Latest version: May 15, 2023.

This document, hereinafter referred to as the “Privacy Policy”, details how CHEESECAKE LABS SOFTWARE S/A., a private legal entity, registered with the CNPJ/MF under No. 19.384.141/0001-83, having its headquarters established at Avenida Desembargador Vitor Lima, nº 260, room 1002, 10th floor, Madison Center Building, Trindade, Florianópolis/SC, CEP 88040-400, collects, stores and uses the personal data of users of its solutions, as well as of its business partners.

1. DEFINITIONS

1.1. For the purposes of reading and interpreting this document, the terms listed will have the meaning in accordance with applicable data protection law, set out below:

(a) User: Any natural or legal person, whether a customer or business partner who provides User Data for the use of CHEESECAKE LABS service platforms. (b) User Data: Data identifying a specific user, subdivided, for the purposes of this document, into: personal data (such as, but not limited to: name, ID, CPF, email address, residential address, telephone); navigation data (such as, but not limited to: login and access password when necessary, length of stay on the CHEESECAKE LABS website) and financial data (bank account information, credit card data). (c) Cookies: Files automatically created and stored on the devices (computers, mobile devices, etc.) of Users when accessing websites on the Internet, and which store data identifying the device and navigation.

2. PURPOSE

2.1. The purpose of using user data at CHEESECAKE LABS is due both to the execution of design and software engineering services, as well as the improvement and creation of services and dissemination of content promoted by CHEESECAKE LABS itself, such as: (a)Improving billing and development deadlines for digital product creation and development projects through design and software engineering; (b)Improvement of services: user data is used to improve performance, content layout, among others; (c )Periodic sending of advertising and information material from CHEESECAKE LABS to the email address registered by each User, in order to keep them updated on the solutions offered by CHEESECAKE LABS, as well as the main news of the digital market through our specialists; (d) Credit protection, anti-fraud and risk assessment: user data is used to add value to the protection of our services and customers, making the environment safer. 2.2 The purpose for using bank details: We use this data to facilitate payment processing.

3. COLLECTION

3.1. CHEESECAKE LABS only collects User Data for legitimate purposes and seeks to maintain its practices in compliance with all current laws and regulations and Regulatory Authorities, both national and international.

3.2. The collection of User Data can be carried out in the following ways:

(a) Manual and voluntary: upon completion of forms by the User himself (example: filling in data such as name, CPF and address when registering a new client); (b) Automated via software: when basic information on access pattern, device type and other information not directly identifiable is collected in an automated way and stored on the User's side and also communicated to our suppliers, which can be stored and processed on both communication sides.

4. STORAGE

4.1. All User Data collected is stored on servers and databases of CHEESECAKE LABS or our partners (national or international), all in full compliance with good market practices and using channel encryption for the traffic of this information on public networks (Internet).

4.2. The information collected is for our exclusive use for the purposes referred to herein, therefore, it will not be sold to third parties under any circumstances. However, we may disclose your personal data in the good faith belief that such action is necessary to:

(a) Legal compliance. To understand (i) legal processes and requests; (ii) establishment or exercise of our legal rights or defense in legal proceedings; or (iii) as required by law; and (b) Provision of Services by Third Parties. We can also work together with other companies in various activities to facilitate our service, to perform a service, as well as sponsors of the services that will be provided. These receive your data only to the extent necessary for the provision of contracted services. We emphasize that our contracts are guided by the data protection rules of the Brazilian legal system, prohibiting these third parties from disclosing or using the data for any other purpose.

4.3. User Data will be stored until:

(a) That the User requests its exclusion, under the terms of item 7.1, “a” of this Policy; (b) That CHEESECAKE LABS decides to disable the data, at its sole discretion; (c) That the exclusion of the data is determined by a governmental authority (administrative or judicial).

4.4. You may exercise the rights described herein by means of written communication by sending your request to the e-mail address: privacy@ckl.io

5. USE AND TREATMENT

5.1 CHEESECAKE LABS seeks to carry out any and all processing of user data in full compliance with the limits set forth in the applicable data protection law and other regulations in force. 5.2 User Data is used by CHEESECAKE LABS and shared by it with partners (national or international) in the following possible ways:

(a) Anonymized, when deprived of the personal data that allow the User to be individualized (example: for the preparation of studies and management reports); (b) Encrypted, when data must be transmitted securely and in accordance with encryption standards (eg capture and transmission of payment data); (c) Non-anonymized, when encryption is unnecessary and personal data must be used and/or shared with partners, in accordance with the permissions provided for in item 5 below.

5.3. CHEESECAKE LABS may share user data with police and judicial authorities, as well as with the person owning the data, when notified to do so, or at its own discretion, when it deems sharing necessary or appropriate to cooperate with fraud investigations ( misuse of personal and financial data of third parties) or any other type of illegal activity by Users.

6. USER CONSENT

6.1. When registering as a user, customer or partner in one of the services or channels of CHEESECAKE LABS, the User expressly agrees that his User Data:

(a) Are collected in the ways provided for in clause 2 of this term; (b) Are used to personalize your navigation on the CHEESECAKE LABS websites (eg: navigation optimization, visualization of the list of solutions; visualization of promotional banners); (c) Be included in lists to receive communications from CHEESECAKE LABS (via e-mail; text messages via SMS or Whatsapp and the like), including offers and promotions, being allowed or disabled according to the available opt-in and opt-out functions in the customer's authenticated area; (d) Are used anonymously (without individual identification) for the preparation of statistical studies and management reports; (e) Are stored in secure banks and used to optimize services; (f) Are shared anonymously with partners (national or international) of CHEESECAKE LABS for the purposes of statistical studies, with their security and compliance of use in accordance with the contracts established between CHEESECAKE LABS and its partners; (g) Are shared with partners (national or international) of CHEESECAKE LABS for the delivery of contracted projects of a lease; (h) Are shared with partners (national or international) of CHEESECAKE LABS for the purpose of consulting the database for credit protection purposes; (i) Are shared with partners (national or international) of CHEESECAKE LABS for the purpose of offering services from these partners on the platforms and means of communication used by CHEESECAKE LABS.

7. USER RIGHTS

7.1. The User is allowed to:

(a) Delete, partially or totally, your user data from the CHEESECAKE LABS databases, upon written request sent to the electronic address indicated in item 4.3, or direct request to the respective commercial area, in the case of commercial partners, except for data protected by law of greater sovereignty or legal needs; (b) Delete Cookies, through a procedure carried out at your own risk on your own devices (c) To be removed from the lists to receive offers and promotions through a removal link contained in the messages sent; (d) Update data, upon request sent to the email address indicated in item 4.4; (e) Do not complete the registration in the CHEESECAKE LABS contact and contracting means if you do not agree with any terms set forth in this Policy.

8. COOKIES MANAGEMENT

8.1. Cookies are files created by the websites you visit. They make users' online experience easier by saving browsing information. With cookies, websites can keep users logged in by remembering their website preferences and providing locally relevant content.

Cookies are generally used to:

✓ Keep track of your preferences to only send ads of interest to you; ✓ Track the items stored in your shopping cart; ✓ Carrying out research and diagnostics to improve content, and services; ✓ Prevent fraudulent activities; ✓ Improve security.

The user can block or reject our cookies. For more information and details about cookies, click on 'Help', in the browser settings, to find out how to prevent you from accepting cookies and to be notified when you receive new ones; to see when they expire and also to disable them.

9. RESPONSIBILITIES

9.1. CHEESECAKE LABS undertakes to:

(a) in addition to complying with the security standards required by the regulations, make its best efforts to maintain the privacy of user data, using technology and information security protocols, observing the state of the art available in accordance with market standards; (b) delete and/or update User Data upon request pursuant to item 6.1 items “a, c and d” above; (c) only enter into partnerships with third parties involving data sharing if these third parties also undertake to comply with all standards and obligations required by law regarding the collection, storage and processing of data; (d) report to the competent authorities and Users any events involving undue exposure of User Data, as well as to use its best efforts to avoid damages to Users due to such events.

9.2. Notwithstanding the provisions of item 9.1 above, CHEESECAKE LABS is not responsible for losses or damages suffered by Users due to improper exposure of their Data that has occurred for any reason other than fraud or proven non-compliance with the legislation.

9.3. This Privacy Policy may be unilaterally amended by CHEESECAKE LABS at any time. CHEESECAKE LABS undertakes to publish the text of the new policy on all its websites, platforms and portals, notifying users of the update made. Any new engagement carried out by users after changing the Privacy Policy will imply tacit acceptance of the new conditions provided.

10. CONTACT

10.1. All contact regarding privacy and data protection can be carried out through direct communication by e-mail with the data protection officer. For this, the e-mail address privacy@ckl.io must be used.

10.2. To exercise the rights established by law, the user can either contact the data protection officer, at the aforementioned email, or contact the CHEESECAKE LABS service channels.