This Privacy Policy describes the personal data we collect, how it is used, stored and shared, and your rights in relation to that data. We recommend careful reading.

Introduction

SUMMARY:
1.INTRODUCTION2.OBJECTIVE
3.WHO WE ARE4.DEFINITIONS5.PRINCIPLES OF INFORMATION SECURITY6.DATA WE COLLECT6.a. FROM CUSTOMERS6.a.1.How we use this data6.b. OF CONSUMERS6.b.1. How we use this data7.HOW WE SHARE DATA8.COOKIES AND WEB TRACKING TECHNOLOGIES9.INTERNATIONAL DATA TRANSFER10.INFORMATION SECURITY DATA SUBJECT RIGHTS12.DATA STORAGE TIME11.DATA SUBJECT RIGHTS12.DATA STORAGE TIME13.TIME RMINO DO DATA PROCESSING14.LIMITATIONS OF LIABILITY OF FLECH PAY15.FRAUD AND INTERRUPTIONS OF SERVICES16.LEGAL17. POLICY CHANGES18.HOW TO TALK TO SUMMARY:

FLECH PAY SOLUÇÕES DE PAGAMENTO LTDA (“we”), registered with CNPJ/MF nº 44.640.363/0001-67, with headquarters at QE 40 rua 1 lot 21, Brasília/DF, takes your privacy seriously. Therefore, we have prepared this privacy and data security policy (“Policy”) to reaffirm our commitment to adopting the best information security practices and protecting our customers’ data. When you use our services, you trust your data and information. And that’s why we’re committed to preserving that trust.

When you hire Flech pay services, you provide us with your personal data so that we can enable you to purchase our products and services. At Flech pay, privacy, security and transparency are fundamental values and we will always adopt best practices to guarantee the confidentiality and integrity of your personal data. ACCEPTANCE OF OUR POLICY WILL TAKE PLACE AT THE MOMENT YOU AFFIRMATIVELY AGREE TO THE USE OF YOUR DATA FOR EACH OF THE PURPOSES DESCRIBED BY US HERE. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT ACCEPT IT AND DO NOT CONTINUE YOUR REGISTRATION PROCEDURE.

2.PURPOSE In this Privacy and Data Security Policy (“Policy”) we explain the ways in which we use, store, share and protect personal data collected from the use of our web solutions and applications. We also explain how data subjects can exercise the rights provided for in applicable legislation. The personal data we collect depends on the context of your interactions with Flech pay. To facilitate your understanding, we explain in this Policy how we process the data of (i) Flech pay customers (“Customers”) and Customer consumers (“Consumers”). Specific Privacy Policies may apply to some of our products and services. More information about our privacy practices related to a specific product or service is available in the access and use area of this product or service.

3.WHO ARE WE Flech pay is a Digital bank, we offer a web platform with a complete portfolio of financial solutions that include applications to facilitate purchases in physical and online establishments, billing control, collections, payment method intermediary. It also offers digital wallets allowing payments, transfers between Accounts, international transfers, withdrawals, payment of bills and utility bills, cell phone recharge and debit/credit card transactions, among others.

4.DEFINITIONS For the purposes of this Policy, the following definitions will be adopted: General Data Protection Law (LGPD): Federal Law No. 13,709 published on August 14, 2018 that regulates Personal Data Processing activities, including in the media digital data, by a natural person or legal entity governed by public or private law, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the personality of the natural person. Information: gathering or set of data and knowledge resulting from the processing, manipulation and/or organization of data, in such a way that it represents a change (quantitative or qualitative) in the knowledge of the system (human or machine) that receives it; Information Security: set of actions and controls aimed at ensuring the preservation of aspects of confidentiality, integrity, availability, authenticity and compliance of information, contributing to the fulfillment of Flech pay’s strategic objectives; Confidentiality: information must only be disclosed to authorized individuals, entities or processes; Integrity: safeguarding the accuracy of information and processing methods; Availability: whenever necessary, authorized people must obtain access to information and corresponding assets; Compliance: compliance with a legal or regulatory requirement related to company administration, within the ethical and conduct principles established by Flech pay Senior Management.

5.PRINCIPLES OF INFORMATION SECURITY Our commitment to the appropriate treatment of information from Flech pay, customers and the general public is based on the following principles: Confidentiality: ensuring that information will not be available or disclosed to individuals, entities or applications without authorization. In other words, it guarantees the protection of information given personally in trust and protection against unauthorized disclosure. Integrity: ensuring that the information has not been altered in its content and, therefore, is complete, authentic, genuine and reliable. Complete information is information that has not been altered improperly or unauthorizedly. Availability: allows information to be used whenever necessary, within reach of its users.

6. DATA WE COLLECT a) FROM CUSTOMERS In general, when you or your company hires, uses or interacts with our solutions, we collect your personal data, which can be divided into two categories: (i) Data that you give us provides: when you hire, use or interact with the Services or communicate with us in any way, you (or your company) provide us with some data. The amount of data collected will be according to the need and according to your relationship and the service you contract. This data includes: Customer ID, CPF/CNPJ, full name, company name, mother’s name, father’s name, spouse’s name, profession, professional contact details, gender, date of birth, postal address, address coordinates (longitude and latitude), telephone and cell phone number, email, bank details, as well as data about purchases and loyalty made as a Customer (date of purchase, place of purchase, time of purchase, purchase amount, currency, cart of purchases, sector, type of purchase – online / offline, payment method with voucher, card, bill or invoice Marketing preferences, such as your email address, username and password; credit card details, bank details and address for invoices and bills; Data related to technical support and troubleshooting. This data includes call opening data, such as the type of product or service related to your request for help, contact details. or authentication and the content of your communications with us, including telephone recordings. (ii) Data we collect automatically: when you use our services, we may collect and store data automatically. This data includes: Data from devices you use to access the Services, such as your IP address, operating system, geolocation information and device identifier. Log data, such as your IP address and your activities on the Services (such as the date and time associated with your use, pages and files viewed, searches and other actions you perform (such as which features you used).Browsing data, i.e. data about how you use and interact with our Services, which may include the dates you used the Services and your browsing activities. , including metrics related to sending emails and other types of communications you send through the Services a.1) How we use this data we use the data collected or received from your use of the Services for the following purposes: Comply with our. contractual obligations with you or your company. This includes creating and managing accounts you may have with us, verifying your identity, collecting amounts owed by you, providing,personalize and improve our services; Notify you about any changes to our products and services; Perform internal operations, including support, troubleshooting, data analysis, testing, research and statistics; Strengthen our security and protection procedures, aiming to provide a safer and more effective service; Provide information about other services and/or products we offer, similar to those already contracted by you; Evaluate or understand the effectiveness of the advertising we serve, aiming to provide relevant advertising to you; Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies, contracts or terms of use; As necessary, to establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law. b.1) How we use this data we may use data collected or received from your use of the Services our Customers for the following purposes: Provide, personalize and improve our Services; Perform internal operations, including supporting our customers, troubleshooting, data analysis, testing, research and statistics; Develop marketing strategies for our Clients, so that they can offer relevant advertising to you. Proceed with payment requests made by you, in payment intermediation operations. Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies or terms of use; Establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law.prevent and/or remedy fraud or other potentially illegal or prohibited activities, as well as violations of applicable policies, contracts or terms of use; As necessary, to establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law. b.1) How we use this data we may use data collected or received from your use of the Services our Customers for the following purposes: Provide, personalize and improve our Services; Perform internal operations, including supporting our customers, troubleshooting, data analysis, testing, research and statistics; Develop marketing strategies for our Clients, so that they can offer relevant advertising to you. Proceed with payment requests made by you, in payment intermediation operations. Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies or terms of use; Establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law.prevent and/or remedy fraud or other potentially illegal or prohibited activities, as well as violations of applicable policies, contracts or terms of use; As necessary, to establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law. b.1) How we use this data we may use data collected or received from your use of the Services our Customers for the following purposes: Provide, personalize and improve our Services; Perform internal operations, including supporting our customers, troubleshooting, data analysis, testing, research and statistics; Develop marketing strategies for our Clients, so that they can offer relevant advertising to you. Proceed with payment requests made by you, in payment intermediation operations. Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies or terms of use; Establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law.Proceed with payment requests made by you, in payment intermediation operations. Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies or terms of use; Establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law.Proceed with payment requests made by you, in payment intermediation operations. Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies or terms of use; Establish, exercise and defend rights in judicial, administrative or arbitration proceedings; Comply with legal or regulatory obligations, or as required in a legal proceeding, by any law enforcement or government body having jurisdiction, or claiming jurisdiction, over Flech pay. For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law.

7.HOW WE SHARE DATA As we have several solutions involving consumer, purchasing, financial, customer loyalty operations, among others, we can work together with other companies in various activities. Therefore, we reserve the right to share your information, including personal data relating to your financial situation, whenever possible, in a “pseudo-anonymized” way, aiming to preserve your privacy as much as possible. We do not license, sell or transfer your personal data to anyone, except for the types of companies listed below. Third-Party Service Providers: We work with third-party service providers to help us operate, perform, improve, understand, customize, support, and advertise our Services. When we share data with third-party service providers, we require that they use your data in accordance with our instructions and terms or with your express consent, where applicable. Credit Protection Entities: We may share your registration data with entities dedicated to reducing credit risk and protecting companies and individuals against fraud, in order to validate the information you provide. Regulatory bodies, judicial or administrative authorities: we may share your personal information to provide the competent authorities with all the information requested regarding the Owner and the operations carried out by him on the Sites. Furthermore, we may share your personal data with public authorities or private entities to combat fraud and abuse in the use of the Services, to investigate suspected violations of the law, or to combat any other suspected non-compliance with our policies and contracts. Transfer of Assets: If our company is reorganized or sold and all or substantially all of the assets are transferred to a new owner, your personal information may be transferred to the buyer regardless of your authorization to ensure continuity of services;

8.COOKIES AND WEB TRACKING TECHNOLOGIES Cookies are small text files saved on your computer that can be accessed again at a later date. The use of cookies does not harm you or your device. Cookies allow us to understand how you have used our website and web platform and thus facilitate your navigation to improve your experience. Cookies allow you to log in to access our services and also help us to personalize our website for you, as well as allowing us to measure the advertising and online digital content most relevant to your browsing. We may use various technologies to automatically collect and store data about your use of the Services. These technologies include cookies, pixels, web beacons and SDKs. We use the information collected through these technologies to optimize and personalize your browsing experience, target advertising campaigns, develop and apply security features and fraud prevention procedures, among other possible uses. Some areas of our websites can be accessed without the need for login or registration. In these areas we will also record certain information automatically, which will allow us to collect static data regarding the use and efficiency of our websites and thus adapt them to the needs of our users. For this reason we record information about your IP address, the time and duration of your visit, the number of visits, your use of online forms, your search and viewing settings, and your favorite tools on our website. Cookies’ storage time is different. Most of the Cookies we use are Temporary Cookies that are automatically deleted as soon as you leave our website (session cookies). However, we also use persistent cookies, which remain on your device for a longer period, used to recognize you when you access our website. We record each time our website is accessed and each time the user opens a file stored on our website. We emphasize that conventional Internet browsers accept cookies in their default settings. However, you can change your browser settings to disable certain or all cookies, or to obtain your permission before accepting a new cookie. Relevant instructions in this regard are provided by most browsers under the “Help” item in the menu list. There you will also find instructions on how to delete any cookies you have already received. We emphasize that, if you refuse the use of cookies, you may not be able to use all the functions of our website. Through the use of our website, you will be able to express your consent to the use of cookies.
9.INTERNATIONAL DATA TRANSFERS We may transfer some of your personal data to service providers located abroad, including cloud service providers. When your personal data is transferred outside Brazil, Flech pay will adopt appropriate measures to ensure adequate protection of your personal data in accordance with the requirements of applicable data protection legislation, including through the conclusion of appropriate data transfer agreements. data with third parties of your personal data when required.

10. INFORMATION SECURITY Personal Data processed by Flech pay is protected by technical and organizational security measures to reduce risks of loss, misuse and unauthorized access, disclosure and alteration, such as firewalls and data encryption, in addition to security controls. authorization of access to information. Your Account is protected with a password for your privacy and security. You must prevent and prevent unauthorized access by third parties to your Account and your personal data by selecting and protecting your password and/or other additional connection mechanism that may be implemented appropriately and limiting access to your computer or device and browser , also logging out after completing access to your Account. In order to guarantee the security of your personal data, we adopt practices related to user authentication; encryption of data and transaction content; intrusion prevention and detection; prevention of information leakage; carrying out periodic tests and scans to detect vulnerabilities; protection against malicious software; traceability mechanisms; computer network access and segmentation controls; and maintaining backup copies of data and information. We strive to protect the privacy of your Account and other personal data about you that we maintain in our records, but unfortunately we cannot guarantee complete security. Unauthorized Account entry or use, hardware or software failure, and other factors may compromise the security of your personal data at any time, so please help us maintain a safe environment for everyone. Furthermore, in addition to adopting good security practices in relation to your Account and your data, if you identify or become aware of something that compromises the security of your data, please contact “FLECH PAY”.

11. DATA SUBJECT’S RIGHTS Personal data holders have certain rights with regard to their personal data and can exercise them by contacting us via email: support@flechpay.com Confirmation of the existence of personal data processing ; Access to personal data, in accordance with applicable legislation; Correction of incomplete, inaccurate or outdated data; Data portability; Deletion of data, when it is processed based on the Holder’s consent or when the data is unnecessary, excessive or processed in non-compliance with applicable legislation; Request for information about shared data use. Please note that this Privacy Policy describes Flech Pay’s personal data sharing activities. To receive more information about how we share your data, please contact us; Revocation of consent, when applicable. For security reasons, we will only be able to respond to your request if we are certain of your identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the Holder. Please note that, as mentioned above, in most of the products and services we offer, Flech Pay acts as the operator of personal data, in accordance with the instructions of our Customers. If you are a consumer and wish to exercise your rights in relation to the personal data that Flech Pay processes as an operator, you must contact the Customer who is using the Services.

12. DATA STORAGE TIME We will keep your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of complying with any legal, contractual, accountability obligations or requests from competent authorities . To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for processing your data and whether we can achieve such purposes through other means, through applicable legal requirements. And if you have registered an account with Solutions, your account information will be retained as long as you keep that account active. If you request the deletion of your data and/or your account, we will delete your data, unless its maintenance is necessary to comply with the purposes for which the data was collected, legal, contractual, provision of accounts or request from competent authorities.

13.TERMINATION OF DATA PROCESSING This Privacy Policy applies to the circumstances mentioned above throughout the period in which Flech Pay stores personal data. We store and maintain your information: (i) for as long as required by law; (ii) until the end of the processing of personal data, as mentioned below; or (III) for the time necessary to preserve Flech Pay’s legitimate interests. Therefore, we will process your data, for example, during the applicable statute of limitations or as long as necessary to comply with a legal or regulatory obligation. The termination of the processing of personal data will occur in the following cases: (i) when the purpose for which the personal data was collected has been achieved, and/or the personal data collected is no longer necessary or relevant to achieving such purpose; (ii) when the Owner requests the deletion of their data; and (III) when there is a legal determination in this regard. In cases of termination of the processing of personal data, except in the cases established by applicable legislation or this Privacy Policy, personal data will be deleted and this Policy will no longer apply to your relationship with Flech Pay.

14. LIMITATIONS OF FLECH PAY’S LIABILITY “FLECH PAY” is not responsible for transactions carried out by holders through their account. It is the owner’s responsibility to: Keep the environment of their devices used to access applications safe, using specific tools for this purpose, such as antivirus, firewall, among others, in order to contribute to the prevention of electronic risks; Use updated and efficient operating systems for full use of applications; Equip and be responsible for the hardware devices necessary to access applications, as well as their access to the internet. All communications carried out by “Flech Pay with the holder will be made through the applications or email indicated by the holder at the time of registration. It is the holder’s duty to leave the Anti Spam systems configured so that they do not interfere with the receipt of communications. Responsibility for receiving and viewing communications lies solely with the holder. “Flech Pay” is not responsible for the veracity of the personal information provided by the holder, in any way.

15.FRAUD AND INTERRUPTIONS OF SERVICES “Flech Pay” has the right to cancel, block and interrupt the customer’s services at any time that the customer has carried out under suspicion any operation within the application, whether credit, debit, loyalty program , bill or others.

16. LEGAL “Flech Pay” gives itself the right to take appropriate legal action against the customer if an attempted fraud on the “Flech Pay” web platform is proven.