NOTICE EXTERNAL OF PRIVACY 4SMART CLOUD

This External Privacy Notice (“Notice”) details how the 4SMART CLOUD LTDA., registered with the CNPJ/MF under no. 52.687.503/0001-80, with headquarters at Alameda Rio Negro, no. 503, room 1915, CEP: 06.454-000, Barueri/São Paulo (“4Smartˮ) processes the personal data of its Users (“Userˮ), collected through its various services (“Servicesˮ).

The Notice applies to all services offered by 4Smart, including our Website, available through the link https://4smart.cloud/ (“Platformˮ). The terms governing the use of 4Smart services are defined in the respective Terms and Conditions of Use available at https://4smart.cloud/termos-de-uso/, of which this Notice forms part.

We may develop new services or offer additional services from time to time. If the introduction of these services to the 4Smart services results in any change in the way we collect or process your personal data, we will provide you with additional information, terms or Notices. Unless otherwise stated, whenever we introduce these new services or additional features, they will be subject to this Notice.

In order to provide greater clarity as to the content of this Notice, the following words and expressions, in the singular or plural, have been used with the following meanings: meanings:

We hope this Notice helps you understand our commitments regarding privacy and data protection. For information on how to contact us if you have any questions or concerns, please see Section 12, “Contacting Us.” 4Smartˮ.

• Which data personal will be treaties?

In respect of the privacy of our customers, users, partners and interested parties, we understand that any and all processing of personal data must be limited to the minimum necessary, relevant, proportional and non-excessive to enable the intended purpose. Therefore, the personal data that may be processed will vary according to the data provided by our customers, partners and third parties, and according to the service provided.

4Smart provides data analysis services through its Platform and through information and data made available by our Customers, Partners, and Third Parties related to them, whose products and platforms are integrated with ours.

For this reason, in the vast majority of data processing carried out, we act as data operators, following the instructions of the processing controller(s), which may be the Client company(ies), Partner(s) and/or Third Parties that share the data. with us.

Valuing the security and privacy of the holders of personal data, whenever possible, measures are taken to anonymize personal data.

Below, grouped into categories, we present the main personal data processed by 4Smart:

• • Main identification information for accreditation on the Platform: Considering that accreditation is required to access our Platform, we may process data such as name, CPF, RG, telephone, email, address, position, employer, among others, provided directly by our client and/or partner to allow their employees to access the Platform;
  • Attributes associated with electronic devices: As an application provider, 4Smart may collect access log data, IP address, operating system, browser (type, version, enabled options and installed plug-ins), video settings

(size/resolution and number of colors), date and time of access and pages viewed through cookies;

• • General contact data: We may also process data such as name, telephone number, email address, when an interested party sends us, for example, of their own free will, a request for a proposal or fills out a contact form on the 4Smart website, or otherwise contacts 4Smart;
  • Third parties: general information provided by partners, by our client or third parties linked to them, when integrating these services with the 4Smart Platform, which may contain personal data.

Our Platform was not designed for and should not be used by anyone under 18 (eighteen) years of age (“Children and Adolescentsˮ). For this exact reason, we will not collect personal data from Children and Adolescents.

• How personal data will be collected?

We may collect personal data from the following: forms:

• • Data provided by the Holder We collect personal data when the holders provide them, voluntarily entering them when requesting a proposal or filling out a contact form on the 4Smart Website, or even when contacting us via telephone or carrying out any direct interaction with 4Smart.

We trust that the holder will always provide us with true and up-to-date information; therefore, we are not responsible if the personal data provided is false or is incorrect or out of date.

It is possible to correct and/or update data. To do so, please see the item “What are my rights regarding my personal data?”;

• • Provided by third parties: 4Smart provides analysis services based on data provided by our Customers, Partners and/or Third Parties related to them, through integration with the 4Smart Platform. Therefore, the main source of personal data collection is through the receipt of data by companies and entities that contract 4Smart's services. In this case, we act as the data processing operator.
  • Information obtained from your browsing of the Site. We may collect information also put quite from the use of cookies (and technologies similar, as Web beacons and JavaScript resources) to obtain information about your access to the Site, provide greater security for your activities on the Site, and make your experience better and more customized. All of this, of course, in strict compliance with the law and respecting your privacy.

• To what we will use you data personal?

In some cases, personal data is processed by 4Smart to enable the provision of our services. It is in this context that your personal data will be used for the following purposes:

• • Provision of our Services. To enable our relationship with our Customers and Partners and to fulfill the contracted services, such as the credentials of users designated to access the 4Smart Platform. Whenever possible, we perform our analyses using anonymized data.
  • Communication and contact. Data may also be processed to respond to requests from interested parties, customers, partners and data subjects. Therefore, personal data is important for:
    
    • we serve adequately to the requests It is we clarify doubts;
    • keep your registration and access credentials to the Platform up to date, in case we need to contact our customers, partners and interested parties by telephone or e-mail;
  • Improve our services. Even when we think that everything is fine with the Website, the Platform and the experience of our users and customers, there is always something that we need to fix or that we can improve. In these cases, personal data will help us to:
    
    • Identify and correct any failures, based on our users' usage accredited;
    • Conduct statistical studies, research and surveys related to the use and services we provide — all in an anonymous and secure manner;
  • Comply with our legal obligations and protect our rights in legal proceedings. We also retain your personal data to comply with the laws applicable to our activities, including to cooperate with authorities when requested. In addition, we may also use personal data to exercise our rights in judicial, administrative or arbitration proceedings.

• With who we share you data personal?

In order to provide even better services, during the execution of our services, we may associate ourselves with some business partners, with greater expertise in certain activities, and with our Clients. Therefore, we rely on the help of these partners, with whom we share/obtain the least amount of personal data necessary for the purpose that motivated us to share them, always observing a safe way for this to happen. In other words, your personal data will only be shared with:

• • companies in the same economic group as 4Smart, to provide the contracted services and to ensure, among other factors, that the Platform and the Website continue to function correctly for you;
  • companies supplying goods and services to 4Smart, which will use personal data for specific purposes such as fraud prevention, risk analysis, infrastructure and information technology; and
  • public authorities to protect our interests in court or out of court, and also if we receive a court order or request from a competent authority determining the sharing of personal data.

• You data personal will be transferred to outside of country?

Your personal data may be stored on our own servers or on third-party servers. In the latter case, your data may be stored outside of Brazil. But don't worry: your data will only be transferred to locations with security standards that are as strict or stricter than those we adopt here or where we guarantee compliance with rules and standards capable of keeping your personal data safe. security.

• As we protect you data personal?

Our security measures are in line with the best standards currently available on the market. We have internal policies and protocols that determine how personal data should be handled by 4Smart. These standards aim to ensure the appropriate and lawful handling of the personal data we hold, including yours. Any and all information to which you have access is confidential. For example, some of the security measures we use are:

• • Strict control of the processing of Personal Data, including limitation of access, and password-protected access;
  • The existence of a security program information;
  • Implementing Data Access Segregation Personal;
  • Guidelines for the protection of passwords;
  • Access the services, exclusively, put networks safe;

• Anonymization of personal data received, so that only the information necessary for the analyses requested by our Clients is maintained, without however allowing the identification of a natural person.

Finally, we also count on the help of our Users, Customers and Partners to always keep their Access Account data safe and not share it with anyone. If you notice any suspicious access or notice any problem or inconsistency in the Platform, please contact us.

• Links

Our Platform may integrate third-party services and products and other content with links to third-party websites. We cannot control, nor are we responsible for, the privacy practices and content of third parties. When clicking and/or accessing a third-party platform, the User must be aware that they will leave the 4Smart Platform and that any personal data they provide will not be covered by this Notice. The User must read their respective Privacy Notices to find out how they collect and process their personal data.

• Cookies

Cookies are text files that can be stored on your electronic devices when you visit our Platform. 4Smart uses this tool for different purposes, such as generating access statistics, improving your experience on our Platform.

We list below the types of cookies used and their purposes:

We highlight that the cookies necessary are essential for the normal functioning of our Platform. This means that, if You object to the use of this tool, this may imply the unfeasibility of your experience or the suspension of your access.

• Put as time you data personal will be stored?

Our policy is to delete personal data as soon as we have achieved the purposes for which it was collected. In some cases, we will need to keep this data for longer periods, even after the original purposes have been achieved, to comply with legal obligations, protect our rights or comply with judicial/extrajudicial agreements. We undertake to keep it only for the period permitted by law and to delete it in a safe and efficient manner when it is no longer necessary.

• Which they are your rights on you your data personal?

The General Data Protection Law (Law No. 13,709/18) guarantees the data subject the following rights:

• confirmation of what your data they are treaties and, in case positive, the access the they;

• correction or update of the data that is incomplete, inaccurate or outdated;
• anonymization, blocking or elimination of data unnecessary or excessive;

• information about the entities with whom we share your data;

• information about the possibility of not providing your consent for certain processing operations, and the consequences of such refusal;
• deletion, blocking or anonymization of data processed based on your consent; and

• portability of your personal data, which still depends on regulation by the National Data Protection Authority.

Users and Interested Parties may contact us to obtain more information or exercise these rights whenever they wish, through the channels provided in item 12 below.

It is possible that the request cannot be fulfilled for technical or legal reasons, but in any case, all requests will be responded to within a reasonable time, as required by law.

• Changes to the present Notice of Privacy

This Privacy Notice may be updated from time to time, particularly if any important aspect of our Services changes. We recommend that you visit this page regularly to keep an eye on any changes. In any case, we will always notify you of any material changes, either by means of a notification on the Platform, Website or by other means of contact.

• Speak with the 4Smart

If you have any questions regarding this Notice and/or to exercise your rights related to personal data, please contact us by email at sac@4smartcloud.com or via form of contact.

Last updated on September 4, 2024.

Version: 1.0