PRIVACY POLICY

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1. Initial Statement

BILLINGROUP recognizes the value of privacy and information security in the world of dynamic and transactional relationships characterized by the large volume of data that transits through new technologies. This privacy policy reveals the commitment of BILLINGROUP and its controlled companies with the faithful compliance with the data protection norms of the Federative Republic of Brazil (Law nº 13709/18) and of the European Union (Regulation 16/679).

This Privacy Policy is assumed by the company:

BILLINGROUP INFORMÁTICA DO BRASIL LTDA.

The scope of this privacy policy is specifically directed to activities that involve the processing of personal data on its services platform, systems and Internet portals.

Personal Data Processed

BILLINGROUP declares to promote the processing of personal data necessary for registration in its systems and portals, such as name, email address, and IP address.

In addition to the registration data, BILLINGROUP declares to promote the collection of indirect personal data related to access to Internet portals, collected by the system itself without the necessary information by users, such as an IP address.

Purpose of Treatment

The processing of data collected by BILLINGROUP will be in full compliance with the Brazilian and European data protection legislation and in strict compliance with the following purposes:

(a) promotion of products and services offered by BILLINGROUP, as well as new features, updates, pricing policy, etc.;

(b) dissemination of content related to the activities performed and products and services offered by BILLINGROUP;

(c) study the interaction of users with BILLINGROUP means of communication, in order to develop improvements and new forms of relationships;

(d) establish criteria for identifying the registered user and their activities on the platform, system and website;

(e) prevent the occurrence of fraud against the user and third parties;

(f) enable the execution of system, platform or website functionalities, meeting user expectations;

(g) performance of contractual obligations established by the Declarant to the user, including provision of service, support, reporting, data hosting and others;

Data Treatment

When collecting personal data, BILLINGROUP ensures that it will store them in safe conditions and technological structure, applying the most advanced technical criteria for information protection.

The data will be stored for a minimum period of 6 (six) months, in accordance with the requirements of the Brazilian Civil Rights Framework for the Internet (MCI), and will last while the relationship between the user and BILLINGROUP lasts.

Personal data obtained by BILLINGROUP will have restricted access, with an information security structure applied to limit the access of personal, professional or sector data only to perform some of the stated purposes of data processing.

Despite paying attention to the best information security practices, BILLINGROUP does not guarantee the impossibility of a harmful event. Therefore, BILLINGROUP is not responsible for the user's negligence or the malicious action of third parties, exempting itself from the duty to repair damages arising from security incidents or data breaches resulting from invasions, failures or vulnerabilities, unless proven to be caused by conduct guilty or deliberate by BILLINGROUP itself.

Data Sharing

The User's personal data may only be shared by BILLINGROUP with third parties, in the case of:

business succession, such as mergers, acquisitions and incorporations;

contracting data processing services from third parties (operators), such as data hosting, processing systems (cloud computing services), information technology consulting, telecommunication services, delivery services, advertising and marketing, event organization, credit billing services (financial), and travel services.

Access by these third parties - under the contracting of BILLINGROUP - to user data will be subject to a requirement of confidentiality and compliance with current data protection laws, in particular with Law No. 13.709/2018 to be reduced to term in contractual instrument or in a specific statement with mandatory enforcement.

BILLINGROUP informs the user that it is required by law to share user's personal data in the event of a requirement emanating from a judicial, police or administrative authority. The availability of these data will only be made upon validation of the order issued with the competent bodies.

International Data Transfer

Some of the direct and indirect processors may be outside Brazilian territory. BILLINGROUP is committed to ensuring and demanding compliance with the legal requirements arising from the rules for the protection of personal data. In particular, BILLINGROUP undertakes to require third parties to sign the Commitment to the Terms of Information Security and Protection of Personal Data.

By declaring awareness and acceptance of the terms of this Privacy Policy, the user expresses his or her unequivocal and express consent to the possible transfer of data in compliance with the order issued by official authorities from countries outside the Brazilian territory. BILLINGROUP further clarifies that the consent in question is not necessary if the provision of information to the authorities is due to a legal requirement.

Use of Cookies

NEXNEURAL declares to use cookies to improve the experience of its users on its platforms and pages on the Internet. Cookies are files sent by BILLINGROUP and installed in users' browsers that allow the identification of the Internet terminal, authenticate the user, personalize the browsing experience and contract services, record access and activities on the page.

BILLINGROUP uses cookies to perform:

(a) authentication and security

(b) offer of advertisements and content

(c) offer of products and services

(d) performance measurement and statistics.

BILLINGROUP ensures that both in the execution of its own cookies and those of third parties, the best security practices are adopted to ensure the protection of personal data collected.

The use of cookies by BILLINGROUP is previously authorized by the user when accessing online platforms and websites. Authorizations can be reviewed and modified at any time by the user.

Rights of the Holder

BILLINGROUP grants the user the right to access personal data in use. In addition to access, the user is guaranteed:

(a) the right to rectify your data;

(b) the right to data portability, if applicable;

(c) the right to object to the use of data for a previously authorized purpose;

(d) the right to data deletion, except for the maintenance of data necessary to fulfill a legal duty and exercise the right of defense in judicial and/or administrative proceedings;

BILLINGROUP ensures that, when the contractual relationship is terminated or the consent for data processing is revoked, the personal information, collected and stored, will be eliminated, except for the maintenance of records necessary for the fulfillment of legal duty or for possible defense in legal or administrative proceedings.

Disclaimer

BILLINGROUP is not responsible for the user's negligence with their own personal data. BILLINGROUP's responsibility is limited to efforts to ensure the use of best security practices.

It is up to the user to ensure the confidentiality of information related to the access and operation of their data on the BILLINGROUP system, platform and website, such as login information, password, security keys, double factor authentication and any other security solution implemented by the Declarant.

Contacts, Questions and Requests

To request clarifications, questions and requests of any nature related to the processing of personal data and the terms of this privacy policy, BILLINGROUP is available for direct contact about privacy and the terms of this policy. Queries and requests can be directed to our person in charge of Personal Data Protection (DPO) by email daniel@softecnologia.com.br.

São Paulo, August 18, 2021

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