PRIMI TECNOLOGIA LTDA ("PRIMI"), headquartered at Estrada Rosa Scarpa, No. 65, Votuparim, Santana de Parnaíba, São Paulo – SP, ZIP Code 06513-010, in compliance with legal requirements and committed to serving its prospects, visitors, clients, former clients, suppliers, service providers, former suppliers, former service providers, users, job candidates, employees and former employees ("DATA SUBJECTS"), establishes its Privacy Policy.

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Not only due to its security certifications, PRIMI has a dedicated and trained team to protect all collected data and operates with the transparency of this policy to assure DATA SUBJECTS that their data is protected against leaks and breaches, as well as to use it strictly for consented purposes.

We collect and use some of our users' personal data, as controllers and processors of such personal data, being subject to all associated normative text.

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Thus, under these terms, DATA SUBJECTS give full consent to the Processing of such Personal Data.

I. COLLECTED DATA AND COLLECTION METHODS

The data collected by PRIMI, with the consent of DATA SUBJECTS, includes Registration Data (Name, CPF, phone number, among others); Access Data (passwords, among others); Digital Information and Navigation (Cookies, among others); Financial Data (payment data, other information).

The collection of this data is done directly with DATA SUBJECTS through the platforms themselves or indirectly through third parties.

For information and data provided by DATA SUBJECTS, direct collection occurs through PRIMI's digital platforms (Website, Primi Platform, Smart Seal, service centers, forms, chatbots, among others).

For information and data obtained through third parties, PRIMI receives data and information through intermediary third parties, for example, in hiring platforms, public agencies, including Credit Information Systems, among others.

Additionally, information and data may be obtained automatically through the devices that DATA SUBJECTS use. This information is used to improve the experience of DATA SUBJECTS on our platforms and utilities, such as cookies, tags, beacons for identity and session control, for example.

Data may also be collected from social media (LinkedIn, Instagram, Facebook) and public agencies (Inmetro, Transparency Portal, among others).

II. PROCESSING - DATA STORAGE AND PROTECTION

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PRIMI holds Security certifications such as ISO 27001 – Information Security and NBR 15540 – Graphic Security, and adopts physical and digital processes for data protection, as well as the best and most modern information technology security practices.

PRIMI protects data through restricted access to Personal Data, including electronic and physical access with password protection, data masking, anonymization, among other data protection techniques.

Furthermore, PRIMI adopts a strict Information Security Policy, which constantly has processes audited internally and externally; these processes safeguard the integrity and confidentiality of processed data, especially because these processes guide and direct the actions of internal personnel and any third parties responsible for processing such data.

Personal data is stored for as long as necessary for its use, depending on the respective legal obligation for storage, needs and legitimate interest of PRIMI.

III. PURPOSE OF DATA COLLECTION

All data collected by PRIMI has various purposes, including but not limited to:

• For the development of our products: in the production of materials, PRIMI may use data received from clients and public agencies, being necessary requirements for security printing;

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IV. SHARING OF PERSONAL DATA

PRIMI only shares personal data with third parties under legitimate interest and with public authorities to comply with legal obligations and under legal and judicial determination.

In this sharing of personal data, PRIMI has processes to ensure that the receiving party receives this data appropriately, guaranteeing the confidentiality of data transfer. PRIMI performs data transfers, which may be international, through secure processes with trusted suppliers.

V. RIGHTS AND DUTIES OF DATA SUBJECTS

At any time, DATA SUBJECTS have the right to know about the processing of their personal data; which personal data is processed; for what purpose it is processed; to request and correct incomplete, inaccurate or outdated data; to request anonymization, blocking, or deletion of data they consider excessive; to request review of data that is of their interest; to request deletion of data processed with consent, except for compliance with legal obligation or other legitimate interest of PRIMI; to refuse to consent to the terms - in this case, PRIMI will inform about the consequences of non-consent.

DATA SUBJECTS have the right to know how PRIMI processes their data, with a mandatory response within 15 days in complete format or immediately with a simplified response.

Processed data of DATA SUBJECTS may include information about the purpose of processing, data categories, storage periods, and entities with whom data was shared. Additionally, DATA SUBJECTS may request data portability - except for already anonymized data.

PRIMI recommends that DATA SUBJECTS always maintain the confidentiality of their login and password, and never share their personal data and information with third parties. PRIMI cannot be held responsible for improper sharing of such data by the DATA SUBJECTS themselves.

DATA SUBJECTS must always provide truthful information when using our products and services, under penalty of applicable legal sanctions.

VI. DATA PROTECTION OFFICER CONTACT

For any contact needs, to exercise your rights and clarify doubts with PRIMI, you can use the direct contact of the Data Protection Officer, Ms. Victória Colombarolli Ferreira.

Contact: dpo@primi.com.br

VII. FINAL PROVISIONS

Finally, PRIMI reserves the right to modify this policy and privacy notice at any time, always keeping it updated and available at https://primi.com.br/privacidade.

a. ANPD: National Data Protection Authority is the Public Administration body responsible for overseeing the LGPD in Brazil.

b. COOKIES: Cookies are text files created by the website, installed and stored on devices (smartphones, tablets, notebooks, among others). When the permission condition is enabled by the USER, cookie storage occurs automatically. The purpose of collecting this data is to identify and collect USER information to improve site services. Cookies are intended to provide a more personalized, agile service based on your choices.

c. DATA: the set of collected information.

d. ANONYMIZED DATA: data protected by techniques that prevent USER identification.

e. COLLECTED DATA: data obtained by PRIMI directly or indirectly.

f. PERSONAL DATA: identified or identifiable personal information of DATA SUBJECTS/USERS who access the site and platforms in an identified manner by the system.

g. SENSITIVE PERSONAL DATA: any personal data indicating racial or ethnic origin, religious belief, political opinion, union membership or affiliation with a religious, philosophical or political organization, as well as data related to sexual life, genetic or biometric issues;

h. DATA PROTECTION OFFICER: person responsible for acting as a communication channel between PRIMI, DATA SUBJECTS and ANPD;

i. HYPERLINKS: clickable link that may appear on the site or be placed in some content, directing the USER to another page on the PLATFORM or external site.

j. REGISTRATION INFORMATION: data you register on our PLATFORM.

k. DIGITAL INFORMATION: data collected by the PLATFORM during its use.

l. NAVIGATION: interaction, research and consumption of material or content from the PLATFORM or site.

m. PLATFORMS: all PRIMI channels and sites, its dependent domains, social networks, Customer Service.

n. PRODUCT: material developed by PRIMI.

o. PROSPECTS: potential clients with whom the Sales team has exclusive contact.

p. DATA SUBJECTS: prospects, visitors, clients, former clients, suppliers, service providers, former suppliers, former service providers, users, job candidates, employees and former employees;

q. THIRD PARTIES: any natural or legal person that PRIMI relates to or may relate to.

r. PROCESSING: any and all actions performed with personal data.

s. USER(S): site visitors who access regardless of the means of our PLATFORM. They are our clients and partners who must necessarily have legal capacity to accept the terms and conditions of this Cookie Policy and other legal documents of the PLATFORM.