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Privacy Policy

1. Purpose

MRV&CO’s External Privacy Policy (“Policy”) was created to evidence MRV&CO’s commitment to the privacy and security of information collected from Users of interactive services offered on MRV’s website and applications.

2. What personal data will MRV process?

MRV may collect information actively entered by you (the “User”) upon any contact or registration by filling out the contact form, or by the online broker, in addition to information collected automatically when using our services. Thus, two types of personal data are processed: (i) data provided by Users themselves, and (ii) data collected by MRV automatically.

2.1. Personal Data Provided by Users

MRV collects all personal data entered or actively forwarded by Users when they contact or fill out their register in our portal. It includes: Full name, e-mail, telephone, date of birth, income, taxpayer identification number CPF (holder and spouse), RG, Passport (if foreign), marital status, employment time security fund FGTS, employment relationship, occupation and full address.

Regardless of which personal data Users actively provides MRV with, we will only make use of data effectively relevant and necessary to achieve the purposes stated them upon the data collection.

2.2. Data collected automatically by MRV

MRV collects various information automatically in the User interaction portals, such as access device characteristics, browser, IP (including date and time), IP source, click information, pages accessed, search terms typed in our portals, among others. For such collection, MRV will make use of some standard technologies, such as cookies, pixel tags, beacons and local shared objects, which are used to improve our services browsing experience, according to your habits and preferences.

MRV does not process data defined as sensitive, which are considered as those related to racial or ethnic origin, religious conviction, political opinion, union membership or religious, philosophical or political organization, or data relating to health or sex life, genetic or biometric data, or data on children, thus considered as individuals that are less than 12 years of age, for the general purposes set out here. In the unlikely event that it is necessary to process such data, we will request the Users’ or User guardians’ specific and separate consent based on the cases authorized by the General Data Protection Law.

3. For what purposes will MRV process your data?

MRV processes personal data mainly to allow the Users to know the products and services offered by the platform, providing information via the contact form or the online broker, identifying Users browsing the site and keeping User data updated.

MRV may use your information in other services provided directly by MRV, subject to the purposes disclosed and your prior consent to us, where such collection is required by law.

In some cases, MRV may process your personal data if necessary to meet a legal obligation or for the due exercise of a right in judicial, administrative or arbitral proceeding.

Moreover, MRV may also process personal data based on your beneficial interest, always within the limits of your expectations, and never to the detriment of your interests, rights and fundamental freedoms.

Additionally, the information collected may, upon your prior consent, be used for advertising purposes, such as sending e-mail marketing to users. If you feel uncomfortable and no longer wish to receive any MRV advertising information, you may, at any time, contact us using the form available and express your opposition.

4. With whom will MRV share your personal data?

MRV, in order to make MRV’s services operational, has established a partnership with several companies based in Brazil and abroad. Accordingly, MRV may share your personal data in the following cases:

A. With partner companies and suppliers in the development and provision of services focused on you;

B. With authorities, governmental entities or other institutional third parties, to protect MRV’s interests in any type of conflict, including judicial and administrative proceedings;

C. In the case of corporate transactions and changes involving MRV, where the transfer of information will be necessary for the continuity of services;�

D. By court order or at the request of competent administrative authorities requiring them.

Additionally, it is possible that some of the above transfers occur outside the Brazilian territory. In such instances, MRV undertakes to do so only for countries that provide a degree of protection for their personal data as provided by the applicable law, or by adopting warranties and safeguards as specific clauses, as well as by prior collection of their specific consent.

5. How does MRV keep your personal data safe?

Any information provided by Users will be collected and stored in accordance with the strictest security standards. To this end, MRV takes several precautions, observing the legislation on security standards guidelines, and its Information Security Policy, such as:

A. It uses the latest methods and equipment available on the market to encrypt and anonymize your personal, if necessary;

B. It provides protection against unauthorized access to its systems;

C. MRV only authorize the access of specific persons to the place where personal information is stored, provided that this access is essential for the development of the intended activity; and

D. It ensures that those agents, internal employees or external partners who process personal data will undertake to maintain absolute confidentiality of the information accessed, and implement the best practices for handling this information, as determined in the policies and procedures.�

Access to the information collected is restricted to employees and authorized personnel. Those who misuse such information in violation of this Privacy Policy and in the event of a breach of the information security rules will be subject to the appropriate disciplinary and legal sanctions.

In addition to technical efforts, MRV also adopts institutional measures to protect personal data, and has implemented a privacy program focused on its activities, which is updated on regular basis.

Although MRV makes every effort to preserve your privacy and protect your personal data, no information transmission is completely secure, thus, MRV cannot fully guarantee that all information it receives and/or sends is not subject to unauthorized access perpetrated by means developed to obtain information in an improper manner, such as technical failures, viruses, or invasions of the website database.

In any case, in the remote hypothesis of incidence of such episodes, MRV guarantees full effort to remedy the consequences of the event.

6. How long will MRV store your data?

MRV will automatically delete your personal data when they are no longer useful for the purposes they were collected and are no longer necessary to fulfill any legal obligation directed to MRV, or when the User requests its deletion, unless the maintenance of the data is expressly authorized by law.

Users’ information may be retained for compliance with legal or regulatory requirements, transfer to third parties - provided that the data processing requirements are met - and exclusive use of MRV, including for the exercise of its rights in judicial or administrative proceedings.

7. What are your rights as a personal data subject?

MRV acknowledges and guarantees to Users the possibility of submitting requests for the processing of their personal data, based on the following rights:

A. Confirmation of any processing;

B. Access to personal data;

C. Correction of incomplete, inaccurate or outdated data;

D. Anonymization, blocking or deletion of unnecessary, excessive or illegally processed data;

E. Data portability to another service or product provider, upon express request by the User;�

F. Deletion of data processed with the consent of the User;�

G. Obtaining information about the entities with which you have shared your data;

H. Information on Users’ possible consent decline, and being informed of the consequences in case of decline;

I. Consent revocation.

8. How to exercise your rights as data subject?

Your rights as a personal data subject may be exercised directly by you, from the management of registration information, while another party will depend on sending a request via electronic form, for further evaluation and adoption of the necessary measures.

Users acknowledges any request for deletion of essential information for the management of their records with MRV will imply the termination of their contractual relationship, with the consequent cancellation of the services then rendered.

MRV will make every reasonable effort to meet the requests made by Users in the shortest possible time. However, reasonable factors including the complexity of the action requested may delay or prevent its prompt response, being certain that, in case of delay, it will present the due reasons.

Finally, Users must be aware that their request may be legally rejected, either for formal reasons (such as their inability to prove their identity) or for legal reasons (such as the request for deleting data MRV is freely entitled to keep), being understood that, in the event of impossibility to meet these requests, MRV will provide reasonable cause.

9. What are cookies and how does MRV use them?

Cookies are files or information that may be stored on your devices when you visit MRV’s websites or use MRV’s online services. Typically a cookie contains the name of the site that originated it, its lifetime and a value, which is randomly generated.

MRV uses cookies to facilitate the use and better adapt its website and applications to the interests and needs of its Users, as well as to assist and improve its structures and contents. Cookies can also be used to speed up your future activities and experiences with our services.

Through cookies, the site stores information about browser activity, including IP address and the page accessed. These logs will be used only for statistical and metrics purposes of the services made available or for the investigation of fraud or undue changes in their systems and registrations, not having the purpose of providing the data to third parties without express authorization of Users.

These records may include data such as the Users’ IP address, the actions performed on the site, the pages accessed, the dates and times of each action and access to each page of the site, the information about the device used, operating system version, browser, among other installed applications.

Cookies can be divided according to the information they store and their purpose, namely:

A. Cookies required: They are essential for MRV’s website to load correctly and allow you to browse and use all features available appropriately.

B. Performance Cookies: They help to understand how visitors interact with MRV’s website by providing information on the areas visited, the time spent visiting the site, and any problems found, including error messages.

C. Functional Cookies: They allow the website to remember your choices to provide a personalized experience. They allow Users to watch videos, use social tools, comment fields, forums and others.

D. Marketing Cookies: They are used to provide more relevant content and interest to Users. They can be used to present more targeted advertising or limit the number that this is broadcast on MRV’s pages. Also, they allow the measurement of the effectiveness of an advertising campaign launched.

At any time you can revoke your consent to the use of cookies, using your preferred browser settings or our specific channel available on the site.

However, we warn that, according to the choice made, certain features may not work as ideally expected. For more information on managing cookies directly in your browser, MRV suggests you to consult the links below:

10. Applicable law

This Policy was prepared for and in compliance with Federal Law No. 13,709/2018 (General Law on Personal Data Protection), Federal Law nº 12.965/2014 (Internet Civil Framework) and Federal Law nº 8.078/1990 (Consumer Protection Code), without prejudice to compliance with other laws applicable to MRV.

11. Technical Data Sheet

Document version: 01

Approved by the Board of Directors on: March 16, 2020

Next revision estimated date: March 16, 2022

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