Code of Ethics

Introduction

In Loco

We are a Brazilian localization technology company. We offer business solutions which use localization data for brand communication strategies and application user engagement.

What this document is

Our Advertising Ethics Code contains usage rules for our platform, technology, services, products, data (we will collectively call them “Actives”). Here you will find information that is essential for us to work together. And, we believe it’s worth emphasizing, they’re non-negotiable.

Commitment

In order to work with In Loco, you, client, partner, advertiser, service provider or collaborator, must be aware of and accept the rules determined here.

Review and Protest

To ensure perfect compliance of the rules established in this document, In Loco reserves the right to review the creative content to be served in our Actives. The period for this review is on average, from 24 to 48 hours from the date of submission, depending on variables such as campaign size and amount of pieces. We do our best to perform all reviews in this timeframe, but in some cases may take longer. If that happens, we will notify you about it by email. In case the ad isn’t approved, you will receive an email stating the reason and will need to adjust the piece to match In Loco’s guidelines. If you consider this decision to be a mistake, and not in accordance with this document, you may protest the decision by answering the email sent by In Loco’s team. In about two days will receive an answer with our decision by email.

Partners and consumers who in chance may be affected by these ads which are not in accordance with the Ethics Code may initially send a warning through the email [email protected]

Right to Refuse Campaigns

In Loco reserves the right to ask for adjustments to be made in ads, or refuse all together to serve them through its technology, as well as refusing to honor any commercial agreement in case of non-compliance of the rules contained in this In Loco Advertising Ethics Code or in our Privacy Policy (see next subject), regardless of your headquarter’s location, or the ad recipient’s location.

Use of Data

Privacy-Friendly

The first rule you need to know about when using In Loco’s platform, our solutions and our products is that we believe privacy is an inalienable right for each and every citizen.

We defend and act to ensure people’s right to privacy. We do not access, collect, store, process, license, sell, give or in any way pass along information containing a name, civil identification number (such as ID and social security), phone number or personal or corporate email of any user.

Behavior, yes. Identity, no.

The data used by In Loco is collected through partner apps, after being authorized by the app’s user. This data is used only to make a behavioral profile of the user, without ever identifying them.

Privacy Policy

To be our partner, client, advertiser, or to be a part of our team, you need to be aware that our privacy policy is mandatory and all rules have to be followed, without exception.

Visits we map and those we don’t map

Visits we map

Among the visited places where we collect location data are:

• Lawful commercial establishments such as malls, dealerships, restaurants, department stores.
• Public spaces such as squares, parks, and beaches.
• Places where one waits for public transportation, such as bus stops, or subway stations.
• Lawful entertainment spaces such as museums, movie theaters, aquariums, zoos.
• Locations where cosmetics, beauty products, are sold, including pharmacies.
• Locations where one may eat, such as restaurants, fast foods places.

Locations where visits are not identified in our base

Some places in which we do not identify visits, due to their sensitive nature. This means it is not possible to serve ads to impact user, not identify they are in places such as:

• Religious temples
• Political parties
• Places where illegal activities may take place, such as contraband markets.
• Establishments related to sexual activities.
• Places where support is offered to groups of people in sensitive conditions, such as AA meetings.
• Places related to health conditions, such as medical clinics, hospitals, among others.

Content we do not promote

Lobbying

It is not permitted to use In Loco’s Actives to make lobbying campaigns. It is forbidden to campaign for regulation or deregulation of any matter as well as campaigns for or against subjects such as:

• Abortion
• Tobacco
• Licquor
• Promote using or not using any drug
• Weapons
• Political parties
• Political systems
• Candidates to any representative position
• Religious beliefs
• Ideological beliefs
• Any form of prejudice

Political Campaigning

It is forbidden to serve political campaign material for any party or candidate, regardless of region, country or the representative position in question.

Underage Audience

In Loco doesn’t serve ads directed to audiences of 13 or under.

Untruthful Content Campaigns

It is forbidden to use In Loco’s Actives to disseminate untruthful content, that may lead to error, false information or fake news.

Slanderous campaigns, campaigns against honor or containing hate messages

All campaigns promoting a message of hate or prejudice of any kind are forbidden. It is also forbidden for any campaign to slander, insult or defame any person or company.

Promotion of illegal or irregular products

It is forbidden to use In Loco’s Actives to publicize any illegal products or services, according to Brazilian law or any other competent authority. In this category are, for example, drugs, chemical substances of any kind, wild animals, guns, among others.

It is also forbidden to campaign for products which are currently legal but have not yet been certified by competent bodies such as INMETRO e ANVISA, or which are not in accordance with current legislation.

It is forbidden to serve ads of any kind of tobacco or products which include tobacco in its composition, such as cigarettes, cigarillos, cigars, pipes and any other variations.

Medication and any other controlled substances

It is forbidden to serve campaigns which promote, or sell any kind of chemical product, drugs or medication which require a specific authorization to be sold.

Campaigns which put national security at risk

It is forbidden for campaigns to incite the population or its citizens to act in a way which threatens national security, or the security of individuals.

Ads for weapons or explosive materials

It is forbidden to serve ads which intend to sell or promote weapons, including firearms or of any other kinds, as well as their components, and ammunition. Ads promoting explosive materials or any other object that might threaten an individual, or collective security are also forbidden.

Ads for games prohibited by law

It is forbidden to serve ads which intend to promote or publicize games which are illegal in Brazil. In this category, we can find casinos, animal lottery, bingo or any other not organized by Caixa Econômica Federal.

Multilevel Marketing

It is forbidden to serve campaigns promoting any kind of Multilevel Marketing.

Formats we don’t use

Lead

We do not work with lead campaigns for the collection, storage, use or commercialization of any kind of personal identification data.

Suspicious Directions

It is forbidden to direct users to any place, site or information which promotes the practice of illegal activities or which represent safety risks for the users.

Campaigns which carry limitations

Alcoholic Beverages

It is allowed to serve ads for alcoholic beverages as long as the regulations established under Brazilian law are respected.

Financial Services

Serving ads for financial services is allowed as long as they are in accordance with appropriate regulations.

Non-tolerated Practices

Threatening the violation of the right to privacy

It is absolutely forbidden to use In Loco’s Actives to violate someone’s right to privacy.

Personal Identification Information

We don’t use information that directly identifies a person for ad direction. So, campaigns which ask for, collect or provide data like name, civil identification number (such as ID and social security), phone number, or email are absolutely forbidden.

Crimes of any nature

It is forbidden to use In Loco’s Actives to commit crimes of any nature.

Any kind of fraud

It is forbidden to use In Loco’s Actives to commit frauds of any kind, against any institution, company or citizen.

Plagiarism

It is forbidden to serve campaigns, slogans, phrases or any kind of product or content which violates the right to intellectual property of another, thus characterizing this action as improper use.

Establishment Base

It is forbidden to use In Loco’s Actives to segment ads in a way to impact users who go to locations where we can’t identify visits in our base, as stated above.

In Loco’s Commitment

In Loco highlights through its Advertising Ethics Code its commitment to:

• The Brazilian Constitution
• Human Rights
• Right to privacy
• Plurality and diversity
• The Consumer Protection Law
• CONAR - National Council for Self-Regulation in Advertising.

Finally, you recognize you’re responsible for understanding and abiding by all the laws and applicable regulations, including the rules set above in In Loco’s Commitment. The non-observance of these rules, as stated in this Advertising Ethics Code, might result in the termination of your contract with In Loco, including the cancellation of ads, as well as the appropriate legal consequences. In Loco reserves the right to approve, refuse or remove any ad and for any reason, at its discretion, including ads which may negatively affect its relationship with users, or which promote content, services or activities contrary to the interests of In Loco and its Advertising Ethics Code.