LGPD Compliance & Data Privacy

1. Introduction

Aevum Zenth Conglomerate ("the Company", "we", "us") is committed to protecting the personal data and privacy of individuals residing in Brazil in full accordance with the Lei Geral de Proteção de Dados Pessoais (LGPD), Lei nº 13.709/2018, and the regulations issued by the Autoridade Nacional de Proteção de Dados (ANPD).

As a multidivisional enterprise operating across energy, technology, aerospace, healthcare, finance, and 400+ other sectors, Aevum Zenth processes vast amounts of personal data globally. This policy outlines how we collect, use, store, and protect personal data specifically within the jurisdiction of Brazil.

Data Controller

The Data Controller for operations in Brazil is:

2. Legal Bases for Processing

We process personal data only when one or more of the following legal bases under Article 7 of the LGPD apply:

• Consent: Where you have explicitly provided consent for a specific purpose.
• Contractual Necessity: To fulfill contracts with you or take preliminary steps at your request.
• Legal Obligation: Compliance with tax, labor, financial, or regulatory laws in Brazil.
• Legitimate Interest: For purposes that do not override your fundamental rights (e.g., fraud prevention, network security).
• Protection of Vital Interests: To protect your life or physical integrity, particularly in our healthcare and energy divisions.
• Exercise of Rights: To participate in judicial, administrative, or arbitration proceedings.

For sensitive personal data (e.g., health information, biometric data), we rely exclusively on bases stipulated in Article 11 of the LGPD.

3. Rights of the Data Subject

Under Article 18 of the LGPD, individuals have the right to request the following from Aevum Zenth:

• Confirmation of Processing: Verify if we process your personal data.
• Access: Obtain a copy of your data and details of how it is used.
• Correction: Rectify incomplete, inaccurate, or outdated data.
• Anonymization, Blocking, or Deletion: Request deletion of unnecessary or excessive data, or data processed in violation of the LGPD.
• Portability: Request transfer of your data to another service provider upon request, subject to secrecy and industrial property.
• Review of Decisions: Request review of decisions made solely by automated processing that affect your interests.
• Withdrawal of Consent: Withdraw previously given consent at any time, without affecting the lawfulness of prior processing.

4. Data Sharing & International Transfers

As a global conglomerate, Aevum Zenth may share personal data across subsidiaries and with third-party partners. In Brazil, we ensure:

• Internal Sharing: Data may be shared with other Aevum Zenth entities solely for legitimate business purposes, subject to this policy.
• Third-Party Processors: We engage only with vendors who provide adequate data protection guarantees, governed by Data Processing Agreements (DPAs).
• International Transfers: Transfers of data from Brazil to Aevum Zenth headquarters in Neo Geneva or other jurisdictions are conducted in compliance with Articles 33-36 of the LGPD, ensuring the receiving entity offers an adequate level of data protection or using contractual clauses, certifications, or standards issued by the ANPD.

5. Security Measures

Aevum Zenth implements technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure, as required by Article 46 of the LGPD:

• Encryption: AES-256 encryption for data at rest; TLS 1.3 for data in transit.
• Access Control: Role-based access, multi-factor authentication, and least-privilege principles.
• Monitoring: 24/7 security operations center (SOC) monitoring across all Brazilian and global assets.
• Data Minimization: Retention periods strictly defined per data category; automated deletion protocols.
• Incident Response: In the event of a data breach, we notify the ANPD and affected individuals within the legally mandated timeframe.

6. Sensitive Data & Health Sciences Division

Our Zenth Health Sciences division processes sensitive personal data including health records, genetic data, and biometric identifiers. Such processing is strictly governed by:

• Explicit Consent: Obtained separately for sensitive data processing.
• Purpose Limitation: Used solely for medical treatment, research, or public health as disclosed.
• Anonymization: Where possible, data is anonymized for research and AI training.
• Special Safeguards: Additional encryption, audit trails, and restricted access protocols apply to healthcare data.

Individuals may withdraw consent for sensitive data processing at any time, though this may affect service continuity in healthcare contexts.

7. Cookies & Tracking Technologies

Our Brazilian websites and applications use cookies and similar technologies to ensure functionality, analyze usage, and personalize content. We categorize cookies as:

• Strictly Necessary: Required for website operation (no consent needed).
• Analytics: Help us understand visitor interaction (aggregated, anonymized).
• Functional: Remember preferences (e.g., language, region).
• Marketing: Used for targeted advertising (requires explicit consent under LGPD).

Manage your preferences via our Cookie Consent Manager or browser settings.

8. Contact the Data Protection Officer (DPO)

Aevum Zenth has appointed a Data Protection Officer responsible for overseeing compliance with the LGPD and addressing privacy concerns. You may contact the DPO via:

You also have the right to lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) if you believe your rights have been violated.

9. Policy Updates

This policy may be updated periodically to reflect changes in the LGPD, ANPD regulations, or Aevum Zenth's data processing activities. Material changes will be communicated via our website and, where applicable, by direct notice.

Version: 3.2.0
Last Revised: December 10, 2026
Effective Date: December 10, 2026

© 2026 Aevum Zenth Conglomerate. All rights reserved. This document is provided for informational purposes and does not constitute legal advice. In the event of any discrepancy between this policy and the LGPD or ANPD regulations, the law prevails.