalize the sending of advertisements to you, based on your interest in our Store; and

• To contact you by a provided phone number and/or email address. We may contact you personally, by voice message, through automatic dialing equipment, by text messages (SMS), by email, or by any other means of communication that your device is capable of receiving, in accordance with the law and for reasonable commercial purposes.

Additionally, the Personal Data provided may also be used in a manner that we deem necessary or appropriate: (a) under the terms of the Data Protection Laws; (b) to meet the requirements of a judicial process; (c) to comply with a court order, regulatory decision, or decision of competent authorities, including authorities outside the country of residence; (d) to protect our operations; (e) to protect our, your, or third-party rights, privacy, and security; (f) to detect and prevent fraud; (g) to allow us to use available actions or limit damages we may suffer; (h) in other ways permitted by law.

OUR STORE IS NOT INTENDED FOR PEOPLE UNDER 18 (EIGHTEEN) YEARS OLD AND WE ASK THAT SUCH PERSONS NOT PROVIDE US WITH ANY PERSONAL DATA.

Failure to Provide Personal Data

You are not obligated to share the Personal Data we request; however, if you choose not to share it, in some cases we may not be able to provide you with full access to the Store, some specialized features, or be able to provide the necessary assistance, or even enable the delivery of the product or the provision of the service contracted by you.

Data Collected

The general public may browse the Store without the need for any registration and sending of Personal Data. However, some of the Store's features may depend on registration and sending of Personal Data, such as completing the purchase/contracting of the service and/or enabling the delivery of the product/provision of the service by us.

Upon contact with the Store, we may collect:

Contact Data. First name, last name, phone number, city, state, and email address; and

Information you send. Information you submit via a form (questions, complaints, suggestions, criticisms, compliments, etc.).

When Browse the Store in general, we may collect:

Location Data. Geolocation data when you access the Store;

Preferences. Information about your preferences and interests regarding products/services (when you tell us what they are or when we deduce them from what we know about you);

Store Browse Data. Information about your visits and activities on the Store, including the content (and any advertisements) that you view and interact with, information about the browser and device you are using, your IP address, your location, and the address of the website from which you arrived. Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons, and embedded web links. To learn more, read how we use Automatic Data Collection Tools in section 7 below;

Anonymous or Aggregated Data. Anonymous responses to surveys or anonymous and aggregated information about how the Store is used. During our operations, in certain cases, we apply a de-identification or pseudonymization process to your data so that it is reasonably unlikely that you will be identified through the use of this data with the available technology; and

Other information we may collect. Other information that does not specifically reveal your identity or is not directly related to an individual, such as information about the browser and device; Store usage data; and information collected through cookies, pixel tags, and other technologies.

Unless you provide it in a free-form field filled out by you, we do not collect Sensitive Personal Data.

Sharing Personal Data with Third Parties

We may share your Personal Data:

• With the partner company(s) you select or choose to send your data, questions, etc., as well as with service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the United States, Argentina, Brazil, or other global locations, including servers for approval and production, and providers of hosting and data storage services, fraud management, customer support, sales on our behalf, order fulfillment, content personalization, advertising and marketing activities (including digital and personalized advertising), and IT services, for example;

• With third parties, with the aim of helping us manage the Store; and

• With third parties, in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

International Data Transfers

Personal Data and other types of information collected by us may be transferred to or accessed by entities belonging to the corporate group of partner companies worldwide in accordance with this Privacy Policy.

Automatic Collection of Personal Data

When you visit the Store, it may store or retrieve information in your browser, either in the form of cookies or other similar technologies. This information may be about you, your preferences, or your device and is mainly used to make the Store work as you expect. The information generally does not identify you directly but can offer a more personalized internet experience.

In accordance with this Privacy Policy, we and our third-party service providers may collect your Personal Data in several ways, including, but not limited to:

Through the browser or device: Some information is collected by most browsers or automatically through internet access devices, such as the type of computer, screen resolution, operating system name and version, device model and manufacturer, language, and the type and version of the internet browser you are using. We may use this information to ensure the Store functions properly.

Use of cookies: Cookies allow the collection of information such as browser type, time spent on the Store, pages visited, language preferences, and other anonymous traffic data. We and our service providers may use this information to, among other things, personalize your experience when using the Store, as well as to direct advertising to you, according to your interests. We also collect statistical information about the use of the Store for continuous improvement of our design and functionality.

• If you do not want your information to be collected through cookies, you can configure cookies in the "options" or "preferences" menu of your browser. In the links below you can find more details on how to adjust the cookie preferences of the most popular internet browsers:

   

   

  • Google Chrome

     

     

  • Mozilla Firefox

     

     

  • Safari

     

     

  • Internet Explorer

     

     

  • Microsoft Edge

     

     

  • Opera

     

     

• If you would like to know a little more about advertising and remarketing cookies, which are used to direct advertising based on the interests of each user and the number of visits they have made to our website and their searches on the internet, access:

   

   

  • Facebook

  • Google

  • Bing

Use of pixel tags and other similar technologies: Pixel tags (also known as Web beacons and clear GIFs) may be used to track the actions of Store users (including email recipients), measure the success of our marketing campaigns, and collect statistical data about the use of the Store and response rates. If you have ad personalization enabled in tools like Facebook, Google, or Bing, the information may be used to show ads on their services. If you do not wish to be tracked, you can ask each of the services:

• Facebook

• Google

• Bing

We may hire behavioral advertising companies to obtain reports on Store advertisements across the internet. For this, these companies use cookies, pixel tags, and other technologies to collect information about your use, or the use of other users, of our Store and third-party websites. We are not responsible for pixel tags, cookies, and other similar technologies used by third parties. You can configure your preferences in your browser's menu. Be aware that if you change computers or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser.

User Rights

You can, at any time, request: (i) confirmation that your Personal Data is being processed; (ii) access to your Personal Data; (iii) corrections to incomplete, inaccurate, or outdated data; (iv) anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data; (v) portability of Personal Data to another service provider, provided that this does not affect our industrial and commercial secrets; (vi) deletion of Personal Data processed with your consent, to the extent permitted by law; (vii) information about the entities with which your Personal Data has been shared; (viii) information about the possibility of not providing consent and about the consequences of the refusal; and (ix) revocation of consent. Your requests will be treated with special care to ensure the effectiveness of your rights. You may be asked to provide proof of your identity to ensure that the sharing of Personal Data is only done with its owner.

You should keep in mind that, in certain cases (for example, due to legal requirements), your request may not be immediately satisfied, and we may not be able to fulfill it due to compliance with legal obligations.

Security of Personal Data

We seek to adopt the appropriate technical and organizational measures provided for by the Data Protection Laws for the protection of Personal Data in our organization. Unfortunately, no data transmission or storage system is guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe the security of any of your accounts has been compromised), please notify us immediately.

Hypertext Links to Other Websites and Social Media

The Store may, from time to time, contain hypertext links that will redirect you to websites of our partners, advertisers, suppliers, etc. If you click on one of these links to any of these websites, we remind you that each website has its own privacy practices and that we are not responsible for these policies. Please consult these policies before submitting any Personal Data to these websites.

We are not responsible for the collection, use, and disclosure policies and practices (including data protection practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other software developer or application provider, social media Store, operating system, wireless internet service provider, or device manufacturer, including all Personal Data you disclose to other organizations through the applications, related to such applications, or posted on our social media pages. We recommend that you inform yourself about the privacy policy of each website visited or each service provider used.

Updates to this Privacy Policy

If we modify our Privacy Policy, we will publish the new text on the Store, with the updated revision date. We may change this Privacy Policy at any time. If there is a significant change in the terms of this Privacy Policy, we may inform you through the contact information we have in our database or through a notification on our Store.

We remind you that we are committed to not processing your Personal Data in a manner incompatible with the objectives described above, unless otherwise required by law or court order.

Your use of the Store after the changes means that you have accepted the revised Privacy Policies. If, after reading the revised version, you do not agree with its terms, please cease access to the Store.

Person Responsible for Personal Data Processing

If you wish to exercise any of the rights provided for in this Privacy Policy and/or in the Data Protection Laws, or resolve any questions related to the Processing of your Personal Data, please contact us via email at [email protected].