Privacy Policy

1. Introduction

This Privacy Policy describes how we handle personal data. Xeqmate is a Brazilian company, so processing is governed by Brazil’s General Data Protection Law (LGPD — Law No. 13,709/2018); where other privacy laws apply to you — such as the GDPR in Europe or state privacy statutes in the United States — we handle your data under those as well.

By using the Platform, you agree to the practices described in this document.

2. Data We Collect

We may collect the following categories of personal data:

• Identification data: name, email, phone, tax identification number and other details provided at sign-up;
• Access data: username, password (stored securely), session logs and IP address;
• Usage data: interactions with the Platform, preferences and settings;
• Technical data: device type, browser, operating system and cookies;
• Communication data: messages sent to support or through contact forms.

3. Purposes of Processing

We use your personal data to:

• Provide, operate and improve the Platform Services;
• Create and manage your user account;
• Authenticate access and keep the system secure;
• Send service-related communications, notices and updates;
• Handle support requests;
• Comply with legal and regulatory obligations;
• Prevent fraud and unlawful activity.

4. Legal Bases

Processing relies on the following legal bases, as applicable under the LGPD and equivalent provisions of other privacy laws:

• Performance of a contract or pre-contractual steps;
• Compliance with a legal or regulatory obligation;
• Legitimate interests, with the data subject’s rights respected;
• The data subject’s consent, where required.

5. Data Sharing

Your personal data may be shared with:

• Service providers that support the operation of the Platform (hosting, email, payments, support);
• Public authorities, where required by law, regulation or a court order;
• Commercial partners, with your consent or where necessary to deliver the service.

We do not sell personal data. We require third parties to apply the same level of protection set out in this Policy.

6. Data Retention

Personal data is kept for as long as necessary to fulfil the purposes described in this Policy, to meet legal obligations or to resolve disputes. After that period, the data is deleted or anonymised, unless the law requires it to be retained.

7. Your Rights

Under the applicable privacy law, you may request:

• Confirmation that processing exists, and access to the data;
• Correction of incomplete, inaccurate or outdated data;
• Anonymisation, blocking or deletion of data that is unnecessary or processed unlawfully;
• Data portability, where applicable;
• Information about the sharing that has taken place;
• Withdrawal of consent, where consent is the legal basis.

To exercise your rights, use the contact channels provided on the Platform. We will reply within the statutory deadlines.

8. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or improper disclosure, including access control, encryption in transit and system monitoring.

No method of transmission or storage is completely secure. In the event of an incident that poses a risk to data subjects, we will take the measures required by the applicable law.

9. Cookies and Similar Technologies

We use cookies and similar technologies for authentication, for the Platform to work, for usage analytics and to improve the experience. You can manage cookies in your browser settings, bearing in mind that disabling essential cookies may affect how some features work.

10. International Transfers

Your data may be processed on servers located in Brazil or abroad. Where an international transfer takes place, we apply appropriate safeguards as required by the applicable privacy law.

11. Minors

The Platform is not intended for anyone under 18 without the supervision of a legal guardian. We do not knowingly collect data from minors without appropriate consent. If we identify such a case, we will take steps to delete the data.

12. Changes to this Policy

This Policy may be updated from time to time. The current version is published on the Platform with its update date. We recommend checking this document regularly.

13. Contact

For questions, requests or complaints about this Privacy Policy and the processing of personal data, use the contact channels provided on the Platform.

You may also lodge a complaint with Brazil’s National Data Protection Authority (ANPD): www.gov.br/anpd, or with the supervisory authority in your own country.

Last updated: June 2026.