Privacy Policy

Introduction
Cogtive is committed to protecting the privacy and security of its users’ and partners’ information. This Privacy Policy for Personal Data (“Policy” or “Privacy Policy”) outlines the standards and guidelines for processing personal data collected by Cogtive, in compliance with applicable legislation, including the General Data Protection Law (Law No. 13,709/2018 – “LGPD”).

By agreeing to this Privacy Policy, the data subject consents to the terms described herein and to the processing of their personal data for the purposes outlined in this document.

Scope
This Privacy Policy applies to all activities involving the processing of personal data by Cogtive, including websites, portals, applications, and forms.

Key Definitions
Below are important definitions to help understand this Policy:

• Personal Data: Information related to an identified or identifiable natural person.
• Sensitive Data: Information about racial or ethnic origin, religion, political opinions, health, genetic or biometric data.
• Data Processing: Any operation performed on personal data, such as collection, storage, processing, or sharing.
• Data Subject: The individual to whom the personal data pertains.
• Controller: The entity responsible for decisions regarding the processing of personal data.
• Cookies: Small files stored on the user’s device to personalize their browsing experience.

Collection of Personal Data
Cogtive may collect personal data under the following circumstances:

• Data provided directly by the data subject: Information voluntarily entered by the user into forms, portals, or applications.
• Data provided by companies or third parties: Information shared by partners or obtained from public databases.
• Automatically collected data: Information gathered during the use of our services, such as browsing data and preferences, through cookies or other technologies.

Purpose of Data Processing
Cogtive processes personal data for the following purposes:

• Compliance with legal or regulatory obligations;
• Execution of contracts or services requested by the data subject;
• Exercising legal rights in administrative, judicial, or arbitration proceedings;
• Conducting analyses and improving the services provided;
• Sending relevant communications and information to users, with their consent.

Data Sharing
Cogtive may share personal data with:

• Service providers: Companies assisting in the execution of our services, in alignment with this Policy.
• Strategic partners: For analysis, auditing, security, or operational support.
• Public authorities: When required by law or judicial order.
• Data subject’s consent: In specific cases, with prior and explicit authorization.

Data Storage and Security
Cogtive employs technical and organizational measures to safeguard personal data against unauthorized access, loss, destruction, or alteration. Key practices include:

• Restricted access for authorized employees only;
• Encryption and protection of sensitive data;
• Continuous monitoring of systems and infrastructure.

Data will be retained for the period necessary to fulfill the purposes outlined or as required by law. Once this period ends, data will be securely deleted.

Data Subject Rights
Under the LGPD, data subjects have the following rights:

• Confirmation of the existence of data processing;
• Access to their processed personal data;
• Correction of incomplete, inaccurate, or outdated data;
• Request for anonymization, blocking, or deletion of unnecessary data;
• Data portability, as regulated;
• Withdrawal of consent at any time;
• Information about data sharing with third parties;
• Review of automated decisions.

Data subjects can exercise their rights by contacting Cogtive through the available communication channels.

Use of Cookies
The cookies used by Cogtive are intended to:

• Ensure the proper functioning of our services;
• Enhance user experience;
• Personalize content and ads based on user interests.

Users can manage or disable cookies directly in their browser settings, understanding that some features may be affected.

Amendments and Updates
Cogtive may periodically update this Privacy Policy to reflect service improvements or changes in legal and regulatory requirements. We encourage data subjects to review this document regularly.

Contact
For questions, requests, or additional information, data subjects can contact Cogtive’s Data Protection Officer (DPO) via email at contato@cogtive.com.br.

Jurisdiction
This Policy is governed by Brazilian law. Any disputes will be resolved in the courts of São Paulo/SP.

Cogtive reaffirms its commitment to the privacy and security of personal data and remains available for further clarification.