Privacy policy

1. Introduction FCX Solutions Inteligência de Negócios Ltda. ("FCX"), registered under Brazilian company registry (CNPJ) No. 54.288.721/0001-78, values your privacy and is committed to protecting the personal data processed in connection with the use of the FCX platform (the "Platform"). This Privacy Policy describes how we collect, use, store and share information when you use our services, in accordance with Brazilian Law No. 13,709/2018 (LGPD) and the principles of Privacy by Design, data minimization, transparency and information security. 2. Information Collected We collect personal and non-personal information in the following ways: 2.1 Registration and Access Data: Full name, e-mail address, telephone number and other information required to create and manage the account, including the CNPJ of the company linked to the registration. 2.2 Commercial Data Provided by the User: Information about products, market segments, territories of interest and lists of leads or commercial accounts entered into the Platform for the execution of the analyses. This data is processed exclusively to provide the contracted services. 2.3 Usage and Browsing Data: Information about how you use the Platform, including the modules accessed, analyses performed, time of use and actions taken, recorded in an audit log for traceability and service improvement. 2.4 Device and Access Data: Device type, operating system, unique device identifiers, IP address and browser user agent, collected at the time the terms are accepted and during use of the Platform. 3. Use of the Information We use the collected data for the following purposes: — Provision of the contracted services: execution of the four internal engines of the Guided Analysis (Up-sell and Cross-sell, Persona, Opportunities and Leads), generation of reports and operational recommendations. — Maintenance and improvement of the Platform: refinement of analytical models in an aggregated and anonymized form, without individually identifying users. — Communication: sending operational notifications, relevant service updates and notices about changes to plans or to these documents. — Security and compliance: protection against unauthorized access, traceability of actions on the Platform and compliance with legal obligations. — Billing and contract management: payment processing, invoice issuance and subscription lifecycle management. FCX does not use personal data for purposes other than those listed above without the user's prior written authorization. 4. Sharing of Information FCX does not share personal data with third parties, except in the following cases: — Authorized sub-processors: service providers acting on behalf of FCX (cloud providers, payment processing, security and monitoring), with which FCX maintains contracts containing equivalent data protection obligations. — Legal requirement: when necessary to comply with legal or regulatory obligations, or to respond to orders from competent authorities. — Protection of rights: to protect the rights, property or safety of FCX, its users or third parties. 5. Roles in Data Processing For personal data entered into the Platform, the user (the contracting company) acts as Controller, responsible for the applicable legal bases and consents. FCX acts as Processor, handling the data exclusively in accordance with the contracted purposes. Where FCX processes data for its own purposes — such as compliance with legal obligations — it acts as Controller for those specific purposes. 6. Information Security FCX adopts technical and administrative measures consistent with the state of the art to protect personal data, including: — Access control by profile and authentication; — Encryption of data in transit and, where feasible, at rest; — Continuous access monitoring and an append-only audit log; — Environment segmentation and internal information security policies. In the event of a relevant security incident, FCX will notify those affected within 48 hours of becoming aware of the event, describing the nature of the incident, the data affected and the mitigation measures adopted. 7. Data Retention and Deletion Personal data is retained for as long as necessary to perform the contracted services and to comply with legal obligations. The IP address may be anonymized after 12 months, in accordance with the LGPD. Upon termination of the agreement, data may be returned or securely deleted as instructed by the user, subject to applicable legal retention obligations. 8. Your Rights In accordance with the LGPD, you have the right to: — Confirm the existence of processing and access your data; — Correct incomplete, inaccurate or outdated data; — Request the anonymization, blocking or deletion of unnecessary data; — Obtain information about the sharing of data with third parties; — Withdraw consent where processing is based on that legal basis. To exercise these rights, contact us at suporte@fcxsolutions.com.br. 9. International Transfers Should any international transfer of data occur, FCX will adopt the appropriate legal mechanisms required by the LGPD, including specific contractual clauses or the use of providers in countries with an equivalent level of protection. 10. Changes to this Policy We may update this Privacy Policy periodically to reflect changes in our practices or for other operational, legal or regulatory reasons. We will publish any change on the Platform with at least 15 days' prior notice. For significant changes affecting data processing, we will provide more prominent notice and, where necessary, request new acceptance. 11. Cookie Policy We use cookies and similar technologies to ensure the proper functioning of the Platform, analyse service usage and personalize the experience. The detailed conditions are set out in our Cookie Policy. 12. Contact For questions, requests or concerns relating to this Privacy Policy or to the processing of personal data, contact us at suporte@fcxsolutions.com.br or through the support available on the Platform. 13. Acceptance of this Policy By using the Platform, you confirm that you have read, understood and agree to this Privacy Policy. If you do not agree with this policy, you must immediately stop using the Platform. This Privacy Policy was updated on 10 April 2026.