Tarpon values the privacy and protection of individuals’ personal data. Accordingly, this Privacy Policy has been developed to explain the practices adopted in the handling of personal information of data subjects (“Data Subject”) that Tarpon may access, particularly information collected or provided through the website www.tarpon.com.br (“Website”). The Data Subject should carefully read this Privacy Policy in full before submitting any information to Tarpon, whether through the Website or by other means.
PERSONAL DATA COLLECTED
In the course of its business activities, Tarpon may have access to certain personal information capable of identifying the Data Subject, including, but not limited to, name, email address, phone number, and other information collected or provided (“Personal Data”), as described below:
a) Personal Data provided by the Data Subject: This includes data provided via the Website or by other means to: (i) send inquiries, complaints, or comments to Tarpon (e.g., “Contact Us” or “Investor Relations”); (ii) sign up to: (a) receive information via email (i.e., “Subscribe to our Mailing List”), or (b) participate in earnings webcasts; or (iii) participate in hiring processes or engage in procurement, rental of spaces, partnerships, sponsorships, or similar activities. Tarpon will collect Personal Data and other information that the Data Subject voluntarily provides, which will be handled in accordance with this Privacy Policy and applicable law. The Data Subject is responsible for ensuring the accuracy and truthfulness of the data provided and must keep it updated.
b) Automatically collected Personal Data: When accessing the Website, the following information may be automatically collected for security and/or statistical purposes, or to administer the Website and identify issues: (i) internet and service provider names; (ii) means of accessing the Website (e.g., browser type, operating system, device used); (iii) IP address; (iv) geographic region, date, and time of access; and (v) activity performed on the Website and the page(s) visited before or after. Cookies may also be sent to the device to enhance the Website’s performance and personalize the user experience. The Data Subject may choose to block cookies, though doing so may impact the availability of certain functionalities or a personalized experience.
c) Personal Data collected from third parties: Tarpon may also receive Personal Data from third parties who have obtained appropriate consent or from publicly available sources. This may include analytics on Website usage or support for data processing, hosting, technical assistance, or other services used to operate or customize the Website. These partners may automatically collect information such as IP address, browser type/version, pages viewed, time spent on pages, clicked links, and conversion data.
PURPOSES OF PROCESSING
Personal Data collected by Tarpon may be used for the following purposes:
(i) to operate the Website;
(ii) to better understand the needs, concerns, and interests of Data Subjects, including users of the Website, and to improve content provided through the Website or other channels;
(iii) to enable communication for support, responding to inquiries/complaints, or gathering feedback, as well as for hiring, procurement, or partnership purposes;
(iv) to send notices and/or additional information related to Tarpon or the Website;
(v) to improve the usability and interactivity of the Website;
(vi) to conduct statistical analyses using anonymized Personal Data, as permitted by applicable law;
(vii) to conduct marketing and/or communications campaigns;
(viii) to comply with legal or regulatory obligations;
(ix) to conduct financial, legal, and compliance reviews of the Data Subject, if and when applicable.
Tarpon may be required to disclose Personal Data in full or in part to comply with legal obligations or orders from competent authorities, or to investigate and/or address any suspected or actual violations of this Privacy Policy, the Website’s Terms and Conditions, or applicable laws. In such cases, Tarpon will disclose only the minimum necessary information to comply with its legal obligations.
STORAGE AND RETENTION
Tarpon is headquartered in Brazil, and all Personal Data collected will be stored:
(i) physically, at Tarpon’s headquarters; and
(ii) electronically, on Tarpon’s own servers and/or on servers of third-party cloud service providers located in Brazil or on servers used by third-party vendors contracted by Tarpon.
Tarpon and its service providers store and process Personal Data in accordance with this Privacy Policy and applicable data protection laws. When Personal Data is no longer needed under the terms of this Policy or upon the Data Subject’s specific request for deletion, Tarpon will delete and/or anonymize such data, in compliance with applicable law. For more information about where and how long your Personal Data is stored, or about your deletion and portability rights, you may contact contato@tarpon.com.br. Tarpon will respond within a reasonable timeframe and in accordance with applicable law.
DATA SHARING
Tarpon does not sell or transfer Personal Data, except as described in this Privacy Policy and/or as required by law. Tarpon does not disclose Personal Data to third parties unless:
(i) expressly requested or authorized by the Data Subject or a legally authorized representative (e.g., power of attorney);
(ii) required by law or pursuant to a subpoena, search warrant, or court or administrative order;
(iii) necessary to fulfill an agreement with the Data Subject or to resolve disputes/complaints or protect the rights of Tarpon, its employees, clients, or partners;
(iv) necessary in the event of emergencies or acts of God/force majeure; or
(v) necessary for partners of Tarpon to perform services on its behalf, in accordance with this Policy and applicable law.
In all cases, Tarpon, as the controller of the Personal Data it stores, remains responsible for the processing carried out by its partners, except in cases beyond its reasonable control.
SECURITY
Tarpon adopts reasonable measures to safeguard the Personal Data it collects, storing it in secure environments and protecting it with physical, technical, and administrative procedures commonly used for such data. Access to Personal Data is restricted to authorized personnel who require access and are obligated to comply with this Privacy Policy.
DATA SUBJECT RIGHTS
To the extent permitted by applicable law, the Data Subject may contact Tarpon to exercise the following rights:
(i) confirm whether Personal Data is being processed;
(ii) access the Personal Data;
(iii) correct incomplete, inaccurate, or outdated Personal Data;
(iv) anonymize, block, or delete unnecessary, excessive, or unlawfully processed data;
(v) request data portability to another service or product provider, subject to commercial and industrial secrecy;
(vi) request deletion of data processed based on consent;
(vii) obtain information about data sharing;
(viii) be informed of the option to withhold consent and the consequences thereof;
(ix) revoke consent, as permitted by applicable law.
To exercise these rights, the Data Subject may contact contato@tarpon.com.br. Tarpon will respond within a reasonable timeframe and in accordance with applicable law.
HYPERLINKS
Tarpon does not endorse, sponsor, or assume responsibility for the content or features of third-party websites not covered by this Privacy Policy, even if accessed via links on the Website. When redirected to an external site, we recommend reviewing that site’s terms of use and privacy policy before browsing or submitting any personal information. Use of such third-party sites is at your own risk, and Tarpon is not liable for any loss or damage arising from reliance on those sites.
CHANGES TO THIS POLICY
This Privacy Policy may be updated from time to time. The current version will always be available on the Website for the Data Subject’s review. Access to or continued use of the Website or ongoing relationship with Tarpon following any updates will be deemed acceptance of the revised Policy.
CONTACT
If you have any complaints, questions, or comments regarding this Privacy Policy or how Tarpon handles your Personal Data, please contact contato@tarpon.com.br. Tarpon will respond within a reasonable timeframe and in accordance with applicable law.