FULL GAUGE ELETRO-CONTROLES LTDA.
FG FINDER
PRIVACY POLICY

Version 2.0 – May, 2025

This Privacy policy (“Policy”) was created to show the commitment of Full Gauge Eletro-Controles Ltda., company registered with CNPJ/ME Nº 90.446.048/0001-10, (herein mentioned as “Full Gauge”, “we” or “our”), with information safety and privacy, gathered from the users, with their personal data owned by the users themselves (“Holder”, “User” or simply “you”), as well as helping the holders to make decisions based on their privacy.

The Policy clarifies the general gathering, use, storage and other forms of treatment and personal data protection conditions on the **FG Finder **App (“App”), in accordance with current in-force Brazilian law in terms of personal data privacy and protection, including but not limited to, Law Nº12,965, from April 23rd, 2014, and Decree Nº 8,771, from May 11th 2016 (“Internet Civil Framework”), Law Nº 13,709, from August 14th, 2918 (“General Data Protection Law” or “LGPD” in Portuguese).

To maintain direct contact with you, a Coordinator for Personal Data Treatment was designated by company to manage a communication channel:

Coordinator: G2 Law – Gabriela Coelho: privacidade@fullgauge.com.br
Substitute: Francesca Moretto Hendges: privacidade@fullgauge.com.br

By using our app, you express your agreement with this Policy in a free, informed, unmistaken, complete, and integral manner. We recommend you read it carefully.

  • 1.

    TARGET AUDIENCE

  • 2.

    WHAT IS PERSONAL DATA TREATMENT

  • 3.

    WHO CONTROLS YOUR DATA

  • 4.

    INFORMATION WE MAY GATHER

  • 5.

    THIRD-PARTY PERSONAL DATA GATHERING

  • 6.

    LEGAL BASE FOR PERSONAL DATA TREATMENT

  • 7.

    PERSONAL DATA SHARING

  • 8.

    RIGHTS OF PERSONAL DATA HOLDERS

  • 9.

    HOW WE STORE AND TREAT PERSONAL DATA

  • 10.

    INTERNATIONAL PERSONAL DATA TRANSFERENCE

  • 11.

    INFORMATION KEEPING TIME

  • 12.

    COMMUNICATION POLICY

  • 13.

    CONNNECTIONS (LINKS) TO OTHER WEBSITES

1. TARGET AUDIENCE

This Privacy Policy is applicable to everyone who:

Access our app

2. WHAT IS PERSONAL DATA TREATMENT

Personal data treatment (or data treatment) means any operation performed with the data:

For example:

Data gathering
Use
Access
Processing
Storage
Deleting
Communication
Transference

3. WHO CONTROLS YOUR DATA

When you access our app, Full Gauge takes on the role of controller of your personal data treatment, acting in accordance with the applicable law, and as described in this Policy.

4. INFORMATION WE MAY GATHER

Important: You are not obligated to grant us your information, however, without granting specific information when it is requested, some functions may not be accessed. In addition to the data you inform us, whenever you interact with our app, information will be gathered automatically. Such information is generally not identifiable; however, when it is combined with other data allowing your identification, it will be treated by Full Gauge as personal data. In the limits allowed by the applicable law, Full Gauge may treat the following personal data informed by you:

Please note that the personal data listed above will be gathered by Full Gauge and afterwards will be treated only when necessary to achieve the objectives contained herein.

We do not gather, store, or handle in any intentional manner excessive or unnecessary personal data for the objectives that promoted their gathering, as well as data considered as sensible (those related to your ethnic or racial origin, religious beliefs, public opinion, affiliation to any syndicate or any religious, philosophic, or political organization, health status or sexual orientation, as well as genetic data) and data from children and teenagers.

Based on the aforementioned, we request that you do not share such data with us. If we are aware that such data was collected inadvertently, they will be deleted from our registries.

5. THIRD-PARTY PERSONAL DATA GATHERING

The FG Finder app uses technologies provided by third-party platforms to enable its operation and enhance the user experience. In this context, some data may be directly gathered by these platforms, as described below:

Voiceflow Platform

The FG Finder Chatbot is developed and hosted on the Voiceflow platform, which may gather, automatically, the following data when using the app:

a) IP address and approximate location (city level): used for performance analysis, use metrics and continuing improvement of the app.

b) Navigation and Session data (Cookies): Technical and analytics cookies may be gathered by Voiceflow or the hosting platforms used (such as AWS and Google Cloud,) with the objective to monitor the service’s performance and stability.

The collection of such information is executed without directly identifying the user, since no personal data is gathered, and it is subject to Voiceflow’s privacy policy, which we recommend reading.

OpenAI Platform

The artificial intelligence feeding the chatbot uses OpenAI’s API, whose servers operate primarily on Microsoft Azure infrastructure, in the United States. OpenAI may access anonymous data from the interactions for performance and security goals of the language model. For more information, please access OpenAI’s Privacy Policy.

6. LEGAL BASE FOR PERSONAL DATA TREATMENT

The classification of the legal base for stored and processed data by Full Gauge listed in Section 4 happens through the analysis of the specific context in which we gathered them.

The data treated by Full Gauge tend to be collected only:

Art. 7º, I of Law Nº 13.709/18 With your consent
Art. 7º, II of Law Nº 13.709/18To comply with legal or regulatory obligations.
Art. 7º, V of Law Nº 13.709/18When it is necessary to execute a contract or preliminary procedures in relation to the contract.
Art. 7°, IX + Art. 10º of Law Nº 13.709/18When the personal data processing is in accordance with Full Gauge’s legitimate interests, always considering your interests in relation to data protection or liberties and essential rights. There is also a need to process your data to protect your interests, or third-party interests.

7. PERSONAL DATA SHARING

Whenever necessary to achieve the objectives described in Section 4, Full Gauge may share your personal data with the third parties listed below, aiming to the correct execution of the services offered, the storage safety of your personal data and a better experience with Full Gauge. Whenever it is performed, the data sharing will be done within the limits and purposes of our business, in accordance with the personal data treatment objectives and following the authorizations by the applicable law. Thus, your data may be shared with:

A company responsible for hosting the app.Enable sharing with the company responsible for hosting the app
DevelopersCompanies responsible for the development and maintenance of the app and Chatbot.
Security service suppliersWarranty of information security treated by Full Gauge.
Cloud ServersInformation cloud storage.
Public AuthoritiesIn response to claims, investigations, judicial orders and processes, when requested, as well as complying with legal, regulatory and fiscal obligations.

8. RIGHTS OF PERSONAL DATA HOLDERS

In the form and limits of the applicable law, you, in the title of personal data holder, may contact us to exercise your rights, to request:

Confirmation and accessIt allows you to confirm the existence of personal data treatment, and if so, request the access to a copy of the data.
Correction It allows you to request a data correction that may be incomplete, inexact or outdated.
Anonymity, blocking, or deleting.It allows you to request data anonymity (so they cannot be related to you in any way), data blocking (temporarily suspending our use,) or data deleting (so we delete them irreversibly.)
PortabilityIt allows that, through a written request, we deliver your personal data to other services or product suppliers, in a structured and interoperation manner.
Information about sharingIt allows you to know which public and private entities we have shared your personal data with.
Information about the possibility of non-consent.It allows you to have clear and complete information about the consequences of not granting your consent, meaning that you are free to deny consent, even when that limits our services offered to you.
Consent revokingIt allows you to revoke the granted consent, at any moment, without it affecting the legality of the treatment performed previously.
ObjectionAllows you to object to the processing of your personal data if you do not agree with such processing.

Your request may be made free of charge through the e-mail privacidade@fullgauge.com.br. We will review your request and respond as soon as possible, in accordance with the times and terms established in the applicable legislation. If it is not possible to fulfill your request immediately, we will indicate the factual and legal reasons that prevent us from doing so.

Full Gauge is not responsible for the accuracy, truthfulness, authenticity, completeness, and/or updating to the data offered by the Holder. It is an exclusive responsibility of the Holder to offer only accurate, truthful, authentic, complete and updated information.

You may interrupt the collection of Personal Data in the App by uninstalling the FG Finder App through using the standard uninstalling processes that may be available in your mobile device or through the store or mobile app network.

9. HOW WE STORE AND TREAT PERSONAL DATA

Full Gauge adopts security, technical, and administrative measures to keep all stored data safe through internal training, confidentiality clauses, and strict access control, and our collaborators have access only to strictly necessary data to answer specific requests, in accordance with the disposition in Section 4. Specifically in relation to the data gathered through our Website, it is stored, treated and protected in accordance with the best practices in hosting and processing.

Nevertheless, the Holder must be aware that no security system on the Internet is guaranteed against unauthorized intrusions, and Full Gauge’s commitment is limited to adopting recommended protective measures in accordance with the current state of art.

10. INTERNATIONAL PERSONAL DATA TRANSFERENCE

Full Gauge will carry out the international transfer of your data to other countries or international organizations only when strictly necessary to achieve the purpose that justified the processing of your personal data, prioritizing, whenever possible, storage on servers located in Brazil. When your personal data is transferred abroad by Full Gauge, we will take appropriate measures to warrant adequate protection of your personal data in accordance with the applicable data protection law requirements, including the appropriate data transference contract signing with third parties, when necessary.

11. INFORMATION KEEPING TIME

We store and keep your data: (i) for the period required by law; (ii) until the end of the personal data processing, as mentioned below; (iii) for the time necessary to preserve Full Gauge’s legitimate interest, as applicable; (iv) for the necessary time to safeguard Full Gauge’s regular exercise of rights in judicial, administrative, or arbitration proceedings. Thus, we will process your data, for example, during the applicable statute of limitations or as long as necessary to comply with a legal or regulatory obligation.

The end of the personal data treatment will happen in the following situations:

c) When the purpose for which the Holder’s personal data was collected has been fulfilled and/or the collected personal data is no longer necessary or relevant for achieving that purpose;

d) When the Holder withdraws their consent or is using their right to request the end of data treatment and the deletion of their personal data is requested; and

e) When there is a legal determination.

Observing the principle of necessity, some data sent through the Website may be excluded from our registries through routine registry maintenance. We are not obliged to store the personal data for an indefinite period of time, and we disclaim any liabilities arising from or related to the destruction of such personal data.

Upon the end of the personal data processing, and except in cases established by the applicable legislation or by this Privacy Policy, such data will be deleted from Full Gauge’s database. If immediate deletion is not possible, the data will be securely stored and isolated from any further processing until deletion becomes feasible.

12. COMMUNICATION POLICY

We strive to avoid sending unsolicited emails, limiting our communications with you to topics that are relevant or of specific interest to you.

Please be aware that many fraudulent initiatives try to use well-known brands to obtain personal information such as passwords and financial data. Full Gauge WILL NEVER REQUEST YOUR FINANCIAL DATA THROUGH EMAIL OR PHONE CALLS. IN CASE OF ANY SUSPICIOUS ACTIVITY, PLEASE SEND US YOUR DOUBTS OR ALERTS THROUGH E-MAIL AT privacidade@fullgauge.com.br.

13. CONNNECTIONS (LINKS) TO OTHER WEBSITES

Our Website may have links or frames of other sites. These links or frames seek to provide additional benefits to the contents and services offered to the User.

We clarify that the inclusion of these links in our Website does not mean that Full Gauge knows, agrees, or is responsible for the content in said links and frames. It is important to highlight that our objective is only to post links or frames from reputable and trustworthy companies, and Full Gauge is not responsible for the information, products and services obtained by the User in the referred sites, nor for the commercial practices and privacy policies adopted by those companies. Full Gauge may not be held responsible for eventual losses and damages, or profit shortcomings suffered as a result of using these resources.

Since the sites linked are not a part of our Website, we do not control, recommend or endorse these sites and their content, products, services, policies and their privacy policies; we do not have access to your personal data gathered and treated by them and their advertising policies, cookies and terms or use. Therefore, we recommend reading carefully these documents from third-party sites

Upon accessing our App and interacting with us, you agree and accept the terms herein.