CCPA NOTICE AT COLLECTION

BASIC ("we," "us," or "our") collects personal information about California consumers. This notice describes the categories of personal information we collect, the purposes for which we use it, and your rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

A. Identifiers

• Real name, alias, postal address, unique personal identifier
• Online identifier, Internet Protocol (IP) address, email address
• Account name or other similar identifiers

B. Personal Information Categories (Cal. Civ. Code § 1798.80(e))

• Name, signature, physical characteristics or description
• Address, telephone number
• Bank account number, credit card number, debit card number
• Any other financial information

C. Protected Classification Characteristics Under California or Federal Law

• Age (40 years or older), race, color, ancestry, national origin
• Citizenship, religion or creed, marital status, medical condition
• Physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions)
• Sexual orientation, veteran or military status

D. Commercial Information

• Records of personal property, products or services purchased, obtained, or considered
• Other purchasing or consuming histories or tendencies
• Shopping preferences and fitness/casual fashion style profiles

E. Internet or Other Similar Network Activity

• Browsing history, search history on our website
• Information on consumer's interaction with our website, application, or advertisement
• Click patterns, page views, and time spent on pages

F. Geolocation Data

• Physical location or movements
• Approximate location derived from IP address

G. Sensory Data

• Audio, electronic, visual, or similar information
• Photographs or video recordings (when visiting our retail locations)

H. Professional or Employment-Related Information

• Current or past job history or performance evaluations (when applicable)

I. Inferences Drawn from Other Personal Information

• Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, and abilities
• Fashion preferences, style predictions, and purchasing patterns
• Customer lifetime value predictions

J. Sensitive Personal Information

We may collect the following categories of sensitive personal information:

• Account log-in credentials, financial account information, debit card or credit card number in combination with required security or access code
• Precise geolocation
• Contents of mail, email, and text messages (when you contact us)

SOURCES OF PERSONAL INFORMATION

We collect personal information from the following sources:

Directly from you when you:

• Create an account on our website
• Make purchases or place orders
• Contact customer service
• Sign up for our newsletter or promotional emails
• Participate in surveys, contests, or sweepstakes
• Leave product reviews or feedback

Automatically as you navigate through our site through:

• Cookies, web beacons, and similar tracking technologies
• Log files and server data
• Analytics services

From third parties such as:

• Social media platforms (Facebook, Instagram, Pinterest, TikTok)
• Data brokers and marketing partners
• Payment processors and fraud prevention services
• Shipping and logistics partners (Correios, private couriers)
• Customer data platforms and analytics providers

From public records databases

• Publicly available information and government records

From our business partners and affiliates

• Co-marketing partners
• Affiliate marketing networks
• Fashion industry partners

BUSINESS OR COMMERCIAL PURPOSES FOR COLLECTION AND USE

We collect and use personal information for the following business or commercial purposes:

Operational Purposes

• Fulfilling orders and transactions: Processing purchases, payments, shipping, returns, and exchanges
• Customer service: Responding to inquiries, providing support, and handling complaints
• Account management: Creating and maintaining your account, order history, and preferences
• Communication: Sending transactional emails, order confirmations, and shipping notifications

Marketing and Personalization

• Marketing communications: Sending promotional emails, newsletters, and special offers (with your consent)
• Personalization: Customizing your shopping experience and recommending products based on your preferences
• Advertising: Delivering targeted advertisements on our website and third-party platforms
• Social media engagement: Interacting with you on social media and sharing user-generated content

Analytics and Improvement

• Analytics: Understanding how customers use our website and products
• Internal research: Conducting research for technological development and demonstration
• Quality improvement: Improving our products, services, and website functionality
• A/B testing: Testing new features and designs

Security and Compliance

• Security: Detecting, preventing, and responding to security incidents, fraud, and illegal activity
• Debugging: Identifying and repairing errors that impair existing intended functionality
• Legal compliance: Complying with laws, regulations, and legal processes
• Auditing: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions

Other Purposes

• Short-term, transient use: Including non-personalized advertising shown as part of your current interaction with us
• Business transactions: Facilitating mergers, acquisitions, or sale of assets
• Verification: Verifying customer information and maintaining data quality

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

We may share your personal information with the following categories of third parties:

Service Providers and Contractors

• Payment processors (payment gateway providers)
• Shipping and fulfillment companies (Correios, private courier services)
• Cloud storage and hosting providers
• Email service providers
• Customer service platforms
• Website analytics providers (Google Analytics)
• Marketing automation tools

Business Partners

• Co-marketing partners for joint promotional efforts
• Affiliate marketing networks
• Social media platforms for advertising (Meta, Google, Pinterest, TikTok)
• Influencers and brand ambassadors

Affiliates and Subsidiaries

• Parent companies, subsidiaries, and affiliates within our corporate family

Government Entities and Legal Parties

• Law enforcement, government agencies, and regulatory authorities when required by law
• Courts and legal counsel in connection with legal proceedings

Business Transaction Parties

• Third parties in connection with mergers, acquisitions, bankruptcy, or sale of assets

Advertising Networks

• Advertising networks and advertising partners
• Data analytics providers
• Social media companies

SALE AND SHARING OF PERSONAL INFORMATION

Sale of Personal Information

We do not sell personal information in the traditional sense of exchanging data for money. However, under the CCPA's broad definition, certain data sharing activities may be considered a "sale."

We may share the following categories of personal information in ways that could be considered a "sale" under CCPA:

• Identifiers (such as cookies and device identifiers)
• Internet or network activity (browsing and interaction data)
• Geolocation data (approximate location)
• Inferences (preferences and characteristics)

These are shared with:

• Advertising networks
• Social media platforms
• Data analytics providers

You have the right to opt-out of the sale of your personal information. See "How to Exercise Your Rights" below.

Sharing for Cross-Context Behavioral Advertising

We share personal information for cross-context behavioral advertising (targeted advertising). The categories shared are similar to those listed above under "sale."

You have the right to opt-out of sharing for targeted advertising purposes.

RETENTION PERIOD

We retain each category of personal information for as long as necessary to fulfill the purposes described in this notice, typically:

• Account information: Until you request deletion or 3 years after last activity
• Transaction records: 7 years for tax and legal compliance
• Marketing data: Until you unsubscribe or 2 years after last engagement
• Analytics data: 26 months
• Security logs: 1-2 years

YOUR CALIFORNIA PRIVACY RIGHTS UNDER CCPA/CPRA

California residents have the following rights:

1. RIGHT TO KNOW

You have the right to request that we disclose:

• The categories of personal information we collected about you
• The categories of sources from which we collected personal information
• Our business or commercial purpose for collecting or selling personal information
• The categories of third parties with whom we share personal information
• The specific pieces of personal information we collected about you

2. RIGHT TO DELETE

You have the right to request that we delete any personal information about you that we collected from you, subject to certain exceptions such as:

• Completing the transaction for which the information was collected
• Detecting security incidents
• Complying with legal obligations
• Other uses compatible with the context in which you provided the information

3. RIGHT TO CORRECT

You have the right to request that we correct inaccurate personal information that we maintain about you.

4. RIGHT TO OPT-OUT OF SALE/SHARING

You have the right to opt-out of:

• The sale of your personal information
• The sharing of your personal information for cross-context behavioral advertising (targeted ads)

To opt-out, click here: [Do Not Sell or Share My Personal Information Link]

Or visit: [BASIC website]/ccpa-opt-out

5. RIGHT TO LIMIT USE OF SENSITIVE PERSONAL INFORMATION

You have the right to limit our use and disclosure of your sensitive personal information to only what is necessary to perform services or provide goods reasonably expected by an average consumer.

6. RIGHT TO NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights, including by:

• Denying you goods or services
• Charging different prices or rates for goods or services
• Providing a different level or quality of goods or services
• Suggesting that you will receive a different price or rate or different level or quality of goods or services

Note: We may offer financial incentives for the collection, sale, or deletion of personal information, but participation is voluntary and you may opt-out at any time.

HOW TO EXERCISE YOUR RIGHTS

Submit Requests Through:

Online Request Form: [BASIC website]/privacy-request

Email: basicoficial01@gmail.com | lud.leika@gmail.com

Phone: +55 (43) 3337-4422
Available Monday-Friday, 9 AM - 6 PM BRT

WhatsApp: +55 (43) 99653-6170

Mail:
BASIC - California Privacy Rights
Attn: Privacy Officer / Marcela Favaro
Rua Professor Joaquim de Matos Barreto, 1000 - Sala 3
Londrina, Paraná, Brazil
CEP: [Insert ZIP Code]

VERIFICATION PROCESS

To protect your privacy and security, we will verify your identity before processing your request. You may be asked to:

For "Right to Know" requests:

• Provide your name, email address, and phone number
• Answer questions about your account or recent purchases
• Match at least two data points we have on file

For "Right to Delete" requests:

• Provide your name, email address, phone number, and account information
• Answer detailed questions about your account
• Provide a signed declaration under penalty of perjury that you are the consumer whose personal information is subject to the request
• Match at least three data points we have on file

For "Right to Correct" requests:

• Identify the specific information to be corrected
• Provide supporting documentation if necessary

AUTHORIZED AGENTS

You may designate an authorized agent to make a request on your behalf. The authorized agent must:

• Provide proof of written authorization signed by you giving the agent permission to submit the request
• Verify their own identity with us
• Provide proof that they are registered with the California Secretary of State to conduct business in California (if the agent is a business)

Note: Even when using an authorized agent, we may still require you to verify your identity directly with us and confirm that you provided the authorized agent permission to submit the request.

RESPONSE TIME

• We will acknowledge receipt of your request within 10 business days
• We will respond to your request within 45 days of receipt
• If we need more time (up to 90 days total), we will inform you of the reason and extension period in writing
• We will deliver our written response electronically unless you request otherwise

NO FEE FOR REQUESTS

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide a cost estimate before completing your request.

APPEAL PROCESS

If we deny your request, you have the right to appeal our decision. Instructions for submitting an appeal will be provided in our response.

CALIFORNIA "SHINE THE LIGHT" LAW

Under California Civil Code Section 1798.83 (the "Shine the Light" law), California residents who have an established business relationship with us may request information about the personal information we have shared with third parties for their direct marketing purposes during the previous calendar year.

To request this information, please contact us at: basicoficial01@gmail.com

Please include "California Shine the Light Request" in the subject line and include your name and the address to which you would like us to respond.

FINANCIAL INCENTIVES

We may offer programs, benefits, or other offerings to consumers related to the collection, retention, or sale of personal information, such as:

• Newsletter discounts: Special offers when you sign up for our email list
• Loyalty program: Earn points for purchases and engagement
• Birthday rewards: Special discounts during your birthday month
• VIP early access: First access to new collections and sales

Terms of Financial Incentives:

• Participation is voluntary
• You may opt-in by signing up through our website or in-store
• You may opt-out or withdraw at any time by unsubscribing from emails or contacting customer service
• The value of your data is reasonably related to the value of the discount or benefit offered
• We calculate the value based on the estimated revenue generated from purchases and engagement

DO NOT TRACK SIGNALS

Our website does not currently respond to "Do Not Track" (DNT) signals from web browsers. However, you can opt-out of targeted advertising through your browser settings, cookie preferences on our website, or through the opt-out mechanisms described in this notice.

CHILDREN'S PRIVACY

Our website and services are not directed to children under 16 years of age. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will delete that information promptly. If you believe we have collected information from a child under 16, please contact us at basicoficial01@gmail.com.

CHANGES TO THIS NOTICE

We may update this CCPA Notice at Collection from time to time. When we make changes, we will update the "Effective Date" at the top of this notice and post the revised notice on our website. For material changes, we will provide additional notice such as email notification or a prominent notice on our website.

We encourage you to review this notice periodically to stay informed about how we collect, use, and protect your personal information.

CONTACT INFORMATION

If you have questions or concerns about this CCPA Notice or our privacy practices, please contact us:

BASIC - Privacy Department

Owner/Privacy Officer: Marcela Favaro

Email: basicoficial01@gmail.com

Phone: +55 (43) 3337-4422

WhatsApp: +55 (43) 99653-6170

Attn: California Privacy Officer / Marcela Favaro
Rua Professor Joaquim de Matos Barreto, 1000 - Sala 3
Londrina, Paraná
Brazil

Tax ID (CNPJ): 34.490.242/0001-22