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    Privacy Policy

    Last updated: December 2025

    1. Introduction

    1.1. SATS is committed to preserving the privacy and protection of personal data of Users and values transparency in relationships with its Users, employees, suppliers, and partners.

    1.2. This Privacy Policy refers exclusively to the personal data of Users processed by SATS within the scope of providing SATS Products through the SATS Platform.

    1.3. This Privacy Policy does not address privacy and data protection practices carried out by third parties. For policies applicable to your personal data processed by SATS partner third parties, we suggest you visit their respective websites.

    1.4. By clicking "accept" at the end of this Privacy Policy, the User will be legally bound to all terms and conditions presented here. If the User disagrees with any of the rules provided, the User should not accept this Privacy Policy and should not use SATS Products.

    1.5. After reading this Privacy Policy, if the User has any questions or complaints about the content of our Privacy Policy, they may contact our Data Protection Officer through the channel privacy@satscapital.com.br.

    2. General Definitions

    2.1. Terms capitalized herein have the same meaning attributed to them in the Terms of Use applicable to SATS Products ("Terms of Use"), unless the term is defined differently in this document.

    2.2. Throughout this Privacy Policy, the User will find a series of other words or expressions beginning with capital letters. Below, we present the meanings of these words/expressions:

    • "User" means the natural person, capable of performing civil acts or duly represented or assisted, as the case may be, who effectively contracts, uses, or accesses one or more SATS Products;
    • "Processing Agents" means those responsible for Data Processing and are separated into two categories: Controller and Processor;
    • "Personal Data" means information that identifies or may identify the User;
    • "Sensitive Personal Data" means Personal Data related to racial or ethnic origin, religious conviction, political opinion, union membership, health or sex life data, genetic or biometric data;
    • "Device" means the device - such as computers, tablets, and smartphones - that can be used by the User to access SATS Products;
    • "Cookies" are small files containing a sequence of characters, created and sent by websites to your computer whenever you visit them;
    • "Processing" means any operation that can be performed with Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, diffusion, or extraction.

    3. Personal Data

    3.1. Collection Methods. Personal Data is collected by SATS as follows:

    • (i) when the User registers on the SATS Platform via Website or Application;
    • (ii) when the User uses the SATS Platform and/or contracts or uses any of the SATS Products;
    • (iii) when the User contacts SATS through Service Channels;
    • (iv) through companies in the same group as SATS, to the extent necessary for us to carry out our activities, improve SATS Products, and comply with legal obligations; and
    • (v) through Partners, when SATS needs to confirm the User's registration after making a purchase.

    3.2. Main Purposes. The collected Personal Data is used for the following main purposes:

    • (i) provide SATS Products and/or other benefits offered through the SATS Platform;
    • (ii) improve and develop SATS Products and offer the User a better experience;
    • (iii) identify, authenticate, and verify requirements for contracting SATS Products;
    • (iv) maintain contact with the User in general, including for service through Service Channels;
    • (v) comply with legal obligations and/or requirements by competent authorities;
    • (vi) detect, prevent, and solve technical or security problems, fraud, illicit acts, and financial crimes.

    4. Data Sharing

    4.1. SATS may share User Personal Data with:

    • Commercial Partners, for the provision of SATS Products;
    • Service providers and suppliers, for the operation of the SATS Platform;
    • Government authorities, when required by law or court order;
    • Companies in the same economic group, for the purposes described in this Policy.

    5. User Rights

    5.1. The User has the following rights regarding their Personal Data:

    • Confirmation of the existence of processing;
    • Access to data;
    • Correction of incomplete, inaccurate, or outdated data;
    • Anonymization, blocking, or deletion of unnecessary or excessive data;
    • Data portability;
    • Deletion of personal data processed with consent;
    • Information about entities with which data was shared;
    • Information about the possibility of not providing consent and the consequences;
    • Revocation of consent.

    6. Security

    6.1. SATS adopts technical and organizational security measures to protect User Personal Data against unauthorized access, destruction, loss, alteration, communication, or any form of improper or illicit processing.

    6.2. These measures include, but are not limited to:

    • Data encryption in transit and at rest;
    • Access control and authentication;
    • Continuous monitoring and auditing;
    • Employee training on data protection.

    7. Contact

    7.1. For any questions regarding this Privacy Policy or the processing of your Personal Data, please contact our Data Protection Officer:

    Email: privacy@satscapital.com.br

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