Privacy Policy

Zappts Soluções LTDA is a private legal entity, registered under CNPJ No. 21.240.231/0001-42, headquartered at Av. Aclimação, 205 – Jardim Alvorada, São José dos Campos, State of São Paulo – SP, ZIP Code: 12.240.570, under the trade name "ZAPPTS", operating in the provision of services and development, support and maintenance of computerized systems (Information Technology – IT), within ethical principles, aiming to maintain a solid reputation in the market, with social and environmental responsibility, respect for institutions, healthy practices of free competition, free market, and contribution to the development of information technology, always guided by integrity, loyalty, respect and appreciation of the human being in their dignity, with respect for diversities, opinions and beliefs, without any prejudice or forms of discrimination.

With the purpose of following and practicing the ethical principles and values adopted, Zappts Soluções LTDA, hereinafter briefly referred to by its trade name "ZAPPTS", hereby formulates this Code of Ethics and Conduct & Anti-Corruption Policy, which shall be governed by the following provisions:

This Code of Ethics and Conduct & Anti-Corruption Policy guides "ZAPPTS" to follow guidelines based on ethical and moral standards that govern the behavior of all its collaborators, internal and external, especially all members of its corporate and administrative body, employees and representatives, including outsourced service providers, suppliers and business partners, in the exercise of their functions and activities related to its operations.

The purpose of this Code of Ethics and Conduct & Anti-Corruption Policy, without prejudice to the other premises and propositions listed herein, is:

• Avoid irregularities in its activities;

• Respect integrity in professional relationships, both internal and external, as well as those with its clients and suppliers;

• Reinforce compliance with laws and standards of conduct in the company's core activities;

• Ensure the confidentiality of information about the company and its clients, suppliers, internal and external collaborators, and the entire community involved in its activities;

• Maintain excellence in daily work and encourage ethical behavior in relationships among employees and between them and their clients, suppliers and everyone who, in any way, relates to the company;

• Avoid and repudiate any form of discrimination based on race, origin or background, creed or political and ideological convictions, or any form of injustice that may compromise the company's image before its internal or external collaborators, clients and suppliers, and everyone who, in any way, relates to the company;

• Preserve working relationships based on transparency between leader and led for a respectful, constructive and collaborative relationship, regardless of hierarchical position, command or subordination of each one, always respecting human dignity and the social purpose of the capital and labor relationship, according to constitutional and legal norms;

• Provide a healthy and safe working environment for its employees and collaborators, and the necessary conditions for the full exercise of their capabilities and skills.

In addition to the objectives already listed in the previous item, and without prejudice thereto, the values contemplated by "ZAPPTS" in the exercise of its activities and its market performance are:

• Provide technology services in an intelligent and sustainable manner for our clients' businesses.

• Full respect for people in their dignity, with social and environmental responsibility, contributing to the full exercise of citizenship and rights inherent to the human person, through the appreciation of work, education and learning, and entrepreneurial capacity.

• Transparency in work processes, supply of products and services, and professional relationships with clients, internal and external collaborators.

• Absolute professional and commercial confidentiality in all stages of contracting and execution of contracted services and/or supply of products.

• Technical competence and results partnership as the objective of its performance as an Information Technology (IT) company.

• Good relationships with the various social sectors in which it operates, ensuring clients professionalism and confidence in the solutions they seek, constant investment in updating and improving technological resources best suited to their clients' needs, and strict compliance with obligations assumed towards clients, internal and external collaborators, always within the ethical, moral and legal norms that guide its activities, in order to provide a healthy environment of mutual trust, rigorously complying with signed agreements and contracts.

• Appreciation of partnerships built with its clients, seeking satisfactory results for the parties involved and for society as a whole.

• Recognition and respect for the work of controlling or guiding bodies of its activities, whether public entities or private entities with inspection and control power, class associations, educational and union entities.

• Maintenance of a work environment based on professionalism, mutual trust, cooperation, integration of all collaborators, and respect for individual differences.

• Sharing of resources, knowledge and professional experiences acquired or developed – provided that due professional and commercial confidentiality is respected – seeking to improve technical capacity, methods and processes, in order to achieve better overall results for clients and collaborators.

• Appreciation of people and respect for their dignity, contributing to their personal, intellectual, technical and professional development.

• Permanent care in its operations for the appropriate and economical use of available material, intellectual, technical and financial resources, aiming for a sustainable economy.

• Preservation and respect for the image, assets and interests of the people and companies involved, clients and collaborators in general.

• Recognition and appreciation of the company's intellectual capital and encouragement of the emergence of new leaders who can contribute to its development and performance.

• Appreciation and encouragement of individual and collective ethical conduct of internal and external collaborators, clients and suppliers.

• Legality, impersonality, morality, publicity and efficiency in all acts performed, valuing transparency, loyalty and reliability.

• Maintenance of a relationship guided by mutual respect, preservation and confidentiality of information relevant to the company, its clients and internal and external collaborators.

• Relationships with clients, suppliers and partners who have practices harmonious with the ethical standard adopted by ZAPPTS and social morals, avoiding those who knowingly do not have the same principles.

• Rejection of contractual provisions that affront or minimize the dignity, quality of life and social well-being of its direct employees or outsourced employees.

• Recognition of the legitimacy of dialogue channels with legally constituted worker representative institutions, through appropriate instruments to seek the composition and convergence of conflicting interests.

• Compliance with the determinations set forth in the instruments that regulate the company's relationship with its employees, collaborators, clients and suppliers.

• Establishment of fair and balanced relationships with the community through encouragement, promotion, support and participation in social responsibility and citizenship actions.

• Encouragement, support and participation in governmental and institutional actions aimed at social and cultural development, providing access to information and knowledge, as well as the preservation of the environment.

• Encouragement of socio-cultural and sports initiatives of its employees, collaborators, clients and everyone who, in any way, relates to ZAPPTS' operations.

This Code of Ethics and Conduct & Anti-Corruption Policy applies to directors, executives, employees, collaborators, suppliers and partners of "ZAPPTS". Reading and understanding this Code of Ethics and Conduct & Anti-Corruption Policy by all members of management, internal and external collaborators, and everyone who in any way relates to the company is essential to support actions and decisions in an ethical and integral manner, and its compliance is fundamental to achieve the highest levels of quality and trust in the market.

The Partners and Directors of "ZAPPTS" must guide their behavior by this Code of Ethics and Conduct & Anti-Corruption Policy, under the terms listed below, and without prejudice to others:

• Not tolerate, and report to the proper authorities, the use of illicit practices, acts of corruption, bribery or fraud, both in internal processes and in the execution of services or in conducting business with clients and partners.

• Not tolerate, and not condone, business involved in any crime of money laundering or financing of criminal activities, involving partners, directors, employees, collaborators, suppliers and third parties who, in any way, relate to "ZAPPTS".

• Treat people and their ideas with dignity and respect, and proceed with loyalty, justice and frankness in relationships with employees and collaborators, clients, suppliers and third parties who, in any way, relate to "ZAPPTS".

• Preserve the well-being of the community involved in the company's activities, respecting personal characteristics, freedom of opinion and privacy of each individual.

• Act with clarity and loyalty in defending the interests of "ZAPPTS", and present oneself appropriately for the performance of their position and functions.

• Not claim personal benefits or advantages for themselves or for third parties, as a result of commercial or financial relationships entered into on behalf of "ZAPPTS" with clients, government agencies, financial institutions, suppliers, entities and other companies with which "ZAPPTS" maintains a relationship.

• Not use for personal benefit, or transfer to third parties, documents, works, methodologies, products, operational tools and information owned by "ZAPPTS" or its clients, suppliers and collaborators, except by legal or judicial determination.

• Refrain from using internal or external influence to obtain personal and functional advantages by reason of or as a result of the company's activities.

• Refrain from using the status of partner or director of "ZAPPTS" to obtain undue advantages for themselves or for third parties.

• Use company resources only for purposes of interest to the company itself.

• Contribute to the proper functioning of the entire company, refraining from acts and attitudes that prevent, hinder or disrupt its operations or the achievement of its social and economic purposes.

• Prepare and present information that reflects actual positions and economic, financial, operational, logistical results and any others that affect company performance.

• Prioritize and preserve the interests of "ZAPPTS" with clients, government agencies, non-governmental organizations, financial institutions, suppliers, class entities and other companies with which "ZAPPTS" maintains a commercial or institutional relationship.

• Observe and ensure compliance with the guidelines and strategic business management of "ZAPPTS".

• Respect, and ensure respect for, in all its terms, this Code of Ethics and Conduct & Anti-Corruption Policy and the current legal and regulatory provisions, as well as provide, whenever possible, its dissemination and defense.

Employees and collaborators in general must guide their behavior by this Code of Ethics and Conduct & Anti-Corruption Policy, under the terms listed below:

• Perform their functions and activities with full commitment and dedication, being aware that their acts and attitudes will positively or negatively impact everyone involved in the provision of services;

• Preserve and cultivate the positive image of the company before its clients and other collaborators, suppliers, and everyone who, in any way, relates to it;

• Not practice any type of discrimination, whether based on race, color, geographic, social or religious origin, humiliation, embarrassment, sexual or moral harassment, threat or any type of verbal, gestural or physical violence;

• Not tolerate, and report to the proper authorities, the use of illicit practices, acts of corruption, bribery or fraud, both in internal processes and in the execution of services or in conducting business with clients and partners;

• Not tolerate, and not condone, business involved in any crime of money laundering or financing of criminal activities;

• Respect legal norms, professional and commercial confidentiality, professional ethics and workplace safety;

• Commercialize, within the premises of the companies involved, only products and services owned by and of interest to "ZAPPTS";

• Develop favorable conditions for establishing a productive and pleasant climate in the work environment;

• Treat people and their ideas with dignity and respect, and proceed with loyalty, justice and frankness in relationships with employees and collaborators, clients, suppliers and third parties who, in any way, relate to "ZAPPTS";

• Not use narcotic substances, tobacco, alcoholic beverages, or carry weapons of any kind on the premises of "ZAPPTS" or its clients, suppliers, collaborators or those who, in any way, relate to the activities of "ZAPPTS";

• Not use spaces of "ZAPPTS" or its clients, suppliers, collaborators or those who, in any way, relate to the activities of "ZAPPTS" to conduct debates or discussions of a political or ideological nature, or any political party campaign;

• Make correct and appropriate use of the facilities, equipment and work tools made available to perform their functions and tasks;

• In case of dismissal and acceptance of another job in any area of activity, maintain absolute confidentiality of commercial practices, professional secrets and techniques developed by "ZAPPTS" in its activities, client portfolio and collaborators in general, and its commercial practices;

• Not engage in parallel professional or commercial activities during work hours or with the use of material, financial or intellectual resources of "ZAPPTS". And outside working hours, such engagement cannot interfere with the activities and objectives of "ZAPPTS" nor represent a conflict of interest with these objectives.

• The provision of gifts and presents with the "ZAPPTS" logo by its employees and collaborators must be related to commercial activity and never be used as an influence mechanism in decision-making.

• Admissions and promotions must be based exclusively on the technical knowledge, experience and merit of the candidate, considering, whenever possible, their efforts to obtain better training and knowledge through courses related to their activity in the company, academic work and research in the company's area of expertise.

By browsing our website, you authorize Zappts to use your personal data for some or all of the purposes described in this document. We may change the Privacy Policy at any time, but you will be notified when we make any substantial change. We also need you to agree to these changes to continue having access to the website. You may notice that we always inform, at the beginning of this Policy, the date of its last update. For any questions about this Policy and Zappts' practices, please contact us at zappts@zappts.com.

Zappts is committed to protecting your privacy, ensuring that your personal data will be treated in accordance with Brazilian law and best market practices. We are transparent about our practices and are available to talk whenever you want. Therefore, see below some of the principles that guide how Zappts handles your personal data:

• All collection and processing of personal data will be carried out in accordance with this Privacy Policy and to fulfill the purposes specified herein.

• Your data will not be transferred, sold, rented or disclosed differently than indicated in this Privacy Policy.

• When any personal data is no longer necessary and we have no legal obligation to store it, our intention is to delete, destroy or anonymize it.

• Our intention is to collect the smallest possible amount of personal data – we really only intend to collect the data necessary to fulfill the purposes described herein.

See below some important definitions to better understand the protection we apply to your personal data, the limits of our use and your rights:

• Data Subject – You are the owner of your personal data.

• Personal data – Information that identifies or leads to the identification of a data subject. Examples of personal data include your full name, phone number, email and address.

• Controller – Person responsible for making decisions related to the processing of personal data of data subjects. In this case, it is Zappts.

• Processing – Any operation carried out with personal data, which may include obtaining, access, analysis, transfer, storage, anonymization, deletion, etc.

• Anonymization – Process of depersonalizing personal data by removing any association of this information with the data subjects to whom it refers.

Brazilian legislation grants you a series of rights regarding your personal data and you may exercise them as described in this Policy. See below your main rights related to your personal data:

• Question whether your personal data is subject to processing by Zappts.

• Obtain information about the manner of processing of your personal data.

• Correction of incomplete, inaccurate or outdated data.

• Anonymization, blocking or deletion of personal data that is unnecessary, excessive or being processed in non-compliance with the law.

• Request the deletion of your personal data that has been processed based on consent previously given by you.

• Know which public and private entities have access to the data by Zappts' decision.

• Not provide consent for the processing of your data and be informed of the consequences of such refusal.

• Revoke consent, at any time, for the collection of new personal data.

• Request the review of decisions made solely based on automated processing of personal data that, for example, determine your personal, professional, consumer or credit profile.

Zappts collects and stores a) personal data sent by you, b) personal data sent by third parties, including public data, and c) personal data collected by our systems, as described below:

Personal data sent by you: Personal data sent by you refers only to the voluntary completion of forms on our website.

Personal data collected by our systems: Due to a legal obligation, we are required to keep, for six months, browsing data on our website and, eventually, judicial authorities may request such information. Browsing data includes: IP addresses, Uniform Resource Identifiers (URIs), request times, methods used to send requests to the server, size of files received as response, numeric codes indicating the status of the server response, and other parameters related to the user's operating system and computing environment. Computer systems and software designed to browse this website collect, during their normal use, certain personal data, whose transmission is implicit in the use of Internet communication protocols. As a rule, this information is not collected to identify users, but due to its nature, it may allow identification through associations with other data.

Zappts informs that the website uses "cookies", related to certain characteristics or functions. Cookies are specific types of information that a website transmits to the user's computer hard drive, for the purpose of keeping records. Cookies can serve to facilitate the use of a website, by storing passwords and preferences while the user browses the internet.

Through cookies, we cannot access other information stored on your device, even if these cookies are downloaded here. Cookies cannot upload code of any kind or carry viruses or malware, and do not harm the user's terminal.

"Web beacons" are images inserted into a website or email, which can be used to monitor visitor behavior, as well as store information about the user's IP address, duration of interaction on such website and the type of browser used, among others.

Zappts automatically collects and stores certain information about the activity of its Users. Such information may include the URL they come from, the URL they frequently access, the browser they use and their IP addresses, as well as the sites visited and searches performed.

Zappts uses the collected personal data for the following purposes:

• To offer you products and services to the extent we are authorized to carry out this type of communication;

• Compliance with legal obligations, cooperation with public authorities or for the exercise of some right provided by law;

• Send you confirmations and updates about Zappts, as well as any other relevant information. This information may be sent via email, SMS or WhatsApp, or another form of contact you have provided. These messages may contain (without limitation) information about Zappts' services, as well as contact information of service providers that could assist your experience.

• For the purpose of offering better services or providing users with information regarding their preferences, Zappts may also develop internal studies on user interests, behaviors and demographics, to better understand their needs and interests, improve our commercial and promotional initiatives, personalize your content, presentation and services, display advertising or promotions and banners that are interesting to our users, and for this purpose, Zappts will only use anonymized data.

By accepting the terms of this privacy policy, you acknowledge and agree that Zappts, as data controller, under the terms of applicable legislation, may share your personal data with companies belonging to the same commercial group.

In case of transfer of personal data, we inform that the recipient of such personal data will assume the same corresponding obligations as the party that transfers such personal data.

Please be aware that if you provide, freely and voluntarily and on your own initiative, personal data directly to service providers (whether or not they are service providers for Zappts), such providers will collect, process and store this information in accordance with their own Privacy Policies.

Zappts is not responsible for any misuse of Personal Information by external companies outside the website.

All personal data is collected and stored on servers physically located in Brazil and abroad. Zappts may in the future relocate such servers to any other country, and may store personal data in the United States or other countries, for backup purposes. In any case, Zappts undertakes to ensure compliance with legally required standards for the protection and safeguarding of your personal data, through the signing of agreements or terms, whose purpose is the protection of your personal data.

Zappts has tools to protect your personal data from malicious or unauthorized third parties. We adopt adequate security measures to protect against unauthorized access, alteration, disclosure or destruction of data. These measures include internal analysis of our data collection, storage and processing practices. With the precautions we take, we can guarantee that we avoid as much as possible potential security failures that affect your personal data. However, recognizing that there are natural risks inherent to the use of the Internet, we understand that we cannot completely eliminate this risk. In any case, we guarantee that the protection of your personal data is one of our priorities and that, if any incident occurs, we will take all possible measures to minimize any damages.

Zappts safeguards your personal data in accordance with security and confidentiality standards and procedures in force in Brazil. Zappts does not transmit, disclose or share collected personal data with third parties, except those described in this Policy. Accordingly, this website takes the necessary measures to protect users' personal data.

In compliance with Article 41 of Law No. 13.709/2018 (LGPD), Zappts appoints its CTO as the Data Protection Officer, responsible for receiving communications from data subjects and the ANPD and providing guidance on data protection practices. Contact: dpo@zappts.com.

This website may contain links to other websites that have their own privacy and confidentiality policies. For this reason, we recommend that, if you access these other websites, carefully review their respective practices and confidentiality policies, as this Privacy Policy does not encompass practices or policies of third parties, including those that may disclose and/or share information with Zappts.

We are not responsible for improper processing or data leakage occurring outside Zappts' servers and domains, even if the data source was provided by Zappts, by contractual force.

In case of doubts about what the correct conduct to adopt should be, the collaborator should seek help sincerely and transparently. Any situation that may characterize a conflict of interest, or facts that may harm the company or that contradict the principles of this Code of Ethics and Conduct & Anti-Corruption Policy, must be communicated immediately and formally to the legal representative of "ZAPPTS".

"ZAPPTS" ensures confidentiality in the conduct of these matters and the commitment to investigate reported cases.

Situation that, by chance, are not explicitly stated herein, will be treated as an exception and forwarded to the legal representative of "ZAPPTS", who will analyze and decide the announced issue within the principles of this Code of Ethics and Conduct & Anti-Corruption Policy.

Everyone who, in any way, relates directly or indirectly with "ZAPPTS", must know and ensure compliance with this Code of Ethics and Conduct & Anti-Corruption Policy.

This Code of Ethics and Conduct & Anti-Corruption Policy comes into effect from the date of its publication on the "ZAPPTS" website (zappts.com), and each collaborator, internal or external, client, or any person who, in any way, relates to "ZAPPTS", must acknowledge its terms.