2.1 Data Provided by the Client

• Registration information: Name, email address, phone number, job title, department, and other information necessary for creating Authorized User accounts.
• Employee and third-party data: Any information that the Client decides to enter or synchronize in PowerComm, including Microsoft Entra data.

2.2 Automatically Collected Data

• Usage data: Information about how Authorized Users interact with PowerComm, including access logs, IP addresses, device type, operating system, and other technical information.
• Cookies and similar technologies: We use cookies and similar technologies to improve user experience and collect statistical data.

PowerComm processes Personal Data exclusively to:

PowerComm’s Processing of Personal Data is based on the following legal bases:

• Contract execution: Necessary for the provision of services agreed upon with the Client.
• Compliance with legal or regulatory obligation: To meet legal, judicial, or regulatory requirements.
• Legitimate interest: For security purposes, fraud prevention, and service improvement, provided that the fundamental rights and freedoms of the Data Subject do not prevail.

PowerComm may share Personal Data with:

• Authorized sub-processors: Service providers contracted to assist in Processing, provided they comply with confidentiality and security obligations equivalent to those established in this policy.
• Competent authorities: In case of legal requirement, court order, or regulatory demand.

Personal Data may be transferred and stored on servers located outside Brazil. In such situations, PowerComm ensures that international transfers are carried out in compliance with LGPD and GDPR, adopting appropriate measures to ensure data protection, such as standard contractual clauses and recognized certifications.

We implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, loss, alteration, or destruction, including:

Personal Data will be retained for the period necessary to fulfill the purposes for which it was collected, in accordance with applicable legal, regulatory, or contractual obligations. After this period, data will be securely deleted or anonymized, unless there is another legal basis justifying its retention.

Data Subjects have the following rights, which may be exercised through the Controller (Client):

PowerComm will assist the Client in responding to Data Subject requests, in accordance with legal obligations.

We use cookies and similar technologies to:

• Authenticate users and maintain active sessions.
• Analyze platform performance and usage.
• Personalize content and features.

The Client and Authorized Users may manage cookie preferences in their browser settings, noting that disabling certain cookies may affect PowerComm functionality.

This privacy policy may be updated periodically to reflect changes in our services or applicable laws. We will notify the Client of significant changes with reasonable advance notice. Continued use of PowerComm after changes take effect constitutes acceptance of the updated privacy policy.

• Applicable Law: This privacy policy is governed by Brazilian law.
• Dispute Resolution: Any disputes will be resolved as provided in the PowerComm Terms and Conditions of Use.
• Entirety: This privacy policy supplements the Terms and Conditions of Use, prevailing in case of specific conflict regarding privacy and data protection.

This privacy policy takes effect on its creation date and will remain valid until March 20, 2026, and may be revised, updated, or revoked at any time by decision of the Board of Directors. Upon expiration of the validity period, it must be reassessed regarding its applicability and currency, and may be renewed upon new formal approval.