Privacy Policy

AJUDA.DIGITAL LTDA, a privately held limited liability company registered under CNPJ 55.080.297/0001-34, with its registered office at BR 470 — KM 176, nº 2492, Sala 04, Veranópolis/RS, CEP 95330-000 ("AJUDA.DIGITAL", "we" or "Company"), is the data controller responsible for the personal data processed through its digital products and services. This Privacy Policy describes how we collect, use, store, share, and protect your personal data, in compliance with the Brazilian General Data Protection Law (Law No. 13,709/2018 — LGPD) and other applicable legislation. By accessing or using any AJUDA.DIGITAL product, platform, or service, you acknowledge that you have read and understood this Policy.

We may collect the following categories of personal data: • Identification data: full name, CPF, RG, date of birth, gender, nationality. • Contact data: email address, phone number, residential or business address. • Professional data: job title, company, field of work, resume, professional history (especially on the penseempregos.com.br portal). • Account and access data: email address, encrypted password, profile photo, account preferences. • Usage and browsing data: IP address, browser type, operating system, pages visited, time spent, clicks, referral source, device identifiers. • Financial data: payment information (processed by third parties — payment gateways), billing data, transaction history. • Communication data: content of messages sent via contact forms, email, or support chat. • Real estate data: registered property information, search preferences, interaction history (xcub platform). • AI-generated data: interactions with artificial intelligence agents, prompts, generated responses, and session metadata. • Sensitive data: we do not collect sensitive data (racial or ethnic origin, religious beliefs, political opinions, health or sexual life data, genetic or biometric data) unless strictly necessary and with the data subject's specific consent.

The processing of your personal data is grounded in the following legal bases set forth in Article 7 of the Brazilian General Data Protection Law (LGPD): • Consent (Art. 7, I): when you expressly agree to the processing, such as when accepting optional cookies or subscribing to newsletters. • Performance of a contract (Art. 7, V): when processing is necessary for the performance of a contract or preliminary contractual procedures to which you are a party, such as the provision of our SaaS services. • Compliance with a legal or regulatory obligation (Art. 7, II): when we need to process data to comply with legal, tax, or regulatory obligations. • Regular exercise of rights (Art. 7, VI): when processing is necessary for the regular exercise of rights in judicial, administrative, or arbitration proceedings. • Legitimate interest (Art. 7, IX): when processing is necessary to serve the legitimate interests of AJUDA.DIGITAL or third parties, such as fraud prevention, information security, product improvement, and statistical analyses, always respecting your fundamental rights and freedoms. • Credit protection (Art. 7, X): when applicable to financial operations related to our services.

We use your personal data for the following purposes: • Provision and operation of our digital services and platforms (SaaS, job portal, real estate platform, AI agents). • Creation and management of your user account. • Payment processing and issuance of tax documents. • Communication about service updates, security alerts, and relevant notifications. • Sending marketing communications, newsletters, and offers, when authorized. • Personalization of the user experience and AI-based recommendations. • Statistical analyses, usage metrics, and continuous product improvement. • Prevention and detection of fraud, abuse, and unlawful activities. • Compliance with legal, regulatory, and contractual obligations. • Responding to requests and providing customer support. • Defense in judicial, administrative, or arbitration proceedings.

We use cookies and similar technologies to improve your experience, analyze traffic, and personalize content. The types of cookies used include: • Essential cookies: required for the basic operation of the platforms, such as authentication and security. These cannot be disabled. • Performance and analytics cookies: collect information about how you use our services, enabling continuous improvements. Example: Google Analytics. • Functionality cookies: store preferences such as language, region, and interface settings. • Marketing cookies: used to display relevant advertisements and measure the effectiveness of advertising campaigns. You may manage your cookie preferences at any time through the consent banner displayed on our websites or through your browser settings. Disabling non-essential cookies may affect certain functionalities.

Your personal data may be shared with: • AJUDA.DIGITAL ecosystem companies: our child products (sentic.link, tempo.sale, penseempregos.com.br, xcub, Potentius) may share data within the ecosystem for integration purposes, service improvement, and a unified user experience. • Service providers and partners: companies contracted for hosting services (Google Cloud Platform), payment processing, email delivery, analytics, customer support, and other essential services, always pursuant to contracts that ensure the protection of your data. • Public authorities: when required by law, regulation, court order, or request from a competent authority. • Legal and accounting advisors: for compliance with legal and tax obligations. We do not sell, rent, or trade your personal data to third parties for purposes not described in this Policy.

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including: • Account data: while your account is active and for up to 5 (five) years after closure, for compliance with legal obligations and defense in potential disputes. • Tax and financial data: for the period required by Brazilian tax legislation (minimum of 5 years). • Usage and analytics data: for up to 2 (two) years, in aggregate or anonymized form when possible. • Application data (penseempregos.com.br): for the validity period of the application or for up to 2 (two) years, unless renewed by the data subject. • Data for legal defense: for the applicable statute of limitations period, as provided by current legislation. After the retention period expires, data will be deleted or anonymized, unless retention is required by a legal or regulatory obligation.

Under Articles 17 to 22 of the Brazilian General Data Protection Law (LGPD), you have the following rights: • Confirmation of processing: to know whether we process your personal data. • Access to data: to obtain a copy of the personal data we hold about you. • Correction of data: to request the correction of incomplete, inaccurate, or outdated data. • Anonymization, blocking, or deletion: of unnecessary or excessive data, or data processed in violation of the LGPD. • Portability: to request the transfer of your data to another service provider, upon express request. • Deletion of consent-based data: to request the deletion of data whose processing was based on your consent. • Information on sharing: to know which public and private entities your data has been shared with. • Withdrawal of consent: to withdraw consent at any time, without prejudice to the lawfulness of processing carried out prior to the withdrawal. • Objection to processing: to object to processing carried out on the basis of legitimate interest, if you believe your fundamental rights are not being respected. • Review of automated decisions: to request a review of decisions made solely on the basis of automated processing of personal data. To exercise your rights, please contact us at privacy@ajudadigital.com. We will respond to your request within 15 (fifteen) days, as provided by the LGPD. We may request additional information to verify your identity before fulfilling the request.

Your personal data may be transferred to and stored on servers located outside Brazil, particularly in the United States, due to the use of cloud computing services (Google Cloud Platform) and other infrastructure tools. Such transfers are carried out in compliance with Article 33 of the LGPD, adopting the following safeguards: • Standard contractual clauses ensuring a level of protection equivalent to that provided by Brazilian legislation. • Transfers to countries or international organizations that provide an adequate degree of personal data protection as required by the LGPD. • Specific and prominent consent from the data subject, when applicable. AJUDA.DIGITAL ensures that, in any international transfer, your personal data will be processed with the same level of protection required by Brazilian legislation.

Our services are not directed at individuals under 18 (eighteen) years of age. We do not intentionally collect personal data from children (under 12 years old) or adolescents (between 12 and 18 years old) without the specific consent of a parent or legal guardian, as required by Article 14 of the LGPD and the Brazilian Child and Adolescent Statute (Law No. 8,069/1990). If we become aware that we have collected data from minors without proper consent, we will take immediate steps to delete such data. If you are a parent or legal guardian and believe your child has provided personal data without authorization, please contact us at privacy@ajudadigital.com.

AJUDA.DIGITAL adopts appropriate technical and administrative measures to protect your personal data against unauthorized access, destruction, loss, alteration, disclosure, or any form of improper or unlawful processing, including: • Encryption of data in transit (TLS/SSL) and at rest. • Role-based access controls (RBAC) and the principle of least privilege. • Multi-factor authentication for access to internal systems. • Continuous security monitoring and intrusion detection. • Regular backups and disaster recovery plans. • Periodic security audits and vulnerability testing. • Staff training and awareness on data protection. • Firewalls, intrusion prevention systems, and network segmentation. In the event of a security incident that may pose a risk or significant harm to data subjects, AJUDA.DIGITAL will notify the Brazilian National Data Protection Authority (ANPD) and the affected data subjects, as provided in Article 48 of the LGPD, and will take the necessary measures to mitigate the damage.

AJUDA.DIGITAL reserves the right to amend this Privacy Policy at any time to reflect changes in our services, data processing practices, or legal requirements. Changes will take effect on the date the updated version is published on our websites and platforms. When we make material changes, we will notify you through a prominent notice on our services or by email, as appropriate. We recommend that you review this Policy periodically to stay informed about how we protect your data.

The Data Protection Officer (DPO) of AJUDA.DIGITAL is: Name: Lúcio Carobin Machado Email: privacy@ajudadigital.com The DPO is responsible for receiving complaints and communications from data subjects and the ANPD, providing clarifications, and taking appropriate action, as set forth in Article 41 of the LGPD.

For questions, requests, or complaints regarding this Privacy Policy or the processing of your personal data, please contact us: AJUDA.DIGITAL LTDA CNPJ: 55.080.297/0001-34 Address: BR 470 — KM 176, nº 2492, Sala 04 — Veranópolis/RS, CEP 95330-000 Email: privacy@ajudadigital.com If you believe that the processing of your personal data violates applicable legislation, you have the right to file a complaint with the Brazilian National Data Protection Authority (ANPD) — www.gov.br/anpd.