PRIVACY POLICY

1. Introduction

The purpose of this Policy is to demonstrate the commitment of:
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Legal entity governed by private law, with office at Coronel Silva Telles Avenue, n° 1002, rooms 31, 32, 33, 34, Cambuí, ZIP Code 13024-001, Campinas, São Paulo, Brazil. CNPJ: 08.583 .723/0001-72 (“We”)

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to the privacy and protection of your Data, in addition to establishing the rules on the Processing of yourPersonal Data, within the scope of services and functionality of Sensedia Portals, our applications, as well as inperson at our physical units (“Our Environments”), in accordance with the laws in force, with transparency andclarity with You and the market in general. As a condition for accessing and using the exclusive features in Our Environments, You declare that you havefully and carefully read this Policy, being fully aware, thus granting your free and express agreement with theterms stipulated herein, including the collection of the Data mentioned herein, as well as its use for thepurposes specified below. If You are not in compliance with the provisions of this Policy, You must discontinueyour access to or use of Our Environments.

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SPECIAL NOTE FOR MINORS UNDER 18 Please do not provide your Personal Data in Our Environments if you are under the age of 18. SPECIAL NOTE FOR LEGAL GUARDIANS Although we prohibit the provision of Personal Data of children and adolescents, parents and/or legalguardians must supervise the online activities of minors under their responsibility.

2. What Personal Data we collect and how it is used

During your interaction with us, your Personal Data may be collected as shown below:

Dados Cadastrais

What is collected?

  • Full name
  • CPF
  • Age
  • Gender
  • Marital Status
  • Nationality
  • Social Network Addresses
  • Email
  • Address
  • Phone
  • Company and position
  • Voice & Image

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What is it collected for?

  1. Identify and authenticate You;
  2. Provide services to You, including answering calls, doubts, questions, suggestions and technical help;
  3. Extend our relationship, inform You about news, features, content, promotions carried out, advertising campaigns and other events that we consider relevant to You;
  4. Allow the registration of requests through our “Customer Service - SAC”;
  5. Recruit employees if You want to work with us;
  6. Guarantee the portability of the Registration Data to another Controller in the same branchof our activity, if requested by You, complying with the obligation of Article 18 of theBrazilian General Data Protection Law.
  7. For promotional and advertising purposes (institutional videos, whose purpose is to reinforce the brand and events held by Sensedia).
  8. Contact the third parties listed as emergency contacts, if necessary, in emergency situations related to safety or well-being.

Information about your interests

What is collected?

  • Your interests
  • Your Habits and characteristics
  • Your Hobbies

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What is it collected for?

  1. Improve our Products and Services;
  2. Measure the satisfaction of using our services or products or the effectiveness of our advertising campaigns

Payment Data

What is collected?

  • Credit card number and security code
  • Bank account details

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What is it collected for?

  1. Comply with legal obligations under our contract by sharing the Data with the third party responsible for processing the payment;
  2. We can process your orders; and
  3. Protect You by performing fraud prevention, credit protection and associated risks, inaddition to complying with legal and regulatory obligations.

Professional Data

What is collected?

  • Occupation
  • History of professional experience
  • Educational background
  • Knowledge of languages
  • Gross Salary

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What is it collected for?

  1. Identify professional profile; and
  2. Recruit employees if You want to work with us.

Health Data

What is collected?

  • Information on workers with disabilities

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What is it collected for?

  1. Recruit employees if You want to work with us; and
  2. Comply with the legal obligations established by Lei das Cotas (Brazilian Affirmative Action Law) - Law no. 8,231/1991.

Digital Identification Data

What is collected?

  • Source IP Address and Logic Port
  • Device (operating system version)
  • Geolocation
  • Your Voice
  • Timestamps of each action You take
  • Which screens You accessed
  • Cookies
  • Video images captured on CCTV

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What is it collected for?

  1. Security monitoring of Our Environments for the sake of yours and our security;
  2. Comply with legal record keeping obligations established by Marco Civil da Internet (Brazilian Civil Rights Framework for the Internet) - Law 12,965/2014; and
  3. Comply with legal obligations for maintenance and recording of calls established by Decree 6523/2008.

● Required data. Many of our services depend directly on some Data indicated in the table above, mainly Registration data. If you choose not to provide some of this Data, we may be unable to provide all or part of our services to You.
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● Data Update and Accuracy. You are solely responsible for the accuracy or lack thereof in relation to the Data You provide or for its outdating. Be aware that it is your responsibility to ensure accuracy or keep it up to date.Likewise, We are not required to process any of your Data if there is reason to believe that such processing could attribute to us any breach of any applicable law, or if You are using Our Environments for any purpose that is unlawful, illegal or contrary to morality.

● Database. The database formed through the collection of Data is our property and is under our responsibility, and its use, access and sharing, when necessary, will be made within the limits and purposes of the business described in this Policy..

● Technologies employed. We use the following technology(s):-Cookies, and it is up to You to configure your Internet browser if You wish to block them. In this case, some features that We offer may be limited.

● All the technologies used will always respect the current legislation and the terms of this Policy.

We do not use any type of solely automated decision that impacts You.

3. Personal Data of Children and Adolescents

We do not knowingly request, collect, process, store or share Personal Data of underage children and adolescents. If we discover that any type of handling of said data has occurred unintentionally, we will promptly remove the Personal Data of that child or adolescent from our records.However, we may collect Personal Data from children and adolescents directly from their parents or legal guardians, and with the specific and prominent consent given by at least one parent or legal guardian and in accordance with current legislation.

4. Sharing Your Personal Data

We may share your Personal Data with the following third party organizations:

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● Partner companies required to provide the Services: such as, but not limited to, third parties that are used to assist in your service or product operations, such partner companies always being required to comply with the security and data protection guidelines covered in this Policy.

● Third party companies that use Personal Data for their own marketing purposes: We will not license or sell your Personal Data to third parties to use for their own marketing purposes. In cases where this type of sharing occurs, the identity of these third parties will be revealed before obtaining your consent.

● Automatically in cases of corporate transactions such as merger, acquisition and consolidation : If We or your assets are acquired, merged or consolidated with another company, or if we have declared our bankruptcy, we will share your Personal Data with our legal successors, respecting the requirements in force in this situation.

● With authorities: whenever there is a legal determination, request, requirement or court order from competent judicial, administrative or governmental authorities.

● Data Anonymization. For the purposes of market intelligence research, disclosure of data to the press and advertising, the data provided by You will be shared anonymously, that is, in a way that does not allow your identification.

5. Retention and Termination of the Processing of Your Personal Data

In accordance with current legislation, We will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected, as described in this Policy, or to comply with applicable legal requirements. In this sense, when the processing of your Personal Data ends, it will be eliminated within the scope and technical limits of the activities, with conservation permitted in the situations provided for in the current legislation.We may also keep records of CCTV recordings for short periods in accordance with our policies of security and monitoring of physical environments to protect You, our employees and Our Environments.For the purposes of auditing, security, fraud control, credit protection and preservation of rights, We may remain with the your Data record history for a longer period of time in the event that the law or regulatory rule so establishes or for the preservation of rights.The collected Data may be stored on our servers located in Brazil, as well as in an environment of use of resources or servers in the cloud (cloud computing), which may require the transfer and/or processing of this Data outside of Brazil.

6. How We Protect Your Data and How You Can Protect It

We take appropriate measures to ensure that your Personal Data is kept confidential and secure. However, when You use Our Environments, You may be taken, via a link to other portals or platforms, which may collect your information and have their own Data Processing Policy.

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● People who can access your Personal Data:: Your Personal Data will be handled by our employees or authorized agents, as long as they need access to such information, depending on the specific purposes for which your Personal Data has been collected.

● Measures taken in operational environments: We store your Personal Data in operational environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data.

● Measures that we expect You to take: It is important that You also keep your Personal Data safe. When creating an online account, please be sure to choose a password that is strong to prevent unauthorized users from guessing it. We also recommend that You never reveal or share your password with others. You are solely responsible for keeping this password confidential and for any action taken through your account on the supported websites and services.

-If You use a shared or public computer, never choose the option to remember your login, email address or password, and make sure that You log out of your account (logged out) whenever you leave the computer. You must also use any privacy settings or controls that We provide on your website, services or applications, including those considered optional..

● Transfer of your Personal Data: Given the nature of our services and products, it is possible that We may need to transfer your Personal Data to third parties, in accordance with the purpose set out in this Privacy Policy. For this reason, We may transfer your Personal Data to other countries, as long as they have laws and regulations compatible with those in force in Brazil.

● Partner services. We have business partners who might occasionally offer services through features or websites that can be accessed from Our Environments. The Data provided by You to these partners will be their responsibility, thus being subject to their own data collection and use practices.

● Third party processing under our guideline: If outsourced companies carry out the Processing on our behalf of any Personal Data that We collect, they will mandatorily respect the conditions stipulated herein and the information security rules.

7. Your Rights Regarding Personal Data

You have the right to request confirmation of the existence of processing of Personal Data, in addition to access or rectification of your Personal Data.At any time, You may also limit the use and disclosure, or revoke consent to any of our activities for the processing of your Personal Data, except in situations provided for in the legislation in force. These rights can be exercised through the communication channels detailed in this Policy. If You withdraw your consent to purposes that are fundamental to the regular functioning of Our Environments and services, such environments or services may be unavailable to You. We emphasize that, in certain cases, We cannot delete your Personal Data without also deleting your user account. In addition, some situations require the retention of your Personal Data after You request its deletion, in order to comply with legal, regulatory or contractual obligations.

8. Changes to our Privacy Policy

Whenever We decide to change the way We process your Personal Data, this Policy will be updated. We reserve the right to make changes to our practices and this Policy at any time, depending on the purpose or need, such as for the adequacy and legal compliance of a provision of law or rule that has equivalent legal force, and it is up to You to check it whenever You access Our Environments or use our services.

9. How to Contact Us:

In case of any doubt regarding the provisions contained in this Privacy and Data Processing Policy, You can contact us through the service channels listed below, whose opening hours are from Monday to Friday, from 8:00 a.m. to 5:00 p.m., except for national holidays:

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● Person in charge of the Processing of Personal Data: Mariana Rosignoli

● E-mail: privacy@sensedia.com

● By phone: +55 19 3500.8265

● In person or by mail: Coronel Silva Telles Avenue, n° 1002, rooms 31, 32, 33, 34, Cambuí, ZIP Code 13024-001, Campinas, São Paulo, Brazil.

You acknowledge that all communications made by email (to the addresses informed in your registration), SMS, instant communication applications or any other digital form, are also valid, effective and sufficient for the disclosure of any matter that refers to the services We provide, your Data, as well as the conditions of its provision or any other matter addressed therein, with the sole exception of what this Policy provides for as such.

10. Jurisdiction and Governing Law

This Policy will be interpreted in accordance with Brazilian law, in the Portuguese language, and the jurisdiction of your domicile will be chosen to settle any dispute involving this document, except in the case of a specific proviso of personal, territorial or functional jurisdiction by applicable legislation.If You do not have a domicile in Brazil, and due to the services offered by Us only in the national territory, You submit yourself to the Brazilian law, agreeing, therefore, that in the event of any dispute to be resolved, the action must be brought before the Courts of the Judicial District of Campinas/SP.

11. Definitions

● Anonymization: Use of reasonable and available technical means at the time of Processing, whereby data loses the possibility of direct or indirect association with an individual.

● Controller: One who is responsible for decisions regarding the processing of personal data.

● Cookies: Small files sent by Our Environments, saved on your devices, that store preferences and little other information, in order to personalize your navigation according to your profile.

● Data: Any information entered, processed or transmitted through Our Environments.

● Personal Data: Any information collected directly or indirectly by us or our affiliates capable of making an identified natural person identified or identifiable.

● Solely automated decisions: These are decisions that affect a user that have been programmed to function automatically, without the need for human operation, based on automated processing of personal data.

● Person in Charge: person appointed by the controller and operator to act as a communication channel between the controller, the data subjects and the Brazilian National Data Protection Authority (“ANPD”).

● Purposes: the purpose we want to achieve from each act of processing personal information.

● Our Environments: Designates the electronic addresses https://br.sensedia.com/, https://portal-demo.sensedia.com/api-portal/ , their subdomains, our applications and our physical units.

● Operator: One who performs the processing of personal data on behalf of the controller.

● User: All individuals who will use or visit the Website(s) and/or Application(s), over 18 (eighteen) years old or emancipated and fully capable of practicing the acts of civil life. Here in this policy referred to as “You”.

● Processing: Any operation performed with Personal Data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction.