EPOC Privacy Policy

IMPORTANT!

We clarify, from the outset, that by registering on our website /aplicativo, ao inserir dados em nossa plataforma/redes sociais e/ou ao nos enviar de qualquer outro modo quaisquer informações, o usuário estará, neste ato, vinculando-se, legal e formalmente, a esta Policy, to the Cookie COOKIES and to the other regulations governing the activities of EPOC TECH (“Acceptance”).

What does this mean?

O Acceptance means that the user declares and attests to full and complete awareness of how our company will process personal data.

ATTENTION!

If you do not agree with this Policy please immediately discontinue use of our sites /aplicativos/plataformas, não efetuando qualquer cadastro em nossos ambientes, inclusive redes sociais, nem tampouco fornecendo, de qualquer outro modo, quaisquer informações à EPOC TECH. Esteja ciente de que, ao não concordar com a nossa Policy, Cookie COOKIES and/or the other regulations governing this company's activities; such activities, including the provision of our Products and the rendering of our Services, will not be able to take place.

Although our journey together cannot continue if you decline the above documents, your opinion is extremely important to us! That's why we kindly ask that you let us know the reason for your disagreement, so that we can continuously improve our activities.

• To make it easier for you to find what you need, we've highlighted below the main topics of this Policy:

TABLE OF CONTENTS

• WHAT IS PERSONAL DATA?
• WHAT DOES IT MEAN TO PROCESS PERSONAL DATA?
• WHAT PERSONAL DATA DO WE PROCESS?
• WHY DO WE COLLECT AND USE PERSONAL DATA?
• WHO DO WE SHARE PERSONAL DATA WITH, AND WHY?
• ACCESS TO PERSONAL DATA, SECURITY, AND DISPOSAL
• HOW TO CANCEL YOUR REGISTRATION OR CHANGE/DELETE PERSONAL DATA?
• INFORMATION ABOUT CHANGES TO THE PRIVACY POLICY
• APPLICABLE LAW
• If you have any questions regarding this Policy, don't hesitate to contact us at the following email: [email protected], using the subject line “Privacy Policy – [Title].” The EPOC TECH has a Data Protection Officer (“DPO”) formally appointed, and an established Data Protection Governance Committee, as recorded in registered minutes, working to ensure LGPD governance and compliance.

1. WHAT IS PERSONAL DATA?

› Any information related to an identified or identifiable natural person (Art. 5, I, LGPD).

2. WHAT DOES IT MEAN TO PROCESS PERSONAL DATA?

› Processing personal data means carrying out any activity involving the data/information of a natural person. These activities include: collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, disclosure, or extraction (Art. 5, X, LGPD).

3. WHAT PERSONAL DATA DO WE PROCESS?

› Contact data: these are the data collected through fields available on our sites /aplicativos/plataformas e/ou em outros meios disponibilizados, a fim de propiciar a realização de contatos, inclusive para a disponibilização de Services and/or Products by EPOC TECH: first/last name, personal/business address, email/phone number.

› Data collected for the effective performance of activities: these are the data, including registration data, collected so that EPOC TECH can effectively carry out its activities, in particular to provide its Services and/or supply its Products: in addition to contact data, this includes RG/RNM (ID document), CPF (taxpayer ID), date of birth, gender, and photo. Corporate data, such as CNPJ, State/Municipal Registration, A1 Certificate (file and password), full business and administrative address, among other registration-related data, may also be collected for the provision of Services and/or the supply of Products.

› Browsing/device data on our sites /aplicativos/plataformas: these are the data collected when browsing our sites /aplicativos/plataformas: endereço IP, localização geográfica, fonte de referência, tipo de navegador, duração/frequência das visitas e páginas visitadas. Essas informações, normalmente, são obtidas mediante COOKIES installed in the browser itself. For more information, please visit our Cookie COOKIES, at the following link: <https://epoc.com.br/cookies/>.

› Contact history: The EPOC TECH may store information regarding contacts already made, such as personal interactions, via email, phone/chat/ whatsapp and/or website /aplicativo/plataforma.

› Data made manifestly public: a EPOC TECH may process this type of data, which includes, for example, information posted on social media and similar platforms. But don't worry! Even in this case, we, at EPOC TECH, respect the good faith and purpose that justified making that data available/public on social media. Still worried? Relax! Any questions can be clarified at any time through the channel indicated above.

› On occasion, requests for other information may be made through direct contact with our team.

4. WHY DO WE COLLECT AND USE PERSONAL DATA?

› The data collected by EPOC TECH are used so that it can fully carry out its activities, including providing its Services and/or supply its Products, aiming, on the one hand, whenever possible, to improve the user experience and, on the other hand, to keep each person's privacy preserved. That's why the data/information collected by EPOC TECH will be treated as confidential and used only for the purposes described herein.

› In this spirit, we will be able to safeguard the personal data involved in the processing carried out by EPOC TECH, protecting it while, at the same time, personalizing our activities, including our Products e Services, so as to improve them and increasingly tailor them to users' preferences, in compliance with applicable law, in particular the LGPD, and the other provisions of this Policy and the Cookie COOKIES.

› For more information about our Products e Services, please visit the following link: <www.epoc.com.br / www.epocgo.com.br>.

› Occasionally, the EPOC TECH may process the personal data referred to in this Policy for purposes not provided for herein, but that fall within legitimate expectations. Any use of personal data for purposes that do not meet this requirement will only take place with authorization/notice.

› In addition to the situations mentioned in this Policy, personal data may be processed for the following purposes, in compliance with applicable law and legal bases in force, as well as the other provisions contained in this Policy, of the Cookie COOKIES and the regulations of EPOC TECH:

› Users may cancel, at any time, their registration for receiving advertising messages, in compliance with the provisions of this Policy, in particular, item 7.

• The emails and/or phone numbers/chat/ whatsapps registered may be used to send information requested on our sites /aplicativos/plataformas. Também poderão ser utilizados para o envio de notícias, ofertas de produtos, serviços e outras informações relacionadas a temas de interesse do usuário. Os e-mails e/ou os telefones/chat/ whatsapps may also be used to announce the launch of new services and/or products.
• Employees of EPOC TECH may get in touch via email and/or phone/chat/ whatsapp, to conduct surveys and/or share information about products, services, promotions, news, updates, events, and other matters that may be of interest to the user.
• A EPOC TECH may also carry out statistical analyses, preferably in anonymized form, and send advertising based on the user's tastes, interests, and preferences, as well as customize the service to increasingly match those tastes, interests, and preferences. The data may also be used, when compatible with these purposes and within the limits of the LGPD, for statistical models, development of artificial intelligence-based features, and continuous improvement of the services provided;
• A EPOC TECH may develop sector-based consumption profiles from anonymized data, which may be shared with interested third parties, always respecting the principles of the LGPD and ensuring that data subjects cannot be identified;
• May be sent by EPOC TECH, messages regarding support or related services, such as alerts, notifications, and updates;
• A EPOC TECH may also use personal data for any purpose compatible with legitimate expectations or authorized at the time of collection; and
• A EPOC TECH may also use personal data to comply with legal/regulatory obligations or for the regular exercise of rights.

5. WHO DO WE SHARE PERSONAL DATA WITH, AND WHY?

› A EPOC TECH may share personal data with partners/third parties and/or companies within the same group (“Group”), to the extent that such sharing proves reasonably necessary for the purposes established in this Policy and for the effective performance of its activities, including the provision of its Services and/or the supply of its Products, in compliance with applicable law, in particular the LGPD, and the other provisions contained in this Policy, of the Terms and Conditions of Use, as well as the other policies, regulations, and contractual relationships of EPOC TECH. For more information about any partners referenced on our website/ app/platform, as well as their policies, we kindly ask that you visit their respective web pages.

› Personal data/information may be shared with third parties as a result of negotiations in which EPOC TECH takes part, to the extent strictly necessary, in compliance with applicable law, in particular the LGPD, and the other provisions contained in this Policy, of the Terms and Conditions of Use <https://epoc.com.br/termos-de-uso/>, as well as the other policies and regulations of EPOC TECH.

› Personal data/information may also be shared with third parties in the following situations: (i) pursuant to a court order; (ii) if the act is necessary for compliance by EPOC TECH with applicable law; and/or (iii) if there is express authorization.

› A EPOC TECH may also share personal data with companies located in other countries, such as Google, Microsoft, and/or Amazon, primarily for the purpose of cloud data storage.

› A EPOC TECH hereby advises that, should any international data transfer occur, it will be carried out in accordance with the security measures necessary to guarantee the confidentiality, integrity, and availability of the personal data transferred, in compliance with applicable law, in particular the LGPD.

6. ACCESS TO PERSONAL DATA, SECURITY, AND DISPOSAL

› Without prejudice to item 5 above, the personal data processed by EPOC TECH will be restricted solely to the employees of EPOC TECH and, among these, only to those persons with the specific internal authorizations required. Occasionally, if such information is entered as part of actions created through partnerships, explicitly identified partners will also have access to the information, according to the quantum necessary, in compliance with applicable law, in particular the LGPD, and the other provisions contained in this Policy, of the Terms and Conditions of Use, as well as the other policies, regulations, and contractual relationships of EPOC TECH. Exceto por força da lei, nenhum dado pessoal tratado pela EPOC TECH may be publicly disclosed without prior express authorization.

› The personal data processed by EPOC TECH are considered confidential, and any use of such information will comply with applicable law, in particular the LGPD, with this Policy, the Terms and Conditions of Use, as well as with the other policies, terms, regulations, and contractual relationships of EPOC TECH. Nós, da EPOC TECH, we will make every reasonable effort, in accordance with current technology, to ensure the security of our systems and, consequently, of the personal data processing we carry out.

› The personal data processed by EPOC TECH will, whenever possible, be anonymized or encrypted, provided this practice does not prevent their use by EPOC TECH, in the supply of its Products and/or in the provision of its Services.

› Upon request, we may grant access to and/or provide information about the personal data we process and store in our systems, when acting as controller of the personal data processing, pursuant to Art. 5, VI, of the LGPD, subject to the rights and obligations set forth in contracts and/or by law. In that case, the user who is the data subject may directly exercise the rights provided for under applicable law, in particular those under Art. 18 of the LGPD, namely: (i) confirmation of the existence of processing, (ii) access to the data, (iii) correction of incomplete, inaccurate, or outdated data, (iv) anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in noncompliance with the LGPD, (v) portability, among others.

› We, at EPOC TECH will keep personal data in our database only: (i) for as long as they are necessary or relevant to the purposes described in this Policy; (ii) to meet deadlines predetermined by law; (iii) to comply with a legal or regulatory obligation; (iv) for the regular exercise of rights; (v) for as long as they are necessary to maintain the legitimate interests of EPOC TECH, under the terms of the law.

› Information about the access, security, and disposal mechanisms for personal data adopted by any of our partners can be found in their respective policies, it being each one's sole responsibility to adopt measures consistent with applicable law, in particular the LGPD, to protect the privacy of, and any data relating to, identified or identifiable natural persons.

7. HOW TO CANCEL YOUR REGISTRATION OR CHANGE/DELETE PERSONAL DATA?

› The data processed by EPOC TECH will be deleted from our servers upon express, written request, or when they are no longer necessary or relevant to carrying out our activities, unless there is any other reason for retaining them, such as: (i) compliance with a legal or regulatory obligation; (ii) the regular exercise of rights; (iii) legitimate interest, without being limited to these. To change personal information or delete it from our database, in compliance with the provisions of this Policy and applicable law, the user must send an email to <[email protected]>, using the subject line “Privacy Policy – Registration Cancellation/Change/Deletion of Personal Data.”

› At any time, those who receive emails sent by us, at EPOC TECH, may choose to stop receiving them, except with respect to those: (i) essential to the continuity of the provision of our Services and/or provision of our Products; and (ii) that, due to a legal or regulatory obligation, need to be sent by EPOC TECH to its clients/users. To effectively exercise this option, simply request the removal of your email from our contact list through the following email address <[email protected]>, indicating as the subject “Privacy Policy – Removal of email from the contact list”.

› It is important to clarify that, upon filling out any form again or completing any type of registration, you will be automatically reintegrated into the contact list of EPOC TECH. Portanto, caso seja de interesse não mais receber os nossos e-mails, será necessário solicitar, novamente, a exclusão do respectivo endereço eletrônico da nossa lista de contatos.

8. CHANGES TO THE PRIVACY POLICY

› We clarify, from the outset, that our Policy may undergo updates. Therefore, we recommend periodic visits to our website/application/platform to keep up with the latest news! Any and all revisions and updates will only be valid and take effect upon their publication on our sites/ applications/platforms.

› If any material changes are made, the user will be notified accordingly.

9. GOVERNING LAW AND JURISDICTION

› This document is governed by the laws of the Federative Republic of Brazil and must be interpreted in light of them.

› The courts of the Judicial District of São Paulo, State of São Paulo, are hereby elected as competent to settle any disputes that may arise from this document, with express waiver of any other, however privileged it may be.

This Policy was last modified on June 10, 2025.

*Document compliant with CD/ANPD Resolution No. 2/2022, applicable to small-scale data processing agents.