This PRIVACY POLICY is part of the WINPULSE NETWORK PLATFORM Terms of Use. The USER should carefully read the following conditions, as they contain important information about the PRIVACY and protection of his / her personal data.

To accept the WINPULSE NETWORK Terms of Use the USER must know and be in accordance with the PRIVACY POLICY, which has clear and complete information about the collection, use, storage, processing, and protection of personal data.

INTRODUCTION

(I) The solutions contained in the WINPULSE NETWORK PLATFORM (or simply "PLATFORM ") are made available by WINPULSE NETWORK PLATAFORMA DE SERVIÇOS LTDA, a legal entity of private law, registered with CNPJ/MF under number 39.694.123/0001-05, headquartered in Porto Xavier/RS - Brazil, at Rua Oswaldo Cruz, 596 - Centro – Zip Code 98.995-000;

(II) This PRIVACY POLICY ("POLICY") is intended to establish the rules on (a) how and for what purposes personal data is processed by WINPULSE NETWORK; (b) with whom such personal data may be shared; and (c) how USERS can manage their personal data;

(III) The official language of this POLITICS is the Portuguese. Any version in another language is a courtesy translation. In the event of a conflict due to interpretation, the Portuguese version shall prevail for the personal data processed by WINPULSE NETWORK.

GENERAL INFORMATION AND DEFINITIONS

The expressions contained in the item DEFINITIONS of the Terms of Use are used in this PRIVACY POLICY with the same meaning.

Any person who accesses the PLATFORM is considered a USER, regardless of whether or not he / she has registered. However, registration and personal data are only requested from registered USERS, which may be PROPRIETARIES, VISUALIZERS, PARTICIPANTS or ACQUIRERS.

First, it is important to emphasize that to WINPULSE NETWORK is essential to collect, store and process the personal data obtained from USERS, to enable the provision of the services offered through its PLATFORM. By using the PLATFORM, the USER agreesto this POLICY expressly and unequivocally.

It is worth noting that some personal data are necessarily collected by WINPULSE NETWORK to enable the execution of the service contract (Terms of Use) signed with the USERS, as well as in the legitimate interest of allowing the operation of the PLATFORM.

The USER is aware and agrees that it is his / her responsibility to provide true, accurate, current, and complete information when registering for access to the PLATFORM. We remind that the indication of incomplete or false data is a crime typified by law and may result in severe punishments to those who provide it.

The data collected by WINPULSE NETWORK will be stored in secure databases, within best practices, with restricted access only to employees and authorized persons with the appropriate credentials, who are obliged to maintain the confidentiality of the information and not use it improperly.

WINPULSE NETWORK may store and process the Personal Data collected and other information collected on a server located in Brazil or abroad.

CONTROL OF REGISTRATION DATA BY USERS

Each USER has control over the Registration Data contained in the profile created on the PLATFORM, being able to access and change them using their login and password. We remind that the login and password are individual being the password known only by the USER himself, who should ensure the confidentiality of this data. WINPULSE NETWORK is not responsible for the way this data is used by the USER.

The WINPULSE NETWORK PLATFORM has the principle of collecting the minimum of mandatory information from the USER but allows the USER to provide other information that he deems relevant to make up his Personal Page, which will be accessible to other USERS, as detailed below.

The goal of having a Personal Page is to give credibility to the relationships between USERS through the PLATFORM, allowing to include relevant information, such as their skills and professional experiences, as well as other external means of contact and social networks. The Personal Page will be fully editable by the USER through the "Profile" menu and must contain minimum information for the maintenance of registration, such as Name, Username, and e-mail.

In addition to the Personal Page the USER will be able to create initiatives highlighting their professional services, which will be available on the Internet, will be fully responsible and fully editable by its PROPRIETARY

DATA FROM MINORS

We only request registration and personal data of a person empowered to practice all acts of civil life (over 18 years of age, or regularly emancipated). If we become aware that we collected personal data of a minor under 18 years and not emancipated, we will block the respective account created on the PLATFORM and delete the personal data, only being able to keep personal data that aim to prevent further attempt to register.

PERSONAL DATA PROCESSED BY WINPULSE NETWORK

Mandatory Registration Data:(a) Username; (b) Full name; (c) email; (d) Password; (e) Telephone; (f) CPF / CNPJ for Brazilians; (g) address for Brazilians;

Additional Non-Mandatory Data: (a) professional identity; (b) address for nonBrazilians; (c) presentation; (d) professional skills or products; (e) social networks (LinkedIn and Instagram); (f) website; (g) WhatsApp; (h) photo;

Payment Data: (a) PayPal API credentials; (b) current account number; (c) tax identification number for non-Brazilians; (d) other necessary information, such as for the case of international transfer, as requested by the contracted entity and regulatory bodies;

Activity Data: (a) sales made through the PLATFORM; (b) Receipts for sales of CONTENT and individual access to Initiatives;

Reviews: (a) USER reviews through their Personal Page; (b) evaluations of the Initiatives produced by the PROPRIETARY;

Additional Evidence: (a) proof of student regularity; (b) proof of majority; (c) other professional or student vouchers;

Mandatory Registration Data, Additional Non-Mandatory Data, and Payment Data make up the Registration Data.

The Personal Page comprises the Assessments, Mandatory Registration Data and Additional Non-Mandatory Data, except the telephone, address and CPF / CNPJ, which are not disclosed on the Personal Page.

PURPOSES OF THE COLLECTION AND PROCESSING OF PERSONAL DATA BY WINPULSE NETWORK

• Perform the Registration;
• Allow access via login and password;
• Perform identification of USERS with the PLATFORM;
• Security POLICY - two-factor authentication;
• Allow communication between USERS via chat or e-mail;
• Make content purchases;
• Allow access to the Content;
• Allow the issuance of invoice;
• Send communications;
• Contact the USER, when necessary;
• Manage payments and subscriptions;
• Send email messages with relevant information from the PLATFORM;
• Perform support activities;
• Carry out fraud prevention analysis activities on the PLATFORM;

• Compose the Personal Page, along with email, name, and Username;
• Improve the presentation of the USER in the network;
• Offer contact alternatives;
• Offer alternatives for personal and professional evaluation for USERs with whom they wish to interact;
• Direct USERs to his / her website or social networks;
• Present qualifications and professional skills;
• Improve the credibility of the USER’s profile in the network;

• Allow direct payment to the PROPRIETARY for the content sold;
• Allow payment to the USER who sold using the PayPal credentials of the PLATFORM;
• Allow deposits directly to the USER's bank account;
• Allow international transfers to the USER who does not have a deposit account in Brazil;

Some payment data will only be requested for the specific action, such as transferring amounts to the USER's account and may be kept in the WINPULSE NETWORK database.

• Issuance of receipt by the PLATAFORM;
• Check payments by USERS;
• Pay USERs who used the PLATFORM credentials for receipt;
• Tracking for accountability to regulatory bodies;

• Allow the USER's evaluation by other USERS;
• Allow the evaluation of a USER's initiatives by other USERS;
• Increase the security and credibility of interactions between USERS;
• Provide feedback mechanisms for interactions performed;

• In case of suspicion, prove the USER's majority to maintain the registration in the PLATFORM;
• Offer discounts and promotions to students;
• Seek greater adherence of students to the activities of the PLATAFORM;
• Promote the entrepreneurial development of students;
• Encourage the development of Coaching in the tools of the PLATFORM;
• Encourages the development of professionals from specific areas in the PLATFORM tools;

DELETION OF PERSONAL DATA

Retention Period: All USERS' personal data processed as provided in this POLICY will be kept by WINPULSE NETWORK for as long as necessary for their purposes. We may also retain information as required by law or regulation or for the regular exercise of rights, or in circumstances where there is a legitimate purpose of WINPULSE NETWORK or third parties.

Deletion Requests: The USER may delete at any time the personal data with the WINPULSE NETWORK PLATFORM, through the menu "Profile”, however, it is necessary to keep the name, account name, email, and telephone number, which will remain registered even if the account is inactive. This minimum information will be accessible to third parties (except the phone) with whom he / she has already been in contact via chat. If he / she does not want new USERS to have access to his / her Personal Page, the USER should also delete all his / her Initiatives on the PLATFORM.

SHARING OF PERSONAL DATA

WINPULSE NETWORK may share the USERS’ personal data with third parties, as described in the table below:

RIGHTS WITH RESPECT TO THE USER PERSONAL DATA

Rights and Warranties: the USER has rights and guarantees in relation to his / her personal data. We provide mechanisms, detailed below, so that USERS have clarity and transparency in the exercise of their rights. Whenever necessary, our team will be ready to evaluate any requests.

Rights Provided for in the LGPD:pursuant to the General Data Protection Act (Law 13.709/2018 –) ("LGPD"), the USER is entitled to:

1. confirm that we have processed his / her personal data;
2. access his / her personal data;
3. require the correction of personal data that are incomplete, inaccurate, or outdated;
4. request anonymization, blocking or deletion of unnecessary, excessive, or processed personal data in non-compliance with the provisions of the LGPD;
5. request the portability of his / her personal data to another service provider or product, in compliance with our trade and industrial secrets, after regulation by the National Data Protection Authority;
6. request the deletion of personal data processed based on his / her consent, except in the case of retention of personal data provided for in the LGPD;
7. request information about with whom we share his / her personal data;
8. request information on the possibility of not providing his / her consent and the consequences;
9. revoke his / her consent to the processing of his / her personal data, when there is processing carried out based on his / her consent;
10. opposition to treatment that violates the LGPD.



Additional Information: Before we respond to a request to exercise the rights mentioned above, we may ask you to provide us with some information to confirm your identity.




SPAM PRACTICES

Positioning: We are against any practice that promotes SPAM of any kind and we are committed to ensuring that the messages sent by the PLATFORM are always of interest or importance to the respective recipients.




WINPULSE NETWORK Guidelines: likewise, we charge our USERS who do not practice SPAM, that make sure that the messages sent are always of interest to the recipient, being aware that failure to comply with good practices of internet use may generate the cancellation of the offending USER's account on the PLATFORM, as defined in the Terms of Use, as well as the disclosure of personal registration data, in accordance with this PRIVACY POLICY.

INFORMATION SECURITY

Data Storage: The personal data collected by WINPULSE NETWORK will be stored in secure databases, within best practices, with restricted access only to employees with the appropriate credentials, who are obliged to maintain the confidentiality of the information and not use it improperly.




INFORMATION AND DOUBTS

Questions about the POLICY or Your Personal Data: If after reading this POLICY the USER has any questions or want to submit any requests regarding his /her personal data, he / she can contact our data security team via email support@winpulse.net




PRIVACY POLICY CHANGES

WINPULSE NETWORK reserves the right, at any time, to change this PRIVACY POLICY by updating its content according to the needs for technological improvement or its functionality.




When there is a change in the PRIVACY POLICY, WINPULSE NETWORK will communicate its USERS by e-mail or in publication in a prominent area on the PLATFORM.




If the USER continues to use the tools offered by WINPULSE NETWORK after the communication of the PRIVACY POLICY change, this will mean and will be considered as their unequivocal consentand irrevocable and irrevocable acceptance of all terms and conditions contained in the amended PRIVACY POLICY.




For clarification and more information about this PRIVACY POLICY please contact us at support@winpulse.net , including in the title of the message the following sentence: “PRIVACY POLICY".




LEGISLATION

1. Decree regulating the Civil Framework of the Internet - Brazil -http://www.planalto.gov.br/ccivil_03/_ato2015- 2018/2018/lei/L13709compilado.htm
2. GDPR - General Data Protection Regulation - instituted through Regulation (EU) No 2016/679;