At Grupo Vista Alegre, we value your privacy and, therefore, we want you to know how we handle your personal data, what your rights are and how you can clarify any doubts you may have. Thus, we would appreciate if you could take a few minutes of your time to read the terms below.

1. COLLECTION AND PROCESSING OF CUSTOMER DATA

This Privacy Policy is intended to provide Customers of the physical shops and Users of the websites - hosted at www.vistaalegre.com, www.bordallopinheiro.com, www.casaalegre.com, www.cartaoprivate.vistaalegre.com and www.ccva.vistaalegre.com (hereinafter referred to as the “website”), with detailed information on how Grupo Vista Alegre Atlantis, S.A., based at Lugar da Vista Alegre, 3830-292 Ílhavo - Portugal, carries out the processing of personal data.

As a rule, Personal Data is collected from the Customer/User when making a purchase in a shop, navigating on one of the websites, requesting a contact, sending newsletters, subscribing to a certain product or service, providing or requesting information, joining a loyalty program, purchasing a product or establishing a contractual relationship with Grupo Vista Alegre purchasing in one of our physical shops or on the websites.

The Personal Data collected and processed consists essentially of information regarding name, gender, date of birth, telephone, mobile phone, email, address, tax identification number, credit card data (collected only for payment purposes), although other Personal Data may be collected that may be necessary or appropriate for the provision or collection of services by Grupo Vista Alegre.

When registering to use the websites, the User is requested to create a password. The Customer should keep it strictly confidential, not revealing nor

sharing it with third parties. The Customer is entirely and exclusively responsible for the use of his/her password and any orders placed by using it, even without his/her knowledge.

When entering our website you have also the possibility of subscribing to our newsletter, and so we collect some Personal Data, such as name and e-mail, which will be treated to receive information on the brand, namely: news, exclusive campaigns, invitations to events, etc.

In the case of Users who purchase online or in physical shops, the elements necessary for completing the entire commercial transaction and future contacts that may be necessary to establish will be collected, in order to ensure the best customer service, such as full name, e-mail, tax identification number, address and telephone number.

Grupo Vista Alegre also collects and processes information about the characteristics of your hardware device, your IP address and browser/software characteristics as well as information about the pages visited by the User within the Website. This information may include your browser type, domain name, access times and the links through which you accessed the website (“Usability Information”). We use this information to improve the quality of your visit to our Website and whenever you consent to analyze your user profile and browsing habits on the Website, to measure the conversion of advertising on the Website and to send commercial and marketing information tailored to your profile.

Usability Information and Personal Data are referred to in this Privacy Policy as “Customer Data”.

For the purposes of this Privacy Policy a contractual relationship is understood to be any contract established between Grupo Vista Alegre and the entities related to it, regardless of its object. 2. RECIPIENTS OF THE DATA

Personal data collected by Grupo Vista Alegre are not shared with the exception of the situations mentioned in the following paragraph. However, in the event the Customer signs a contract with Grupo Vista Alegre for services that are to be provided by other companies responsible for processing personal data,

Customer data may be transmitted and/or accessed by these companies to the extent necessary for providing such services.

Under applicable law, Grupo Vista Alegre may transmit or communicate Customer Data to other companies, in case such transmission or communication is necessary to carry out the contract signed between the Customer and Grupo Vista Alegre, or for pre-contractual procedures at the request of the Customer, complying with the legal obligations that Grupo Vista Alegre is subject to, with the legitimated interests of Grupo Vista Alegre or a third party. In the event that we transfer Customer Data to a third party, we will use reasonable efforts to ensure that it is transferred complying with this Privacy Policy.

2.1 Sub-Contracting Companies

As far as processing Customer Data is concerned, Grupo Vista Alegre uses or may use third parties sub-contracted on its behalf and according to its instructions to process Customer data within the scope of the applicable law and to this Privacy Policy.

These third parties must not transmit the Customer Data to other entities without Grupo Vista Alegre’s prior written consent.

Grupo Vista Alegre undertakes to subcontract only companies offering maximum security implementing suitable technical and organizational measures, in order to ensure the protection of Customer rights. All companies subcontracted by Grupo Vista Alegre shall be bound by a written agreement in which the object, duration, nature and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties and other requirements set forth in Article 28 of the GDPR are regulated.

In accordance with the duty of information to which Grupo Vista Alegre is obliged, hereafter are the categories of sub-contractors to whom the personal data Grupo Vista Alegre customer and other users of the website are disclosed:

2.2 Third Parties

Grupo Vista Alegre may also communicate to other third parties not qualified as subcontractors under Article 4, paragraph 8 of the GDPR.

These entities are subject to confidentiality and all of them have undertaken to ensure the processing of personal data according to GDPR. Grupo Vista Alegre communicates data to other recipients, in detail:

3. DATA COLLECTION CHANNELS

Grupo Vista Alegre may collect data directly (directly from the Customer) or indirectly (through subcontractors, partner entities or third parties). Collection may be carried out by the following channels:

• Direct collection: in person, by telephone, by e-mail and through the Website;

• Indirect collection: through partners or companies of the Grupo and official entities.

4. GENERAL PRINCIPLES APPLICABLE TO THE TREATMENT OF CUSTOMER DATA

Grupo Vista Alegre undertakes to ensure that the Customer data it processes is:

• Collected for specific, objective and legitimate purposes and no further processing contrary to those purposes;

• Processed lawfully, fairly and transparently in respect to the Customer;

• Adequate, justified and limited to what is necessary in relation to the purposes for which they have been collected;

• Accurate and up-to-date, whenever necessary, and the necessary measures taken to ensure that data which are inaccurate or no longer up-to-date (in terms of the purposes for which are processed) are erased or corrected without delay;

• Kept in such a way as to allow identification of the Customer only during the period necessary for the purposes that the data is processed;

• Processed in such a way as to ensure its security, including protection against unauthorized or unlawful processing and against their loss, destruction or unforeseen damage, with suitable technical and organizational measures being taken.

Data processing carried out by Grupo Vista Alegre is permitted and legitimate when at least one of the following situations occurs:

• The User has given free, positive, explicit and unequivocal consent to the processing of Customer Data for one or more specific purposes;

• Processing is necessary to carry out a contract to which the Customer is a party, or for pre-contractual procedures upon the Customer's request;

• Processing is necessary to comply with a legal obligation to which the Grupo Vista Alegre is subject;

• Processing is necessary in order to protect the vital interests of the Customer or another individual;

• Processing is necessary for the purposes of the legitimate interests pursued by Grupo Vista Alegre or a third party (unless the interests or fundamental rights and freedoms of the Customers prevail and require protection of personal data).

Grupo Vista Alegre undertakes to ensure that the processing of Customer Data is carried out only under the conditions listed above and in compliance with the aforementioned principles. Where the processing of Customer Data is carried out by Grupo Vista Alegre based on consent, the Customer has the right to revoke their consent at any time. The revocation of consent, however, does not compromise the legality of the processing carried out by Grupo Vista Alegre based on the consent previously given by the Customer. The period of time during which data is stored and maintained varies according to the purpose for which the information is processed, being filled only for the time necessary to fulfil the purposes for which they are processed, taking into account the Data Retention Policy approved by Grupo Vista Alegre. There are legal requirements which require the retention of data for a minimum period of time. Thus, whenever there is no specific legal obligation, the data shall be stored and retained only for the minimum period of time necessary for the purposes for which they were collected or subsequently processed and that, upon expiry, they shall be deleted.

5. USE AND PURPOSES OF PROCESSING CUSTOMER DATA

In general terms, Grupo Vista Alegre uses Custom Data for the following purposes:

• Customer contact management;

• Billing and collection from the Customer;

• Customer registration on Grupo Vista Alegre’s websites;

• Allowing access to restricted areas of the websites of Grupo Vista Alegre, according to previously established terms;

• Ensure that the website meets the Customer’s needs, through development and publication of suitable contents matching the interests and requests expressed by the Customer, improving search capabilities and platform functionalities as well as obtaining the associated or statistic information regarding the type of Customer profile (analysis of consumption profiles);

• Information/Contact requests;

• Presence in social networks;

• Newsletters and Mailing;

• Events;

• Planning and organization of events, meetings, and fairs;

• Providing you with services;

• Managing and maintaining our contractual relationships;

• For accounting and tax purposes;

• For marketing and business development;

• Compliance with applicable legal and regulatory requirements;

• Establishing, exercising or defending legal rights;

• Responding to requests and communications from competent authorities;

• Recruitment and business development;

• Website Customer Relationships, including:

o Sending communications or details of our services;

o Contacting you for feedback on our services;

o Contacting you for market research or research purposes.

• Voucher acquisition and management;

• Management and response to a budget;

• Inform the Customer, upon request, about new products and services available on the Website, special offers and campaigns, updated information about Grupo Vista Alegre’s activity and in terms of marketing purposes of this company and its brands, through any means of communication, including electronic means;

• Participation in campaigns to collect contacts or competitions on Grupo Vista Alegre’s social networks;

• Subscription to loyalty programs of Grupo Vista Alegre (“Cartão Private” and “Clube Colecionadores”) that allows access to specific campaigns of the brand;

• Sending satisfaction questionnaires;

• Recording conversations in the Web chat;

• Recording telephone calls made when requesting or providing information on products or services and their commercial and usage conditions, as well as any contractual relationship, both during the contract elaboration phase and during its term.

Grupo Vista Alegre may combine Usability Information with anonymous demographic information for research purposes and it may use the results to provide more relevant content on the Website. With your consent, in certain restricted areas of the Website, Grupo Vista Alegre may combine Personal Data with Usability Information to provide you with more personalized content.

6. BASIS OF LAWFULNESS FOR PROCESSING SOCIAL DATA

The processing of your personal data has the following purposes:

7. TECHNICAL, ORGANIZATIONAL AND SAFETY MEASURES IMPLEMENTED

In order to ensure the security of Customer Data and maximum confidentiality, Grupo Vista Alegre handles the information provided to us in an absolutely

confidential manner, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated as necessary, as well as with the terms and conditions provided by law. In view of the nature, scope, context and purposes of data processing, as well as the risks arising from processing for the Customer’s rights and freedoms, Grupo Vista Alegre undertakes to apply, both when defining the means of processing and when processing itself, the necessary and appropriate technical and organizational measures to protect Customer Data and to comply with legal requirements. It further undertakes to ensure that, by default, only data that are necessary for each specific purpose of processing are handled and that such data are not made available without human intervention to an indefinite number of persons. The communication between the Customer’s device and the website of Grupo Vista Alegre is made through secure channels and communications using the HTTPS protocol and SSL security standard. Nevertheless, in terms of general measures, Grupo Vista Alegre adopts the following:

• Regular audits to identify the effectiveness of technical and organizational measures implemented;

• Awareness raising and training of staff involved in data processing operations;

• Pseudonymization and encryption of personal data;

• Mechanisms capable of ensuring ongoing confidentiality, availability and resilience of information systems;

• Mechanisms to ensure that information systems are rapidly re-established and personal data can be accessed in the event of a physical or technical incident. In the event of an incident of personal data breach, Grupo Vista Alegre undertakes to adopt all measures provided for in article 33 and 34 of the GDPR.

8. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Personal data collected and subject to processing are stored in databases suitable for that purpose. The personal data is kept, according to its purpose, in compliance with the applicable legal deadlines. In cases where no legal deadline applies in regards to keeping and storing personal data, such data will only be stored and kept for the appropriate period and to the extent necessary, given the purposes for which they were collected,

unless, at any time, the subject of the personal data, within the limits of the law, exercises their rights of opposition, erasure or withdrawal of consent.

9. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

Grupo Vista Alegre may transfer your personal data to recipients in countries outside the European Union, which may have different levels of protection in terms personal data. Consequently, Grupo Vista Alegre is concerned with adopting adequate measures to ensure the safe transfer of the Customer Data, whenever there is a transfer to a third country, whose level of protection of its personal data is different from that of the country where the personal data are collected. Grupo Vista Alegre undertakes to ensure that transfers of Customer Data to countries outside the European Union comply with the applicable legal provisions, in particular in terms of determining the suitability of such country in terms of data protection and the requirements applicable to such transfers.

10. USE OF COOKIES

When you visit our website, small text files (Cookies) are created and saved on your computer disk. These text files will enable a more personalized and efficient browsing experience. Each time you visit the Website, your internet browser sends these cookies back to the Website, allowing it to recognize and memorize your identity and your usage preferences. These Cookies will only be installed with your express consent, to be collected when presenting the cookies banner in the pages of the companies of Grupo Vista Alegre, except in cases in which they are strictly necessary for Websites to function. The information about the cookies that we use on the websites, including their purpose, categories, duration and to whom they belong to, can be found in our Cookies Policy available here. In addition, you may at any time manage your preferences regarding the collection of cookies in the preference manager available here.

11. THIRD-PARTY TOOLS INTEGRATED INTO THE WEBSITE

Facebook and Instagram:

On our Websites there is interactivity with Facebook and Instagram, through a connection to the servers of these social media. This will allow us to identify the website the User is visiting and possibly store other data, such as the IP address. If the User has their Facebook and/or Instagram session started, data will be associated with their accounts. To prevent this from happening, the User must log out of Facebook and Instagram before visiting the website. Information regarding the data processing carried out by these social media is available at: https://www.facebook.com/about/privacy/ https://help.instagram.com/519522125107875

12. Use of Social Media for Marketing Purposes

In order to meet our customers’ needs in the best possible way and to provide more personalized services, Grupo Visabeira may share Customer Data with social media, including Facebook, to allow the presentation of personalized advertisements which better meet the subject’s interests. As such social media may use the Customer Data to pursue its own interests. The information regarding data processing by these social media is available at:

https://www.facebook.com/about/privacy/

https://help.instagram.com/519522125107875

13. CUSTOMERS’ RIGHTS (DATA SUBJECTS)

13.1. RIGHT TO INFORMATION

13.1.1. Information provided to the Customer by Grupo Vista Alegre (when data are gathered directly from the Customer):

• The identity and the contact details of the responsible for the processing and, where applicable, his/her representative;

• The contact details of the Data Protection Officer;

• The purposes for processing personal data as well as, where applicable, the legal reasons for processing;

• If data processing is based on legitimate interests of the Grupo Vista Alegre or a third party, indication of such interests;

• Where applicable, the recipients or categories of recipients of the personal data;

• Where applicable, indication whether personal data will be transferred to a third country or an international organization and the existence or not of an adjustment decision adopted by the European Commission or reference to suitable transfer safeguards;

• Period of time to retain personal data;

• The right to request permission to access personal data from Grupo Vista Alegre, as well as its correction, deletion or limitations, the right to oppose its processing as well as the right to access data;

• If data processing is based on the User’s consent, the right to withdraw it at any time, without compromising the lawful process of the processing carried out based on the consent previously given;

• The right to present a complaint with the CNPD (National Commission for Data Protection) or any other supervisory authority;

• Indicating whether communication of personal data represents a legal or contractual obligation or a necessary requirement to sign a contract, as well as whether the data subject is obliged to provide personal data and the possible consequences of not doing so;

• Where applicable, the existence of automated decisions, including profiling, and information concerning the basic concept, as well as the relevance and the expected consequences of such processing for the data subject.

13.1.2. When the collection of Customer Data is not carried out directly by Grupo Vista Alegre with the Customer, besides the information aforementioned, the Customer shall also be informed as to the categories of personal data subject to processing, as well as about the source of the data and possibly, whether they come from publicly available sources. In case Grupo Vista Alegre intends to further process the Customer Data for a purpose other than the one for which data were collected, prior to this processing, Grupo Vista Alegre shall provide the Customer with information regarding this purpose, as well as any other relevant information, as mentioned above.

13.2. Procedures and measures implemented in order to comply with the right to information. The information referred to in 13.1 shall be provided in writing (including electronic means) by Grupo Vista Alegre to the Customer prior to the processing of the personal data concerned. Under applicable law, Grupo Vista Alegre shall not be obliged to provide the Customer with the information referred to 13.1. if the Customer is already aware of it. The information is provided by Grupo Vista Alegre free of charge.

14. RIGHT OF ACCESS TO PERSONAL DATA

Grupo Vista Alegre shall provide means for the Customer to access his/her Personal Data. The Customer has the right to obtain confirmation from Grupo Vista Alegre as to whether personal data concerning him/her are being processed and, if so, the right to access his or her personal data as well as the following information:

• The purpose of the data processing;

• The categories of personal data concerned;

• The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or those which belong to international organizations;

• The right to be informed as to the guarantees in terms of the transfer of data to third countries or international organizations;

• The period for retaining personal data;

• The right to request Grupo Vista Alegre to correct, erasure or limit the processing of personal data, or the right to prevent such processing;

• The right to file a complaint with the CNPD or other supervisory authority;

• The information available on the source of such data, if it has not been collected from the Customer;

• The existence of automated decisions, including profiling, information regarding the underlying logic, as well as the importance of expected consequences of such processing for the data subject. Upon request, Grupo Vista Alegre shall provide the User, free of charge, with a copy of the Customer Data that is being processed. The provision of other copies requested by the Customer may entail administrative costs.

15. RIGHT TO CORRECT PERSONAL DATA

Customers have the right to request, at any time, the correction of their Personal Data as well as the right to complement their personal data, even if through an additional declaration. In case data are corrected, Grupo Vista Alegre shall communicate this

information to each recipient to whom the data have been transmitted, unless such communication is deemed impossible or involves a disproportionate effort for Grupo Vista Alegre.

16. RIGHT TO DELETION OF PERSONAL DATA (“RIGHT TO BE FORGOTTEN”)

The customer has the right to obtain from Grupo Visabeira, the deletion of his/her personal data when one of the following reasons should occur:

• Customer Data is no longer necessary for the purpose it was collected or processed;

• The Customer withdraws the consent on which the data processing is based and there is no other legal ground for said processing;

• If the Customer objects to the processing under the right to object and there are no overriding legitimate interests justifying processing;

• In case there is no lawful basis justifying processing;

• In case Customer Data must be erased for compliance with the legal obligation which Grupo Vista Alegre is subject to. Under applicable legal terms, Grupo Vista Alegre shall not be obliged to delete Customer Data if processing is necessary to comply with a legal obligation which Grupo Visabeira is subject to or for the purposes of asserting, exercising or defending a Grupo Vista Alegre’s right in a legal proceeding. In case of data deletion, Grupo Vista Alegre shall notify this information to each recipient/entity to whom the data have been transmitted, unless such notification is deemed impossible or involves a disproportionate effort for Grupo Vista Alegre. In case Grupo Vista Alegre has made public the Customer Data and it is obliged to delete it pursuant to the right of such deletion, Grupo Vista Alegre undertakes to ensure that reasonable measures, including those of a technical nature, taking into consideration the available technology and the costs of their implementation, are taken to inform those responsible for the actual processing of personal data that the Customer has requested them to delete the links to such personal data, as well as the copies or reproductions thereof.

17. RIGHT TO LIMITATION OF PROCESSING OF PERSONAL DATA

The Customer has the right to obtain, from Grupo Vista Alegre, the limitation of the processing of his or her personal data if one of the following applies:

• If you contest the accuracy of the personal data, for a period that allows Grupo Vista Alegre to verify its accuracy;

• If the processing is unlawful and the Customer opposes to the deletion of the data, requesting, in return, the limitation of its use;

• If Grupo Vista Alegre no longer needs Customer Data for processing purposes, but such data is required by the customer for the purposes of asserting, exercising or defending a right in legal proceedings;

• If the Customer has objected to processing, until it is ascertained that the legitimate grounds of Grupo Vista Alegre prevail over those of the User. When Customer Data is subject to limitation, it may, with the exception of storage, only be processed with the consent of the User or for the purpose of asserting, exercising or defending a right in legal proceedings, defending the rights of another natural or legal person, or for reasons of public interest as provided by law. Customers who have obtained the limitation of the processing of their data in the aforementioned cases shall be informed by Grupo Vista Alegre before the limitation of processing is cancelled. In case of limitation of data processing, Grupo Vista Alegre shall inform each recipient to whom the data have been disclosed, unless such communication is deemed impossible or involves a disproportionate effort for Grupo Vista Alegre.

18. RIGHT TO PORTABILITY OF PERSONAL DATA

The Customer shall have the right to receive the personal data concerning him/her which have been provided to Grupo Vista Alegre, under a structured, commonly used and machine readable format, as well as the right to forward such data to another processing officer, if:

• Processing is based on consent or on a contract to which the Customer is a party;

• Processing is automated. The right of portability does not include inferred data or derived data, i.e., personal data that are generated by Grupo Vista Alegre as a result of the analysis of the data undergoing processing.

The Customer has the right to have his/her personal data transmitted directly between processing officers, whenever it is technically possible.

19. RIGHT TO OBJECT TO PROCESSING

The Customer has the right to, at any time, for reasons related to his/her particular situation, object to his/her personal data processing, and which is based on exercising the legitimate interests pursued by Grupo Vista Alegre, or when processing is carried out for purposes other than those for which the personal data were collected, including profiling, or when the personal data are processed for statistical purposes. Grupo Vista Alegre will cancel the processing of Customer data unless there are urgent and legitimate grounds for such processing which override the interests, rights and freedom of the Customer, or for the purposes of asserting, exercising or defending a right of Grupo Vista Alegre in a legal proceeding. When the Customer data are processed for direct marketing purposes, the Customer shall have the right to, at any time, object to his/her data processing, for the aforementioned purposes, including profiling, as long as related to direct marketing. In the event that the Customer objects to the processing of his/her data for the purposes of direct marketing, Grupo Vista Alegre shall cease processing data for such purposes. The Customer shall also have the right not to be subject to any decision taken solely on the basis of automated processing, including profiling, which produces legal effects, or which affects him/her significantly, unless the decision:

• Is necessary for the conclusion or the execution of a contract between the Customer and Grupo vista Alegre;

• Is authorized by legislation to which Grupo Vista Alegre is subject; or

• Is based on the Customer’s explicit consent.

20. PROCEDURES FOR EXERCISING CUSTOMER RIGHTS

The right of access, the right of correction, the right of deletion, the right of limitation, the right of portability and the right to object may be exercised by the Customer by contacting the Privacy Department by e-mail rgpd@vistaalegre.com For further information please contact the Data Protection Officer of Grupo Vista Alegre at dpo@vistaalegre.com or by letter addressed to the DPO of Grupo Vista Alegre: Lugar da Vista Alegre, 3830-292 Ílhavo - Portugal.

Grupo Vista Alegre shall respond in writing (including by electronic means) to a Customer’s request within one month from receipt of the request, except in cases of particular complexity, where such period may be extended to two months. If requests submitted by the Customer are unjustified or excessive, in particular due to their repetitive characteristics, Grupo Vista Alegre reserves the right to charge administrative costs or refuse to comply with the request.

21. CHANGES TO PRIVACY POLICY

Grupo Vista Alegre reserves the right to change this Privacy Policy at any time. We encourage you to read this document regularly.

22. RIGHT TO FILE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You can always file a complaint with the competent supervisory authority to protect personal data. In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados, located at Av. D. Carlos I, 134 - 1.º 1200-651 Lisboa, with the telephone number (+351) 213928400 and e-mail: geral@cnpd.pt.