Privacy and Cookies Policy

1. Who this applies to

This policy applies to the Lions Soluções website, to our support channels (0800 line, WhatsApp, email and the site form) and to the operation of our systems, including Sentinel, the gate and access control platform. Lions Soluções, based in Uberaba, Minas Gerais, Brazil, provides technology, electronic security and telecommunications services to condominiums, businesses and public agencies.

2. Data collection and purposes

We collect only the data strictly necessary to provide our technology, electronic security, telecommunications, billing and technical support services and to operate the Sentinel access control system:

• Support channels (site, 0800 line and WhatsApp / virtual assistant Lia): name, phone, email, condominium or company and information reported during the service. This data is used exclusively to record, triage, follow up and resolve technical tickets and commercial or financial requests.
• Site contact form: name, company or condominium, phone, email, customer type, city, interests and message, plus the date and time of submission, the language and the page of origin. They are used to answer your contact and prepare proposals.
• Access control operation (Sentinel system and app): registration data of residents, visitors and service providers, entry and exit records, vehicle license plates (plate reading, LPR), package records and biometric data (facial recognition).

3. Legal bases

We process personal data only when there is a legal basis under the LGPD, depending on the situation:

• Consent (Art. 7, I), for example, when submitting the contact form on the site or allowing the optional features in the cookie notice.
• Performance of a contract or preliminary procedures (Art. 7, V), to provide the contracted services and prepare proposals.
• Compliance with a legal or regulatory obligation (Art. 7, II).
• Legitimate interest (Art. 7, IX), in a proportionate manner, for security, fraud prevention and service improvement.
• Biometric data (sensitive personal data): processed in the cases provided for in Art. 11 of the LGPD, in particular to guarantee fraud prevention and the data subject's security in identification and authentication processes, or with specific and highlighted consent, as defined by the condominium or contracting customer.

4. Role of the processing agents (condominiums and customers)

Within the operation of the access control and monitoring software:

• The Condominium / Contracting Customer acts as Controller of the personal data entered into the platform, determining the access rules and local authorizations.
• Lions Soluções acts as Processor, processing and storing the data exclusively for contract performance and system operation, following the settings determined by the end customer.
• Sensitive data, such as facial biometrics, is processed exclusively for the purpose of secure authentication and access control on the premises of the contracting customer, and any other use is prohibited.

5. Technical support rules and tacit acceptance

When you contact our technical support via WhatsApp, phone (0800 or landline) or the service portal:

1. The user agrees that their contact data and message history are recorded in our ticket management system, for follow-up by protocol number.
2. Ticket validation and closure (tacit acceptance): after the service, a message is sent automatically to the requester to confirm acceptance of the solution. If there is no response within 2 (two) hours, the solution will be considered validated and tacitly accepted, and the ticket will be closed. Open tickets that stop receiving a response from the requester may also be closed.

6. Data sharing

Lions Soluções does not sell, rent or share personal data collected in its systems or support channels with third parties for advertising purposes. Sharing occurs only:

• With the condominium or contracting company to which the data subject is linked;
• To comply with a legal or regulatory obligation or a court order;
• With technology infrastructure providers essential to the secure operation of the system, bound by strict confidentiality agreements.

Tools we use to operate: contacts sent through the site form are received in a Google spreadsheet (Google Sheets and Google Apps Script), with access restricted to our team, and the site is hosted on our own server. Providers may store data on servers located outside Brazil; in such cases, the international transfer takes place with the safeguards provided for in Art. 33 of the LGPD.

7. Storage and retention

We keep data for as long as necessary to fulfil the purposes described in this policy, the contract and legal obligations. Form contacts that do not lead to a commercial relationship are deleted or anonymized within a reasonable time. Sentinel system data follows the rules defined by the condominium or customer (Controller) and by the contract. Once the purpose has ended, data is deleted or anonymized, unless retention is required by law (Art. 16 of the LGPD).

8. Data security and governance

We adopt technical and organizational measures to protect personal data against unauthorized access, loss, alteration or accidental or unlawful destruction, including:

• Data traffic protected by SSL/TLS encryption;
• Database encryption and pseudonymization and anonymization techniques where applicable;
• Strict logical and physical access control to local and cloud servers.

In the event of a security incident that may cause significant risk or harm to data subjects, we will notify the affected data subjects, the Controller and the Brazilian National Data Protection Authority (ANPD), pursuant to Art. 48 of the LGPD.

9. Cookies and local storage

Cookies and similar technologies are small files or records stored in your browser. This site does not use advertising, tracking, analytics or social media cookies. We also do not load fonts or other third-party resources: the site font is served by us.

How we ask for your consent. On your first visit, we show a notice with the options Accept all, Reject optional and Customize, all with the same prominence. Essential items always work; optional ones are only turned on if you allow them. You can change your choice at any time using the link Cookie preferences, in the footer of every page.

Categories:

• Essential: needed for the site to work and to remember your choices, such as the theme (light, dark or automatic) and your decision about cookies. Always on.
• Chat and calls (optional): will let you talk to our team by chat and call from your browser. The chat runs on Lions own servers and may store a conversation identifier in your browser to resume the service. For browser calls, the browser will ask for your permission to use the microphone.
• Notifications (optional): will let you receive notices in your browser, even with the site closed. Besides your choice in the notice, the browser will ask for its own permission. To stop receiving them, simply revoke the permission in your browser settings or untick the option in Cookie preferences.

The optional features are not yet active on this site. When they are turned on, they will work only with your consent, and this policy will be updated with the data processed and the retention periods of each one.

The site stores only the following items in your browser's local storage:

Form submission. When you submit the form, your browser communicates with the Google services that receive the contact. These services may process technical data, such as the IP address, in accordance with Google's privacy policy.

How to manage. You can delete these records at any time in your browser settings (clear site data). This does not prevent you from using the site: it only makes it forget your theme and show the notice again.

New tools. If we start using cookies that are not strictly necessary (for example, analytics), we will ask for your consent first, with the option to refuse, and we will update this section.

10. Data subject rights (Art. 18 of the LGPD)

The personal data subject may, at any time and upon request, ask for:

• Confirmation that processing exists and access to their data;
• Correction of incomplete, inaccurate or outdated data;
• Anonymization, blocking or deletion of unnecessary or excessive data or data processed in violation of the law;
• Portability of the data to another service or product provider, upon express request;
• Deletion of data processed on the basis of consent;
• Information about data sharing;
• Information about the possibility of not giving consent and about the consequences of refusal;
• Revocation of consent, at any time;
• Review of decisions made solely on the basis of automated data processing, where applicable.

Note: for data managed directly by your condominium's administration (such as resident and vehicle records and facial biometrics), the request should be addressed primarily to the condominium administration or manager (Controller).

We will handle requests within the deadlines set by the LGPD. You may also file a complaint with the Brazilian National Data Protection Authority (ANPD).

11. Children and adolescents

The processing of data of children and adolescents (for example, minor residents registered in access control) is carried out in the best interest of the minor and with the specific consent of at least one parent or legal guardian, as defined by the condominium (Controller). The site is not intended for people under 18, and we do not intentionally collect their data through the form.

12. Changes to this policy

We may update this policy to reflect changes in our services or in the law. The date of the last update appears at the top of this page, and relevant changes will be highlighted.

13. Contact channel and Data Protection Officer (DPO)

For questions, privacy-related requests or to exercise your rights under the LGPD, contact us through our official channels:

• Email: contato@lionsse.com.br / suporte@lionsse.com.br
• Phone / WhatsApp: 0800 322 3758 | (34) 3322-3758
• Address: Rua Conquista, no. 21 – São Benedito district, Uberaba/MG, Brazil – CEP 38020-240
• Jurisdiction: District of Uberaba/MG, Brazil.