AXIANSEU DC LC, S.A. and its subsidiaries (hereinafter “Company”) is committed to respect the privacy and data protection rights of data subjects and to ensure the protection of all personal data processed by us, and to act in accordance with the provisions of the applicable privacy and data protection laws. This privacy policy explains how the Company (“Company, “we” “our” or “us”) collects, processes, stores, uses, shares and protects any information about you when you interact with us using our website, our services, when you register or attend our events, webinars, download an e-book and reply to the Company’s satisfaction survey.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately and to the extent permitted by law, you have control of any personal information relating to your data processed by the Company.

Contents

1. Who we are?
2. Who is responsible for processing your data?
3. What data do we collect about you?
4. For what purposes and on what lawful basis does the Company process personal data?
5. Who are the recipients of your data?
6. International Transfers
7. What security measures we have in place?
8. Where do we store the personal data?
9. How long do we keep your data for?
10. What rights do you have as a data subject?
11. Your marketing choices
12. Cookies
13. How can you exercise your rights?
14. California and Delaware “Do Not Track” disclosures
15. How can you know about the changes to this privacy policy?

1. Who we are?

The Company is a global digital solutions provider specialized in guiding and accelerating customers’ journeys through their agile development & digital transformation. The Company company group is comprised by the Company and its subsidiaries worldwide. You can find our office locations and the full list of the Company companies at https://www.lowcode.axians.us/contacts/

2. Who is responsible for processing your data?

The Company entity which is responsible for processing your personal data may differ based on where you live, as following:

If you are domiciled in Europe, the entity responsible for processing your personal data is:

AXIANSEU DC LC, S.A. with its registered office at Av. Dom João II, 44 C, Piso 5, 1990-095 Lisboa, Portugal, VAT identification number 503 676 985, or

If you are domiciled in Brazil, the entity responsible for processing your personal data is:

Truewind Brasil – Sistemas de Informação Ltda, with its registered office at Rua Padre Carapuceiro, 733 Empresarial Center I, 8°andar, Boa Viagem, Recife/PE CEP 51.020-280, CNPJ 14.335.171/0001-86, Brasil.

3. What data we collect about you?

The Company may collect personal data related to prospects, customers, customers’ employees, IT professionals, providers’ employees and applicants. The types of personal data we collect about you depends on your use of our services and the ways that you interact with us. This may include information about:

• How you use or visit our websites.
• How you use our services and interact with us.
• Contact, billing and other information you provide.
• Improve our services.
• Personalize our services and make recommendations.
• Advertise and market to you, which includes sending promotional communications and targeting advertising.
• Job applications.

We also obtain information from third-party sources. We protect information obtained from third-parties according to the privacy practices as described in this Privacy Policy. These third-party sources vary over time and may include:

• Partners with which we offer co-branded products or services or engage in joint marketing activities.
• Publicly available sources, such as websites and professional networks.

The personal data we collect can include the following:

• Contact details such as your name, email address, mailing address, and contact telephone numbers.
• Employment information such as your job title and other business or company information.
• Job application information such as your name, contact information and your Curriculum Vitae (CV).
• Credentials such as your passwords, password hints, and similar security information used for providing the services to you.
• Web form information you provide in our web forms (forms that you choose to complete will indicate whether the information requested is mandatory or voluntary).
• Account history information related to the services you purchase, and the activities associated with your account.
• Cookie and tracking information such as IP address, device identifier, location data, browser type and language, access times, the Uniform Resource Locator (URL), other unique identifiers and other technical data that may uniquely identify your device, system or browser.
• Feedback and rating information you provide to us such as customer survey feedback and service reviews.

4. For what purposes and on what lawful basis does the Company process personal data?

The Company may process personal data for the following purposes and on the following lawful basis:

• Website optimization: grounded on your consent we use functional, performance and targeting cookies to compile statistics in order to improve the website’s appearance, performance, and user experience, and to optimize our marketing. You can customize your preferences or accept all the cookies at any time, as you wish.
• Customer and potential customer management and Marketing: grounded on our legitimate interest we may process your data to promote our business to you, exclusively in your professional capacity, and related to the role you have in your company and in the market, and we consider such use goes no further than reasonably expected and is likely aligned with your interests in that we estimate you regularly make strategy, purchasing and other corporate decisions related to the products and services we sell and is unlikely to be detrimental to your fundamental rights and freedoms.
• Provision of the services and contractual management: we will process your personal information for the performance of a contract we have executed with you and/or your employer or if it is required for us to comply with any legal obligations. We also consider having the legitimate interest to process your data to ensure we can provide the best service possible, by sharing news, new services, events invitations, and conducting satisfaction surveys to assess the services provided by us.
• Recruitment and selection: which includes analyzing applications and CVs, as well as the internal selection process for staff according to the Company’s needs. The lawful basis is consent either via applications and CVs you have submitted or made available on business related social media.

5. Who are the recipients of your data?

We may share your information with our subsidiaries, acting as data controllers or data processors, for customer support, sales, marketing, technical and development operations, recruitment and account management purposes and with third-party subcontractors engaged to provide you the services.

6. International Transfers

The Company may transfer your personal data to other companies within the Company group and/or to its business partners, if required for the purposes described in this Privacy Policy. This may involve the transfer of your personal data to countries outside your country, which may have a different level of data protection from your country. In order to provide adequate protection for the transfer of your personal data, we have in place contractual arrangements (as appropriate) with our subsidiaries, affiliates and business partners in respect of such transfers. We will take all reasonable technical and organizational measures to safeguard personal data we transfer.

7. What security measures we have in place?

The Company uses appropriate technical and organizational security measures to ensure a level of security appropriate to the risk and to protect the data supplied by you and managed by us against loss, unauthorized access, disclosure, alteration, and destruction and against other forms of unlawful or abusive treatment. The ways we do this include:

• Using encryption methods, such as VPN IPsec and Secure Socket Layer (SSL).
• Using secure data networks, with physical and logical access to servers and equipment, restricted, located in controlled facilities (protected by firewalls and intrusion detection systems, IDS e IPS).
• Limiting physical access to our facilities.
• Limiting the access to the data we collect about you.
• Ensuring that our business partners have appropriate technical and organizational security measures to keep your personal data protected.
• As required by the applicable law, destroying or de-identifying personal data.

The technical and organizational security measures created and implemented by the Company are also required from our service providers that may process personal data on our behalf and as per our instructions.

We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from the Company asking for your personal information. The Company will not request your ID or password through email.

It’s important to remember that “perfect security” does not exist on the Internet. Also, our website can contain links to some external websites and therefore the Company is not responsible for the security practices or the content of such sites. Thus, you must always consult the relevant privacy policy of all the websites you use and visit beforehand.

8. Where do we store the personal data?

Your personal data may be hosted and stored in our cloud infrastructure located in Portugal, Brazil or using services like Google Workspace, Atlassian and HubSpot on servers that are located in the European Union and the United States, as well as other countries which might not have the adequacy decision of the European Union.

9. How long do we keep your data for?

The Company will only keep your personal data for as long as necessary for the purposes described in this Policy or during the period required by the applicable legislation or regulations.

10. What rights do you have as a data subject?

With regard to your information that is collected and/or processed by the Company, you may exercise the following rights:

• Right to know: you may have the right to request information about the personal information we have collected about you and for what purpose.
• Right of access: You may request the Company to confirm if information about you is processed. If such is the case, you will receive access to your information and information about that processing. You may also obtain a copy of the personal data that is processed.
• Right to rectification: you have the right to rectify your personal data if it is in any way inaccurate, incorrect, outdated or incomplete.
• Right to deletion: you can ask us to delete your data, however, please note that this is not an absolute right, since we may have legal grounds or other legitimate interests for the retention of your personal data.
• Right to data portability: in cases where the processing of data is based on a contract to which you are a party or on your consent, you may ask the Company to hand over to you the data you supplied in a structured, current and automatic reading format. You may also ask the Company to transfer this data to other data controllers, as long as this is technically possible.
• Right to object: when the data processing is based on the Company legitimate interest or when it is carried out for purposes other than those for which the data was gathered, but which are compatible with the same, you have the right to object to the processing of your data for reasons related to your own personal situation. For example, in terms of marketing communications you have the right to opt out, by unsubscribing from any electronic message or communication we send you.
• Right to restrict processing: you may request the Company to restrict the processing of your information, if [i] the information is inaccurate, [ii] the processign is unlawful, [iii] you need us to retain the information after the retention period for a legal claim, or [iv] you have objected to the processing and verification of our legitimate interests is pending.
• Right to Be Free from Discrimination: the Company will not discriminate against you for exercising your privacy rights.
• Right to withdraw consent: you may withdraw your consent to the processing of data when such processing is based on your consent. Withdrawal of consent does not affect the legality of consent-based treatment prior to withdrawal.
• Right not to be subject to automated decision-making: the Company makes no automated individual decisions, including profiling, which have an effect on your legal status or significantly affect it in a similar way.
• Right to file a complaint: You have the right to file a complaint to your local Data Protection Authorities about matters related to the processing of your personal data.

11. Your marketing choices

You have choices about how we reach you with marketing offers and about other uses of your information. To update your preferences, you can click “unsubscribe” in any email marketing communications we send to you.

12. Cookies

We use first and third-parties cookies to collect information about how you interact with our website, to improve and customize your browsing experience, for marketing and for analytics.

These cookies have programming code to collect information about your interaction with our website, such as the pages you visit, the links you click on and how long you are on our sites.

In our Preferências de cookies, you have all the categories of cookies we use on our website and see the details of each one. When you access our Preferências de cookies, you will be able to customize your preferences or accept all the cookies at any time, as you wish.

13. How can you exercise your rights?

If you would like to exercise any of the rights listed above, please contact our Data Protection Officer at privacidade.axianspt@axians.com, and/or write to us at:

If you are domiciled in Europe, the entity responsible for processing your personal data is:

AXIANSEU DC LC, S.A.

Av. Dom João II, 44 C, Piso 5, 1990-095 Lisboa, Portugal.

If you are domiciled in Brazil, the entity responsible for processing your personal data is:

Truewind Brasil – Sistemas de Informação Ltda

Rua Padre Carapuceiro, 733 Empresarial Center I, 8°andar, Boa Viagem, Recife/PE CEP 51.020-280, Brasil.

Attention: Data Protection Officer, Alexandra Mousinho

14. California and Delaware “Do Not Track” disclosures

Privacy regulations in the United States, such as the laws of California and Delaware, require the Company to indicate whether it honors your browser’s “Do Not Track” settings concerning targeted advertising. As such, the Company does not monitor or respond to Do Not Track browser requests.

15. How can you know about the changes to this privacy policy?

We might need to change this privacy policy from time to time. If we do, the “last updated” date will be reviewed, so we recommend that you check it regularly for any changes. For your benefit, we may send you information on the updates.

Last updated: February 28, 2024