PRIVACY POLICY

Fully Ecosystem is committed to complying with laws that protect the privacy of customer data and the general public. For services related to the Fully application to be provided, it is necessary to process and share personal data. The purpose of this Privacy Policy is to present information about the collection, processing, and protection of your personal data so that it is clear to you how we handle your personal data within the Fully application and how your personal data is handled by partners responsible for the technologies involved in the application.

Within the Fully application, customers can expect their information to be kept accurately and protected against manipulation and errors, as well as against crimes and improper disclosure.

The security of customer data is protected by complying with the General Data Protection Law (Law No. 13,709/2018) and all other applicable local laws, ensuring compliance with strict security and confidentiality standards. The submission of data will depend on the customer's express prior consent to Fully Ecosystem and effective registration in the Fully application.

1. GENERAL CLARIFICATIONS ABOUT THE FULLY PLATFORM AND THOSE RESPONSIBLE FOR PROCESSING YOUR DATA

Fully Ecosystem is an ecosystem that integrates technological features of third-party applications, developed and maintained by our partners. This integration aims to provide users, in one place, with access to wellness journeys a) physical; b) financial; c) nutritional; and d) mental and any other aspect that affects quality of life. For more information on how personal data is processed within these journeys, please refer to item 3 of this Privacy Policy.

In the Fully application, users can go through wellness journeys. As they progress, users will complete activities and goals and be rewarded with points called "Coins", which can be accumulated and exchanged for vouchers.

2. GENERAL CLARIFICATIONS ABOUT DATA PROCESSING IN THE FULLY APPLICATION

For services related to the Fully application to be provided, it is necessary to process and share your personal and sensitive data. This document details why your data is collected, what purposes they are used for, to whom your personal data may be provided, from whom they may be collected, and how to access, review, change, and request the interruption of processing your data. The provision of your personal and sensitive data is free, unequivocal, and informed, and the use of the Fully application will only be possible after your consent to the processing of personal data.

2.1. WHAT PERSONAL DATA IS COLLECTED, WHY IS IT COLLECTED, AND HOW CAN IT BE USED?

Personal data and sensitive personal data are collected in a series of circumstances, including registration in the application and activation of advertising, when you contact us, ask questions, make comments, use or request our products or services, or the products and services of our strategic partners. Personal data is collected to process, administer, implement, and carry out requests, transactions, or membership services within the Fully application, as well as for other possible programs that may be made available.

The data to be collected and processed, sometimes in an automated way, may fall into the following exemplary categories of personal data: personal identification and contact (for example: CPF number, address, date of birth, full name, gender, phone number, email, account login information, technical information about the mobile device and financial and payment information, among others), physical health information, mental wellness information, personal budget financial information and food and nutritional information.

In addition, sensitive personal data is collected, such as data on your physical activities, medical and health information, for the selection of wellness journey(s) presented to the user in Fully.

IMPORTANT: Rest assured, your personal data will never be commercialized.

2.2. WITH WHOM IS YOUR PERSONAL DATA SHARED AND FOR WHAT PURPOSES?

When disclosure is necessary to satisfy any of the purposes mentioned above and provided that necessary data governance and security standards are met, provided to the following parties:

• any of our affiliates and/or any affiliate of Fully Ecosystem partner companies and any affiliate of strategic partners;
• Fully Ecosystem partners and their agents for providing products and/or services to platform users, as well as for platform administration;
• any agent, contractor, or third-party service provider that provides maintenance support to platform users;
• other companies that help collect your information or communicate with you, such as research companies and rating agencies;
• regulatory, governmental bodies, or any person to whom Fully Ecosystem or its partners have a legal obligation to disclose.

2.3. PERSONAL DATA STORAGE

Processed personal data may be stored on Fully Ecosystem's own server, in São Paulo, the United States, or Germany, or on third parties contracted for this purpose, located in Brazil or abroad.

2.4. INTERNATIONAL DATA TRANSFER

Personal data collected by Fully Ecosystem will be shared with servers hosted in different countries where our strategic partners and technology partners operate. Subsequently, the data will be processed and consolidated in Fully Ecosystem cloud computing in various geographies, including the United States, where they will be aggregated with strategic partner data in the so-called Fully data lake.

Even when sharing customer personal data internationally, Fully Ecosystem observes all requirements established in current legislation and adopts market best practices to ensure the protection and privacy of such data.

2.5. HOW IS DATA KEPT SECURE?

Fully Ecosystem has and requires from its partners internal policies and procedures aimed at preserving your privacy, ensuring the security and protection of your personal data. In this context, we adopt technical measures capable of keeping your personal data safe and protected from unauthorized access and accidental or illicit situations of destruction, loss, alteration, communication, or any other form of inadequate or illicit treatment, always in light of applicable data protection and information security standards.

2.6. MINORS' DATA

The Fully application is not available to minors under 18 years of age. Even if a partner allows the use of wellness journeys by minors, Fully Ecosystem prohibits it. As provided in item 6 of the Terms and Conditions, being over 18 years old is one of the necessary requirements to use the platform. Therefore, there will be no intentional processing of minors' data by Fully Ecosystem.

2.7. WHAT ARE YOUR RIGHTS?

As a personal data subject and our customer, you have the following rights regarding your personal data:

• access, review, know if we perform any processing with your personal data and request an electronic copy of the information we have about you;
• correct or request correction of incomplete, inaccurate, or outdated personal data;
• request anonymization, blocking, or elimination of unnecessary and excessive data;
• request data portability to another service or product provider;
• request elimination of data collected and used with your consent;
• obtain information about public or private entities with which we share your personal data;
• when the processing activity requires your consent, you may refuse to consent;
• when the processing activity requires your consent, you may revoke it at any time.

To exercise your rights:
Phone: 0800 725 1016 (Monday to Friday, 8am to 8pm)
Email: suporte@livefully.com
DPO: dpo@livefully.com

3. PERSONAL DATA PROCESSING BY PARTNERS

Having presented the general characteristics of personal data processing in the Fully application in the previous topics of this Privacy Policy, which apply to both data processing performed by Fully Ecosystem and the Fully application and processing performed by partners, which must be considered in full, we now present to you, objectively, specific information about how your personal data is processed within each wellness journey in light of the privacy policy.

3.1 GOOGLE FIT INTERACTION

Google Fit is an application or service with one or more features to benefit health and fitness users through a user interface that allows users to write directly to the diary, report, monitor and/or analyze, as well as synchronize, their physical activity, sleep, mental well-being, nutrition, health measures, physical descriptions and/or other descriptions and measurements related to health or fitness.

Use of information received from Google Fit APIs will be in accordance with the Google Fit Developer and User Data Policy, including the Limited Use Requirements set forth in the Google Fit Developer and User Data Policy, available at: https://developers.google.com/fit/policy.

4. COOKIES

Cookies are unique identifiers placed on your computer or other device by a web server, containing information that can then be read by the server that sent you the cookie. You may use cookies on various websites we maintain. The information collected will be used to compile aggregate statistics on how our visitors arrive at and navigate our websites to help us understand how we can improve your experience on our websites.

5. DIGITAL MARKETING

By joining the Fully application and participating in it, you understand and acknowledge that Fully Ecosystem may send marketing communications via social networks, such as: Facebook, Instagram, Google, LinkedIn, etc. Additionally, Fully Ecosystem may also contact you via WhatsApp. You, however, may opt out of receiving marketing communications by sending a request to the email suporte@livefully.com.

6. PRIVACY POLICY CHANGES

The content of this Privacy Policy may be updated or modified at any time to ensure our commitment to transparency with you. In this case, Fully Ecosystem will make available, with the update date, the Privacy Policy in the Fully application; will leave the updated version available in the application used by you and will inform you about the consequences of not accepting the updates/changes in the Privacy Policy.

7. HOW TO CONTACT US

In case of questions about the provisions contained in this Privacy Policy, about the processing of your personal data by Fully Ecosystem, or in case of intention to exercise personal data subject rights provided for in LGPD, contact our department responsible for personal data processing - DPO, at the email dpo@livefully.com.

8. IMPORTANT DEFINITIONS

For the purposes of this document, the following definitions and descriptions should be considered for better understanding:

Benefits: Refers to discounts, exclusive offers, cashback rewards, and other benefits related to products and/or services offered periodically by our partners and available to Fully members through Fully.

Coins: Are accumulated through achieving goals and activities throughout the journeys. These have value and can be exchanged for vouchers.

Consent: Free, informed, and unequivocal manifestation of the data subject, authorizing the processing of their personal data for a specific purpose.

Personal Data: Information related to an identified or identifiable natural person, such as name, CPF, email, and phone.

Sensitive Personal Data: Personal data about racial or ethnic origin, religious belief, political opinion, affiliation with a union or organization of a religious, philosophical, or political nature, data referring to health or sexual life, genetic or biometric data when linked to a natural person.

Fully Ecosystem (Wellness): Fully Ecosystem (Wellness) Services Ecossistema de Bem Estar Ltda., business company headquartered at Av. das Nações Unidas, 14401 – 7th floor - Chácara Santo Antônio, São Paulo - SP, 04730-090, registered under CNPJ/ME 32.300.669/0001-95.

This policy contains all terms about personal data processing. For additional clarifications, contact us through the official channels mentioned in this document.

Last update date: June 24, 2024