Last Updated: March 26, 2024.

Herein are presented the Terms of Use (“Terms”) of SASI COMMUNICATION AGILE LTD., trading name SASI, a private legal entity, with its HEAD OFFICE registered under the CNPJ (National Registry of Legal Entities) number 35.379.670/0001-45, located at Avenida Brigadeiro Faria Lima, No. 1306, 7th Floor, Suite 71, room B, Jardim Paulistano District, ZIP Code 01451-914, São Paulo/SP, Brazil, and BRANCHES registered under the CNPJ/MF number 35.379.670/0002-26 with address at Avenida Ephigênio Salles, No. 126, Room “E”, Parque 10 de Novembro District, ZIP Code 69055-736, Manaus/AM, Brazil, and SASI COMTECH DMCC, a private legal entity, free zone company, license number: 911256, located at Platinum Tower, 1406, Jumeirah Lakes Towers, Dubai, UAE, email: compliance@sasi.io; phone: (11) 4210-2846, hotline: 0800-580-2912, owner of SASI platforms, applications, and websites, henceforth referred to as “SASI”. This document outlines the key rules that must be observed by all who access any SASI environments or use its features.

These Terms of Use (“Terms of Use”) govern your relationship with the SASI Mobile Application as well as its platform, aimed at providing a system that enables greater accessibility to the user through the development of “no code” applications, allowing the definition of fields for various purposes; the scope of the service may depend on the type of account, subscription, or evaluation you hold.

The services and content made available on the SASI Platform are the sole and unrestricted responsibility of the client, who is, in fact, the application developer. SASI is not responsible for profiles, channels, fields, content, and the like generated and stored on the Platform.

The services are provided to you as a limited, non-exclusive, sublicensable, and transferable basis for your private, personal, and commercial license to download, install, and use on a compatible device under your control or ownership.

Please read the Terms of Use carefully before using the SASI Application (“Service”).

Your access to the Service is conditioned upon your acceptance of and compliance with these Terms of Use. These Terms of Use apply to all visitors, Users, or anyone else who accesses or uses the Service provided by SASI.

By accessing or using the Service, you agree to be bound by the Terms of Use. If you disagree with any part of these Terms, you should not access the Service.

1. User Registration and Truthfulness of Information

Access to SASI’s Services requires prior registration or enrollment of Users on the platform. Users may register according to specific registration mechanisms.

When you create an account on our Application or platform, you must provide accurate, true, complete, and up-to-date information at all times.

All information provided to use SASI’s Services must be truthful; therefore, by registering, you guarantee the authenticity of all data you provide through the completion of forms or through automated registration or login mechanisms.

Providing false or inaccurate statements constitutes a violation of these Terms of Use, which may result in the immediate termination of your account on our Services. In any case, the user is always solely and exclusively responsible for their conduct and for damages caused to SASI, third parties, and partners.

You are responsible for safeguarding the password you use to access our Service and for any other activities or actions under your password, whether your password is with our Service or a third-party service.

You agree not to disclose your password to any third party and to notify us immediately upon becoming aware of any breach of security or unauthorized use of your account.

The User commits to use SASI’s Services in good faith and in accordance with all possibly applicable legal, regulatory, and contractual precepts, as well as public order, norms, and standards of social and professional conduct generally accepted or considered as good practices.

2. Fraud

SASI may contact the User via telephone or email to verify their personal contact information. SASI reserves the right to request more information from you.

The User agrees to provide such additional information, to ensure that their registration on the Application has not been fraudulently completed. If such information is not provided to SASI in the requested manner within 15 (FIFTEEN) days of such request, SASI may reject your registration or suspend your registration and subscription until the requests for information are satisfied.

3. Payment

If you wish to use SASI’s paid Service, you must provide certain relevant payment information (“Payment”), including, without limitation, your credit card number, the credit card holder’s name, the credit card expiration date, the security code, the billing address of the credit card, your identification document number, your mobile phone number, and your date of birth.

You warrant that: (i) you have all rights to use the credit card or other means of payment used to purchase the Service; and that (ii) the information provided is true, correct, and complete.

By submitting this information, if necessary, you grant us the right to share such information with third parties (“Payment Means”) for the purpose of processing or facilitating the completion of the Payment. We reserve the right to refuse or cancel your order at any time for any reason, including, but not limited to: service availability, errors in the service description, errors in your registration, or other reasons.

The SASI Application and platform reserve the right to refuse or cancel your payment if there is suspicion of fraud, unauthorized, or illegal transaction.

4. Service Cancellation

If you have purchased a service subject to charges on the App and on the platform as a User, you have the right to revoke this contract within up to 15 (fifteen) consecutive days, without the need to specify reasons.

This right of revocation exists for a period of 15 (fifteen) consecutive days from the date of service subscription.

To exercise your right of revocation, you must notify SASI through the support channel at the email compliance@sasi.io.

The period of revocation of the service before the end of the term established in the previous paragraphs is sufficient to comply with the revocation period.

After the service cancellation, the User may export the data used in the development of their work for a maximum period of up to 60 (sixty) days.

5. Content

Our Service allows you to post, link, store, share, or otherwise make available certain information, text, videos, or other materials (“Content”) about your Users for “no code” development on the platform. You are responsible for the Content you post on our Application and Platform, including its legality, reliability, and appropriateness.

You warrant that: (i) you have all the legal authorizations provided by the data holders to share health information and clinical cases submitted to our Service; that (ii) the information provided is true, correct, and complete; and that (iii) the publication of your Content on our Application and Platform does not violate data protection and privacy rights, health rights, contractual rights, or any other rights of any person; (iv) the information is not abusive, offensive, hateful, threatening, or otherwise violates any law or infringes the rights of third parties (including copyright, privacy, publicity, trademark, or other personal or proprietary rights); (v) in SASI’s exclusive judgment, is explicit, or questionable, damages, exploits, or otherwise may expose SASI or third party to damages or liability of any kind.

By posting content on our Application and Platform, you grant us the right and license to use, process, store, or otherwise handle the data exclusively for the purpose of providing the Service. You retain all rights to any content you submit, post, link, store, and share or otherwise make available through our Service, and you are responsible for protecting those rights.

6. Availability, Errors, and Inaccuracies

We are constantly updating our Services offerings on the Application and Platform. As such, despite our best efforts to provide accurate, up-to-date, correct, and complete information, the Services may occasionally be mispriced, described inaccurately, or unavailable due to delays in updating information on the Application and Platform, in any informational material, or on our website (or https://sasi.io/).

Therefore, we cannot and do not guarantee the accuracy or completeness of any information regarding the Service, including prices, specifications, availability, and services. We reserve the right to change or update information and to correct errors, inaccuracies, or omissions at any time without prior notice.

7. Protection of Minors

Users under the age of 18 (eighteen) may access the functionalities of the SASI platform and App, provided they are assisted or represented by their parents, guardians, or conservators, as per the law, who will be considered responsible for all acts performed by the minor.

8. Intellectual Property

Our Service and its original content (excluding Content provided by the user), features, and functionalities of the Application and Platform, are and shall remain the exclusive property of SASI and its licensors. The Service is protected by copyright.

All trademarks, patents, trade names, and distinctive signs of any kind present in the services of the Application and platform, including its own brand and designation, belong to their respective right holders. Our trademarks, names, and signs cannot be used without prior written consent from SASI, under penalty of administrative and judicial measures of an obligatory and compensatory nature.

9. Data Protection

SASI has its own document, called the Privacy Policy, which regulates the processing of data collected at SASI, being an integral and inseparable part of these Terms and can be accessed on our website (or https://sasi.io/).

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

10. Support

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

11. Voluntary and Sanctioned Deregistration

The USER is free to request voluntary deregistration from the SASI platform at any time.

Voluntary deregistration can be requested through the SASI support channels available on the website or by email: compliance@sasi.io.

The SASI support will process the request within up to 15 (fifteen days), and this period may be extended for a justified reason.

Non-compliance with these Terms by the USER may result, immediately and at SASI’s sole discretion, in the sanctioned deregistration of the USER, without prejudice to compensation for losses and damages caused to SASI.

12. Third-Party Services

Our Application and Platform may contain links to third-party websites or services that may not be controlled by SASI.

SASI has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party websites or services. You also acknowledge and agree that SASI shall not be responsible, directly or indirectly, for any damage or loss caused or alleged to be caused by, or in connection with, the use of any content, goods, or services available through any third-party websites and services. We strongly recommend that you read the terms of use and privacy policies of any third-party websites or services that you visit.

13. Service Suspension and User Withdrawal

SASI reserves the right to terminate, suspend, or interrupt unilaterally and at any time, without prior notice, the total or partial provision of the service, or carry out its complete transformation or modification, for any reason.

Upon termination, your right to use the Service will cease immediately. If you wish to terminate your account, you may simply discontinue using the Service.

14. Limitation of Liability

In no event shall SASI, its legal representatives, directors, employees, partners, agents, suppliers, or licensors be liable for any direct, indirect, incidental, special, consequential, or punitive damages, including without limitation, material damages or lost profits, or other monetary and intangible losses, related to any claim, judicial action, or other proceedings taken in connection with the use of the SASI service, content, functionalities, or tools, as well as for the correction or inaccuracy resulting from any of these elements: (i) damages and losses that the user may experience due to the unavailability or partial functioning of the application and services; (ii) damages and losses that users or third parties may experience due to information entered by the user in the application and platform; (iii) damages and losses that the user or third parties may experience as a result of using the application in non-compliance with these terms of use or with the privacy policy; or inability to access or use the service; (iv) damages and losses that the user or third parties may experience as a result of using the application in non-compliance with the law, customs, or public order; (v) damages and losses that the user or third parties may experience as a result of failures in the application and platform, including those resulting from system failures, server, or network connection, or even from malicious interactions such as viruses that may damage the user’s equipment or access information from the user’s equipment; (vi) any content or conduct of any third party in the application.

The user declares and guarantees that they are solely and exclusively responsible for their development on the platform and in the application and for the data entered in the application.

15. Disclaimer of Warranties

The use of the service is at your own risk. The service is provided on an “as is” basis. The service is provided without warranties of any kind, either express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement, or infallibility.

SASI, its subsidiaries, affiliates, or its licensors do not warrant that: a) the service will function uninterruptedly, securely, or available at any particular time or location; b) any errors or defects will be corrected; c) the service is free of viruses or other harmful components; or d) the results of using the service will meet your requirements.

16. Right to Change

SASI reserves the right, at our sole discretion, to modify or replace these Terms at any time. We will attempt to notify you 30 (thirty) days before any new terms take effect. By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you should stop using the

Service.

17. Applicable Law

These Terms shall be governed and construed in accordance with the laws of Brazil and international data protection laws, with the Court of São Paulo – SP being the only competent to resolve any question or controversy arising or resulting from the use of the Application, expressly waiving any other, however privileged it may be or become.

The failure of SASI to enforce any right or provision of these Terms will not be considered a waiver of those rights or provisions. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions will remain in effect. These Terms constitute the entire agreement regarding our Service and supersede any prior agreements we might have had.

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

The 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

The 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

The 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.