Zallpy Digital's Privacy Policy applies to all services offered by Zallpy that use Personal Data (as defined below) of customers, potential customers, employees and/or third parties (“Data Subjects”). (a) Zallpy Software LTDA: software development and support company for large corporations. By accessing and using the products or services offered by Zallpy, you fully agree and accept the provisions of the Privacy Policy. Policy effective from August 9, 2020.

General Data Protection Law (LGPD): Federal Law No. 13.709 published on August 14, 2018 that regulates Personal Data Processing activities, including in digital media, by a natural person or by a legal entity governed by public or private law, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the natural person's personality.

Processing Agents: are those responsible for the Processing of Personal Data and are separated into two categories: the Controller and the Operator. The Controller is the person or company responsible for decisions regarding the Processing of Personal Data. The Operator is the person or company that carries out the Processing of Personal Data on behalf of the Controller, following its instructions.

Anonymization: technique through which data loses the possibility of association, directly or indirectly, with an individual, so that later re-identification is impossible, even if through technical solutions.

National Authority for the Protection of Personal Data (ANPD): is the body of the federal public administration with attributions related to the protection of personal data and privacy, including supervision for compliance with the LGPD.

Cookies: is a small file containing a string of characters, created and sent by websites to your computer whenever you visit them. They help you remember your preferences and personalize your access, making your browsing safer, faster and more enjoyable. You can configure your browser not to accept cookies or notify you when a cookie is being sent, but without them some features or services on the website may be compromised and limited.

Personal Data: are defined in the LGPD as information related to an identified natural person or information that allows his/her identification such as name, address, CPF, RG, identity documents in general, telephone, among others.

Sensitive Data: are defined in the LGPD as Personal Data on racial/ethnic origin, religious conviction, political opinion, union membership, philosophical or political nature, data relating to health or sexual life, genetic or biometric data when linked to a natural person.

Device: is the device that can be used to access services offered by Zallpy, such as desktop computers, tablets and smartphones.

Data Protection Officer: responsible for ensuring Zallpy complies with privacy laws and regulations, ensuring the protection of Personal Data and for being the communication interface with ANPD and with the Data Subjects.

IP Address: This is the number assigned to each Device connected to the internet, known as an Internet Protocol (Internet Protocol or IP) address. These numbers are usually assigned in geographic blocks. An IP address can be used to identify, for example, from which location a Device is connecting to the Internet.

Geolocation: a feature that, when activated by the Data Subject, allows defining the precise or approximate position of a Device and brings information such as the country, state, city and street where this Device is located, also providing the time at which it was accessed.

Data Subject: any identified or identifiable natural person to whom the processed personal data refer. These are, for example, our customers, potential customers, account holders, employees, third parties, service providers, job applicants, among others.

Processing: any operation carried out with Personal Data, whether automated or not. In other words, it is the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

We handle your information to develop and improve our products and services. However, in some cases, you will be able to manage the information used by Zallpy, through one of the privacy service channels, indicated in item 9 of this Policy.

Other information is collected when you use our App or Website and it falls into three categories:

Data provided by the Data Subject: is the information provided by you when interacting, contracting or using any products or services provided by Zallpy, such as:

Name, email, telephone number, CPF, address, profession, marital status, image of your official identity documents or any other Personal Data provided.

Verification and confirmation of Personal Data may, at Zallpy's discretion, be carried out by third-party partner companies, which will respect the same security and privacy criteria as set forth herein.

You will be solely and exclusively responsible for the quality and veracity of the Personal Data provided to Zallpy in carrying out your registration, quotation and/or contracting of any products or services. Zallpy has no responsibility for the veracity of the data provided, as well as for any damage arising from the inaccuracy and/or outdated information.

Data collected during the use of our services on the App or website (browsing): is the information collected by Zallpy when you browse and/or use Zallpy's services.

Browsing data: information we collect about your interactions with the App or website, such as: search history, browsing history, access dates and times, resources used, the way you use products and services, App problems and other system activities. This information is important for a better performance of the functionalities available on the website and App, and for enabling display of relevant content for you.

In some cases, we can do this collection through Cookies, important tools for the perfect functioning of our services. Therefore, you should be aware that if you choose to refuse or remove Cookies, you may have the availability and functionality of Zallpy's services affected. To learn more, see our Cookies Policy.

Devices: We also collect information about the Device you use to access the App and Website, such as: brand, operating system, IP address, type of network connection (WI-FI, 3G, LTE, Bluetooth or others) , network and Device performance, browser type, version, language and App version. This information is necessary to ensure the compatibility of our services with the Device you use and, thus, allow a better experience.

Geolocation: it is the information we collect about your location that allows us to:

• Improve your experience on the App, showing, for example, the location to perform your check-in in our coworking services;

• Identify the origin of an incoming call in our service channels.

We were able to determine your location by the following means:

GPS (check-in, website access); or

IP address (access to chat).

The types of location data we collect depend, in part, on your Device and App settings. You can enable or disable tracking of your location by going to your Device's Settings/Privacy option.

Data collected from other sources: information collected by Zallpy from partner third-party companies, suppliers and service providers, respecting the purposes set out in this Policy. These companies may change depending on the services offered by Zallpy and the information collected.

Zallpy may use the data provided or collected, as described above, to send advertising, mailing or any other means of communication, in compliance with items 6, 7 and 9 of this Policy.

The Personal Data collected under this Policy is used for the following purposes:

• Comply with our contractual obligations, in particular the execution of terms of your contract with Zallpy;

• Comply with applicable legal and/or regulatory requirements;

• Provide our products and services to you;

• To notify you of any changes to our products and services;

• Strengthen our safety and security procedures, aiming at providing a safer and more effective service;

• Manage our provision of services and/or supply of products;

• Perform internal operations, including support to customers and other data subjects, troubleshooting, data analysis, testing, research and statistics;

• Improve and enhance our services and products, ensuring that they are most effectively presented to you;

• Evaluate or understand the effectiveness of the advertising we serve, in order to provide you with relevant advertising;

• Allow you to participate in interactive features of our services, when you choose to do so;

• Provide information about other services and/or products we offer;

• Offer personalized products or services, suitable and relevant to your interests;

• Produce evidence and assist in conducting legal, administrative or arbitration proceedings, as well as assisting in the fulfillment of other legal requirements;

• And make automated decisions regarding the use of our services.

Without prejudice to the purposes set out above, the table below informs, in an exemplary and non-exhaustive way, some of the Personal Data that we handle and the purpose of its processing:

Product/Service:

Contact Form

Ethics Channel

Zallpy Check-In App

Collected data:

Name, email and phone

Name, email, title and gender

Name, email and location

Purpose:

Provide information for tracking and verifying misconduct

Provide coworking services for workroom reservations in our environments

In the event that the Processing of Personal Data of children and/or adolescents is necessary, for any purpose, we will request the specific and prominent consent of at least one of the parents or legal guardian of the Data Subject.

Zallpy has internal procedures and technologies to assist in verifying the powers of the legal guardian, thus seeking to guarantee the validity of consent, as this can only be given by the legal representative of the child and/or adolescent.

After valid consent, the collection and processing of Personal Data from children and/or adolescents is carried out following the rules detailed in this Policy.

The period for Processing of your Personal Data by Zallpy will vary according to:

• With the types of products and services contracted/provided/supplied;

• For the purposes of the Processing;

• With the contractual and legal provisions in question.

Thus, Personal Data will be deleted by Zallpy, except if its storage must be done due to legal or regulatory obligation, when:

• The purpose for which information was collected is achieved or when Personal Data is no longer necessary or relevant for achievement of this purpose;

• When consent is revoked;

• Or upon determination of the competent authority to do so.

The LGPD grants a series of rights to Data Subjects. Therefore, you, as Data Subject, can make requests to Zallpy, as detailed in the table below:

Confirmation of the Processing: You can ask Zallpy to confirm that your Personal Data is being processed and what processing operations are being carried out.

Access to your Personal Data: You can ask Zallpy for information about the Personal Data that we process. We will provide, by electronic or physical means, a copy of the Personal Data we maintain about you. We cannot provide Personal Data to third parties.

Correction of your Personal Data: You can change, request correction or update of your Personal Data, when they are wrong, incomplete or outdated. Before we update your Personal Data, we may request documents and/or information that prove the new information you have provided, in order to guarantee the quality of informed data and its security.

Request the anonymization, blocking or deletion of your Personal Data: You can request that your Personal Data be anonymized, blocked or deleted from Zallpy's bases when these are unnecessary, excessive or treated in violation of the provisions of the LGPD.. You may ask us to delete the Data when:

(i) you believe there is no reason for us to continue using it;

(ii) you wish to withdraw the consent (permission) you gave us in the first instance;

(iii) object to our use of the information;

(iv) you believe that we use the information illegally; or

(v) the law requires us to delete the information. We will not comply with your deletion request when Zallpy is required to store such Personal Data as a result of legal or regulatory obligation.

Portability of your Personal Data: You can request the migration of information registered with Zallpy to another institution. The fulfillment of this request, by Zallpy, will consider the current legal provisions and the Personal Data, when provided, will be in a structured form, in a format commonly used and readable by the systems. We cannot share Personal Data that is confidential or business secret.

Information about sharing your Personal Data: You can request information about public and private entities with which Zallpy has shared data usage. .

Possibility of not providing consent: If you refuse to provide Zallpy with consent to access or Process your Personal Data, we will inform you the consequences of this refusal, which, in some situations, may make the provision of our services unfeasible.

Revoke consents: If you have consented to the Processing of your Personal Data, you may, at any time, cancel such consent. We emphasize that it will be lawful for us to use your Personal Data until the time of revocation of consent, as well as for the archiving of such Personal Data for a period longer than the processing period, whenever necessary to comply with a legal or regulatory obligation on the part of Zallpy.

Opposition to processing of your Personal Data : You can object to the Processing of your Personal Data when it is in disagreement or in breach of any determination of the LGPD.

Automated decision review: You may request that decisions taken solely on the basis of the Automated Processing of Personal Data that affect your interests are reviewed, respecting commercial and industrial secrets.In order to exercise any of your rights set out above, as well as to determine your preferences in handling and use by Zallpy of some of your personal data, you may send an email to dpo@zallpy.com. You will receive a response within a maximum of 15 (fifteen) business days from the date of your request. For security reasons, we will only be able to fulfill your request if we are sure of your identity. Therefore, we may request additional data or information to confirm the applicant's identity and authenticity.

Zallpy takes care of your data privacy and, in compliance with data protection regulations, only shares your information for the purposes set out in this Privacy Policy.

• With business partners, service providers, suppliers and subcontractors for perfect and correct execution of contracts entered into with them or with you;

• With advertising and marketing companies to select and serve ads relevant to you as authorized; and

• With search engine and analytics providers, to help improve and optimize our App and website.

We may also disclose your personal information to third parties:

• In case of transactions and corporate changes involving any Zallpy company, in which case the transfer of data will be necessary for the continuity of the services offered herein;

• In compliance with current legislation;

• In compliance with Contracts or other agreements with our data subjects;

• To protect Zallpy's interests in cases of claims and conflicts, including judicial, administrative and arbitration proceedings;

• By court order or by request of competent administrative authorities that have legal competence to request it.

• In accordance with a court order or at the request of competent administrative authorities who possess the legal authority to request it.

Zallpy may share your Personal Data with business partners, service providers, suppliers and subcontractors located in other countries for the purposes described in this Policy, such as:

• Perform internal operations, including support to our data subjects;

• Problems solution;

• Data storage and analysis;

• Tests;

• Research and statistics;

• Comply with our contractual obligations, in particular the execution of terms of your contract with Zallpy and provision of our products and services.

We will only share data with third parties who are in countries that provide the level of data protection provided for in the LGPD.

Zallpy will ensure that the transmission of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical and organizational measures are observed, ensuring greater security for your Personal Data.

The terms of this Policy may be modified at any time, due to legislative changes or in the products or services we provide, as a result of the update of technological tools or, when necessary, at our discretion, such as due to the offer of new products or services. When we make relevant changes, Data Subjects will be notified by a notice on our App, Website, email or by any other means of communication available, at Zallpy's discretion. Be sure to read any warnings of this nature carefully.

Any and all disputes arising from the terms set out in this Privacy Policy will be resolved in accordance with Brazilian law, with jurisdiction in the city of Porto Alegre – RS, excluding any other, however privileged.

The use of services and/or orders commanded outside Brazilian territory, as the case may be, or those arising from operations initiated abroad may also be subject to the legislation and jurisdiction of the authorities of the countries where they are commanded or initiated.

Any doubts about this Policy, as well as the processing of data, can be dealt with by Personal Data Protection, Luis Ladereche, through the 'Contact the DPO' button available in the footer, or by e-mail at dpo@zallpy.com. It is available on business days between 9 am and 6 pm. You will receive a response within a maximum period of 10 business days.