Policy

ClOUD2B PRIVACY POLICY

To improve our services and the browsing experience continuously, we collect important information of our customers.

Registration information: many of our services require the customer to have a register with an user account. When you register, we collect your name, e-mail, delivery address and billing, contact phone number, ID number, date of birth, gender, product preferences, favorite football team, sports practices, among other items. The customer can choose not to provide some information, but it is likely that the browsing experience does not count on all the features offered.

Sending e-mail: in order to improve the relevance of our communication, we receive a notification when our emails are opened, if this feature is available on the client computer. 
Other sources may collect specific information from mobile devices accessing CLOUD2B. Eventually we receive customer information from other sources, as partners of entries, to sum- them to us.

SHARING INFORMATION

Our customer´s information security and confidentiality are very important to our business. However, the viability of certain services by our partners only occurs.
sharing some of this information, what we do with responsibility and following strict parameters. Below we cite cases where the information sharing is necessary:

Suppliers: suppliers and third work with CLOUD2B to improve our business. Examples of logistic service applications, sending e-mails, database analysis, creation of marketing actions and processing of transactions by credit card. Many of these services are only possible with our customer´s  information share, however, it is important to stress that its use is authorized only for the contracted purposes.

New businesses: Our continued business  development, procurement processes and merging of companies, subsidiaries and other businesses may occur. During This transfer of business, the customer´s information is also transferred, but still, the privacy policy will be maintained, and the information will be kept within CLOUD2B environment.
Judicial Requisition: CLOUD2B can share personal data in case of judicial request.
With the customer’s authorization: in other cases that there is the need of sharing information, we will send a notification to the customer requesting their approval
Any additional request may be made to our employees through the telephone numbers below. 

CONDUCT CODE
Message from Gilberto Vilaça

Dear Employees, Customers and Suppliers.

At a time when we are subjected daily to news of unethical practices in the world and especially in Brazil, we are called to reflect on our behavior and to that of those around us.
Some time ago I heard the phrase “only have friends who are ethical”. I believe and understand that this should be a motto in our lives and especially in the environment in which we spend most of our t
ime working.

Ethics should not be written and published as it should be part of our consciousness and guide our lives. Many, if not all the code words that we present should not be explained by me, but I understand that we should have a point of reference and this is the purpose of the document that we are making available attached and is published on our website. I urge you to read and watch over it in our day to day.

We have always been opened to suggestions and would like also to expand this information about any behaviors that are inconsistent with the ideals of this code, whether explicit or implicit;  therefore we ask you to report any questionable situation by the email address  etica@cloud2b.com.br which was created and comes directly to me or put it anonymously in our suggestion box so that we can investigate and take appropriate action in a transparent way and with respect.

I appreciate the commitment of all and strengthen our commitment to joy, transparency and ethics because for me all go together.

Gilberto F. Vilaça

CEO

PART 1: CODE OF CONDUCT

The Code of Conduct rules are to guide and regulate the conduct of a group of persons according to their principles.

In some companies the code of conduct is known as Code of Ethics (honor or good practices). In addition to be also a realization principle instrument it is also the vision and mission of the company. It serves to guide the actions of employees and their social position, establish ethical principles and rules of conduct that should guide the internal and external relations of all employees, regardless of role and responsibility.
The code of conduct needs to reflect the reality of the company. Therefore, it must always change over the time.

The Code of Conduct is aligned with different values, such as:

Ethic;
Humility;
Confidence;
Transparency;
Responsibility;
Commitment.

HOW TO RAISE QUESTIONS AND CONCERNS REPORT 

Because it is essential to raise a question or express a concern?
No matter if you have internal problems in your day to day or even doubts. You have full freedom to talk and express them. Whenever you do it  we have availability to understand the needs. No matter the size of your problem.
Who should I contact?
If you have any questions or would like to express a concern, look for one of these resources:

 Your manager;
Human resources department;
Urn suggestions.

COMPLAINT IN GOOD FAITH AND NOT AS RETALIATION
Act in good faith means that all reports of possible violations of this Code, company law or policies are made of sincere and honest way. In other words, no matter if your complaint is confirmed as true, but you must do it with the best of the intentions.

On the other hand, the company is committed to non-retaliation. To operate efficiently it is vital that all company employees maintain trust and respect to each other. Retaliation against anyone who has a complaint or participated in an investigation will not be tolerated.

INVESTIGATIONS AND DISCIPLINE
Reports will be investigated in a respectful and professional way as quickly and confidentially as possible. If asked to participate in an investigation you will cooperate fully.
Violations of this Code and other policies are taken seriously. There are consequences for violations of this Code or other company policies, which may include up to dismissal. 

 TRANSPARENCY
Working with family members and friends

It is natural to want the best for your family, but when family members interact in the workplace it is not hard to give the impression of favoritism. The proactive approach of these situations can prevent problems.

SECOND JOB
You should direct all your professional energy to your  work in Cloud2b. All parallel jobs or personal business activities related to income must be reported to the Law Department. Cloud2b encourages the participation in non-profit activities, consistent with our commitment to provide assistance to our communities.

FINANCIAL INTERESTS
Cloud2 can create a divided loyalty, or at least the appearance of one. This also applies to financial interest held by a member of your household or immediate relative. Financial interests that represent a possible conflict of interest require the approval of your manager and of the Chief Legal Officer or General Counsel. In addition, the Board adopted guidelines related to potential conflicts of interest that may arise from investments by official.

Representatives of the Company and private companies. Such investments generally require a pre
vious approval of the Legal Department.

CORPORATE OPPORTUNITIES

Anti-Corruption, Bribery and Commissions

Never use bribery, facilitation payments, kickbacks or corrupt practices. Bribery is to offer or give anything of value in order to improperly influence the recipient’s actions. Bribery is illegal in any jurisdiction in which Cloud2b does business.

A facilitation payment is a small tip or payment made to a public official to expedite a routine government action, such as issuing permits or provision of public services. This is illegal in most jurisdictions and is not allowed according to the Global Anti-Corruption Policy.

A commission is the return of a sum paid (or due) as a reward for promotion of commercial arrangements. To accept or receive fees violates this Code.

Bribery is illegal in Brazil and in most countries and the consequences are severe, including prison sentences.


RELATIONSHIP WITH CIVIL SERVANTS

A public server can be a local government official or federal, a candidate for political office, a political party representative, a member of the royal family or an
employee of a government-controlled company.

THIRD
The company can negotiate with third parties, such as agents, consultants, suppliers, dealers or distributors only after going through a legal process of due diligence. Please contact the Global Ethics & Integrity Team for more information about the due diligence process.

FINANCIAL INTEGRITY AND ACCOUNTING RECORDS
Books, records, accounts and financial statements of Cloud2b should be kept with the appropriate data to reflect appropriately  the Company’s business activities. This is a requirement of both laws as the company´s system of internal controls. Moreover, public company financial reports should contain full releases, honest, accurate, timely and understandable, which help to ensure that investors have access to accurate information about the company, as required by law. The financial groups, accounting and legal company are responsible to elaborate procedures to ensure internal and appropriate disclosure controls and should all collaborate with these procedures. For additional information about your specific responsibilities to ensure the integrity of books, records, accounts and financial statements of the Company refer to the Anti-Fraud Policy.

DOCUMENT MANAGEMENT AND RETENTION
When deciding to save documents, archive or dispose always consult the Record of Management Policy, the Records of the Management Procedures Manual and the Records of Management Program for details on the various documents retention time. This policy applies to all types of documents, whether paper or electronic.

AUDITS AND EXTERNAL INVESTIGATIONS
From time to time you may have contact with internal or external auditors, lawyers or researchers who will ask you for information. You must provide to these people accurate and timely  information. Never induce error or attempt to influence any investigation, audit or query received.

UNDERSTANDING TRANSACTIONS INSIDER TRADING
Make a transaction of shares being in possession of material information that are not in the public domain is strictly prohibited, whether this information is about Cloud2b or another company. It is illegal to make a transaction of insider ownership of shares .

DEALING WITH IMPORT AND EXPORT 
When working with international clients, keep in mind that there may be some mandatory steps before sending your products or services abroad.

CONFIDENCE
Using Technology and Other Tools
Cloud2b offers to its employees a wide range of technologies and other tools that make it possible to efficiently carry out their work, and these tools should be used in a balanced way.
Undisclosed Information Protection
Company Information
Many details of how the company operates need to be kept confidential to assure Cloud2b to remain competitive and successful.


INTELLECTUAL PROPERTY
The success of depends of good ideas. Therefore, it is important to protect these ideas through legal tools such as copyright and patents. Collectively, all intangible properties are called intellectual property (IP) and are inclusive of all copyrights, patents, trademarks, trade secrets, design rights, logos and product brands. Remember that Cloud2b own the rights to all PIs created with firm equipment during working hours at the company.
Third-party information and previous employers
In some cases, employees may be responsible for protecting information belonging to other persons or companies. For more information about protection of third party information, see the Company’s Trust website.


PERSONAL INFORMATION ABOUT EMPLOYEES
Any information about Cloud2b should be confidential.
If You See Something, Say Something
You are the security of all, if you witness any action,  abuse, neglect or act prejudicial to Cloud2b or our employees, you should immediately report to your manager to ensure the integrity and quality of the environment created by us. This will Protect our employees and our safe image from possible harmful acts.


SAFETY
The safety of buildings and property  of Cloud2b is a responsibility shared by all employees. The employees shall have responsibility to be absent from their place of work, leaving the equipment switched off (Notebook, monitor, keyboard, television, air conditioning, etc.).

COMPETING IN THE CORRECT WAY
All employees must comply with competition laws throughout the world, which ensures a plot of level playing for all the companies.

FAIR DEALING
Cloud2b is committed to act with honesty and loyalty to all of its customers, suppliers and other business partners. Never misrepresent the quality, features or availability of the Company’s products and never do anything illegal or unethical for business. For more information about the Company’s commitment to negotiate fairly and their specific responsibilities in the prevention of fraud, see the anti-fraud policy.

RESPECT
Diversity and Non-Discrimination
Opinions of diversity, training and culture make Cloud2b a more creative company.
Personal Worthiness
A solid working team requires all employees to treat each other with dignity and respect.
Safety and Health at Work
Cloud2b is committed to provide the safest possible work environment. Our programs focus on security awareness in general and incident response.
Follow all safety rules and report unsafe situations. You can find more information here in the Health and Safety Management System of the company.


COMMUNICATION
External communications
Cloud2b has an open and transparent culture in which the company communicates with the responsibly of public Social media
Remember, Internet is a public place, so drive up properly.


SPEECHES
If you are invited to speak or make a presentation at an event, see the Public Relations team before accepting and ask them to review and approve all material presentation. Before accepting free travel or accommodation, check whether the proposed gift is within the rules of present or consult the Law Department for approval.

POLITICAL ACTIVITIES
You are encouraged to engage in political activities of your choice. Make it clear in such activities that your participation is a personal choice, not endorsed by the company. Cloud2b will not reimburse you for personal political contributions