LAST UPDATED: September 9, 2025.

NAYA COMERCIAL LTDA, a private legal entity, headquartered at Rua Ramão O. S. Filho, registered with the CNPJ/MF under No. 60.748.114/0001-46, takes your privacy seriously and safeguards the security and protection of data of all its clients, partners, suppliers, and users (“Users” or “you”) of the website “nayasemijoias.com.br” and any other website, store, or application operated by the Retailer (hereinafter collectively referred to simply as the “Store”).

This Privacy Policy (“Privacy Policy”) is intended to inform you about how we use and disclose information collected during your visits to our Store and in messages exchanged with you (“Communications”). This Privacy Policy applies only to information collected through the Store.

BY ACCESSING THE STORE, SENDING COMMUNICATIONS, OR PROVIDING ANY TYPE OF PERSONAL DATA, YOU ACKNOWLEDGE AND AGREE TO THE TERMS SET FORTH HEREIN AND TO THIS PRIVACY POLICY, WHICH DESCRIBES THE PURPOSES AND METHODS OF PROCESSING YOUR PERSONAL DATA THAT YOU MAKE AVAILABLE IN THE STORE.

This Privacy Policy provides an overview of our privacy practices and of the choices you can make, as well as the rights you may exercise regarding the Personal Data processed by us. If you have any questions about the use of Personal Data, please contact us at [email protected].

In addition, this Privacy Policy does not apply to any third-party applications, products, services, websites, or social media features that may be offered or accessed through the Store. Accessing such links will cause you to leave the Store and may result in the collection or sharing of information about you by third parties. We do not control, endorse, or make any representations about these third-party sites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any site you interact with before allowing the collection and use of your Personal Data.

If you send us Personal Data regarding other natural persons, you declare that you are competent to do so and that you have obtained the necessary consent to authorize the use of such information under the terms of this Privacy Policy.

Definitions
For the purposes of this Privacy Policy:
“Personal Data” means any information that directly or indirectly identifies or may identify a natural person, such as name, CPF (Individual Taxpayer Registry), date of birth, IP address, among others;
“Sensitive Personal Data” means any information that reveals, in relation to a natural person, racial or ethnic origin, religious conviction, political opinion, union membership or membership in a religious, philosophical, or political organization, data concerning health or sex life, genetic or biometric data;
“Processing of Personal Data” means any operation carried out within the scope of Personal Data, by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Any other operation provided for under applicable law is also considered Processing of Personal Data;
“Data Protection Laws” means all legal provisions that regulate the Processing of Personal Data, including, without limitation, Law No. 13.709/18, the General Data Protection Law (“LGPD”).

Use of Personal Data
We collect and use Personal Data to manage our relationship with you and better serve you when you are purchasing products and/or services in the Store, personalizing and improving your experience. Examples of how we use data include:
• Enabling you to purchase products and/or services in the Store;
• To confirm or correct the information we have about you;
• To send information we believe may be of interest to you;
• To personalize your experience using the Store;
• To personalize the delivery of advertising to you, based on your interest in our Store; and
• To contact you via a phone number and/or email address provided. We may contact you in person, by voicemail, via autodialing equipment, by text messages (SMS), by email, or by any other means of communication your device is capable of receiving, under the law and for reasonable business purposes.

Additionally, the Personal Data provided may also be used in the manner we deem necessary or appropriate: (a) under the terms of the Data Protection Laws; (b) to comply with legal process requirements; (c) to comply with court orders, regulatory decisions, or decisions of competent authorities, including authorities outside the country of residence; (d) to protect our operations; (e) to protect our, your, or third-party rights, privacy, and security; (f) to detect and prevent fraud; (g) to allow us to pursue available remedies or limit damages we may suffer; (h) in other ways permitted by law; and (i) to enforce our Terms and Conditions of Use.

THE PLATFORM IS NOT INTENDED FOR PERSONS UNDER 18 (EIGHTEEN) YEARS OF AGE, AND WE ASK THAT SUCH PERSONS DO NOT PROVIDE US WITH ANY PERSONAL DATA.

Failure to provide Personal Data
You are not required to share the Personal Data we request; however, if you choose not to share it, in some cases we may be unable to provide you with full access to the Store, certain specialized features, the necessary assistance, or to enable delivery of a product or provision of the service contracted by you.

Data collected
The general public may browse the Store without the need for any registration or submission of Personal Data. However, some Store features may depend on registering and submitting Personal Data, such as completing a purchase/contracting a service and/or enabling delivery of the product/provision of the service by us.

When contacting the Store, we may collect:
• Contact data. First and last name, phone number, city, state, and email address; and
• Information you submit. Information you submit via form (questions, complaints, suggestions, criticisms, compliments, etc.).

During general navigation in the Store, we may collect:
• Location data. Geolocation data when you access the Store;
• Preferences. Information about your preferences and interests regarding products/services (when you tell us what they are or when we infer them from what we know about you);
• Store browsing data. Information about your visits to and activities in the Store, including the content (and any ads) that you view and interact with, information about the browser and device you are using, your IP address, your location, the address of the site from which you arrived. Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons, and embedded web links. To learn more, read how we use Automatic Data Collection Tools in item 7 below;
• Anonymous or aggregated data. Anonymous responses to surveys or anonymous and aggregated information about how the Store is used. During our operations, in certain cases we apply a de-identification or pseudonymization process to your data so that it is reasonably unlikely that you can be identified through the use of such data with the available technology; and
• Other information we may collect. Other information that does not specifically reveal your identity or that is not directly related to an individual, such as information about browser and device; Store usage data; and information collected through cookies, pixel tags, and other technologies.

We do not collect Sensitive Personal Data.

Sharing Personal Data with third parties
We may share your Personal Data:
• With partner company(ies) that you select or choose to send your data, questions, inquiries, etc., as well as with service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the United States, Argentina, Brazil, or other global locations, including servers for staging and production, and providers of hosting and data storage, fraud management, customer support, sales on our behalf, order fulfillment, content personalization, advertising and marketing activities (including digital and personalized advertising), and IT services, for example;
• With third parties, in order to help us manage the Store; and
• With third parties, in the event of any reorganization, merger, sale, joint venture, assignment, conveyance, or transfer of all or part of our company, assets, or equity (including those related to bankruptcy or similar proceedings).

International Data Transfers
Personal Data and other information collected by us may be transferred to or accessed by entities belonging to the corporate group of partner companies worldwide in accordance with this Privacy Policy.

Automatic collection of Personal Data
When you visit the Store, it may store or retrieve information on your browser in the form of cookies and other similar technologies. This information may be about you, your preferences, or your device and is primarily used to make the Store function as you expect. The information does not usually identify you directly, but it can provide a more personalized online experience.

In accordance with this Privacy Policy, we and our third-party service providers may collect your Personal Data in several ways, including, without limitation:
• Through the browser or device: Some information is collected by most browsers or automatically through internet-access devices, such as the type of computer, screen resolution, operating system name and version, device model and manufacturer, language, and the type and version of the Internet browser being used. We may use this information to ensure the Store functions properly.
• Use of cookies: Cookies allow the collection of information such as browser type, time spent on the Store, pages visited, language preferences, and other anonymous traffic data. We and our service providers may use this information to, among other things, personalize your experience when using the Store, as well as to target advertising to you according to your interests. We also collect statistical information about use of the Store for continuous improvement of our design and functionality.
If you do not want your information to be collected through cookies, you can configure cookies in the “options” or “preferences” menu of your browser. Below you can find more details on how to adjust cookie preferences in the most popular internet browsers:
Google Chrome / Mozilla Firefox / Safari / Internet Explorer / Microsoft Edge / Opera

If you wish to learn more about advertising and remarketing cookies, which are used to serve advertising according to each user’s interests and the number of visits to our site and their searches on the internet, visit:
Facebook / Google / Bing

• Use of pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to track user actions in the Store (including email recipients), measure the success of our marketing campaigns, and collect statistical data about Store usage and response rates. If ad personalization is active in tools such as Facebook, Google, or Bing, the information may be used to display ads on their services.
If you do not wish to be tracked, you can make a request to each of the services:
Facebook / Google / Bing

We may hire behavioral advertising companies to obtain reports on the Store’s ads across the internet. To do so, these companies use cookies, pixel tags, and other technologies to collect information about your use—or other users’ use—of our Store and third-party websites. We are not responsible for pixel tags, cookies, and other similar technologies used by third parties. You can set your preferences in your browser menu. Be aware that if you change computers or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser.

User Rights
You may, at any time, request: (i) confirmation that your Personal Data is being processed; (ii) access to your Personal Data; (iii) correction of incomplete, inaccurate, or outdated data; (iv) anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in noncompliance with the law; (v) portability of Personal Data to another service provider, provided that this does not affect our trade secrets; (vi) deletion of Personal Data processed with your consent, to the extent permitted by law; (vii) information about the entities with which your Personal Data has been shared; (viii) information about the possibility of not providing consent and the consequences of refusal; and (ix) revocation of consent. Your requests will be handled with special care so that we can ensure the effectiveness of your rights. You may be asked to provide proof of your identity to ensure that Personal Data is shared only with its holder.

You should bear in mind that, in certain cases (for example, due to legal requirements), your request may not be immediately fulfilled, and we may not be able to comply due to legal obligations.

Security of Personal Data
We seek to adopt the technical and organizational measures provided for by the Data Protection Laws appropriate to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe the security of any of your accounts has been compromised), please notify us immediately.

Hyperlinks to other websites and social networks
From time to time, the Store may contain hyperlinks that will redirect you to sites within the networks of our partners, advertisers, suppliers, etc. If you click on any of these links, please remember that each site has its own privacy practices and that we are not responsible for those policies. Check the respective policies before submitting any Personal Data to those sites.

We are not responsible for the data collection, use, and disclosure policies and practices (including data protection practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other software developer or application provider, social media store, operating system, wireless internet service provider, or device manufacturer, including all Personal Data you disclose to other organizations through applications, related to such applications, or posted on our social media pages. We recommend that you inform yourself about the privacy policy of each site visited or each service provider used.

Updates to this Privacy Policy
If we modify our Privacy Policy, we will post the new text in the Store with the updated revision date. We may change this Privacy Policy at any time. If there is a significant change in the terms of this Privacy Policy, we may notify you through the contact information we have in our database or via a notice in our Store.

We reaffirm our commitment not to process your Personal Data in a manner incompatible with the purposes described above, except as otherwise required by law or court order.

Your use of the Store after the changes means that you accept the revised Privacy Policies. If, after reading the revised version, you do not agree with its terms, please cease accessing the Store.

 

Person responsible for the processing of Personal Data
If you wish to exercise any of the rights provided for in this Privacy Policy and/or in the Data Protection Laws, or to resolve any questions related to the Processing of your Personal Data, please contact us at [email protected].