PRIVACY POLICY

The following Privacy Policy (“Policy”) applies to the use and processing of personal information collected and used by the Ocean Lounge website (owned by BRIC Group) and embodies our commitment to the protection of your personal data.

Through this Policy you, the individual, have full control of how your personal information is processed. We will not use or process your personal information in any way that is incompatible with this Policy.

By using the Ocean Lounge website and submitting your personal information you consent to the collection, use and sharing of that information as set out in this policy.

THIS POLICY PROTECTS YOUR PRIVACY BY INFORMING YOU ABOUT:

• What kind of personal information we collect about you through the Ocean Lounge website;

• How we collect that information;

• Why we collect such information;

• What we do with that information;

• The choices and means by which you may limit its use and disclosure.

• If and how certain personal information you provide is used (where such use is unrelated to the uses for which you originally disclosed it); and

• If and how a third party uses certain personal information you provide (where such use is unrelated to the uses for which you originally disclosed it).

GIVING YOU FULL ASSURANCE THAT BRIC GROUP:

• Takes all reasonable precautions to protect personal information from loss, misuse, unauthorized access, disclosure, alteration or destruction;

• Implements policies and procedures to ensure that personal information is kept only for the purposes for which it has been gathered;

• Takes measures to ensure that we have accurately and completely recorded the personal information you have provided; and

• Gives you access to your personal information as well as procedures for correcting or changing that information where appropriate.

• Ensuring accountability to individuals who believe that BRIC Group has not complied with these privacy principles.

WHAT INFORMATION DO WE COLLECT DIRECTLY FROM YOU?

We collect personal information that you have directly provided us by registering on the Ocean Lounge website, via telephone calls, email or any other means you have communicated information directly to us. The type of information that we may collect directly from you may include your name, email address, telephone number, country location, postal address and date of birth etc.

WHAT INFORMATION DO WE COLLECT WHEN YOU VISIT THE OCEAN LOUNGE WEBSITE AND ONLINE ADS OR PROMOTIONS

When you visit the Ocean Lounge website and/or view our online advertisements and promotions, we use cookies and other similar technologies from third party advertisers that automatically collect information about you. Examples of the type of information that we may collect through these technologies may include information about your web browser, your device, IP address, your operating system, links you click on and open, web pages you view, emails you open from Ocean Lounge etc.

THIRD PARTY ADVERTISING AND COOKIES

We may place or recognize a unique “cookie” on your hard drive and may use information (this does not include your name, address, email address, or telephone number) about your visits to the Ocean Lounge website and other websites in order to measure advertising effectiveness and to enhance your viewing experience.

WHY WE COLLECT PERSONAL DATA

We collect information about you to provide you with products, offers and services that are relevant to your interests, and to show advertisements, promotions or other content that may be of interest to you.

The Ocean Lounge beach club offers leisure serves that requires we understand you, our customer, and your needs.

We do this primarily through the information you provide to us when signing up for or using one or more of our services. The information you may provide ranges from basic contact details to payment and interest information.

After you have signed up for our services, we may contact you regarding your enquiry, questions you may have about services provided by us, or any other matter relating to those services. These communications are essential to our relationship with you and to our ability to provide you with quality services that answer your needs.

So that we can monitor our operational and quality assurance purposes, we take note of whether and how you use the information and services that we provide. Ways of doing this include recording site traffic patterns and maintaining log files of users’ access to site files.

THIRD PARTY ADVERTISING AND COOKIES

We use information about you to monitor and improve our business operations, as well as to ensure we: (a) account to you properly, (b) administer your account in accordance with your agreements with us, and (c) perform the services you have requested correctly.

We also use the information we have collected to monitor and improve our internal operations, as well as to improve the experience of users on the Ocean Lounge website. For example, we may correlate website traffic information with data about individual users. This data helps us to find out how much our customers use certain sectors of the website, which, in turn, allows us to improve it to fit the needs of as many of our customers as possible. We may also break down overall usage statistics according to customers’ domain names, browser types, and MIME types by reading this information from the browser string (information contained in every user’s browser).

Another example of how we use information to enhance the experience of users on the Ocean Lounge website is our reliance on cookie files. We use these to make it easier for users to access our site or services. A cookie file is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited. However, the only personal information a cookie can contain is information you supply yourself. A cookie cannot read data from your hard disk or read cookie files created by other sites. We use cookies to track user traffic patterns (as described above) when you register for Ocean Lounge services. When you register, we may use a cookie to store a unique, random user ID. We use this ID to identify you anonymously in our database and to track the pages you visit on our site.

If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. You can refuse cookies by turning them off in your browser. Please note, however, that the Ocean Lounge website may require a cookie for access.

Third-party advertisers and other marketing service providers may also collect your personal data. They include Google – Analytics and Adwords; Social media platforms such as Facebook, Instagram, Twitter, LinkedIn, Google+; Yahoo; lead capture forms such as zapier.com; and email marketing providers such as Mailchimp and Zoho.

WHAT DO WE DO WITH YOUR INFORMATION?

We are fully committed to making sure your information is secure and have procedures to safeguard your personal data. We process and store your information in-house within the BRIC Group company offices on secure servers. Your data is normally stored in the office closest to your location, governed by the information you have provided us.

PERSONAL DATA RETENTION

We keep any personal data held by us for marketing and service update notifications until you notify us that you no longer wish to receive this information. We will keep personal information for as long as is necessary to fulfil the purposes for which we collected it for, as outlined in this Privacy Statement, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law.

WE DO NOT SHARE YOUR INFORMATION

We do not share your personal information with any third-party companies. We do not provide any third-party providers with access to your data, unless specifically required by law.

OUR ACCOUNTABILITY TO YOU

BRIC Group fully respects and values the security and privacy of its contacts. BRIC Group follows strict security procedures in the storage and disclosure of personal information in order to prevent unauthorized access. Personal Data is held on our contacts and administration database for two reasons: because of work we have undertaken or are currently engaged in; or because we believe that clients may be interested in receiving material from us about our business and services. For these purposes, we hold client contact details and the history of our client relationship. These records allow us to manage our client relationships effectively and target items of interest so that you do not receive unwanted material. If you no longer wish to receive email or other communications from us you can request this at any time by email to privacy@bric-investment.com or by clicking on the unsubscribe links at the bottom of all of our email communications.

As well as the privacy protections that we provide as a company, our employees are independently responsible for ensuring compliance with this Privacy Policy, as described below.

EMPLOYEE ACCOUNTABILITY

We only authorize access and handling of personal information to those BRIC Group employees that have a legitimate business purpose for this purpose. The unauthorized access or use of such information by a BRIC Group employee is prohibited and constitutes grounds for disciplinary action. In addition, our information management systems are configured so that they block or inhibit employees from accessing information they are not authorized to access.

YOUR PERSONAL DATA AND YOUR RIGHTS

Under data protection laws you have rights regarding your personal data.

If you believe that any personal data we hold on you is incorrect or incomplete, you have the right to request to see this information, change it or request its deletion. To do this, please contact us at privacy@bric-investment.com

If you wish to complain about how we have handled your personal data, please get in touch with us at privacy@bric-investment.com. We will investigate your complaint and work with you to solve it.

NOTIFICATION OF CHANGES

We will post any changes to this Privacy Policy 30 days before their effective date. This ensures that you always know what information we collect, how we use it, and under what circumstances, if any, we disclose it. It is your responsibility to check the Ocean Lounge website periodically for changes to this Privacy Policy. By continuing using the service you agree to any such changes. You may opt out of any published change to our collection, use or disclosure of your personal information by sending an e-mail to privacy@bric-investment.com. If you have any questions regarding this Privacy Policy, please contact privacy@bric-investment.com

DEFINITIONS

In the above terms and conditions:

1. “This website” and “Ocean Lounge website” means our presence on the Internet;

2. “our”, “we” and “us” refers to BRIC Group and, where applicable, its officers, employees and authorized agents; and

3. “you” and “your” refer to any individual, company or business (whether registered by us as an investor or not) to whom we provide services by means, including but not limited to, telephone, face-to-face contact, postal correspondence, electronic mail or via our website www.thecoral.com.br, referred to as the website.

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