1. Introduction

Vitary Assistance & Benefits (“Vitary”, “we”, or “Company”), headquartered in Miami, Florida, United States, is committed to protecting the privacy and personal data of its users, clients, and partners.

This Privacy Policy describes how we collect, use, store, share, and protect personal data in compliance with applicable laws, including, where applicable, the General Data Protection Regulation (GDPR) and United States privacy laws such as the California Consumer Privacy Act (CCPA/CPRA).

By accessing or using our services, you acknowledge that you have read and agree to the terms of this Policy.

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2. Scope and Applicability

This Policy applies to all users of the services provided by Vitary Assistance & Benefits, regardless of their location, including users in the United States, Brazil, and the European Economic Area (EEA).

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3. Legal Bases for Data Processing

Depending on the applicable jurisdiction, Vitary Assistance & Benefits processes personal data based on:

• Performance of a contract
• Compliance with legal obligations
• User consent
• Legitimate interests of the Company
• Fraud prevention and credit protection

For users subject to the GDPR, processing is based on Article 6 of the Regulation.

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4. Personal Data Collected

Vitary Assistance & Benefits collects personal data both directly and automatically.

4.1 Data Provided by the User

• Full name
• Email address
• Phone number
• Address
• Company information (when applicable)
• Payment details

4.2 Data Collected Automatically

• IP address
• Browsing and interaction data
• Device and browser type
• Access logs
• Cookies and similar technologies

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5. Purposes of Data Processing

Personal data is processed for the following purposes:

• Providing contracted services
• Payment processing and billing
• Communication with users
• Sending updates and institutional content
• Customer support
• Platform improvement and optimization
• Fraud prevention and security
• Compliance with legal and regulatory obligations

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6. Cookies and Tracking Technologies

Vitary Assistance & Benefits uses cookies and similar technologies to:

• Ensure proper platform functionality
• Analyze user behavior
• Personalize user experience
• Improve performance
• Deliver relevant content

Users may manage cookies through their browser settings.

For users in the EEA, non-essential cookies are used only with prior consent, in accordance with GDPR and the ePrivacy Directive.

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7. Data Sharing

Vitary Assistance & Benefits may share personal data with:

• Service providers and technology partners
• Financial institutions and payment processors
• Government authorities, when required by law
• Legal and accounting advisors

All third parties are contractually obligated to ensure data confidentiality and security.

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8. International Data Transfers

Personal data may be transferred to and processed in countries outside the user’s jurisdiction, including the United States.

For users in the EEA, such transfers are carried out using appropriate legal mechanisms, including:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions, where applicable

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9. Data Retention

Vitary Assistance & Benefits retains personal data only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law.

Retention criteria include:

• Contractual necessity
• Legal obligations
• Dispute resolution
• Fraud prevention

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10. Data Security

Vitary Assistance & Benefits implements appropriate technical and organizational measures to protect personal data, including:

• Encryption of data in transit and at rest
• Access control based on least privilege
• Multi-factor authentication
• Continuous security monitoring
• Intrusion detection systems
• Backup and disaster recovery procedures

While we strive to protect your data, no system is completely secure, and absolute security cannot be guaranteed.

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11. Data Subject Rights

Depending on applicable law, users may have the following rights:

Under GDPR:

• Right of access
• Right to rectification
• Right to erasure (“right to be forgotten”)
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent

Under U.S. Laws (e.g., CCPA/CPRA):

• Right to know what data is collected
• Right to request deletion
• Right to request correction
• Right to opt-out of data sharing (where applicable)
• Right to non-discrimination

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12. Exercising Your Rights

To exercise your rights, please contact Vitary Assistance & Benefits at:

Email: suporte@vitary.club

We may request additional information to verify your identity before processing your request.

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13. Children’s Privacy

The services of Vitary Assistance & Benefits are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors.

If such data is identified, it will be promptly deleted.

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14. Updates to This Policy

This Privacy Policy may be updated from time to time. We encourage users to review it periodically.

The latest version will always be available through our official channels.

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15. Contact

For any questions, requests, or concerns regarding this Privacy Policy:

Vitary Assistance & Benefits
Miami, Florida, United States
Email: suporte@vitary.club