Date of update: July 15, 2025

This Privacy Policy demonstrates Neogrid’s strong commitment to your privacy and the protection of personal data collected from all visitors and users of the services provided by Neogrid, establishing rules on the processing of collected data within the scope of the services with transparency and clarity to users and the market in general.

To access and use the features offered in Neogrid environments, the user declares that they have read this Policy thoroughly and carefully, are fully aware of its contents, and thus freely and expressly agree to the terms stipulated herein for the processing of the data mentioned herein in accordance with the conditions specified below.

ABOUT US

Neogrid, as a service provider, is the data operator/processor for customers and partners, and controller for suppliers/providers who are contracted to perform various services and supplies.

a. Neogrid Informática, registered in Brazil, Avenida Santos Dumont, 935, CEP 89223-002, Joinville, Santa Catarina;

b. Neogrid North America LLC, registered in the United States of America under number 52-2242825, headquartered at 601 Brickell Key Drive, Ste 901, Miami, FL, 33131, USA;

c. Neogrid Netherlands B.V., registered in the Netherlands under number 34106678, with headquarters at Keizer Karelplein 8 C, 6211TC Maastricht;

1. Data collection and activity registration

Neogrid collects personal data from the Platform when voluntarily entered or submitted by our users, including, but not limited to, access, account creation, browsing, contracting, and use of services. In addition, the Platform may log all activities performed by users. We also collect data through our Website and Landing Page when voluntarily entered or submitted by users when filling out forms on the pages. In addition, the website and landing pages may record visitor activities through cookies.

We may receive data through third parties, including data intelligence bureaus and business partners, when the data subject has authorized the sharing of such data or has a legitimate interest in using it.

1.1. Collection of data from children and adolescents

Neogrid does not collect personal data from children and adolescents under the age of 18. Although we prohibit it, parents should supervise the online activities of their minor children.

If Neogrid becomes aware of the collection of data from children or adolescents, it will take reasonable measures to delete it.

Please do not register with Neogrid Environments if you are under 18 years of age.

1.2. Personal data we collect through:

Access to the Platform:

a) First and last name;
b) Email address;
c) Address;
d) Phone number;

Websites, phone calls and landing pages:

a) First and last name;
b) Business email address;
c) Business phone number;

1.3. The user is solely responsible for the accuracy, veracity, or lack thereof in relation to the Data they provide or for its obsolescence. Likewise, it is the user’s responsibility to ensure its accuracy or keep it up to date.

1.4. Likewise, Neogrid is not obligated to process or handle any of your Data if there are reasons to believe that such handling may cause you to violate any applicable law, or if you are using the Platform for any illegal, illicit, or immoral purposes.

1.5 Data collection on the Platform may include:

a) IP address, logical port of origin of users, and geolocation;

b) Actions performed by users on the Platform;

c) Screens accessed by users;

d) Dates and times of each activity performed, as well as user access to the Platform;

e) Data about the device used by the user, in particular: operating system version, browser, geolocation, and other installed applications, if necessary;

f) Users’ session IDs, when available;

g) History of operations performed; and,

h) Behaviors identified in interactions with the Platform.

1.6 The Platform and Websites may also use technologies such as

a) Cookies, used to improve the functionality of Neogrid systems, in accordance with the information available in the Cookie Policy. Users or visitors may block the use of Cookies through their browser settings, in which case some features of the Platform may be limited.
b) Web Beacons to collect data on user behavior when accessing pages, where the installation of files on devices may not be necessary.
c) Beacons that emit signals using Bluetooth Low Energy (BLE) technology, which can be captured by technological resources that enable interaction between the user and a technological resource.
d) Other technologies for obtaining user browsing data (API analytics).

1.7 All technologies used shall comply with the terms of this Policy.

1.8 It is important to note that, once on the Platform or Websites, the user may be directed, via links, content, or services, to other portals or platforms that are not owned by Neogrid and that may collect their information and have their own Privacy Policy.

1.8.1 It is the user’s responsibility to read the Privacy Policy of such platforms outside the Neogrid environment, and it is the user’s responsibility to accept or reject it. Neogrid is not responsible for the Privacy Policy or content of any websites, content, or services located outside the Neogrid Websites and Platform.

2. Use of Data

2.1 Data collected from Neogrid users and activity logs may be used for the following purposes:

a) Identify and authenticate them properly, in addition to processing transactions in the Access Account.
b) Enable buyers to contact suppliers to request quotes and other information (delivery time, available quantity, quality information, among others) about the products they intend to purchase.
c) Enable suppliers to receive email notifications and respond to buyers through the Neogrid system.
d) Manage system functions, provide services, and fulfill obligations arising from the use of Neogrid services.
e) Provide user support, including answers to questions about the platform.
f) To optimize and improve the user experience.
g) To compile statistics, studies, surveys, and research relevant to user behavior while using the platform.
h) Promote Neogrid’s services and products, as well as those of the following Neogrid companies: Neogrid Netherlands BV (Amsterdam, Netherlands), Neogrid North America LLC (Fort Lauderdale Office, Delaware LLC, USA), and their commercial and technological partners.
i) Provide information about news, resources, content, and other events relevant to maintaining the relationship with our users.
j) Communicate³ with Neogrid customers and prospects, as well as other third parties, regarding: (i) marketing and advertising campaigns for Neogrid products and services; (iii) content promotion; (iv) invitations to virtual and in-person events; (v) contacting potential customers and partners, among others.
k) To safeguard Neogrid’s rights and obligations related to the use of the platform.
l) To enrich the Neogrid database and prevent fraud.

2.1.1 It should be noted that all marketing emails sent by Neogrid contain a link to unsubscribe if the recipient no longer wishes to receive such messages.

2.2 User consent regarding data use:

2.2.1. Consent for the purposes of data use will be collected individually, and the user is not obliged to give their consent to any of them.

2.2.1.1. If the user does not give their consent for purposes directly related to the provision of services by Neogrid, the services will not be made available to them, and their access to the Platform may be blocked/deleted, where applicable.

2.2.1.2. If the user does not grant their consent for optional purposes, Neogrid will continue to provide services as usual.

2.2.2. The Platform user may change their consent by opening a ticket with Neogrid support, granting new permissions or withdrawing their consent for current permissions, being advised of the consequences that withdrawal of consent may cause.

2.3. The data collected and activities recorded may also be shared:

2.3.1. With competent judicial, administrative, or governmental authorities, whenever there is a request, requisition, or court order;

2.3.2. Automatically in the event of corporate changes, such as mergers, acquisitions, and incorporations, observing the principle of transparency with the user.

2.3.3. Automatically with companies that provide Neogrid with services necessary for its activities, processing personal data in accordance with Neogrid’s instructions and for the respective purposes, among which the following stand out:

a) Hosting Service Providers – Data Center services for colocation and/or hosting services;
b) Software as a Service – used for data processing for internal management;
c) Software and Hardware Maintenance Providers – for replacement and maintenance of defective parts, as well as for software updates;
d) Telecommunications Services – data link and Internet connectivity;
e) Consulting (information technology, legal, administrative, accounting, human resources) – for operational management and internal procedures;
f) Advertising Agencies – to send Neogrid newsletters and advertisements;
g) Telephone and mobile phone services – for communication with customers and prospects;
h) Postal and carrier services – to send Neogrid newsletters and advertisements;
i) Financial and insurance services (banks, brokers) – to process payments and implement insurance;
j) Travel agencies – to organize trips to serve customers and prospects;
k) Event management – organizers to communicate with customers and prospects;
l) Marketing platforms – to communicate with customers and prospects;
m) Business partners – to provide services and process data.

2.3.4. If these external companies have access to personal data, Neogrid guarantees that the respective parties have previously signed data processing and confidentiality agreements with Neogrid to comply with applicable data protection legislation.

2.3.5. These service providers may be located in the European Union, Brazil, Asia, and the United States, and international data transfers must be made in accordance with section 6 (International Data Transfers).

2.4. Neogrid is solely responsible for the database formed by the collection of data from its platform.

2.5. The use, access, and sharing of data from Neogrid’s database will be done only within the limits and purposes of the business described in this Policy.

2.5.1. However, considering that no security system is foolproof, Neogrid disclaims any liability for any damages and/or losses resulting from failures, viruses, or intrusions into Neogrid’s database, except in cases of willful misconduct or fault.

2.6. Neogrid may also share data from its database with authorities, whenever legally required.

2.7. Users are responsible for the confidentiality of their personal data. Sharing passwords and login details violates this privacy policy and the terms and conditions of use of our platform.

2.8. It is very important that users protect their data and be aware that Neogrid will never send electronic messages requesting confirmation of data or with attachments that can be executed (extensions: .exe, .com, among others).

2.9. Internally, access to user data is restricted to authorized Neogrid employees only, respecting the principles of proportionality, necessity, and relevance to our business objectives, in addition to our commitment to confidentiality and preservation of user privacy under the terms of this Policy.

2.10. To optimize and improve communication, when Neogrid sends an email to the user, we may receive a notification when they are opened, provided that this possibility is available. It is important for the user to be aware that emails are only sent from the following domains: neogrid.com.

3. Data Storage

3.1. User data collected by Neogrid will be stored for the duration of the relationship with the user and unless there is a request for deletion or revocation of consent, pursuant to Article 9, item II, of the General Personal Data Protection Law. Neogrid may retain user data history for a longer period in cases where applicable law or regulations so provide, such as the six (6) month period for digital identification data, pursuant to Article 15 of the Brazilian Civil Rights Framework for the Internet, and three (3) years for other data, based on Article 206, § 3, item V, of the Civil Code. This period may vary according to specific customer requirements.

3.1.1. Anonymized data is not subject to the storage periods described above, pursuant to Article 12 of the LGPD.

3.2. Data collected from users will be stored in SaaS data centers or local infrastructure. Data centers may be third-party infrastructure, cloud computing located in the United States or any other location where Neogrid and/or the Customer operates.

4. What are the User’s Rights and how to exercise them

4.1. The data subject may request to view or change personal information through their accounts or support tools provided by Neogrid or by contacting our Data Protection Department, and may also request:

(i) The limitation of the use of their Personal Data;

(ii) Expressing their opposition and/or revoking their consent to the use of their Personal Data; or

(iii) Requesting the deletion of their Personal Data that has been collected by Neogrid.

4.2. Once the contract between the user and Neogrid has ended, all accounts are canceled and access is revoked.

4.3. If the user withdraws their consent for purposes that are essential to the proper functioning of the Platform, the platform’s features and services may become unavailable to the user.

4.4. Once the retention period and legal requirement have expired, personal data will be deleted using secure disposal methods or used anonymously for statistical purposes.

4.5. Questions or requests regarding Privacy can be forwarded to Neogrid’s current Data Protection Officer, Leandro Fabricio Dix, by email at dpo@neogrid.com or by mail at the address below:

GDPR – General Data Protection Regulation (2016/679)
Neogrid Netherlands B.V.
Keizer Karelplein 8 C, 6211TC Maastricht.

LGPD – General Personal Data Protection Law (13.709/2018)
Neogrid Informática Ltda
Av. Santos Dumont, 935, 4th Floor, CEP 89223-002, Joinville, Santa Catarina, Brazil.

4.6. If the user considers that their rights to personal data protection have been violated, they may file a complaint with the competent Data Processing Authority.

5. Data recipients

5.1. Your personal data will be processed by Neogrid professionals in the respective departments that need access to personal data:

a) Contact details: any departments that may be involved in processing your request;

b) Comment details: marketing or the respective product departments responsible for operating blogs or discussion forums;

c) Job application data: HR and the departments responsible for the position you applied for;

d) Direct marketing data: marketing and sales departments responsible for your region;

e) Usage data and browser data: marketing and IT departments responsible for operating the respective websites.

5.2. Neogrid is a corporation with global operations. To ensure that your request is processed, it may be necessary to forward your data to local subsidiaries or local distribution partners, whose registered office may also be located in other countries (see section 6). However, these data transfers only occur within the Neogrid group of companies, and the legality of data export will be based on the positions of the competent data protection authorities.

5.3. Furthermore, we do not forward your data to third parties unless we are obliged to do so by contractual obligations, EU statutory provisions, or an order from any judicial authority or other national or EU public authorities, or if you have expressly requested data portability or given your consent for this purpose. Your personal data will not be sold, rented, or exchanged.

6. International Data Transfers

6.1. The recipients of your personal data may be located outside Brazil, the European Union, or the European Economic Area, where data protection laws may not be equivalent to EU data protection law, Brazilian law, and European Union law. In such cases, the recipient will be required to take measures to protect your data.

6.2. We will take all necessary measures to ensure that transfers to such organizations are adequately protected in accordance with applicable data protection legislation, for example, by signing an agreement with the standard contractual clauses stipulated by the National Data Protection Agency (“ANPD”) OR EU Commission with the data recipients. You may request a copy of these relevant guarantees by contacting our Data Protection Department at: dpo@neogrid.com

6.3. If a data transfer to official authorities in countries outside Brazil or the European Union or European Economic Area (so-called third countries) from other countries is necessary, and if not required by law, by consenting to this Privacy Policy, you have given us your express consent for the international data transfer to take place.

7. General Provisions

7.1. The Platform does not use any type of solely automated decision-making based on personal data that impacts the user.

7.2. Neogrid may change the content of this Privacy Policy at any time, according to the purpose or need, such as for legal compliance with a law or regulation that has equivalent legal force, and it is up to our user to check it whenever they access the Neogrid Platform.

7.2.1. In the event of significant updates to this document that require new consent, Neogrid will notify the user through the tools available on the platform and/or support tools available or by the contact email provided by the user.

7.3. If you have any questions about this policy, please contact Neogrid through the service channel https://neogrid.com/en/privacy-policy/.

7.4. If third-party companies process any data collected by Neogrid, they must comply with the conditions set forth herein and Neogrid’s Information Security standards.

7.5. If any provision of this Privacy Policy is deemed unenforceable by a data or judicial authority, the remaining conditions shall remain in full force and effect.

7.6. The user acknowledges that all communications made by -mail (to the addresses provided in your registration), SMS, instant messaging applications, or any other virtual and digital means are also valid, effective, and sufficient for the disclosure of any matter relating to the services provided by Neogrid, as well as the conditions of their provision or any other matter addressed herein, except as expressly provided otherwise in this Privacy Policy.

8. Glossary

8.1. For the purposes of this document, the following definitions and descriptions should be considered for better understanding:

Anonymization: Use of reasonable and available technical means at the time of Processing, through which data loses the possibility of direct or indirect association with an individual.

Beacons: Small devices that use Bluetooth Low Energy (BLE) technology, which emit signals that can be picked up by technological resources, enabling interaction between the user and the technological resource. Web Beacons are programs designed to monitor a user’s navigation on a web page.

Cloud computing: Cloud computing is a service virtualization technology built from the interconnection of more than one server through a common information network (e.g., the Internet), with the aim of reducing costs and increasing the availability of supported services.

Cookies: Files sent by the Platform server to users’ computers for the purpose of identifying the computer and obtaining access data, such as pages browsed or links accessed, thus allowing the customization of users’ navigation on the Platform according to their profile.

User account: User credentials that may be required to use or access restricted areas and exclusive features of the Platform offered by Neogrid.

Data: Any information entered, processed, or transmitted through Neogrid Environments.

Personal data: Data related to an identified or identifiable natural person

Solely automated decisions: These are decisions that affect a user and have been programmed to function automatically, without the need for human intervention, based on the automated processing of personal data.

Officer (Data Protection Officer – DPO): A person appointed by Us to act as a communication channel between the controller, data subjects, and data protection authorities.

IP: Abbreviation for Internet Protocol. It is the alphanumeric set that identifies users’ devices on the Internet.

Landing pages: Web pages containing forms that visitors can fill out to access content such as e-books and special offers.

Logs: Records of user activities performed on the Platform.

Platform: Neogrid’s virtual environment for connecting buyers (legal entities) and suppliers (legal entities).

Session ID: Identification of the user’s session in the process of purchasing services or when accessing the restricted area.

Users: People who access or interact with the activities offered by the Platform and Neogrid websites.

Processing: Any operation performed with Personal Data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.

9. Applicable Law and Jurisdiction

9.1. To settle any dispute or controversy involving this document, the jurisdiction of the location where Neogrid provides the services indicated below shall be elected, unless there is a specific exception of personal, territorial, or functional jurisdiction under applicable law:

a) Neogrid Informática Ltda. – Court of the district of Joinville, State of Santa Catarina, Brazil;

b) Neogrid North America LLC – Court of Fort Lauderdale, State of Florida, United States of America; and

c) Neogrid Netherlands B.V – Court of the city of Amsterdam, Netherlands.

9.2. In any case, we are available to respond to requests for rights or to address any inconvenience, irregularity, or question related to how we process personal data, through our direct channel with the Data Protection Officer/DPO at dpo@neogrid.com or through our customer service channel available at https://neogrid.com/en/privacy-policy/.

Thank you for your attention, and welcome to Neogrid!