1. Introduction

The commercial company ATLANTREES S.A. (hereinafterthe ‘Company’), as an entity that operates the commercialisation ofagricultural products, including, in particular, the cultivation andcommercialisation of avocados, undertakes as a maximum and central commitmentin its commercial activity, the processing of personal data of its Clients(hereinafter the ‘Data Subjects’), ensuring full respect for their privacy andthe protection and security of personal data against external threats andinternal misuse, in compliance with Regulation no. 2016/679 of the EuropeanParliament and of the Council of 27 April 2016 (hereinafter the ‘GDPR’).2016/679 of the European Parliament and of the Council of 27 April 2016(hereinafter ‘GDPR’).

As such, the Data Subjects are aware of and have theright to be informed, within the scope of the respective contract, about howthe Companies collect, organise, store, consult, share, use, correct, store,process, protect and delete the Data Subjects' Personal Data provided to them.

This Personal Data is provided through the [ www.atlantrees.com] website.

The legitimate purposes for which the Personal Data isprocessed by the Company result from the obligation arising from the relevantlegislation for the Company to ensure the existence of lawful conditions topromote the processing of the Data Subjects' Personal Data. In the specificcase of the Company, the Personal Data Subjects that will be processed are theClients and users of the Website.

In addition, the Data Subjects also have the right tobe informed about the processing of their Personal Data for other relevantpurposes within the scope of the operation carried out by the Company,circumstances which the Company intends to inform the Data Subjects of, underthe terms of this Privacy Policy.

Accordingly, the Company has posted its privacy policyon the [ www.atlantrees.com] website, and any DataSubject may and should access and carefully analyse this privacy policy, whichhas been written in a clear and simple manner to facilitate understanding andthe exercise of the respective rights of the Data Subjects (also referred to asARCO Rights).

2. Scope of Application and Responsibility for Processing

This privacy policy applies to personal data processed by the Company, directly or indirectly, within the scope of its commercial activity, obtained through the Website.

Within the scope of the processing of personal data indicated above, the Company may define specific privacy policies that improve, develop or specify specific aspects of the processing of personal data carried out for the purpose indicated or for new purposes that may be developed or promoted by the Company, obliging itself to ensure compliance with the GDPR in relation to such new activity developments.

In compliance with the applicable legal provisions, these sectoral privacy policies will be made known to the Data Subjects through the means agreed between the Parties and available for this purpose, incompliance with the applicable legal and contractual provisions.

It’s responsible for processing the Personal Data Subjects:

ATLANTREES S.A., a commercial company with registered offices at Avenida da Liberdade n. º 249, 1º, 1250-143 Lisboa, registered with the Commercial Registry under the single registration and legal person number515617598.

You can contact the Company on any matter relating to this privacy policy via the following contact points of the Data Protection Officer:

Email address: [ info@atlantrees.com]

Dedicated telephone line: [+351-910433525]

Registered Mail with acknowledgement of receipt:

Registered Mail with acknowledgement of receipt:


[-].

In addition to the above, the data controller may, in specific and particular cases - which are the subject of a sectoral privacy policy - subcontract third parties to carry out the processing of personal data in question - for example in the context of the management and maintenance of IT platforms - always ensuring, at all times, the rights and guarantees of the Data Subjects and the fulfilment, by said subcontractors, of the applicable legal, regulatory and contractual obligations.

In this specific case, the Company subcontracts management and maintenance services for the [www.atlantrees.com] website.



3. Processing Purposes and Legal Grounds

The Personal Data of Clients and users of the Website- within the scope of any recruitment tender processes carried out through the website - include:
(i) With regard to Customers:
All the personal data identified is adequate, relevant and limited to the respective purposes, thus fully respecting the essential principles of the GDPR.

The Company processes the Personal Data Subject's personal data in an automated way for specific purposes, strictly and completely observing the grounds for lawfulness set out in the GDPR, applicable as the case may be.

To summarize, the purposes for which Personal Data is processed and the respective conditions of lawfulness are as follows:
Purpose of Processing
Condition of Lawfulness
Processing  of Customers' Personal Data for marketing purposes, including but not limited  to (i) providing information on news of the Relevant Company's social  activity (Newsletters), (ii) granting promotional discounts and (iii) other  institutional information
Consent  given by the Data Subject for these specific purposes.
Processing  of Customer Personal Data for the purposes of statistical analysis and  commercial management of the Company
Processing  necessary for the protection of legitimate interests pursued by the Company
Processing  of Customer Personal Data for the purposes of Complaints
Compliance  with the Company's legal obligations
Processing  of Technological Personal Data (cookies)
Consent  given by the Data Subject for this specific purpose

4. Communication of Personal Data

The Company grants access to the Personal Data of the Data Subjects to third parties subcontracted exclusively with a view to ensuring the provision of services necessary for the management and maintenance of the Website, namely in the management of the programmers included in said platform and their current and future developments.

In the areas described above, the Company, incompliance with the applicable legal and regulatory obligations, requires the aforementioned subcontractors to undertake to take all necessary security precautions, given the nature of the Personal Data and the risks presented by its processing, to protect the security of the Personal Data provided by the Data Subjects and, in particular, to ensure, as far as possible, that it is not distorted or corrupted or accessed by unauthorized third parties.

5. Subcontractors

The Company grants access to the Personal Data of theData Subjects to third parties subcontracted exclusively with a view toensuring the provision of services necessary for the management and maintenanceof the Website, as indicated in Chapter 4.

In the areas described above, the Company, incompliance with the applicable legal and regulatory obligations, requires theaforementioned subcontractors to undertake to take all necessary securityprecautions, given the nature of the Personal Data and the risks presented byits processing, to protect the security of the Personal Data provided by theData Subjects and, in particular, to ensure, as far as possible, that it is notdistorted or corrupted or accessed by unauthorized third parties.

6. International Transfers of Personal Data

The Company and the entities described in Section 5. above will process the Personal Data of the Data Subject entirely within the territory of the European Economic Area (EEA), and therefore does not plan to carry out any international transfer of Personal Data.

7. Retention period

The Company will keep the Personal Data of the Personal Data Subjects only for the time necessary to fulfil the purpose for which they were collected, and the Personal Data will be deleted after express and autonomous communication by the Personal Data Subject, under the terms setout in the following Chapter.

In general, and with the exception of the defense of legitimate interests by the Company, the retention periods in force are as follows:
Purpose of Processing
Retention Period
Processing of Customers' Personal Data within thescope of managing the provision of services developed by the Company, the legalrelationship established with the Customer and the invoicing process;
In fulfilment of legal obligations and the Company's  legitimate interest, the Personal Data obtained will be kept for the period  necessary to ensure applicable tax obligations.
Processing of Customers‘ Personal Data for marketing  purposes, including but not limited to (i) providing information on news of  the Relevant Company's social activity (Newsletters), (ii) granting  promotional discounts and (iii) other institutional information;
Customers' Personal Data enabling the fulfillmentof the described purpose will be kept until the Data Subject's request fordeletion of Personal Data or in the event of account inactivity for a period ofmore than 5 years.
Processing of Customers' Personal Data with a view  to statistical analysis and commercial management of the Company
Customers' Personal Data that enables the fulfillmentof the purpose described will be kept until the Data Subject requests thedeletion of their Personal Data or for the period necessary to ensure the legalobligations of the Controller.
Processing of Customer Personal Data for Complaint  Purposes
Customer Personal Data that enables the fulfillment  of the described purpose will be kept until the request for deletion of the  Data Subject's Personal Data or for the period necessary to ensure the legal  obligations of the Controller
Processing of Technological Personal Data (cookies)
Customer Personal Data that enables the fulfillment  of the purpose described will be kept until the request for deletion of the  Personal Data of the Data Subject or for the period necessary to ensure the  legal obligations of the Data Controller.

8. ARCO Rights of Personal Data Subjects

Each and every Data Subject who provides the Company with their Personal Data may, at any time and free of charge - in compliance with the applicable legislation - exercise their rights to access, rectify, erase (or de-index) their Personal Data or, depending on the applicability of such options, the right to limit or oppose the processing and portability of their Personal Data.

Likewise, with regard to the processing of Personal Data that has been consented to by the Data Subjects, the Company ensures that the Data Subjects are able to exercise their right to revoke their consent, incompliance with all applicable legal provisions.

All of the above rights must be exercised, alternatively, through the following platforms and as far as technically possible:

Email address: [info@atlantrees.com]

Dedicated telephone line: [+351-910433525]

Registered Mail with acknowledgement of receipt:

A/C Data Protection Officer

[Elisabete Marques].

On the website at [www. atlantrees.com]

The Company fulfils and will comply with all the mandatory information rights provided for in the applicable legislation, within the scope of the respective binding contractual relationships entered into between the Company and the Personal Data Holders.

The Company fulfils and will comply with all the mandatory information rights provided for in the applicable legislation, within the scope of the respective binding contractual relationships entered into between the Company and the Personal Data Holders.

The Company undertakes, at all times and in any event, to comply with the legally established deadlines for the completion and execution resulting from the exercise of ARCO rights by any Personal Data Holder.

The Company reserves the right to exercise, in accordance with the respective legal and regulatory framework, all the rights of exception granted by the applicable legislation, for the full / partial execution of the ARCO rights of the Personal Data Subjects.

In any case, the Data Subject may, if they consider that the Company has violated or may have violated their rights under the applicable data protection legislation, lodge a complaint with the National Data Protection Commission.

9. Responsibility of the Personal Data Subject

When using the Website or any of the technologicaltools made available by the Company, the Data Subject undertakes to exercisethe utmost caution in order to avoid any unauthorised access to their PersonalData, maintaining total confidentiality of their password and of theinformation that may appear in their Personal Account (if any).

In the event that the Data Subject or any other user of the Website or any of the technological tools made available by the Company provides false or inaccurate information to the Company, the latter cannot beheld responsible for such circumstance.

10. Compulsory nature of the Personal Data requested

Personal Data that is not duly identified as ‘optional’  in the forms provided by the Company must be completed in order to fulfil the aforementioned purposes.
In the event that the Data Subject or any other user of the Website or any of the technological tools made available by the Company provides false or inaccurate information to the Company, the latter cannot beheld responsible for such circumstance.

As such, if the Data Subject does not provide thePersonal Data necessary to fulfil the purposes set out above, the Company willnot be able to comply with their request.

11. Personal Data Protection Measures

Bearing in mind the Company's great concern and commitment to defending privacy issues, various technical and organisationalsecurity measures have been adopted to protect the personal data provided to us against its dissemination, loss, misuse, alteration, unauthorized processing or access, as well as against any other form of illicit processing.

To this end, the personal data collection forms require encrypted sessions and all the personal data you provide us with about yourself is stored securely in the systems contracted by the Company, with additional access control and the impossibility of withdrawing information, under cover of all the physical and logical security measures that we believe are indispensable for the protection of your Personal Data.

For further clarification, please contact the Company through the Data Protection Officer, using the means identified in Point 2. above.

12. Information regarding the Personal Data Subject's electronic device and Cookie Policy

The Company obtains technical information from the user's device whenever they visit the application via their mobile phone. The information obtained relates to the navigation of the application.

The website [ www.atlantrees.com] uses cookies. Find out more and accept or reject their use on this website.

For further clarification, please contact the Company through the Data Protection Officer, via the means identified in Point 2.above.

13. Applicable Law

This Privacy Policy is produced and fully subject toPortuguese Law and the GDPR.

14. Changes to the Privacy Policy

The Company reserves the right to amend its Privacy Policy described herein or any terms and conditions of Sectoral Privacy Policies, always in full compliance with applicable national and EU legislation.

Cookies Policy

In order to facilitate navigation on our website(hereinafter, ‘Website’), Atlantrees S.A., a commercial company with the legalperson identification number 516567292 and with registered offices at Avenidada Liberdade, nº 249, 1º piso, 1250-143 Lisboa, (hereinafter, ‘Atlantrees’), asthe owner of the same, informs you that it uses cookies, mobile identifiers,control URLs, log data and other similar technologies (hereinafter, ‘Cookies’).

This Cookie Policy should be read in conjunction with our Privacy Policy.

For any questions about our Cookie Policy you cancontact us at the following e-mail address: info@atlantrees.com

I) Why does Atlantrees use cookies?

We use cookies and other technologies for various purposes, such as:

II) Cookies

Cookies are small files containing information that are downloaded to your device when you visit a web page and which make it possible to identify the accessing device, as well as the pages and elements accessed, in order to improve your experience.

Cookies are essential for the functioning of the Internet, since they offer technical solutions that allow the user to navigate through the different websites, they cannot damage the user's equipment/device and they can be used to identify and resolve possible errors in the functioning of the Website. They may also be used for advertising or analytical purposes.

This page describes what information they collect, how we use it and the reasons why we need to store these cookies. We will also share with you how you can prevent these cookies from being stored, however, this may downgrade or ‘break’ certain elements of the Website's functionality.

III) How we use cookies

Specifically, we use cookies set by us - which are called first-party cookies - generated directly by this domain and third-party cookies - which are cookies from a different domain, generated from other websites, belonging to third-party companies.

In addition to cookies, we use web beacons, which are small graphic images(also known as pixel tags)that may be included in web pages, emails, services, applications or messages in order to transfer data back to the Website. It can work in conjunction with cookies to identify users and their behavior. Information from web beacons issued for various reasons, such as to compile website traffic reports, advertising and email audits and personalization.

We use cookies and other tracking technologies for various reasons, detailed below.

There are two types of cookies used on the Website:(1) ‘session cookies’ and (2) ‘persistent cookies’. Session cookies usually expire when you close your browser, while persistent cookies remain on your device after you close your browser and can be used again the next time you access the Website.

IV) Managing cookies

You can accept, refuse or manage/configure your Cookie preferences via our Cookie Notice. Once the settings have been selected, youkan modify or deactivate part or all of the Cookies at any time, except for necessary Cookies (the deactivation of which could invalidate the basic functionalities of the Website).

In addition, you can manage the configuration of Cookies by adjusting the settings of your browser. All browsers are different, so you should consult the ‘Help’ section of your browser for more information on cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or refuse cookies it may affect the features and certain functionalities of the Website.

V) Cookies we use

●  Flash Cookies

We may use Flash Cookies, also known as local storage objects, and similar technologies to personalize and improve your online experience. A Flash cookie is a small data file that is inserted into a computer using Adobe Flash technology. Adobe Flash Player is an application that allows you to develop dynamic content quickly, such as video clips and animations.

We use Flash cookies to personalize and improve your online experience and to make content available to Flash players. We may also use Flash cookies for security purposes, to collect website metrics and to rememorize settings and preferences. Flash cookies are managed through a different interface to the one provided by your browser. To manage Flash cookies, see the Adobe website.

If you disable Flash cookies or other similar technologies, you may not have access to certain content and product features, such as your device memorizing an Ad you viewed during a previous visit.

● Third-party social plug-ins

The Website may use social plug-ins provided and operated by third parties, such as the Facebook Like button. As a result, you may send the third party the information you are viewing on a particular part of the Website. If you are not logged into your account with the third party, the third party may not know your identity. If you are logged into your account with the third party, the third party may link information or actions about your interactions with the Website to your account with them. Please refer to the third party's privacy policies to learn more about their data practices.

●  Necessary Cookies

These cookies are necessary for the Website to function, allowing the user to navigate the Website and use the different options or services that exist on it, such as, for example, controlling traffic and data communication, identifying the session, using security elements during navigation.

We do not need your consent to install these cookies on your device, and their use is based on the need to provide the services requested. You can configure your browser to deactivate or block all cookies, but some of the utilities available on the Website will not work.


● Functionality Cookies

These cookies make it possible to remember the user's preferences regarding the use of the Website, so that it is not necessary to reconfigure the website each time they visit it, and to differentiate their experience from that of other users. If the user chooses these features themselves (for example, if they select the language of the Website), the cookies will be considered as a service expressly requested by the user, and will therefore be used exclusively for the selected purpose and without requesting their express consent. If you do not allow these cookies, some of these features may not work correctly.

●   Analytical Cookies

These cookies collect information about how visitors use the Website. The function of these cookies is to obtain statistics and reports so that we can measure and improve the performance of our Website. They help us, for example, to know which pages are the most and least popular, whether they receive error messages from web pages, or which buttons on the Website they click on. All the information collected by these cookies is aggregated and therefore anonymised.These cookies are only installed on the user's device when the user accepts them.

● Advertising Cookies

These cookies are used to show you adverts that are relevant to you, as well as to help measure the effectiveness of advertising campaigns. They may be set via our Website by our advertising partners. They may be used by these companies to build up a profile about your interests and show you relevant adverts on other websites. They do not directly store personal information, but are based on the unique identification of your browser and internet device.

These cookies are only placed on the user's device when the user accepts them. If you do not allow these cookies, you will receiverless targeted advertising.

The Website may use services from external providers(such as official YouTube videos or plug-ins and other site drivers and tools) which may collect information from the user about their browsing on the webpages. When visiting publications with content such as those mentioned above, cookies from these websites may be created. We have no control over the dissemination of these cookies.

The Website may use services from external providers(such as official YouTube videos or plug-ins and other site drivers and tools)which may collect information from the user about their browsing on the webpages. When visiting publications with content such as those mentioned above, cookies from these websites may be created. We have no control over the dissemination of these cookies.

VI) Changes to the cookie policy

We may, at any time, make adjustments or changes to this Cookie Policy, and such changes will be duly publicized on the Website.