Zallpy Digital's Privacy Policy applies to all services offered by Zallpy that use Personal Data (as defined below) of customers, potential customers, employees and/or third parties (“Data Subjects”). (a) Zallpy Software LTDA: software development and support company for large corporations. By accessing and using the products or services offered by Zallpy, you fully agree and accept the provisions of the Privacy Policy. Policy in effect as of February 7, 2025.

General Data Protection Law (LGPD): Federal Law No. 13,709 published on August 14, 2018, which regulates the activities of Processing Personal Data, including in digital media, by a natural person or by a legal entity under public or private law, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the natural person's personality.

Data Processing Agents: are those responsible for the Processing of Personal Data and are divided into two categories: the Controller and the Operator. The Controller is the person or company responsible for decisions regarding the Processing of Personal Data. The Operator, in turn, is the person or company that carries out the Processing of Personal Data on behalf of the Controller, following their instructions.

• Anonymization: technique by which data loses the possibility of association, directly or indirectly, with an individual, so that reidentification is subsequently impossible, even using technical solutions;

• National Authority for the Protection of Personal Data (ANPD): is the federal public administration body with responsibilities related to the protection of personal data and privacy, including monitoring compliance with the LGPD;

• Cookies: a small file containing a string of characters, created and sent by websites to your computer each time you visit them. They help remember your preferences and personalize your access, making your browsing experience safer, faster and more enjoyable. You can configure your browser to not accept cookies or to notify you when a cookie is being sent, but without them, some features or services on the website may be compromised and limited;

• Personal Data: defined in the LGPD as information related to an identified natural person or information that allows their identification, such as name, address, CPF, RG, identity documents in general, telephone number, among others;

• Sensitive Data: defined in the LGPD as Personal Data about racial or ethnic origin, religious belief, political opinion, membership of a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data when linked to a natural person;

• Device: is the device that can be used to access the services offered by Zallpy, such as desktop computers, tablets and smartphones;

• Personal Data Protection Officer: is responsible for ensuring that Zallpy complies with privacy laws and regulations, guaranteeing the protection of Personal Data and for being the communication interface with the ANPD and Data Subjects;

• IP address: This is the number assigned to each Device connected to the Internet, known as an Internet Protocol (IP) address . These numbers are usually assigned in geographic blocks. An IP address can be used to identify, for example, from which location a Device is connecting to the Internet;

• Geolocation: a feature that, when activated by the Data Subject, allows the precise or approximate position of a Device to be defined and provides information such as the country, state, city and street where the Device is located, also providing the time it was accessed;

• Data Subject: any identified or identifiable natural person to whom the personal data processed refer. These include, for example, our customers, potential customers, account holders, employees, third parties, service providers, job applicants, among others;

• Processing: any operation performed with Personal Data, whether automated or not. In other words, it is the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

We process your information to develop and improve our products and services. However, in some cases, you will be able to manage the information collected and/or used by Zallpy, through one of the service channels for privacy matters indicated in item 9 of this Policy, as well as through the way you use our services.

Different information is collected when you use our App or Website and it falls into the following categories:

1. Data provided by the Data Holder: is the information provided by you when interacting, contracting or using any products or services provided by Zallpy, such as:

• Name, email, telephone number, CPF, address, profession, marital status, image of your official identity documents or any other Personal Data provided, contract or cancel any product or service provided by Zallpy;

• The verification and confirmation of Personal Data may, at Zallpy's discretion, be carried out by third-party partner companies, which will respect the same security and privacy criteria set out herein;

• You will be solely and exclusively responsible for the quality and accuracy of the Personal Data provided to Zallpy when registering, requesting a quote and/or contracting any products or services. Zallpy is not responsible for the accuracy of the data provided, nor for any damages resulting from the inaccuracy and/or outdated nature of said information.

2. Data collected during the use of our services or website (browsing): this is the information collected by Zallpy when you browse and/or use Zallpy services:

• Browsing data: this is the information we collect about your interactions with the App or website, such as: search history, browsing history, access dates and times, resources used, how you use the products and services, App problems and other system activities. This information is important for better performance of the features available on the website and App and to enable the display of content that is relevant to you;

• In some cases, we may collect this information through Cookies, which are important tools for the proper functioning of our services. Therefore, you should be aware that if you choose to refuse or remove Cookies, the availability and functionality of Zallpy services may be affected. To learn more, see our Cookie Policy.

3. Devices: We also collect information about the Device you use to access the App and Website, such as: brand, operating system, IP address, type of network connection (WI-FI, 3G, LTE, Bluetooth or others), network and Device performance, browser type, version, language and version of the App. This information is necessary to ensure the compatibility of our services with the Device you use and, thus, allow for a better experience.

4. Geolocation: This is the information we collect about your location that allows us to:

• Improve your experience on the App, showing, for example, the location to check in at our coworking services;

• Identify the origin of a call received on our service channels.

We were able to determine your location by the following means:

• GPS (check-in, website access); or

• IP address (chat access, website access, use of services, campaigns).

The types of location data we collect depend in part on your Device and App settings. You can enable or disable location tracking by going to your Device's Settings/Privacy.

Data collected from other sources: this is information collected by Zallpy from third-party partner companies, suppliers and service providers, respecting the purposes set out in this Policy. These companies may change depending on the services offered by Zallpy and the information collected.

Zallpy may use the data provided or collected, as above, to send advertising and publicity by email or any other means of communication, respecting items 6, 7 and 9 of this Policy.

The Personal Data collected, under the terms of this Policy, are used for the following purposes:

• Comply with our contractual obligations, in particular the execution of the terms of your contract with Zallpy;

• Comply with applicable legal and/or regulatory requirements;

• Provide you with our products and services;

• To notify you about any changes to our products and services;

• Strengthen our security and protection procedures, aiming to provide a safer and more effective service;

• Manage our provision of services and/or supply of products;

• Perform internal operations, including support to customers and other data subjects, troubleshooting, data analysis, testing, research and statistics;

• Improve and enhance our services and products, ensuring that they are presented in the most effective manner to you;

• Evaluate or understand the effectiveness of the advertising we serve, aiming to provide relevant advertising to you;

• Allow you to participate in interactive features of our services, when you choose to do so;

• Provide information about other services and/or products we offer;

• Offer personalized products or services, appropriate and relevant to your interests;

• Produce evidence and assist in conducting legal, administrative or arbitration proceedings, as well as assist in complying with other legal requirements; and

• Make automated decisions regarding your use of our services

Without prejudice to the purposes set out above, the table below provides, by way of example and not exhaustive, but not limited to, some of the Personal and/or Sensitive Data that we process and the purpose of their processing:

1. Contact Form:

• Name, email, phone number

• Contact our sales and technical teams

2. Conduct channel:

• Name, email, position and gender

• Provide information for tracking and verifying reports of conduct

3. Zallpy Check-In App:

• Name, email and geolocation

• Provide coworking services for booking workspaces in our environments

4. Email Marketing:

• Name, email, phone, position

• Communication with our customers, suppliers, authorities and employees

5. Internal campaigns:

• Name, email, phone, position

• Communication with our employees

If it is necessary to Process Personal Data of children and/or adolescents, for any purpose, we will request specific and highlighted consent from at least one of the parents or legal guardian of the Data Subject.

Zallpy has internal procedures and technologies to assist in verifying the powers of the legal guardian, thus seeking to guarantee the validity of consent, as this can only be given by the legal representative of the child and/or adolescent.

After valid consent, the collection and Processing of Personal Data of children and/or adolescents is carried out following the rules detailed in this Policy.

The period for which Zallpy processes your Personal Data will vary according to:

• With the types of products and services contracted/provided/supplied;

• For the purposes of the Treatment;

• With the contractual and legal provisions in question.

Therefore, Personal Data will be deleted by Zallpy, unless it must be stored due to a legal or regulatory obligation, when:

• The purpose for which the information was collected is achieved or when the Data reaches the retention time of its life cycle;

• When consent is revoked;

• Or by determination of the competent authority to do so.

The LGPD grants a series of rights to Data Subjects. Therefore, you, as a Data Subject, can make requests to Zallpy, as detailed in the table below:

• Confirmation of the existence of Treatment: You can request that Zallpy confirm whether your Personal Data is being treated and which treatment operations are being carried out;

• Access to your Personal Data: You may request information from Zallpy about the Personal Data we process. We will provide you, by electronic or physical means, with a copy of the Personal Data we hold about you. We cannot provide Personal Data of third parties;

• Correction of your Personal Data: You may change, request the correction or update of your Personal Data, when it is incorrect, incomplete or outdated. Before updating your Personal Data, we may request documents and/or information that prove the new information you have provided, in order to guarantee the quality of the data provided and its security;

• Request the anonymization, blocking or deletion of your Personal Data: You may request that your Personal Data be anonymized, blocked or deleted from Zallpy's databases when they are unnecessary, excessive or processed in non-compliance with the provisions of the LGPD. You may request that we delete the Data when:

(i) believe there is no reason for us to continue using them;

(ii) you wish to withdraw the consent (permission) you initially gave us;

(iii) you object to our use of the information;

(iv) you consider that we have used the information unlawfully; or

(v) the law requires us to delete the information. We will not comply with your deletion request where Zallpy needs to store such Personal Data due to a legal or regulatory obligation.

• Portability of your Personal Data: You may request the migration of the information registered with Zallpy to another institution. Zallpy will comply with the legal provisions in force when fulfilling this request and the Personal Data, when provided, will be in a structured form, in a format commonly used and readable by systems. We cannot share Personal Data that is confidential or a business secret;

• Information about the sharing of your Personal Data: You can request information about the public and private entities with which Zallpy has shared data;

• Possibility of not providing consent: If you refuse to provide Zallpy with consent to access or Process your Personal Data, we will inform you about the consequences of this refusal which, in some situations, may make it impossible to provide our services;

• Revoking consent: If you have consented to the Processing of your Personal Data, you may, at any time, withdraw such consent. We would like to emphasize that it will be lawful for us to use your Personal Data until the moment of revocation of consent, and it will also be lawful to archive such Personal Data for a period longer than the processing period, whenever necessary to comply with a legal or regulatory obligation on the part of Zallpy;

• Opposition to the processing of your Personal Data: You may object to the Processing of your Personal Data when it is in disagreement with or does not comply with any determination of the LGPD;

• Review of automated decision: You may request that decisions made solely based on automated processing of Personal Data that affect your interests be reviewed, respecting commercial and industrial secrets. To exercise any of your rights set forth above, as well as determine your preferences regarding the processing and use by Zallpy of some of your personal data, you may send an email to dpo@zallpy.com. You will receive a response within a maximum of 15 (fifteen) business days from the date of your request. For security reasons, we will only be able to comply with your request if we are certain of your identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the requester.

Zallpy is committed to the privacy of your data and, in compliance with data protection regulations, only shares your information for the purposes set out in this Privacy Policy.

We may share your information with the third parties listed below:

• With business partners, service providers, suppliers and subcontractors for the perfect and correct execution of contracts entered into with them or with you;

• With advertising and marketing companies, to select and serve relevant ads to you, as authorized; and

• With search engine and analytics providers to assist in improving and optimizing our App and website.

We may also disclose your personal information to third parties:

• In the event of transactions and corporate changes involving any Zallpy company, in which case the transfer of data will be necessary for the continuity of the services currently offered;

• In compliance with current legislation;

• To protect Zallpy's interests in cases of lawsuits and conflicts, including in judicial, administrative and arbitration proceedings;

• By court order or at the request of competent administrative authorities that have the legal authority to request it.

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Zallpy may share your Personal Data with business partners, service providers, suppliers and subcontractors located in other countries for the purposes described in this Policy, such as:

• Perform internal operations, including supporting our data subjects;

• Troubleshooting;

• Data storage and analysis;

• Tests;

• Research and statistics;

• Comply with our contractual obligations, in particular the execution of the terms of your contract with Zallpy and the provision of our products and services.

We will only share data with third parties located in countries that provide the level of data protection provided for in the LGPD.

Zallpy will ensure that the transmission of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical and organizational measures are observed, ensuring greater security for your Personal Data.

The terms of this Policy may be modified at any time, due to legislative changes or changes in the products or services we provide, due to the update of technological tools or, when necessary, at our discretion, such as due to the offer of new products or services. When we make relevant changes, Data Subjects will be notified by means of a notice on our App, Website, email or by any other means of communication available, at Zallpy's discretion. Be sure to read any such notice carefully.

Any and all disputes arising from the terms set out in this Privacy Policy will be resolved in accordance with Brazilian law, with jurisdiction being that of the city of Porto Alegre – RS, to the exclusion of any other, however privileged it may be.

The use of services and/or orders placed outside Brazilian territory, as the case may be, or those arising from operations initiated abroad may also be subject to the legislation and jurisdiction of the authorities of the countries where they are placed or initiated.

Any questions about this Policy, as well as data processing, can be addressed to our Personal Data Protection Officer, Luis Ladereche, through the 'Contact the DPO' button available in the footer, or by email dpo@zallpy.com. He is available on business days from 9 am to 6 pm and you will receive a response within a maximum period of 10 business days.