PRIVACY POLICY OF TECHCUBE SOLUÇÕES EM TECNOLOGIA LTDA

1. This Privacy Policy contains information about how we process, in whole or in part, the personal data of Users who use the services of the websites of TECHCUBE SOLUÇÕES EM TECNOLOGIA LTDA (https://www.mailerweb.com.br), registered with the Brazilian Corporate Taxpayer Registry (CNPJ/MF) under no. 11.335.921/0001-21 ('TECHCUBE' or 'MAILERWEB').

2. Our goal is to inform interested parties and Users about the types of data collected, the reasons for collection and how Users may update, manage or delete this information.

3. By using the website or any of the services provided by MAILERWEB, the User must authorize the processing of their personal data and user information (through the virtual button agreeing to the website's terms and conditions), thereby being bound by the information contained in this Privacy Policy.

4. The User may withdraw consent to the provisions of this policy, in whole or in part, at any time, simply by notifying MAILERWEB of their decision by email at the following address: abuse@mailerweb.com.br.

5. This Privacy Policy was prepared in accordance with Brazilian Federal Law No. 12,965 of April 23, 2014 (Brazilian Internet Civil Framework), Federal Law No. 13,709 of August 14, 2018 (General Personal Data Protection Law – LGPD), and Federal Law No. 13,853 of July 8, 2019, and may be updated at any time as a result of regulatory changes.

6. MAILERWEB undertakes to comply with the rules set forth in the LGPD, observing the following principles:

6.1. The User's personal data will be processed lawfully, fairly and transparently (lawfulness, fairness and transparency);

6.2. The User's personal data will be collected only for specified, explicit and legitimate purposes and may not be further processed in a manner incompatible with those purposes (purpose limitation);

6.3. The User's personal data will be collected in an adequate and relevant manner, limited to what is necessary for the purposes for which they are processed (data minimization);

6.4. The User's personal data will be accurate and kept up to date whenever necessary, so that inaccurate data are erased or rectified whenever possible (accuracy);

6.5. The User's personal data will be kept in a form that permits identification of data subjects only for as long as necessary for the purposes for which they are processed (storage limitation);

6.6. The User's personal data will be processed securely, protected against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality).

7. MAILERWEB users have the following rights, granted by the General Personal Data Protection Law (LGPD):

7.1 Confirmation that data processing exists; 7.2 Access to the data; 7.3 Correction of incomplete, inaccurate or outdated data; 7.4 Anonymization, blocking or deletion of unnecessary or excessive data, or data processed in violation of the LGPD; 7.5 Data portability; 7.6 Deletion of personal data processed with the data subject's consent; 7.7 Information about data sharing; 7.8 Withdrawal of consent.

I - DATA PROVIDED FOR CONTACT

8. MAILERWEB will collect the first name, last name, phone number and email provided by Users in the data collection area made available exclusively to its customers and/or in the data collection area available on this platform, for the purpose of contacting them and performing the contracted services.

9. Users' personal data processed in this case will be shared internally for the sole purpose of the proper operation of the tool and internal marketing. Accordingly, personal data submitted by Users will be stored on Amazon servers managed by MAILERWEB, with services performed by both under contract with MAILERWEB.

II - DATA RELATED TO THE PERFORMANCE OF CONTRACTS ENTERED INTO WITH THE USER

10. For the performance or purchase of services, a Service Agreement (a document signed by the User describing the subject matter and other characteristics of the contracted service) will be entered into between MAILERWEB and the User, under which other data related to or necessary for its performance may be collected and stored, including the content of any communications with the User.

11. By using MAILERWEB's services, the User consents to this Privacy Policy. The User has the right to withdraw consent at any time, without affecting the lawfulness of the processing of their personal data before withdrawal. Consent may be withdrawn by email at privacidade@mailerweb.com.br.

12. The User's personal data collected by MAILERWEB are intended to facilitate, expedite and fulfill the commitments made to the User and to fulfill requests made through the contact channels available on the website.

13. Personal data may also be used for broad commercial purposes, to personalize the content offered to the User and to help MAILERWEB improve the quality and operation of its services, including:

13.1 Allowing the User to request and receive news and website content newsletters by email; these newsletters are purely informative and may be defined by the User according to their interests;

13.2 Responding to the User's requests for information about newsletter content and allowing data processing to manage the contacts requested by the User;

13.3 The data collected through the platform will be all data provided by the User, which will be processed and used exclusively to perform the services contracted by the user;

13.4 All data provided by the User on the platform may be processed to perform the services provided by MAILERWEB.

14. Personal data will only be processed for purposes not provided for in this Privacy Policy after prior notice to the User, and in any case the rights and obligations set forth herein will remain applicable.

15. The User's personal data will be retained for a maximum period of 36 (thirty-six) months, unless the User requests their deletion before the end of this period.

15.1 Personal data provided by the user for use on the platform will remain under MAILERWEB's custody for as long as necessary for the operation of the contracted platform, and will be processed and stored in isolation among the platform's customers, that is, without interaction and/or mixing with third-party data.

16. Users' personal data may only be retained after processing ends in the following cases:

16.1 For compliance with a legal or regulatory obligation by the Controller; 16.2 For study by a research body, with anonymization of personal data guaranteed; 16.3 For transfer to third parties in accordance with the law; 16.4 For the Controller's exclusive use, provided the data are anonymized.

17. MAILERWEB does not disclose or share with third parties any information provided by the User through the website that could identify them, except:

17.1 For the Controller's exclusive use, with third-party access prohibited, provided the data are anonymized.

17.2 With Microsoft, for storage of personal data entered by the user in the input fields available on the website.

17.3 With MAILERWEB's internal and external business partners, provided they are involved in performing or supporting the contracted services.

17.4 With business partners in the implementation of services purchased from MAILERWEB following initial contact through the website.

17.5 With law enforcement officers, government authorities or third parties, when legally required.

18. Except as described above, MAILERWEB will not disclose any personal information of the User, including among users themselves, unless duly authorized by the User.

19. The Controller responsible for processing the User's personal data is the legal entity TECHCUBE SOLUÇÕES EM TECNOLOGIA LTDA (MAILERWEB), which determines the purposes and means of processing personal data.

20. The Data Protection Officer (DPO) is the professional responsible for informing, advising and guiding the Controller, as well as the employees who process data, regarding MAILERWEB's obligations under the Personal Data Protection Law.

21. At MAILERWEB, the person responsible for protecting the personal data collected is Paulo Vitor Soares, who may be contacted by email at: privacidade@mailerweb.com.br.

22. MAILERWEB undertakes to apply technical and organizational measures capable of protecting personal data from unauthorized access and from destruction, loss, alteration, communication or dissemination of such data.

23. To ensure security, solutions will be adopted that take into account: appropriate techniques; implementation costs; the nature, scope, context and purposes of processing; and the risks to the User's rights and freedoms.

24. However, MAILERWEB disclaims liability for the exclusive fault of third parties, such as attacks by hackers or crackers, or the exclusive fault of the User, such as when the User transfers their own data to third parties.

25. MAILERWEB further undertakes to notify the User within an appropriate period of any security breach of their personal data that may pose a high risk to their personal rights and freedoms.

26. The User is likewise responsible for taking appropriate measures to protect their passwords, usernames and other special access resources to the website, and MAILERWEB is not responsible for information disclosed due to the User's own negligent use.

27. A personal data breach is a security breach that accidentally or unlawfully leads to the destruction, loss, alteration, disclosure of, or unauthorized access to, personal data.

28. MAILERWEB is not responsible for the registrations, terms of use, or privacy policies and practices of third-party websites.

29. Finally, MAILERWEB undertakes to treat the User's personal data confidentially, within legal limits.

30. Cookies are small information files stored locally on the User's computer or device, containing information about the user's activities on the internet.

31. MAILERWEB only uses cookies that store the User's information and personal data in order to record acceptance of the cookie and privacy policy terms on its servers, in accordance with the cookie policy of the aforementioned websites.

32. Any User of MAILERWEB's services may file a formal complaint to obtain answers to their questions or requests regarding the protection of their data. When contacting MAILERWEB to express their wish to file a formal complaint, the User will be instructed to send the request to privacidade@mailerweb.com.br, using the email originally registered for the contracted services. Once the User's identity is validated, the request will be processed within 15 (fifteen) days from the date it is received. The User will be informed of the procedures adopted to resolve the complaint through the email used for this purpose.

33. MAILERWEB may change this Privacy Policy when necessary, and the information collected is subject to the Privacy Policy in force at the time of collection. If there are changes in the way the User's personal information is processed, MAILERWEB undertakes to notify all users through an announcement on the website and/or by notification to their registered email.

34. By using the service after any changes, the User indicates agreement with the new rules. If the User disagrees with any of the changes, they must immediately request the deletion of their personal data and/or submit their objection to customer service, if they so wish.

35. Brazilian law shall apply in full to the resolution of disputes arising from this Privacy Policy. Any disputes shall be brought before the courts of the district where MAILERWEB's headquarters is located (Rio de Janeiro - RJ).