This Privacy Policy (the "Policy") describes the rules adopted by Komunique regarding the collection, recording, storage, use, sharing, enrichment and deletion ("Processing") of Personal Data, as well as the security and privacy measures adopted by us regarding such Personal Data, especially when collected from the contracting of our services and products and access to our institutional websites.

Komunique is committed to preserving the privacy of Users and protecting the Personal Data collected from Users through our websites, as well as the products and services offered by Komunique, in accordance with applicable laws governing our activities - in particular the LGPD (Brazilian General Data Protection Law) - and to act with transparency and clarity towards Users and the market in general.

We strongly recommend carefully reading this Policy. By accessing and using the functionalities of Komunique's website and products and services, the User declares to have knowledge of this Policy and to be aware of the information contained herein.

Some of the Personal Data processed by Komunique is provided directly by the User when using the functionalities offered on the website, which includes, but is not limited to, access, navigation and contracting/use of products and services. Additionally, the website may record all activities performed by the User through Logs.

Komunique may obtain the following Personal Data from Users who browse our website and/or contract our products and services:

• Full Name;
• CPF/CNPJ (Brazilian individual/company tax ID);
• RG (Brazilian ID);
• Telephone;
• Cellphone;
• Email Address;
• Address;
• Company and/or position;

The Komunique website may also use technologies such as:

• Cookies called necessary, essential to the functioning of the website, which cannot be disabled. These include:
  • Session data, navigation and pages accessed;
  • New sessions;
  • Domain, utk, initial date and time record (first visit), last date and time record (last visit), current date and time record (current visit) and number of sessions;
  • Browsing behavior;
  • Browsing history;
  • User distinction;
  • First navigation;
  • Registration and navigation data;
  • Registration data through IP address.
  • Data for adjusting and optimizing navigability;
  • Data to ensure transaction security (purchase), when on the applicable page.
• Web Beacons: collects Personal Data about User behavior when accessing pages, where the installation of files on devices may be unnecessary;
• Other technologies for obtaining User browsing data (API analytics).

It is important to highlight that, once on the website, the User may be directed, via link, to content, services or conversational platforms - such as chatbots - which may collect other User information.

Komunique may collect Personal Data from Users through other collection points or through sharing of databases from Komunique partners - provided it is in compliance with the LGPD and other applicable regulations - even if they are not necessarily Users of the website. In this case, depending on the Data Subject's relationship with Komunique (client, supplier, etc.), Komunique may process the following Personal Data:

• Registration Personal Data: name, CPF, marital status, signature, nationality, username, date of birth, age;
• Contact Personal Data: address, city, ZIP code, country, telephone, cellphone, User in messaging applications and/or social networks, email;
• Behavioral Personal Data: consumption habits, consumption history, complaint history, browsing history;
• Financial Personal Data: investments and assets, credit card data, credit history, income tax return, public records of assets, banking data (bank, branch and account number), salary;
• Professional Personal Data: position, professional email, profession, professional address, profession, entity/company/organization;

Not all Personal Data described above will be collected in all situations. The collection of specific Personal Data will depend on a series of factors, such as the contracted service, the nature of the Data Subject's relationship with Komunique, the option to provide Personal Data through consent, when applicable, among others.

Komunique may process other Personal Data during the provision and/or supply of its services, and also according to the nature of the direct and indirect relationship with the Data Subject, cases in which it may act as Controller, Co-controller, Operator or Sub-operator.

The Personal Data collected from Users of Komunique's website and from Data Subjects in general may be used for the following purposes:

• a) Identify and properly authenticate them;
• b) Contact suppliers for negotiation, budgeting and other information (about services they intend to contract, as well as to make payments);
• c) Manage system functions, provide services and fulfill obligations arising from the use of Komunique's services;
• d) Provide User support, including answering questions about the products and services offered by Komunique;
• e) Optimize and improve the User experience;
• f) Conduct prospecting, advertising and marketing actions (including promoting offers and sending information about our new products, services and features), statistics, studies, surveys and research relevant to the activities of User behavior during the use of the website and Komunique services, anonymizing Personal Data as much as possible to prevent direct association with the Data Subject;
• g) Inform Users about news, features, content and other events relevant to maintaining the relationship with Users;
• h) Safeguard Komunique's rights related to the use of our website, products and services, as evidence in cases of judicial, administrative or arbitration proceedings, as well as unlawful acts or acts contrary to this Policy or any other legal document made available by Komunique;
• i) Detect, prevent and/or remedy unauthorized changes to its systems and records or actions that may endanger the platform and its Users;
• j) Comply with existing legal requirements to which Komunique is subject;
• k) Execute internal organizational procedures, prepare productivity, sales and billing reports, conduct customer satisfaction studies and create business intelligence indicators;
• l) Prevent the occurrence of fraud.
We may also combine Personal Data received from multiple clients to understand general consumption trends, without identifying a specific Data Subject. To the extent possible, we will anonymize the processed Personal Data to prevent direct association with a Data Subject.

The purposes described here will apply to Data Subjects according to the product or service actually contracted and the Data Subject's relationship with Komunique. To learn more about the purposes that apply in each case, the Data Subject may contact Komunique through the channel indicated in item 11 of this Policy.

It is important to note that the purposes described above refer to activities in which Komunique acts as Controller or Co-Controller of Personal Data. For situations where Komunique acts as Operator, the Data Subject should contact the Controller directly to request the desired information.

In cases where Komunique acts as Controller or Co-Controller, when the legal basis for processing Personal Data is consent, Komunique will ensure that it is collected freely, unequivocally and informedly, and in compliance with all applicable legal requirements.

The Processing of Personal Data from Komunique's database will be done only within the limits and purposes established here, with access to Personal Data restricted only to employees and persons authorized by Komunique, to the extent that such persons need access to Personal Data to perform the Processing, as provided for in this Policy.

The Personal Data processed by Komunique is stored in secure and controlled environments, and is deleted when it is no longer useful for the purposes for which it was collected, or when the Data Subject requests its deletion, except if the maintenance of the data is supported by applicable law or regulation or is part of a system or product backup.

Komunique will only keep the Data Subject's Personal Data for a longer period than established by law for its exclusive use, for legitimate purposes (e.g. for audit, security, fraud control or preservation of Komunique's rights), without access by third parties and adopting the best available technology efforts for data anonymization.

The Personal Data processed by Komunique will be stored in Komunique's own datacenters or contracted from third parties, located both in Brazil and abroad, depending on the purpose and contracted product.

During the Data Subject's relationship with Komunique, it may be necessary to share their Personal Data in some situations, such as, for example, (a) execution of the contract and provision of the requested service, (b) compliance with Komunique's legal obligations, (c) defense of Komunique in administrative, judicial or arbitration proceedings, or (d) execution of activities that meet, under the terms of the LGPD and other applicable regulations, Komunique's legitimate interests.

Personal Data may be shared, depending on the case, with:

• a) Komunique Clients, for contract execution;
• b) Telecommunications service providers, for data link and Internet connectivity;
• c) Companies of the same business group as Komunique;
• d) Companies acquired or incorporated by Komunique;
• e) Communication platforms, for creating business accounts in available communication applications;
• f) Technology companies that provide services to or have partnerships with Komunique;
• g) Law firms or collection agencies;
• h) External audit firms;
• i) Accounting firms;
• j) Advertising agencies, for sending Komunique newsletters and advertisements;
• k) Event management, for organizers to communicate with clients and prospects;
• l) Marketing platforms, to communicate with clients and prospects. Additionally, Data Subjects' Personal Data may also be shared with the following third parties:

• a) Authorities, government entities or other third parties, to protect Komunique's interests, in any type of conflict, including judicial and/or administrative proceedings;
• b) In case of transactions and corporate changes involving Komunique, in which case the transfer of information will be necessary for the continuity of services;
• c) By court order or at the request of administrative authorities that have legal competence to request it. In cases where Komunique shares Personal Data with third-party companies, Komunique undertakes to include clauses that regulate the Processing of Personal Data and provide for confidentiality obligations regarding the shared information in the respective contracts.

For some operations, such as for data backup purposes, it may be necessary to forward your Personal Data to other countries. In any case, Komunique adopts all necessary security measures to ensure that the sharing of Personal Data is done securely and in compliance with applicable legal provisions.

Your Personal Data will not be sold, rented or exchanged by Komunique under any circumstances.

In accordance with the LGPD, Komunique guarantees the following rights to the Personal Data Subject:

• a) Confirmation of the existence of Processing by Komunique or any company in the group.
• b) Access to Personal Data processed by Komunique or any company in the group.
• c) Correction and/or updating of Personal Data processed by Komunique.
• d) Anonymization, blocking or deletion of unnecessary, excessive Personal Data.
• e) Revocation of consent, when Personal Data is processed under this legal basis.
• f) Portability of Personal Data to another service or product provider, upon express request.
• g) Information about third parties with whom Komunique shares Personal Data.
• h) Review of automated decisions, if applicable.

When it is not possible to comply with the Data Subject's request, Komunique will explain the reasons that justified the non-compliance. For example, in situations where Komunique acts as Operator, requests cannot be answered and must be forwarded by the Data Subject directly to the Controller of the Personal Data.

Any information provided by the Data Subject will be collected and, at minimum, stored according to security procedures considered standard by the market, when superior alternatives are not reasonably available to us. To this end, Komunique adopts various precautions, in compliance with the guidelines on security standards established in applicable laws and regulations, such as:

• a. Methods and equipment available on the market to encrypt and anonymize Personal Data, when necessary. Encryption allows protecting Personal Data before being transmitted over the Internet. Advanced encryption techniques make this information unreadable and prevent others from viewing it before it reaches the destination servers;
• b. Protection against unauthorized access to systems;
• c. Use of automated tools that detect and seek to prevent unauthorized access to systems and products;
• d. Limitation of authorization to access the location where personal information is stored to specific people, provided this access is essential to the development of the intended activity;
• e. Ensuring that agents, internal employees or external partners who process Personal Data on behalf of Komunique must commit to maintaining absolute confidentiality of the accessed information, as well as adopting best practices for handling this information, as determined in internal and external policies and procedures;
• f. Performing regular website backups. Website activity is consistently verified to protect the information provided. Sophisticated protection systems are used and activity on the website is monitored.
• g. Employing best efforts to monitor its environment for public vulnerabilities, seeking to correct them whenever necessary;

In addition to technical efforts, Komunique also adopts institutional and administrative measures aimed at protecting Personal Data, such as its privacy governance and data protection program, awareness campaigns and periodic training.

Access to collected information is restricted to employees and authorized persons. Those who misuse this information, in violation of the adopted internal policies, will be subject to applicable administrative, disciplinary and legal sanctions.

Although Komunique makes its best efforts to preserve your privacy and protect your Personal Data, no information transmission is completely secure, so Komunique cannot fully guarantee that all information it receives and/or sends will not be subject to unauthorized access perpetrated through methods developed to improperly obtain information, such as technical failures, viruses or invasions of the website database. In any case, in the remote event of incidents of this nature, Komunique guarantees the greatest efforts to remedy the consequences of the event and notify in accordance with applicable legal provisions.

Komunique may change the content of this Policy at any time, as necessary to adapt it to new use cases of our products and services or to applicable legal provisions or equivalent regulations, and it is the Data Subject's responsibility to check it whenever accessing Komunique's website.

In case of questions about this Policy, the Data Subject may contact Komunique through the channel [email protected]

Attention: There may be conflicts between information in this Policy and in another document with the same purpose, specifically related to some product, service or application. In this case, the specific information in the other document should prevail over the information in this Policy.

Questions or requests regarding Privacy may be forwarded to Komunique, directly to the person in charge (DPO) through the channels below:

[email protected]

Or by the address indicated below:

KOMUNIQUE PLATAFORMA DE COMUNICACAO LTDA
AV JABAQUARA, 1838 CONJ 1840 E 1842,– Mirandópolis
São Paulo - SP
CEP: 04046-300
ATTN: Data Protection Officer

Thank you for your attention, and welcome to Komunique!
External privacy policy, version 1.
Updated on: January 09, 2022.