5C Company

COOKIE POLICY

5C Company LLC

Last updated: May 11, 2026

1. PURPOSE

This Cookie Policy is intended to inform, clearly and transparently, how 5C Company LLC ("Company") uses cookies and similar technologies on its website, in compliance with:

Brazil’s General Data Protection Law – LGPD (Law No. 13.709/2018);
Federal Trade Commission Act (FTC Act – EUA);
California Consumer Privacy Act / CPRA (CCPA/CPRA – EUA), where applicable;
Texas Data Privacy and Security Act (TDPSA – Texas);
Other applicable international data protection laws.

By accessing the Company’s website, the user consents to the use of cookies as described in this Policy, subject to the consent options made available.

2. WHAT ARE COOKIES

Cookies are small text files sent to the user’s device (computer, smartphone, or tablet) by the web browser during the user’s visit to a website.

These files allow the Company to:

Store user preferences;
Recognize navigation patterns;
Improve the website user experience;
Personalize content and functionality.

Cookies generally do not directly identify an individual user, but may constitute personal data when combined with other information that enables identification, pursuant to the LGPD and applicable U.S. laws.

3. PURPOSES OF COOKIE USE

5C Company LLC uses cookies to:

Ensure proper operation of the website;
Improve performance and security;
Analyze usage and navigation patterns;
Personalize content and preferences;
Fulfill legal and regulatory obligations;
Prevent fraud and unauthorized access.

4. TYPES OF COOKIES USED

4.1 Essential (Strictly Necessary) Cookies

These cookies are indispensable for the website to operate and cannot be disabled.

Purposes:

Enable secure navigation;
Provide access to restricted areas;
Authenticate sessions;
Prevent fraud and unauthorized access.

Legal basis:

LGPD: art. 7º, V e IX (performance of contract and legitimate interest)
U.S. laws: security and essential operation of digital services

4.2 Performance and Analytics Cookies

These cookies collect anonymous information about site usage to improve features and performance.

Examples:

Most visited pages;
Time spent on pages;
Navigation errors.

Legal Basis:

User consent (LGPD art. 7º, I)
Legitimate interest under applicable U.S. laws

4.3 Functionality Cookies

These cookies enable the website to remember user preferences, such as language and location.

Purpose:

To enhance the personalized browsing experience.

5. SESSION COOKIES AND PERSISTENT COOKIES

Session Cookies: Temporary cookies are stored only for the duration of the browsing session and are deleted when the browser is closed.

Persistent Cookies: Cookies that remain on the user’s device until manually deleted by the user or until they expire automatically.

6. USER CONSENT AND CONTROL

The user may, at any time:

Accept all cookies;
Reject non-essential cookies;
Configure consent preferences;
Delete cookies directly via the browser.

Refusal of optional cookies will not prevent use of the website but may affect certain functionalities and the user experience.

7. SHARING OF DATA COLLECTED BY COOKIES

5C Company LLC does not sell personal data. Information collected through cookies may be shared only with:

Technology service providers;
Analytics and security service providers;
Law enforcement or regulatory authorities, when required by law.

All sharing shall be conducted in accordance with the principles of Brazil’s LGPD and applicable U.S. laws.

8. LEGAL BASES FOR DATA PROCESSING

The use of cookies may be based on the following legal grounds:

Under the LGPD:

Consent of the data subject (Art. 7, I);
Legitimate interest (Art. 7, IX);
Compliance with a legal obligation (Art. 7, II);
Performance of a contract (Art. 7, V).

Under applicable U.S. law:

Legitimate business interest;
Compliance with legal obligations;
Consumer notice and transparency requirements (including, as applicable, FTC guidance, CCPA, and related state laws).

9. DATA SECURITY AND RETENTION

5C Company LLC implements appropriate technical and organizational measures to protect data collected via cookies against:

Unauthorized access;
Improper use;
Unauthorized alteration or destruction.

Data will be retained only for the necessary period to fulfill the purposes set forth in this Policy or as required by law.

10. USER RIGHTS

Under the LGPD and applicable U.S. laws, users may exercise the following rights:

Confirmation of the existence of processing;
Access to personal data;
Correction of incomplete, inaccurate, or outdated data;
Request for deletion of data;
Withdrawal of consent;
Objection to processing, where applicable.

11. CHANGES TO THIS POLICY

This Cookie Policy may be updated at any time to reflect legal, regulatory, or operational changes.

The updated version will be made available on the company’s official website, with the date of the last revision indicated.

12. CONTACT AND DATA PROTECTION OFFICER

For questions, requests or to exercise data subject rights concerning personal data and cookies, contact:

5C Company LLC – Compliance & Data Protection
E-mail: [email protected]

13. FINAL PROVISIONS

Continued use of the website after presentation of the cookie notice will be deemed acceptance of this Policy, subject to the consent options made available to the user.

This Policy has been prepared in accordance with Brazil’s LGPD and the principal applicable U.S. data protection laws.

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