Last Update: March 26, 2024.

We hereby present the Terms of Use (“Terms”) for SASI COMUNICAÇÃO ÁGIL LTDA., doing business as SASI, a private legal entity, with its HEAD OFFICE registered under the CNPJ (Brazilian National Register of Legal Entities) No. 35.379.670/0001-45, located at Avenida

Brigadeiro Faria Lima, No. 1306, 7th Floor, Suite 71, Room B, Jardim Paulista District, ZIP Code

01451-914,    São    Paulo/SP,    and    its    BRANCHES    registered    under    the    CNPJ/MF    No.

35.379.670/0002-26, with an address at Avenida Ephigênio Salles, No. 126, Room “E”, Parque 10 de Novembro District, ZIP Code 69055-736, Manaus/AM, and SASI COMTECH DMCC, a private legal entity, free zone company, with license number: 911256, located at Platinum Tower, 1406, Jumeirah Lakes Towers, Dubai, UAE, email: compliance@sasi.io; phone: (11) 4210-2846, central phone: 0800-580-2912, owner of the SASI platforms, applications, and websites, henceforth referred to as “SASI”. This document outlines the main rules to be observed by all who access any SASI environments or use its functionalities. These terms govern the use of the distributor and “SASI” on the SASI platform and the products created and managed therein, found on the site https://sasi.io/. The company may offer other products and services under different terms. These terms apply only to the use of SASI. As a condition for access and use of SASI’s exclusive functionalities, especially the contracting of software functionalities for software development made available on the SASI platform, the DISTRIBUTOR declares that they have fully read and carefully considered the rules of this document and its Privacy Policy, being fully aware and thereby giving their free and express agreement to the terms stipulated herein. Should you not agree with these directives, the DISTRIBUTOR must discontinue access. In simplified terms, the use of the SASI platform may include: The DISTRIBUTOR may not impersonate someone else. This applies to anyone who develops any product on the SASI platform. The DISTRIBUTOR must act with civility at the time of service, respecting professional ethical standards. The DISTRIBUTOR cannot falsely suggest that they are affiliated with or endorsed by the company. The DISTRIBUTOR of products on the SASI platform cannot share personal and sensitive data entered on the SASI platform without prior consent from the End User. The DISTRIBUTOR cannot disable, defraud, or circumvent any security or access restriction of the group.

1. OBJECT

1.1. These Terms apply to USERS who access and use the functionalities and services of SASI or made available by it, exclusively belonging to SASI or its partners. 1.2. The services provided and functionalities made available by SASI are intended for USERS who access SASI via the website https://sasi.io/.

1.2.1. DISTRIBUTORS (user creators) include all individuals who develop products, access, or interact with SASI.

1.2.2. All USERS must be 18 years of age or older, or 16 years of age or older with parental or guardian consent (which must be sent via email to the DPO of SASI – compliance@sasi.io), possessing full legal capacity to accept these Terms and use the offered Services.

1.2.3. SASI may change the eligibility criteria for access and use of SASI at any time, such as by improving existing functions and features or adding new functions or features to the Service, as well as for legal or regulatory reasons, without having to make any type of communication or prior notice to the USER.

1.3. DISTRIBUTORS may be subject to additional technical rules and requirements for effective registration on SASI.

2. FUNCTIONALITIES AND SERVICES AVAILABLE IN SASI.

2.1. The functionalities and services offered by SASI to DISTRIBUTORS may include the development of products on the SASI platform. 2.2. For each functionality or service, only the necessary information (in accordance with SASI’s Privacy Policy) will be requested to find the best options and meet the specific needs of each DISTRIBUTOR.

3. PAYMENT

3.1. In the event of non-payment by the USER of any amounts due, SASI will send an email informing about the payment situation and may block or partially or completely suspend its functionalities and access until the payments are regularized.

4. OBLIGATIONS AND RESPONSIBILITIES OF SASI

4.1. SASI and its functionalities are presented to the USER as they are available, subject to constant enhancements and updates, obligating SASI to:

4.1.1. Preserve its functionality, with operational links and utilizing layouts that respect usability and navigability, whenever possible;

4.1.2. Display the functionalities and services in a clear, comprehensive, precise, and sufficient manner, so that there is an exact perception of the operations conducted; and

4.1.3. Protect the data collected via SASI according to the best practices of information security applied in the sector.

4.2. SASI will make its best efforts to maintain the availability of its services and functionalities. However, there may occasionally be some temporary unavailability due to necessary maintenance or even caused by force majeure, such as natural disasters, fortuitous events, like communication systems and Internet access failures, or third-party actions beyond its control and responsibility, with SASI not being responsible for any of these events or the unavailability of its services and functionalities.

4.2.1. Should this occur, SASI will do everything within its power to restore access as soon as possible, within the technical limitations of its services and those of third parties on which SASI relies to be available.

4.3. Under no circumstances will SASI be liable for:

4.3.1. Any services provided by DISTRIBUTORS via SASI, with the END USER being responsible for verifying and being aware of the contracts, terms, and conditions of the respective terms of use for contracting and providing the respective services, and SASI acting merely as an intermediary in making them available to END USERS;

4.3.2. Any potential interactions between DISTRIBUTORS and END USERS, the verification of which is the sole responsibility of the END USER, with SASI being exempt from any and all responsibility in this regard.

4.3.3. Access failures to SASI stemming from circumstances related to the general unavailability of the Internet, power outages, digital or physical malfunction of any telecommunications network, interruptions or suspensions of connection, and failures in the software and/or hardware used by USERS;

4.3.4. Any problems, bugs, glitches, or improper functioning that occur on the devices and equipment of USERS as a result of regular use;

4.3.5. System errors that alter service data or information, including prices informed on

SASI, and for purchases and payments of products or services rejected by financial institutions;

4.3.6. Any direct or indirect damage caused by third-party events, such as hacker attacks, system failures, server or Internet connection issues, including actions of malicious software, such as viruses, Trojans, and others that may, in any way, damage the equipment or connection of USERS as a result of accessing, using, or browsing SASI, as well as transferring data, files, images, texts, audios, or videos contained therein; and

4.3.7. Information contained in the registrations made through SASI, with the data included in the registrations being the total responsibility of the DISTRIBUTORS, who will be, respectively, the only ones responsible for civil and criminal sanctions that may result from inaccuracies in this data.

4.4. SASI only requests personal information through emails from domains “@sasi.io”. SASI is not responsible for any fraudulent electronic communications that collect personal data from its USERS (phishing).

4.5. SASI may, according to its business objectives, modify, suspend, or temporarily discontinue the functionalities, services, and/or content of SASI, at its sole discretion, whenever necessary to offer the best functionalities and services to USERS.

4.5.1. SASI may, at any time, change, adapt, or remodel the content, layout, functionalities, and/or tools related to its platform, as long as it complies with data protection legislation.

4.6. SASI may also schedule downtime to perform maintenance, updates, and configuration adjustments on SASI, aiming to improve the quality of services provided to its USERS, making its best efforts to ensure maintenance times do not coincide with business hours or peak access times.

4.6.1. However, should there be a need for emergency maintenance, it may occur during business hours or peak times, and without prior notice, with SASI not being liable for the unavailability as there would be a justified reason for the maintenance to occur in such a manner.

4.7. Under no circumstances will SASI be responsible for any losses and damages, including

lost profits, related to the suspension of access to SASI. USERS have no right to demand the availability of SASI as it suits them best, nor can they claim compensation or damages in case SASI is offline, regardless of the reason.

4.8. SASI may restrict, limit, or prevent, by any means or form, access for one or more USERS to SASI, at its sole discretion, especially in cases of repeated suspicions of fraud or any other actions that may impair or potentially harm the functioning of the functionalities and services of SASI.

4.9. Without excluding the responsibilities established above, the DISTRIBUTOR is aware that the SASI platform will not be responsible for:

4.9.1. Any failures in billing through the informed payment method, including, but not limited to, reporting incorrect data, expired cards, insufficient limits, among others;

4.9.2. Payment failures resulting from problems generated by third parties with whom the DISTRIBUTOR directly relates, such as integration issues, discrepancies in values and consumption, among others, ensuring that, should such a failure occur, it must be resolved directly between the USER and the third party; and

4.9.3. Cases where discrepancies between the consumption invoice and the amount actually charged to the card are identified, in which case the responsibility remains with the third party, as they are the exclusive holder and manager of the information sent.

4.10. SASI reserves the right, at any time and without prior notice, to suspend the services of any USER who violates any of the provisions established herein, engages in, assists, or instigates actions that may impair the proper functioning of SASI, or uses illicit acts for actions on SASI, including, but not limited to, the insertion of false and/or incorrect data, the use of fraudulent or nonexistent cards, among other acts that violate any legal provision stipulated in the legal system.

4.11. SASI also reserves the right to validate and check, by its own means, the cards and information presented by the USER.

5. USER OBLIGATIONS AND RESPONSIBILITIES

5.1. DISTRIBUTORS are responsible for and must:

5.1.1. Use SASI rightfully and ethically, respecting the conditions governing its use and purpose;

5.1.2. Provide their own accurate, complete, and updated registration information and data, as well as inform a contact channel that can be activated by SASI for the best fulfillment of services, being civilly and criminally responsible for all information provided to SASI, committing to update them whenever there is any change;

5.1.3. Have compatible devices and equipment, an internet connection service with antivirus and firewall enabled, and properly updated software;

5.1.4. Adjust their anti-spam systems, similar filters, or message redirection settings so that they do not interfere with the receipt of communications and materials from SASI, with no excuse being acceptable if the USER has not accessed any email or electronic message due to the aforementioned resources;

5.1.5. Respect all intellectual property rights owned by SASI, as well as all rights related to third parties that may be or have been available in SASI in any way;

5.1.6. Not access SASI’s programming areas, its database, or any other set of information that is part of the administrative activity;

5.1.7. Not perform or allow reverse engineering, nor translate, decompile, copy, modify, reproduce, rent, sublicense, publish, disclose, integrate, transmit, lend, distribute, or otherwise dispose of the tools of SASI and its functionalities;

5.1.8. Not use spider software, or data mining software, of any type or kind, as well as any other not specified here but that acts in an automated manner, both for carrying out mass operations and for any other purposes;

5.1.9. Not transmit materials containing computer viruses or other malicious codes, files, scripts, agents, or computer programs;

5.1.10. Not maliciously exploit the security of SASI to commit illicit acts, prohibited by law and these Terms, harmful to the rights and interests of SASI and third parties, or that can in any way damage, disable, overload, or deteriorate SASI;

5.1.11. Be solely responsible for any damage caused to SASI or third parties due to the non-fulfillment of the obligations established here or the inaccuracy of the information provided, with no talk of subsidiarity of the obligation, nor solidarity of SASI.

5.2. The DISTRIBUTOR is solely and entirely responsible for the information they insert into SASI, being the only one responsible for civil and criminal sanctions that may result from inaccuracies in these data.

5.3. The functionalities that compose SASI are offered in the form of a service, not granting the DISTRIBUTOR any rights over the software used by SASI, its content, or the computer structures that support it.

5.4. The eventual removal, blocking, or suspension of any content or functionality of SASI as a result of a complaint must always be understood as a demonstration of the intention to avoid damages and losses in good faith and the intention of amicable conflict resolution, never as an acknowledgment of guilt or any infringement by SASI of the right of a third party.

5.5. The DISTRIBUTOR acknowledges as SASI’s property the database where the data entered within SASI will be stored and processed.

5.5.1. The USER acknowledges that, although SASI has a backup of the data and information entered on its platform, maintaining the availability of data and information is also the responsibility of the USER, who equally commits to maintaining a secure backup of the data and information under their responsibility.

5.6. Without excluding the obligations and responsibilities established above, the DISTRIBUTOR is aware and declares that:

5.6.1. They are aware and authorize, from now on, the collection of personal data during the provision of services carried out through SASI for the exclusive purposes of realizing these services between the DISTRIBUTOR and the END USER.

5.7. Regarding the content generated by the DISTRIBUTOR, they may post, upload, or contribute in different ways to the content and service offered by SASI (which may include, for example, text, messages, information, descriptions, compilations, and/or other types of content), as well as:

5.7.1. The DISTRIBUTOR, regarding user content resulting from the use of the SASI platform, has the right to post the content of their application, provided it does not infringe third-party rights, applicable law, or intellectual property rights, privacy, personality, copyrights, etc.

5.7.2. SASI may, but is not obliged to, monitor, review, or edit the Content created by the DISTRIBUTOR. In all cases, SASI reserves the right to remove or disable access to any DISTRIBUTOR content for any reason, including content that, in SASI’s sole discretion, violates the agreements. SASI can take these actions without prior notifications to the DISTRIBUTOR or any third party. The decision to remove or disable access to DISTRIBUTOR content is at the sole discretion of SASI, and there is no promise to remove or disable access to any specific user content.

5.7.3. The DISTRIBUTOR is solely and exclusively responsible for the content created on the SASI platform. SASI is not responsible for the content generated on the platform by the DISTRIBUTOR nor does it endorse any opinion contained in any user content.

5.7.4. YOU AGREE THAT, SHOULD ANYONE TAKE ACTION AGAINST SASI RELATED TO THE CONTENT POSTED BY YOU AS A DISTRIBUTOR, TO THE EXTENT PERMITTED BY LOCAL LAW, YOU WILL INDEMNIFY AND HOLD SASI HARMLESS FROM ANY DAMAGES, LOSSES, AND EXPENSES OF ANY KIND (INCLUDING REASONABLE ATTORNEY FEES) ARISING FROM SUCH ACTION.

6. INTELLECTUAL PROPERTY

6.1. Subject to these Terms, SASI grants the USER a limited, temporary, non-exclusive, and non-transferable license to use the functionalities and services contracted from SASI only to the extent strictly necessary for fulfilling obligations and enjoying the rights set out in these Terms.

6.2. All rights related to SASI, as well as its functionalities, are owned by SASI, including all intellectual property rights related to its texts, images, graphics, trademarks, layouts, codes, databases, and other content developed directly or indirectly by SASI (“Intellectual Property Rights”). The unauthorized use of any content or trademarks presented by SASI is expressly prohibited.

6.3. Any use of the Intellectual Property Rights owned by SASI can only be done with prior and express authorization from SASI. The USER assumes all responsibility, both civil and criminal, for the unauthorized and improper use of Intellectual Property Rights.

6.4. The commercial use of the expression “SASI,” and words similar to it but with different spelling, such as trademarks, business names, or domain names, as well as the contents of the SASI screens and the computer programs, databases, networks, and their files, are owned by SASI and are protected by international laws and treaties on intellectual property protection, including, but not limited to, Federal Laws No. 9.609/98, 9.610/98, 9.279/96, and 10.406/2002.

6.5. By accessing SASI, USERS declare that they will respect all SASI’s intellectual property rights, including, but not limited to, computer programs, copyrights, and industrial property rights on trademarks, patents, domain names, company names, and industrial designs, filed by or registered in the name of SASI, as well as all rights related to third parties that may have been or are available in SASI in any form.

6.6. Accessing or using the content and functionalities and services of SASI does not grant USERS any rights to the use of names, titles, words, phrases, trademarks, patents, domain names, company names, images, illustrations, data, and information, among others, that are or have been available.

6.7. The use of SASI for any purposes that contravene these Terms and the Privacy Policy is forbidden, as is the reproduction, distribution, and disclosure, in whole or in part, of the texts, figures, and graphics that comprise it, without prior and express authorization from SASI.

6.8. Any other type of authorized material use, including for editorial, commercial, or advertising purposes, can only be done with prior and express consent from SASI and only within the allowed limits.

6.8.1. Any reuse of authorized material must be the subject of a new authorization from SASI.

6.8.2. The authorization granted for the use of requested material cannot be transferred to

third parties, even if they are linked to the authorized individual.

6.9. USERS assume full responsibility, both civil and criminal, for the misuse of information, texts, graphics, trademarks, patents, domain names, works, images, logos, in short, all and any intellectual or industrial property right existing in SASI or owned by SASI.

6.10. The submission by the USER to SASI, through SASI’s contact channels, of content related to ideas for new products, improvements to existing ones, advertising campaigns, or any other marketing action, will imply authorization for SASI to use the content, with SASI having the exclusive discretion to offer any type of monetary reward or non-financial compensation for what was sent, with the USER having no right to claim in this regard.

7. DATA PROTECTION

7.1. SASI has its own document, named Privacy Policy, which governs the processing of data collected at SASI, being an integral and inseparable part of these Terms and can be accessed through the website https://sasi.io/.

7.2. Should any provision of the Privacy Policy conflict with any other provision of this document, the description in the more specific rule shall prevail.

8. CUSTOMER SERVICE

8.1. Any questions or requests related to these Terms may be sent to SASI through the contact form available at: https://sasi.io/contact-us/, or via the telephone numbers and other means of contact indicated on the websites and SASI platform.

9. LIMITATION OF LIABILITY

9.1. In no event shall SASI, its legal representatives, directors, employees, partners, agents, suppliers, or licensors, be liable for any direct or indirect, incidental, special, consequential or punitive damages, including, without limitation, material damages or lost profits, or any other monetary and intangible losses, related to any claim, lawsuit, or other proceeding taken in connection with the use of the service, content, functionalities, or tools of the SASI platform, as well as for any inaccuracy or incorrectness resulting from these elements: (i) damages and losses that the USER may experience due to the unavailability or partial operation of the functionalities and services; (ii) damages and losses that users and/or third parties may suffer due to information entered by the DISTRIBUTOR in SASI; (iii) damages and losses that the USER or third parties may suffer as a result of any conduct suggested by the analysis of a clinical case; (iv) damages and losses that the USER or third parties may suffer as a result of using SASI in non-compliance with this Term or the Privacy Policy; or inability to access or use functionalities or services; (v) damages and losses that the USER or third parties may experience as a result of using the platform in non-compliance with the law, customs, or public order; (vi) damages and losses that the USER or third parties may suffer due to failures in SASI, including those arising from system failures, server, or network connection, or even malicious interactions such as viruses that may damage the equipment or access the USER’s equipment information; (vii) any content or conduct of any third party on the SASI platform.

10. WARRANTY DISCLAIMER

10.1. The development functionalities of the SASI platform, as well as other services and functionalities of SASI, are at the DISTRIBUTOR’s own risk. The functionalities and services are provided “as is” without any kind of warranty, either expressed or implied, including, but not limited to, implied warranties of merchantability.

10.2. SASI DOES NOT GUARANTEE that a) the service will operate uninterrupted, available at any specific time or location; b) any errors or defects will be corrected immediately; or

1. c) the results from using the service will meet USER requirements.
2. VOLUNTARY AND SANCTIONED DEREGISTRATION

11.1. USERS are free to request their voluntary deregistration from SASI at any time.

11.1.1. Voluntary deregistration can be requested through SASI’s customer service channels available on the website or by email at compliance@sasi.io.

11.1.2. SASI’s customer service will process the request within 15 (fifteen) days, which may be extended for a justified reason.

11.2. Failure to comply with these Terms by the USER may result, immediately and at

SASI’s sole discretion, in sanctioned deregistration of the USER, without prejudice to compensation for damages caused to SASI.

12. DISTRIBUTOR SUPPORT

For customer support related to account and payment issues, send an email to SASI. SASI will make reasonable efforts to respond to all distributor support inquiries within a reasonable timeframe, without promising that customer support inquiries will be answered within any specific period and/or that we will be able to resolve such inquiries.

You can also file a complaint on the SASI platform, through the website https://sasi.io/.

12.1. By accepting these Terms, the USER acknowledges that this Use Agreement and SASI’s Privacy Policy provide proportional conditions, without defects that could lead to their nullity, notably in the absence of deceit, mistake, fraud, simulation, or coercion, and there is no situation that could be considered as a state of danger or necessity.

12.2. By browsing SASI and using its functionalities, the USER agrees to be guided by these Terms in force at the date of access. Therefore, the USER must stay informed.

12.3. These Terms of Use are subject to continuous improvements and enhancements. Thus, SASI reserves the right to modify them at any time, as per its purpose or convenience, such as for legal or regulatory compliance, requiring USERS to verify them whenever they access SASI.

12.3.1. Any disagreement with the new Terms of Use must be immediately reported by the USER to SASI’s customer service.

12.3.2. Disagreement with the new Terms of Use by the USER may, at SASI’s sole discretion, lead to the USER’s deregistration.

12.4. Tolerance of any non-compliance with any provision of this Term will not constitute a waiver of obligations herein stipulated and will neither prevent nor inhibit their enforceability at any time.

12.5. Should any provision of this document be deemed unenforceable or ineffective, the remainder of the document shall continue in effect, without the need for a judicial declaration to that effect.

12.6. These Terms do not create any other type of linkage between the USERS and SASI, including, without limitation, partnerships, joint ventures, employment, or any form of economic group. SASI will remain an independent and autonomous entity.

12.7. The USER acknowledges that all communication made by phone, email, instant messaging app, SMS, or any other digital, virtual, or physical form regarding the data and information provided and registered in SASI will also be valid, effective, and sufficient for the communication of any matter referring to the functionalities and services provided by SASI, as well as to the conditions of its provision or any other matter discussed therein, except for any expressly different provisions provided in these Terms.

13. GLOSSARY

13.1. For the purposes of this document, the following definitions and descriptions should be considered for a better understanding:

13.1.1. SASI: Virtual environment of technological solutions offered by SASI for services aimed at attracting and retaining users.

13.1.2. USERS: Individuals who access the virtual environment of SASI or interact with the functionalities and services offered by SASI.

14. APPLICABLE LAW AND JURISDICTION

14.1. This document will be governed and interpreted according to Brazilian law, in the Portuguese language, electing the jurisdiction of the USER’s domicile to resolve any dispute or controversy involving this document, except for a specific reservation of personal, territorial, or functional competence by applicable legislation.

15. ASSIGNMENT

15.1. SASI may assign the contracts and any rights of its platform, in whole or in part. SASI may delegate any obligations to another entity affiliated with the SASI Holding. The DISTRIBUTOR may not assign this agreement, in whole or in part, nor transfer or sublicense their rights under the contract, to any third party.

Thank you for your attention, and welcome to SASI!

PERSONAL DATA PROCESSING ANNEX

This Personal Data Processing Annex (“Annex”) is part of the General Terms and Conditions of Use of SASI (“Terms of Use”) and regulates the obligations of SASI and the CLIENT (Health Service Provider), either INDIVIDUAL or LEGAL ENTITY, regarding the processing of personal data used on the Platform or Application.

DEFINITIONS

For the accurate understanding and interpretation of the rights and obligations set forth herein, the following definitions are adopted in addition to the definitions of the General Terms:

1. CONTROLLER: An individual or legal entity, a service provider, that contracts SASI’s

technology and is responsible for decisions related to the processing of personal data.

1. OPERATOR: SASI, which processes personal data of users on behalf of the controller.
2. PERSONAL DATA: Data related to the User, a natural person, identified or identifiable,

and processed by SASI on behalf of the CLIENT or in connection with the Terms of Use.

1. SECURITY INCIDENT OR PERSONAL DATA BREACH: Any situation, accidental, intentional, or unlawful, that causes, regarding Personal Data, destruction, loss, alteration, communication, diffusion, or access by Third Parties.
2. SERVICES: The SASI Platform, which processes Personal Data of the User on behalf of the CLIENT, as provided in the Terms of Use and Privacy Policy. The terms “Legal Bases,” “Data Subject,” “Processing,” and “Data Protection Authority” should be interpreted in accordance with data protection legislation.

PERSONAL DATA PROCESSING

SASI and the CLIENT must comply with all laws and regulations concerning personal data protection.

The Operator shall only process Personal Data strictly necessary for the provision of the SERVICES and in accordance with the purposes set out in its Privacy Policy, avoiding the processing of any Personal Data not previously authorized by the Controller.

ACCESS CONTROL

Operator shall take all necessary measures to ensure the reliability of any employee who

may access the Personal Data, ensuring that access is strictly necessary and limited to those individuals who need to access the Personal Data for the provision of Services, as set out in the Terms of Use, and for compliance with legal obligations, ensuring that all such employees are subject to Confidentiality Agreements.

SECURITY

The Operator shall implement technical and administrative security measures capable of protecting Personal Data from unauthorized access or from accidental or unlawful situations of destruction, loss, alteration, communication, or any form of inappropriate or unlawful treatment.

When assessing the appropriate level of security, the Operator shall consider the nature, scope, context, purposes, and risks presented by the Processing of Personal Data, particularly the risk of a Data Breach.

PERSONAL DATA INCIDENTS

The Operator shall notify the Controller without undue delay as soon as it becomes aware of a Security Incident with Personal Data related to the Services provided to the Controller, providing the Controller with sufficient information to enable compliance with any obligation to report or inform the Data Subjects of the data breach.

The Operator shall cooperate with the Controller and take reasonable measures, as instructed by the Controller, to assist in the investigation, mitigation, and correction of any Data Breaches.

DATA PROTECTION IMPACT REPORT

The Controller shall request the Operator for the necessary information to prepare the Data Protection Impact Report whenever requested by the National Data Protection Authority or other competent Regulatory Authorities.

The Operator shall cooperate with the Controller in the preparation and presentation of any

Data Protection Impact Report exclusively related to the Processing of Personal Data under the Services.

RIGHTS OF THE DATA SUBJECTS

Controller shall have a communication channel with the Users to ensure a response to

the request for exercising the rights of the Data Subjects, and, to this end, shall notify the Operator to take the necessary measures for its compliance, as directed by the Controller and in accordance with data protection legislation.

The Operator shall assist the Controller in implementing reasonable technical and organizational procedures for complying with the Controller’s obligations in responding to requests for the exercise of rights by the Data Subjects, according to data protection legislation.

The Operator shall notify the Controller if it receives a request from a User to exercise their rights, leaving it to the Controller to assess the relevance of the request and provide instructions to the Operator for its compliance.

The Operator shall not respond to a request for the exercise of rights by Users, except in response to notification and instructions from the Controller or as required by legal obligations to which the Operator is subject. In such cases, the Operator, to the extent permitted by Applicable Laws, shall inform the Controller about this legal requirement before responding to the User’s request.

DELETION OF PERSONAL DATA

Upon the termination of the Services, the Operator shall cease processing Personal Data of the Users or entered into the platform within up to 60 (sixty) days from the date of termination of the Controller’s subscription, and delete all Personal Data and any copies that may exist.

The Operator shall notify the Controller about the compliance with this obligation.

Should the Operator need to retain the Personal Data to comply with any legal or regulatory obligations, it must inform the Controller of the reasons for retaining such data.

INTERNATIONAL TRANSFER

The Operator may only transfer Personal Data to countries or international bodies that provide an adequate level of personal data protection, and only when such transfers are strictly necessary for the execution of the Terms of Use and the provision of the Services, as previously informed in the Operator’s Privacy Policy.

TRANSPARENCY

Controller  and  the  Operator  shall  adopt  measures  to  ensure  transparency  in  the

processing of Personal Data, informing what data are collected, how they are used, with whom they are shared, where they are stored, and the security measures employed as per the provisions of current data protection regulations and norms.

The Controller must provide information in its privacy policies regarding the use of Personal Data by the Operator.

NOTICES AND COMMUNICATIONS

All notices and communications provided in accordance with the provisions of this Annex must be in writing and can be delivered personally, sent by mail, or through electronic communications, such as email, with proof of delivery.