Your privacy is important to IoTag Tecnologia Ltda ("IoTag"), which is why we outline in our Privacy Policy ("Policy") how all your information is processed.

This Policy applies to all those who use the IoTag System, as well as those whose Personal Data is processed by IoTag in any way. The use of the System by the User implies the acceptance of this Policy. If you do not agree with the terms of this Policy, you will not be able to use any products and services provided by IoTag and its third parties.

If you have any questions, IoTag provides the following unrestricted customer service channels, with no limitations on dates and operating hours:

b) By contact form: iotag.com.br/atendimento;

c) By messaging app: iotag.com.br/mensagem.

TERMS DEFINITIONS

a) "User": an individual or representative of an organization who, by providing their Personal Data, can use the System to monitor, operate, and control machines and vehicles;

b) "Personal Data": any information related to a natural person that identifies her, or when used in combination with other processed information, identifies an individual;

c) "System": a set consisting of the Device, Application, and Platform provided by IoTag to assist the User in his activities;

d) "Device": an electronic device that must be installed in the vehicle or machine for remote communication of its Operational Data;

e) "Operational Data": all information available in machines and vehicles during their operation;

f) "Accessories": all items that allow the installation and connection of the Device, such as fasteners, supports, adapters, and cables;

g) "Application": a computer program that the User can install on mobile devices to assist with field activities. It can be accessed at: iotag.com.br/aplicativo;

h) "Platform": a management portal for all vehicle and machinery information for the analysis of performance in all field activities. It can be accessed at: plataforma.iotag.com.br;

i) "Cookies": digital files stored on your mobile device with the Application installed or on your computer from which the Platform is accessed.

PERSONAL DATA PROCESSING

Personal Data processing refers to the collection, production, reception, classification, use, reproduction, transmission, distribution, archiving, storage, assessment, modification, communication, transfer, dissemination, or extraction of your information.

Through this Policy, you must agree that by downloading, installing, activating, accessing, or in any way using the System, IoTag may have access to information that can be collected automatically or entered manually by you, which may originate from other individuals who operate the machines and vehicles monitored by the System. All this information about you, as well as that belonging to others, are collectively referred to as Personal Data, which may include but is not limited to:

a) Full name and workplace;

b) Driver's license number;

c) National Register of Individuals (CPF – “Cadastro Nacional de Pessoas Físicas”);

d) Registration or functional ID number;

e) Phone number for landline or mobile contact;

f) Email address;

g) Country, state, city, streets, and roads;

h) Device or computer data used;

i) Network connection address;

j) Browser program usage tracking;

k) Social media information;

l) Location of your mobile device;

m) Driver or operator behavior patterns.

On the other hand, there is information that is not directly related to you but is available in the vehicles and machinery operated by you or others, which, in this case, is defined as Operational Data. These may include, but are not limited to:

a) Geographical location coordinates;

b) Clock, odometer, and hour meter;

c) Instantaneous speed and distance;

d) Fuel tank level;

e) Transmission system gear;

f) Engine rotation and torque;

g) Fluid temperature and pressure;

h) Use of brake, accelerator, and clutch pedals;

i) Operation alerts or messages;

j) Acceleration, inclination, or vibrations.

PURPOSE OF PERSONAL DATA

The information collected by IoTag is processed for various purposes related to the operation of the System. In addition to other methods described in other sections of this Policy, all Personal Data collected may be used for:

a) Message targeting: communication with you regarding aspects related to the System, including sending notifications about changes in this Policy;

b) Providing assistance: addressing your inquiries about usage, suggesting improvements, correcting issues, resolving System problems, providing technical support services, training, and more;

c) Fraud prevention: to enhance security through the detection and prevention of harmful conduct, fraud, and other activities detrimental to the use of the System;

d) Billing: for managing debts related to the acquisition or use of the System, as well as notifications regarding price changes, payment conditions, due dates, among others;

e) Research and development: to enable the operation and improvement of the System itself, or to conduct studies and research to address potential issues and create new features;

f) Performance analysis: analyzing operational data from machines and vehicles to enhance their use, maintenance, and other actions that can contribute to improved performance;

g) Market Research: monitoring your behavioral trends to improve IoTag's business for decision-making regarding the advancement, production, launch, and marketing of new products, services, or System features;

h) Advertising purposes: disseminating information related to the launch and offering of new products, services, promotions, commercial events, and other relevant content sent by IoTag or its partners and third-party suppliers to you;

i) Providing community content: using social media accounts and influencers to engage the general public, with the goal of sharing knowledge and topics related to the System, such as responding to the community's chat messages;

j) Information Sharing: access by individuals hired to provide services or working directly for IoTag, as well as its dealers, partners, or consultants involved in your service;

k) Other legal purposes: compliance with legal obligations, defense in judicial or administrative proceedings, or in response to requests from public or government authorities. In this case, IoTag undertakes to adopt the necessary technical and administrative security measures.

SECURITY AND CONFIDENTIALITY

IoTag is committed to maintaining the confidentiality, integrity, and security of any information provided by you, by any other User, or related to them. Similarly, IoTag ensures that its security measures will be continuously reviewed and monitored in accordance with the latest organizational and technological resources.

Without prejudice to other measures, all information processed by the System is protected by encryption mechanisms through a secure communication protocol in transit and storage in IoTag's computing environment or on third-party cloud servers contracted in this country or abroad. In case of the need for international transfer, IoTag is committed to maintaining, at a minimum, the same high standards of security and data privacy as provided in this document, establishing contracts that do not violate security rules and are in accordance with the purposes expressly provided in this Policy.

Your role is also essential in protecting your Personal Data. When creating an access ID for the System, make sure to choose strong passwords and keep them confidential. In case your access ID or password is lost, outdated, or incorrect, you can access the data recovery option on the System's login screen at any time, which will automatically provide you with instructions for recovering your access information via email.

IoTag adheres to the highest technological and legally required levels of information protection, employing all available means and additional measures to prevent data loss, misuse, alteration, unauthorized access, or improper data extraction due to accidents or criminal activities. Nonetheless, IoTag, like any other company, is not immune to attacks and malicious actions by third parties, despite all efforts to prevent such events. In cases of potential data breaches and information security incidents, IoTag commits to taking action to minimize the resulting impacts.

COOKIES USAGE

Cookies are used to enable the System's operation and customization based on your preferences, such as language, location, session frequency, and other variables that developers consider relevant to enhance your experience.

IoTag uses cookies to improve your browsing experience by identifying preferences, Platform access, screen positions where options were selected, or buttons pressed, among other commands, for statistical purposes and to enable service enhancements and future access customization.

As blocking cookies in your browser can affect the System's operation, you should authorize their use when accessing the Platform, which informs you about cookie usage through a notice and the existence of this Policy. Even if your browser is set to allow cookies, you can immediately and without any hindrance remove them or disallow the storage of new cookies by disabling this feature in your browser and deleting any already implemented cookies.

The cookies used by IoTag can be categorized as follows:

a) Essential Cookies: necessary for the Platform to function more simply and efficiently, allowing network management, a safer environment, and accessibility.

b) Performance Cookies: help IoTag understand how you interact with the Platform by providing information about visited areas, visit duration, and any encountered issues, such as error messages.

c) Functionality Cookies: enable the collection of information about the Platform, facilitating technical and static analysis, improving usability, and ensuring proper operation.

d) Advertising Cookies: used to provide more relevant content to you through targeted advertising distribution.

USER RIGHTS

Through the contact methods indicated in this Policy, you have the right at any time to:

a) Inquire about the potential impacts of not providing your Personal Data;

b) Contact us to confirm whether your Personal Data is being processed in accordance with this Policy;

c) Request access to the content of all your Personal Data that is being processed by IoTag;

d) Ask IoTag to change your Personal Data if it is incorrect, inaccurate, or outdated;

e) Request the deletion of your Personal Data in case of processing that is not in accordance with this Policy;

f) Confirm whether your Personal Data has been shared with any public and private entities;

g) Withdraw your consent provided to IoTag for the processing of your Personal Data, if applicable.

You can choose to stop receiving IoTag emails containing advertising content or other related subjects that may not be of interest to you at any time by clicking the option provided in the received message. However, it's important to note that the deactivation may take up to 5 (five) business days, during which canceled messages may still be temporarily received.

Messages related to System operation improvements and problem-solving cannot be canceled, just like notifications regarding changes to this Policy.

IoTag may modify this Policy at any time to reflect any necessary changes aimed at improving and aligning it with the services provided or to address legal or administrative matters or court orders. In this case, IoTag undertakes to inform the effective date through a notification sent to your email with the most recent version of this Policy, which is always available for access at the website iotag.com.br/privacy.

Unless otherwise required by applicable law, any changes to this Policy will be effective from the moment you first indicate your acceptance through the instructions to be provided by email or, in the absence of this acceptance, after your agreement to the changes through the confirmation option available when starting the use of the Application or Platform.

If you do not agree with the changes to the content of this Policy during its term, please discontinue using the System immediately.

SUPPLEMENTARY TERMS - SPECIFIC LEGISLATION

In the event of a conflict between the provisions of the Supplementary Terms - Specific Legislation that are relevant to the jurisdiction from which you access or use the services, and the rest of the Policy, the Supplementary Terms - Specific Legislation of the applicable jurisdiction shall prevail.

BRAZIL

Applicable Legal Basis. The processing of Personal Data by IoTag will always be based on a legal basis as provided in Articles 7 and 11 of the LGPD. In general, the processing of Personal Data will be based on compliance with a legal or regulatory obligation, contract performance, regular exercise of rights in a lawsuit, or legitimate interest, as provided in Article 7, I, II, V, VI, and IX of the LGPD.

Retention and Disposal. All information processed by IoTag will be stored for as long as the System is being used (Art. 7, V of the LGPD). After this period, Users' Personal Data will be stored in accordance with Brazilian legal prescription standards, unless the processing is based on the consent of the data subject, which can be withdrawn at any time. After the prescription period, Personal Data processed by IoTag will be deleted, except in cases where processing is necessary due to the situations provided for in the sections of Article 16 of the LGPD as follows: (a) compliance with a legal or regulatory obligation by IoTag; (b) research by an entity, ensuring the anonymization of Personal Data whenever possible; (c) transfer to a third party, provided that the requirements for Personal Data processing are respected; (d) exclusive use by IoTag, prohibited from being accessed by a third party, and since Personal Data is anonymized.

Anonymization. In this context, Anonymous Data is understood to be data that cannot identify the User using reasonable and available technical means at the time of processing, by which their Personal Data lose the possibility of direct or indirect association with the individual. As anonymization prevents the identification of the individual, Anonymous Data ceases to be considered Personal Data and, therefore, falls outside the scope of the LGPD.

The last update of this document was made on November 1st, 2023.