PRIVACY POLICY

1. INITIAL PROVISIONS AND DATA OF THE CONTROLLER AND DATA IN CHARGE

We are committed to safeguarding your privacy when using our website. This policy is intended to make our data collection and sharing procedures as clear as possible, informing you about the data collected and how we use it.

The following privacy policy is in accordance with current Brazilian laws, its clauses govern the rules of ethical conduct, contains the rights and responsibilities of users who may use this site, as well as information about privacy and use of their data .

Simple Energy is committed to transparency, privacy and security of user data during the entire process of interaction with our website.

These are the official terms of use (hereinafter simply referred to as the “Privacy Policy”) for the Simple Energy website.

SUMMARY TABLE

Dados do Controlador: Simple Energy Comercializadora de Energia Ltda. CNPJ: 17.112.981/0001-61 Adress: Rua Arizona, 491, 17º andar, Brooklin, CEP: 04567-001, São Paulo/SP

Role in treatment: Controller of collected personal data.

Holder: natural person who uses or registers on the site.

Nature and data processed: The website collects personal data from its users. The form and information collected may vary depending on the services you use. Some of the data that may be collected when you enter or register on the website are your full name, a username and password, email address and telephone number.

Data Treatment: Processing is any operation carried out with personal data to serve a specific purpose.

Data Supervisor: Gabriel Pereira E-mail: [email protected]

2. PERSONAL DATA COLLECTED

By using this website, you declare your EXPRESS CONSENT to us collecting information about you necessary to provide our services or to use our website, such as:

• Data you offer. We collect the data provided by you at the time of registration, such as name and last name, email address, IP address, other online contact information or telephone number, and other information required in the registration.
• Content of interest to you. We may collect content from areas of interest to you when you use our Services, such as when you conduct a survey, access or create content, register an account, create or share comments or content, etc.
• Communication. We may record and record all data provided in every communication made with our team, whether by email, messages, telephone or any other means.
• E-mail (e-mail). When logging in to the website, we will collect your e-mail for registration purposes, through which communications of platform updates, promotions and management of your account will take place.
• We record data from your visit to the platform through cookies and other tracking technologies including your IP address and domain name, the version of your browser and operating system, online traffic data, location data, web logs and other data of navigation.

3. PURPOSES: USE OF PERSONAL DATA COLLECTED

By using the website and expressing your consent, you EXPRESSLY AUTHORIZE the processing of personal data for the following PURPOSES:

• Provide, improve and develop available services. We use cookies and similar technologies to provide and support our services, by customizing shared content, to ensure that the content on the platform is relevant.
• Marketing: We may use the data provided by the user at the time of registration on the website to send promotions, advertising, marketing and communication, and the user may at any time request their exclusion from the mailing ("opt-out") using the unsubscribe link inserted into the body of emails.
• Content construction. All content shared, or disseminated, whether through comments, tips or suggestions for improvements, make up the website's database, enabling the improvement and knowledge of the product by other users.
• Usage monitoring. We use your data to monitor activities in order to ensure the quality of service, compliance with applicable laws, compliance with procedures and to combat fraud.

4. DATA SHARING

The information collected will only be shared when necessary: (i) for the adequate provision of services; (ii) protection in case of conflict; (iii) upon court decision or request from a competent authority; (iv) with companies providing technological and operational infrastructure and information storage service providers.

All information requested by government agencies, public authorities or official bodies through legal means will be evaluated and provided in accordance with the requirements contained in the act and duly in accordance with the relevant legislation.

5. WHERE WE STORE AND PROCESS YOUR DATA

The collected data are processed in Brazil and in any other places where the partners involved with the treatment are located. The data you provide may be transmitted, used, processed and stored outside your country of origin.

Whenever Simple Energy handles personal data, regardless of where it occurs, we will take the appropriate measures to ensure that your data is treated securely and in accordance with this Privacy Policy and all applicable laws and regulations.

All personal data will be properly stored for the legal term, as provided for in the Marco Civil da Internet (Law No. 12.965/14), General Data Protection Law (Law No. 13.709/18) and in accordance with the provisions of this Policy of Privacy.

6. LEGAL BASIS FOR PROCESSING

Simple Energy may process Personal Data relating to the user of this website if one of the following applies:

1. a) the user has given his consent for the specific purposes (Simple Energy may have permission to process the Personal Data even if the user objects to this through "opt-out", when there is another legal basis for processing) ;
2. b) the supply of data is necessary for the fulfillment of a contract with the user and/or any pre-contractual obligations of the same;
3. c) the processing is necessary for the fulfillment of a legal obligation to which Simple Energy is subject;
4. d) the processing is related to a task that is performed in the public interest or in the exercise of an official authorization in which Simple Energy is invested;
5. e) processing is necessary for the purpose of Simple Energy's legitimate interests.

In any case and upon request of the holder, Simple Energy will inform the legal basis that applies to the processing, especially if the provision of Data is a mandatory requirement by law or contract, or a necessary requirement to enter into a contract.

7. SECURITY MEASURES

All data you provide us are treated solely to achieve the purposes listed in item 3 of this Policy. This data is stored on secure servers of ours or contracted suppliers, accessed and used in accordance with our security policies and standards. All traffic between our servers or between your computer and our servers is encrypted using the secure protocol SSL or similar.

We take good practice measures to ensure that the data we collect is securely processed wherever the data is located.

Access to your user profile is solely your responsibility, through a password (or through other chosen media) that allows you to access certain parts of our website, and it is your responsibility to keep this password confidential and to comply with any other security procedures. We will never ask for your password, and we ask that you do not share it with anyone. The security and reliability of the devices you use to access our site, such as computers, cell phones, tablets or other devices, is your sole responsibility. You must, by your own means, seek to protect the operating systems of these devices against any external threat.

8. HOW LONG WILL WE STORING YOUR DATA

User's personal data may be processed and stored by Simple Energy for as long as necessary for the purpose for which they were collected

In addition, Simple Energy may be required to store personal data for a longer period whenever necessary for the performance of a legal obligation or by order of an authority.

When the retention period expires in accordance with the respective legal basis, Personal Data will be deleted by Simple Energy. Therefore, the right of access, the right to delete, the right to rectify and the right to data portability cannot be fulfilled after the expiration of the retention period.

Simple will take appropriate security measures to prevent unauthorized access, disclosure, alteration or unauthorized destruction of the Data. Data processing is carried out using computers and/or enabled IT tools, following organizational procedures and means strictly related to the indicated purposes.

9. DATA HOLDER RIGHTS

The holder of personal data has the right to obtain from the controller, information regarding the processed data, at any time and upon formal request, pursuant to article 18 of Law 13. 709/2018:

I – confirmation of the existence of treatment;

II – access to data;

III – correction of incomplete, inaccurate or outdated data;

IV – anonymization, blocking or deletion of unnecessary, excessive or processed data in breach of the provisions of this Law;

V – data portability to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;

VI – deletion of personal data processed with the consent of the holder, except in the cases provided for in art. 16 of the LGPD;

VII – information on public and private entities with which the controller shared data;

VIII – information on the possibility of not providing consent and on the consequences of denial;

IX – revocation of consent, according to the procedure established in this privacy policy and pursuant to § 5 of art. 8 of the LGPD.

10. HOW TO EXERCISE YOUR RIGHTS?

The data subject can request information about their data and exercise their rights when applicable in accordance with the legislation, by contacting the Simple Energy Data Supervisor via the contact e-mail: [email protected].

Simple Energy will endeavor to provide the requested clarifications as soon as possible.

11.  DELETION OF DATA

The user registered on the website can unsubscribe from the platform with the express request for the total deletion of their data, through the email of the Data Supervisor, that is, [email protected].

The user can also request information, change or clarification about their data through the same contact ([email protected]).

If the user re-registers on the site after requesting the deletion of data, Simple Energy will be able to process their data again under the terms of this policy.

You can request deletion of your account at any time. But, remember that Simple Energy will only be able to delete your data if there is no legal basis for treatment that prevents the deletion.

Comments, testimonials and publications made available by you for publication on the website will also be excluded, if this is your option, provided that your intention is expressly expressed.

The user may opt-out of receiving marketing emails at any time using the unsubscribe link inserted in the body of the emails (opt-out).

The holder's data will be deleted at the user's request or unsubscribe option, when there is no legal basis for treatment that justifies the maintenance of such data in Simple Energy's database, in accordance with the General Data Protection Law.

12. COPYRIGHT AND INTELLECTUAL PROPERTY

All content on this site is protected by copyright and other intellectual property rights. These rights are owned by Simple Energy.

The user or visitor declares that they will respect intellectual property rights and those arising from the protection of trademarks, as well as all rights relating to third parties that may be, or were, in any way available on the website. The simple access to the website does not grant the user any right to use the names, titles, words, phrases, brands, patents, works, among others, which are, or were, available on it.

Reproduction of the contents described above is prohibited, unless prior written authorization from Simple Energy, and without the user acquiring any rights over them.

13. CHANGES TO THIS PRIVACY POLICY

Simple Energy reserves the right to make changes to this privacy policy at any time, in our sole discretion, notifying its users on the website, to the extent possible. The manner in which such announcement will be given is at our sole discretion. Once published on our website, they will be automatically considered valid and, if you use the website after the changes become valid, you will be expressing your agreement with them. You should review and review the terms and conditions of this Agreement so that you are aware of the most current rights and obligations.

14. FORUM

This policy will be governed, interpreted and executed in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13.709/2018, regardless of the Laws of other states or countries. Any conflict situation that cannot be resolved in an amicable negotiation must be settled at the Central Forum of São Paulo.

15. LAST UPDATE AND PREVIOUS VERSIONS

Last updated: May 2021.