GreenPath's Privacy Policy

Version: December 2023

Full Gauge's Privacy policy ("Policy") was created to show the commitment of Full Gauge Eletro-Controles Ltda., a company registered with CNPJ/ME Nº 90.446.048/0001-10 (herein mentioned as "Full Gauge," "we" or "our"), with information safety and privacy, gathered from the users, with their personal data owned by the users themselves ("Holder," "User" or simply "you"), as well as helping the holders to take decisions based on their privacy.

The Policy clarifies the general gathering, use, storage and other forms of treatment and personal data protection conditions on the GreenPath app ("app"), in accordance with current in-force Brazilian law in terms of personal data privacy and protection, including but not limited to, Law Nº12,965, from April 23rd, 2014, and Decree Nº 8,771, from May 11th 2016 ("Internet Civil Framework"), Law Nº 13,709, from August 14th, 2918 ("General Data Protection Law" or "LGPD" in Portuguese).

To maintain direct contact with you, a Coordinator for Personal Data Treatment was designated by Full Gauge to manage a communication channel:

• Coordinator: Gabriela Coelho
• Contact: privacidade@fullgauge.com.br

This Privacy Policy may be updated or modified at any moment, with the modifications being informed in highlights on our app.

By using our app, you express your agreement with this Policy in a free, informed, unmistaken, complete, and integral manner. We recommend you read it carefully.

This Privacy Policy is applicable to people who:

• Download our app
• Register on our app

Personal data treatment (or data treatment) means any operation performed with the data:

For example:

• Data gathering
• Use
• Access
• Processing
• Storage
• Deleting
• Communication
• Transference

Personal data is information related to an identified or identifiable natural person. The data related to you, our Full Gauge client, is personal data.

When you download and access our app, Full Gauge takes on the role of controller of your personal data treatment, acting in accordance with and as described in this Policy.

Important: You are not obligated to grant us your information; however, without granting specific information when they are requested, some functions may not be accessed. In addition to the data you inform us, whenever you interact with our app, information will be gathered automatically. Such information is generally not identifiable; however, when it is combined with other data allowing your identification, it will be treated by Full Gauge as personal data.

In the limits allowed by the applicable law, Full Gauge may treat the following personal data informed by you:

Please note that the personal data listed above will be gathered by Full Gauge and afterward will be treated only when necessary to achieve the objectives contained herein.

We do not gather, store, or handle in any intentional manner excessive or unnecessary personal data for the objectives that promoted their gathering, as well as data considered sensible (those related to your ethnic or racial origin, religious beliefs, public opinion, affiliation to any syndicate or any religious, philosophical, or political organization, health status or sexual orientation, as well as genetic data) and data from children and teenagers. Based on the aforementioned, we request that you do not share such data with us. If we are aware that such data was collected inadvertently, they will be deleted from our registries.

The classification of the legal base for stored and processed data by Full Gauge listed in Section 2 happens through the analysis of the specific context in which we gathered them.

The data treated by Full Gauge tend to be collected only:

Art. 7º, I of Law Nº 13,709

With your consent.

Art. 7º, II of Law Nº 13,709

To comply with legal or regulatory obligations.

Art. 7º, IX of Law Nº 13,709

When the personal data processing is in accordance with Full Gauge’s legitimate interests, always considering your interests in relation to data protection or liberties and essential rights. There is also a need to process your data to protect your interests or third-party interests.

Art. 7º, V of Law Nº 13,709

When it is necessary to execute a contract or preliminary procedures in relation to the contract.

Whenever necessary to achieve the objectives described in Section 2, Full Gauge may share your personal data with the third parties listed below, aiming for the correct execution of the services offered, the storage safety of your personal data, and a better experience with Full Gauge. Whenever it is performed, the data sharing will be done within the limits and purposes of our business, in accordance with the personal data treatment objectives and following the authorizations by the applicable law. Thus, your data may be shared with:

Developers

A third-party company responsible for the development and maintenance of the app.

Cloud Servers

Information cloud storage.

Public Authorities

In response to claims, investigations, judicial orders, and processes, when requested, as well as complying with legal, regulatory, and fiscal obligations.

In the form and limits of the applicable law, you, in the title of the personal data holder, may contact us to exercise your rights to request:

Confirmation and access

It allows you to confirm the existence of personal data treatment and, if so, request access to a copy of the data.

Correction

It allows you to request a data correction that may be incomplete, inexact, or outdated.

Anonymity, blocking, or deleting.

It allows you to request data anonymity (so they cannot be related to you in any way), data blocking (temporarily suspending our use,) or data deleting (so we delete them irreversibly.)

Portability

A written request allows us to deliver your personal data to other service or product suppliers in a structured and interoperable manner.

Information about sharing

It allows you to know which public and private entities we have shared your personal data with.

Information about the possibility of non-consent.

It allows you to have clear and complete information about the consequences of not granting your consent, meaning that you are free to deny consent, even when that limits our services offered to you..

Consent revoking

It allows you to revoke the granted consent at any moment without affecting the legality of the treatment performed previously.

Objection

It allows you to object to your personal data treatment in case you don’t agree with the treatment.

Your request may be made free of charge through the e-mail privacidade@fullgauge.com. We will analyze your request and answer it as soon as possible, considering the deadlines and terms expressed in the applicable law. If it is not possible to attend to your request immediately, we will mention the reasons, in fact, and by right, that are preventing us from doing so.

Full Gauge is not responsible for the correction, truthfulness, authenticity, completeness, or updating of the data granted by the Holder. It is the exclusive responsibility of the Holder to offer only correct, truthful, authentic, complete, and updated information.

Full Gauge adopts security, technical, and administrative measures to keep all stored data safe through internal training, confidentiality clauses, and strict access control, and our collaborators have access only to strictly necessary data to attend to specific requests in accordance with the disposition in Section 2. In relation specifically to the data gathered through our app, it is stored, treated, and protected in accordance with the best practices in hosting and processing.

However, the Holder must be aware that no security system on the Internet can offer a warranty against data breaches, Full Gauge’s commitment is limited to adopting the recommended protection measured in accordance with the state of the art.

Full Gauge will perform an international transference of your data to other countries or international organizations only when it is strictly necessary to achieve the objectives for personal data collection, prioritizing, whenever possible, the storage in servers located in the Federative Republic of Brazil. When your personal data is transferred abroad by Full Gauge, we will take appropriate measures to warrant adequate protection of your personal data in accordance with the applicable data protection law requirements, including the appropriate data transference contract signing with third parties, when necessary.

Therefore, we inform you that your personal data will be shared and stored in the following servers located internationally:

We store and keep your information: (i) for the time demanded by law; (ii) up to the end of the personal data treatment, in accordance with the below; (iii) for the necessary time to be kept or legitimate interest of Full Gauge, in a case-by-case manner; (iv) for the necessary time to safeguard the exercise of Full Gauge’s rights in an administrative or arbitral process. Therefore, we will treat your data, for example, for the applicable expiration time or whenever necessary to comply with legal or regulatory obligations.

The end of the personal data treatment will occur in the following cases:

a) When the objectives for which the personal data of the Holder were gathered are completed, and/or the personal data gathered is no longer necessary or pertinent to the scope of such objective;

b) When the Holder withdraws their consent or is exercising their right to request the end of the treatment and the deletion of their personal data; and

c) When there is a legal obligation in relation to this.

Observing the principle of necessity, some data sent through the app may be excluded from our registries through routine registry maintenance. We do not have the obligation to store personal data for an indefinite time, and we disclaim any responsibility arising from or related to the destruction of these personal data.

Having ended your personal data treatment, except arising from the hypotheses established by the applicable law or by this Privacy Policy, the data will be eliminated from Full Gauge’s database. In case the elimination is not possible at first, the data will be stored safely and isolated from any processing up to the moment the elimination is enabled.

We avoid sending non-requested e-mails, restricting the communications with you to topics that are relevant or catering to your specific interests.

If you prefer not to receive information from us, you may request to opt out through the registration cancellation link contained in the e-mail or message received (opt-out).

Please be aware that several scammers try to use recognized brands to gather personal information such as passwords and financial data.

Full Gauge WILL NEVER REQUEST YOUR FINANCIAL DATA THROUGH E-MAILS OR PHONE CALLS. IN CASE OF ANY SUSPICIOUS ACTIVITY, PLEASE SEND US YOUR DOUBTS OR ALERTS THROUGH E-MAIL AT privacidade@fullgauge.com.br.

Upon accessing our app and interacting with us, you agree and accept the terms herein.