Notice: This Privacy and Data Protection Policy was exclusively prepared by the law firm “Fabyolla Fernandes Advocacia Trabalhista e Gestão” for the company Análise Comportamental DISC. Any reproduction, commercialization, or distribution of this document without prior authorization is strictly prohibited.

Análise Comportamental DISC acknowledges the importance of protecting the personal data of its users, clients, and partners. In accordance with Law No. 13.709/2018 – the Brazilian General Data Protection Law (LGPD), we want you to understand how we collect, store, and process your personal data.

We are a recognized reference in Brazil in the field of human behavior studies based on the DISC theory and we value ethical and transparent relationships with everyone who uses our services.

This Privacy and Data Protection Policy represents another commitment made by Análise Comportamental DISC to those who trust us with their personal information. It describes the practices we follow regarding data collected via digital or printed forms, as well as through our website or member platform.

By providing your personal data to Análise Comportamental DISC, you agree to the terms and conditions described in this Privacy and Data Protection Policy. To ensure clarity and security, we explain below how we collect and process your personal data:

1. What is the purpose of this policy?

This policy aims to explain how Análise Comportamental DISC collects, processes, and stores the personal data of its users, clients, and partners, in compliance with Law No. 13.709/2018 – the LGPD.

2. What does this Privacy Policy cover?

This policy applies to the processing of data that identifies or may identify visitors and users of our website and DISC platform, including device-related data, all of which are considered personal data under the LGPD.

3. What personal data do we process?

3.1 Browsing Data:

When you visit our website, even without logging in, we collect navigation-related data such as:

• IP address

• Geolocation

• Device information

• Internet connection and browser details

• Language used

• Page response times

• Clickstream data

Justification: This data is collected to evaluate our website’s performance and improve your browsing experience.

3.2 Cookies:

We use cookies—small files saved on your device—to recognize your location and remember your preferences.

Justification: Cookies allow us to customize and optimize your browsing experience. You may disable cookies in your browser settings, but some features may not function correctly.

3.3 Registration Data:

When you create an account in our DISC Analysis Platform, we request:

• Full Name

• Email

• Password

• Phone number

• User type (Individual or Legal Entity)

• CPF or CNPJ

• Company Name / Trade Name

• ZIP Code

• Address (Street, Number, Neighborhood, City, Complement, State)

Justification: These details are necessary for you to access and use our DISC platform in full.

We may also collect your best email address if you opt to be notified about future training or product releases. You can unsubscribe anytime by clicking “Unsubscribe” in any of our emails.

4. Purpose of Processing Your Data

By submitting your personal data through registration, updates, or transactions, you CONSENT to the processing of data as defined in this Policy.

5. What are the legal bases for processing your data?

6. Does Análise Comportamental DISC share your personal data?

We DO NOT sell or share your personal data for profit. Data is only shared with the hosting provider of our DISC system platform, and only to fulfill contractual purposes (LGPD Art. 7, II and IX).

7. How long do we retain your data?

Your data will remain in our database as long as the contractual relationship and your interest exist. Note: Access to our platform is lifetime unless otherwise stated.

8. What are your rights as a data subject?

You have the right to:

• Confirm data processing

• Access your data

• Correct incomplete or outdated data

• Anonymize, block, or delete unnecessary/excessive data

• Request data portability

• Be informed about the option of denying consent and its consequences

• Revoke consent and request data deletion, except as stated in LGPD Art. 16

• Be informed about third parties with whom your data is shared

9. How do we protect your data and what is your responsibility?

We use advanced security technology to protect your personal data against unauthorized or illicit access. However, no system is entirely immune to threats. You are responsible for keeping your credentials confidential and for reporting any suspicious activity via our communication channels.

10. Policy Updates

This policy may be updated at any time. We recommend you check this document periodically to stay informed about changes.

11. Contact for Data Protection Issues

If you have questions or concerns about this policy, contact our Data Protection Officer:

Gislaine Araújo

📧 Email: protecaodedados@analisedisc.com.br

12. Who is the Data Controller?

LV Desenvolvimento Humano Comportamental DISC

CNPJ: 22.574.237/0001-19

📍 Rua José Versolato, 111, Bloco B, Sala 3.320, Centro – São Bernardo do Campo, SP - Brazil – CEP 09750-730

This policy comes into effect as of its publication on the Análise Comportamental DISC official website.