Privacy Policy — ESELLR.AI LTDA

1. Collection of your personal data

1.1. Identity and contact details of the Processor

ESELLR.AI LTDA, a private legal entity duly registered under CNPJ No. 61.227.829/0001-16, located at Rua Hermes da Fonseca, 163, Sala 01, ZIP 13.738-585, Jardim Primavera, Mococa/SP, Brazil. It acts as the data controller, in accordance with Article 6 of the LGPD (Brazilian General Data Protection Law).

2. Information provided by the user

2.1. Requested information

To optimize the experience on the ESELLR.AI LTDA platform, we may request personal information such as name, email, phone, address and company, collected for example when:

• You request information;
• You send comments;
• You post on social media;
• You take part in promotions, campaigns or surveys;
• You use platform features.

Collection is based on the data subject’s consent, pursuant to Article 7, item I of the LGPD, in a clear and specific manner (Article 8).

2.2. Security of financial information

We never request financial or billing information directly. We adopt technical and administrative protection measures, in accordance with Article 46 of the LGPD.

2.3. Collection of personal data

Collection occurs through:

• Sign-ups on the website;
• Job applications;
• Browsing;
• Contacts via “Contact us”;
• Emails or phone calls.

Always respecting the principle of minimization (Article 6, item III).

3. During use of the platform

3.1. Links or Frames

Links and frames are made available as a benefit, but do not imply responsibility of ESELLR.AI LTDA for their content. Third-party services must follow our privacy standards, in accordance with Article 42.

3.2. Cookies

We use cookies for administrative purposes. You can configure your browser to be notified or to disable them. Data collected by cookies is anonymized, in accordance with Article 12 of the LGPD.

4. Use of collected information

4.1. Purpose of collected data

We use the information to:

• Deliver rewards;
• Respond to requests;
• Grant access;
• Communicate changes to policies.

In addition to:

• (i) Manage events, relationships, marketing, feedback and applications;
• (ii) Promote activities and services;
• (iii) Measure traffic and improve the platform;
• (iv) Manage requests and responses;
• (v) Other purposes informed at the time of collection.

The marketing and promotional purposes above do not cover mobile phone numbers or SMS opt-in data collected under Section 8: such data is used exclusively for the communications consented to and is never shared with third parties for marketing purposes.

4.2. Change of purpose

If purposes change, we will inform the data subject, who may withdraw consent (Article 9, §2).

5. Data sharing

5.1. Data sharing

We do not share personal data with third parties without specific consent, in accordance with Article 7, item I.

5.2. Sharing scenarios

• (i) At the request of the company the user belongs to, to fulfill contractual obligations (Article 7, item V);
• (ii) At the request of public or governmental authorities (Article 7, item II).

5.2.1. Third parties providing services

E.g.: anti-fraud, payments, marketing, database enrichment, cloud storage. Under the rules of Article 39 of the LGPD.

This sharing scenario does not apply to mobile phone numbers or SMS opt-in consent data collected under Section 8, which are never shared, sold or rented to third parties or affiliates for marketing or promotional purposes.

5.2.2. Sharing by contract

Sharing with third parties (e.g. social networks) may occur upon explicit consent, in accordance with Article 7, item I.

5.2.3. Corporate transfers

In mergers, acquisitions or bankruptcies, data may be transferred (Article 7, item IX).

5.2.4. Legal disclosure

To comply with legal or regulatory obligations (Article 7, item II).

6. Information security

6.1. Confidentiality

We follow strict standards (Article 46 and Article 6).

6.2. Rights of the data subject

You may request (Article 18):

• Confirmation of processing;
• Access;
• Correction;
• Anonymization, blocking or deletion;
• Portability;
• Information about sharing;
• Withdrawal of consent;
• To petition the ANPD (Brazilian Data Protection Authority).

6.3. Security measures

We adopt market practices, such as firewalls and encryption, in accordance with Article 46.

6.4. Account cancellation

Request via contato@falecomigo.ai. Deadline of up to 15 business days, in accordance with Article 18, item VI.

6.5. Liability

Although we adopt rigorous controls, no system is 100% secure. Liabilities follow Article 42.

6.6. Restricted access

Only authorized employees or contractors have access, subject to penalties (Article 47).

6.7. Commitments undertaken

• Risk management;
• Controls and continuous improvement;
• Compliance with ISO 27001 standards and legislation;
• Ethics, transparency and accountability (Article 50).

7. Deletion of personal data

After the legal or contractual period, data is deleted (Article 16), unless there is a justification approved by the Privacy Committee.

8. Consent and data use for SMS communication

By providing your phone number and opting in to receive text messages (SMS) from falecomigo.ai, you agree to receive communications related to support, request status and authorized campaigns or notices.

8.1. No sharing of opt-in data

SMS consent information, including phone numbers and opt-in data, will not be shared, sold, rented or transferred to third parties or affiliates for marketing or promotional purposes under any circumstances. This information is used exclusively to send the communications for which the user has given consent.

Sharing data with service providers strictly necessary for the technical operation of the delivery (e.g. messaging platform) may occur, limited to the purpose of supporting the service, with no use for marketing purposes by such third parties.

8.2. Frequency and costs

Message frequency may vary. Message and data rates may apply according to your carrier’s plan.

8.3. Cancellation

You can cancel at any time by replying SAIR (or STOP). For help, reply AJUDA (or HELP).

This practice complies with the Brazilian General Data Protection Law (LGPD — Law No. 13.709/2018).

9. Contact information

For questions or rights, contact our Data Protection Officer: Paulo Henrique Rodrigues — Data Protection Officer, paulinho@falecomigo.ai.

By using our services, you confirm that you have read, understood and agree with these terms in full.