Terms and Conditions of Use – ClickOne

APPYS TECHNOLOGY AND SOFTWARE DEVELOPMENT LTD. (“ClickOne”), a private legal entity, registered under CNPJ/MF No. 52.845.660/0001-77, with headquarters at Avenida Nove de Julho, 5966, Jardim Paulista, CEP 01406-902, São Paulo, SP, Brazil, presents these Terms and Conditions of Use for the Software License and related features – ClickOne (“Terms of Use”), which govern the rules and conditions for access to and use of the ClickOne software (“SOFTWARE”) designed for business management, as well as all financial management services and related services (“Financial Services”) provided under ClickOne plans.

Appys Tecnologia e Desenvolvimento de Softwares LTDA (“ClickOne”), committed to transforming the entrepreneurial landscape in Brazil, firmly believes that all business owners deserve to succeed. Therefore, our goal is to empower small businesses by providing tools that offer effective control over their management. To achieve this purpose, it is necessary to process some personal data of our clients, which we do with the utmost responsibility and respect for each individual’s privacy.

Our Privacy Policy is built on a solid foundation of Brazilian legislation, with emphasis on the General Data Protection Law (LGPD), Law No. 13.709/2018. This legislation defines personal data as any information related to an individual who can be identified or made identifiable. This includes data such as CNPJ, CPF, RG, location, physical address, IP address, age, among others.

The main objectives of this Policy are:

(i) To protect the fundamental privacy and freedom rights of our clients, employees, and partners;

(ii) To implement processes and establish clear rules that ensure compliance with the legislation and best practices in personal data protection;

(iii) To ensure transparency regarding how personal data is handled within our organization;

(iv) To adopt effective measures to mitigate risks in the event of security incidents that may affect personal data.

To provide the Services available through ClickOne, various personal data may be collected, accessed, stored, and, in certain cases, shared with strategic partners.

Committed to maintaining a clear and transparent relationship with you, we present in this section all the rules that guide the handling of your data with us. By registering and using the services of ClickOne, we understand that you accept and agree to all the conditions described here. Therefore, it is essential that you read and understand all the provisions and, in case of doubts, do not hesitate to contact us. This will ensure that your experience with our products is secure, smooth, and highly productive.

Companies using the ClickOne platform must read and agree to these terms before using our platform.

These are the Terms and Conditions that will govern our relationship in all aspects. Please read this document in full, as by using ClickOne’s services and products, you will be accepting these Terms.

1- Acceptance and Agreement

1.1. The use of the SOFTWARE implies the automatic acceptance of the licensing terms and conditions established by Appys, in accordance with Law No. 9.609/98 (Software Law).

1.2. By accessing the ClickOne system (“Platform”) to use the SOFTWARE and the Financial Services, and by accepting the Terms of Use, the licensed user of Appys (“CLIENT” or “LICENSEE”) confirms that they have read and fully and consciously agreed with all the provisions contained in this document and other referenced and/or attached documents. If you disagree with the rules stipulated in the Terms of Use, the use of the services and products offered by Appys will be impossible.

1.3. The acceptance of the Terms of Use, as well as the actual use of the SOFTWARE, the business account services, and other services and products available on the Platform, will be considered valid and effective when performed with the access data registered by the CLIENT, who declares to have the legitimacy and sufficient legal representation powers for such acceptance. It is the CLIENT’s sole responsibility to ensure the security, confidentiality, and sharing of this data with employees, directors, and third parties. It is crucial to follow the security guidelines mentioned in the Terms of Use regarding data sharing, avoiding any insecure actions.

Scope of the Policy

This Policy applies fully to all services and applications offered by ClickOne, hereinafter referred to simply as “services.” It covers all individuals who interact with our services, whether they are customers, accountants, or users of our websites, applications, or any other platforms for providing services by ClickOne. All these will be referred to here as “users.”

2- Types of Processed Data

We collect and process personal information necessary to provide and optimize the services we offer to our users, either to highlight the benefits of our services or for their operation.

2.1. User Data:

(i) General contact and identification information, such as name, email, phone number, physical address, and identification documents of legal representatives and the company, including banking data.

(ii) To facilitate the use or purchase of our services and products, we may request additional financial information, such as credit card details, which are used exclusively for transaction processing and purchases.

(iii) Users may provide additional personal data when contacting our support channels to send suggestions, complaints, or resolve doubts.

(iv) For marketing and promotional purposes, we may request images of the users or individuals associated with the users, as well as information for participation in surveys or advertising campaigns.

2.2. Third-Party Data:

Third-party data may be necessary to provide our services, and users are responsible for providing and ensuring the legitimacy of this data. These include:

(i) Supplier and customer data, such as name, email, phone number, and identification documents.

(ii) Employee information, such as name, address, contact, personal documents, employment details, and social security and labor information.

2.3. Data Collected Automatically:

(i) Geolocation: We may collect location information to enhance the user experience, using technologies such as GPS or IP address.

(ii) Interactions with the Service: We analyze how users interact with our services to continuously improve our platform.

(iii) Log and Device Data: Information is automatically recorded when accessing our services, such as device type and usage history.

(iv) Tracking Technologies: We use cookies, pixels, and SDKs to collect information that helps personalize and improve our services. These data can be managed through the user’s privacy settings.

3- Use of Collected Data

We ensure transparency in the use of personal data collected, informing users of its purposes. The decision to provide the data lies with the user, and they will be informed of the potential consequences of not providing the data.

ClickOne Service Features: For Businesses:

• Financial management and invoice issuance

• Integration for payments and receipts

• Complete ERP system

• Management of services, products, and inventory

• Preparation of detailed reports

• Direct interface with accountants

• Dedicated application for sales management

Offering courses, e-books, webinars, and other educational resources, communications, and Support:

• Sending updates, security alerts, and operational support.

(a) Service Maintenance and Improvement:

Technical operations to ensure, test, and improve service functionality.

(b) Security and Compliance:

Actions to maintain service security, including identity verification and fraud prevention.

(c) Development and Backup:

Investigations for developing new features and backup procedures.

(d) Data Management and User Assistance:

Editing and updating records at the user’s request.

(e) Financial Management:

Managing payment methods and financial status of users.

4- Other Possible Uses of Data

The collected data may also be used for other purposes, always with prior notice to the user.

4.1 Statistical Analysis and Improvement:

Use of data for statistical analysis and service improvement without identifying individual users.

4.2 Disclosure of Campaigns and Promotions:

Using data for sending promotional material, campaigns, and surveys, with an opt-out option available to the user.

4.3 Legal and Regulatory Obligations:

Processing personal data to meet legal requirements, including:

• Sharing tax and fiscal information with government authorities.

• Issuing accounting and tax documents.

• Complying with labor obligations and other legal responsibilities.

In addition to these uses, data may be required for:

• Conducting internal and external audits.

• Responding to legal requests from competent authorities.

This section highlights our commitment to privacy and data security, aligning ClickOne’s operation with the best practices and current regulations.

Sharing Data

ClickOne adopts a policy of not sharing personal data with third parties without the explicit consent of the user, except where permitted or required by law for legitimate reasons.

(i) Sharing with Social Media Platforms:

With the user’s consent, data such as email addresses may be shared with platforms like Facebook and Google for marketing purposes, in accordance with our legitimate interest in promoting our services.

(ii) Inquiries about Data Processing:

Questions about how information is processed by third parties should be directed to those providers.

(iii) Sharing with Authorities and Third Parties:

ClickOne may share data with fiscal, police, and judicial authorities, as well as other authorized third parties when necessary to:

• Fulfill legal obligations.

• Respond to valid legal requests.

• Defend and promote legal actions.

• Enforce our Terms and Conditions.

(iv) Third-Party Service Providers:

To effectively execute our services, we share data with third parties who work in areas such as cloud storage, payment security, and customer service, under strict contractual obligations to protect data.

(v) Candidate Selection Processes:

In recruitment processes, data may be shared with third-party companies that process this information under our direction and on our behalf, ensuring data protection and privacy.

Data Security

ClickOne employs robust security measures to protect the privacy and integrity of our clients’ data. We use cutting-edge technology and security best practices to ensure protection against unauthorized access, misuse, and data loss.

(i) Security Infrastructure:

Our systems and data backups are hosted on Amazon Web Services, one of the most secure and reliable data centers globally.

(ii) Security Practices:

We implement physical and digital access controls, data encryption, and proactive measures against vulnerabilities and security incidents.

User Responsibility

Users have essential responsibilities for the security and integrity of their accounts and data:

(i) Confidentiality of Access:

Users must maintain the confidentiality of their logins and passwords and not share them with third parties.

(ii) Security of Financial Information:

When providing financial information, users must use the security mechanisms offered by our platform.

(iii) Reporting Violations:

It is crucial for users to inform us immediately of any suspected security violations.

(iv) Verification of Communications:

Users must verify the authenticity of any communication received on behalf of ClickOne before responding or providing information.

(v) Accuracy of Provided Information:

It is the user’s responsibility to provide accurate and up-to-date information.

(vi) Third-Party Data:

Users are responsible for the legality and accuracy of third-party data they provide.

(vii) Updating Personal Data:

Users must keep their personal data updated and inform ClickOne of any changes.

ClickOne reserves the right to suspend or cancel accounts in the case of suspected or actual violation of the terms, taking legal and administrative measures as necessary.

Contact and Incident Reporting

For communication regarding any issues related to our Privacy Policy or in exercising your rights, ClickOne provides the following channels:

Contact Form:

The client’s identity may be verified during the service, so additional data may be requested.

In the case of privacy incidents presenting a risk of harm to the data subjects, we also use the above channels to receive notifications or reports of incidents.

Communications will be processed by our data protection officer, who will analyze the incident and implement the “ClickOne Incident Response Procedure.”

Responsible for the Privacy Program

The person responsible for our Privacy Program is the Data Protection Officer (DPO):

Name: Ygor Rafael

Email: info@clickone.com

The DPO’s responsibilities include:

• Managing and overseeing the Privacy Program.

• Proposing and reviewing the organization’s privacy policies.

• Monitoring compliance with privacy-related policies and procedures.

• Conducting periodic assessments and defining action plans for improving the Privacy Program.

• Communicating with the National Data Protection Authority (ANPD) and data subjects.

• Addressing data subject requests.

• Preparing Reports on Personal Data Protection Impact.

Access to and Correction of Personal Data

Users have the right to access their personal data stored on our platform and request the correction of any incorrect or outdated information. To ensure that personal data is always correct and up-to-date, ClickOne commits to:

• Allowing users to access their own data via their account in the system.

• Correcting personal data at the user’s request, ensuring that inaccurate or incomplete information is promptly updated.

• Providing simple and effective mechanisms for users to exercise their rights to access and correction through our website or customer support.

Transparency in Software Updates

ClickOne is committed to keeping users informed about all software updates that may affect how personal data is processed. This includes:

• Prior notification about significant software updates, especially those impacting data security or user privacy.

• Clear documentation on the changes made in each software update and how these changes may affect users’ data.

• A commitment to maintaining compatibility and security for previous software versions for a reasonable period to allow for a smooth transition to newer versions.

Review of the Terms

ClickOne’s Privacy Policy may be subject to changes. Revisions will be communicated to clients in advance, and the most up-to-date version will always be available on our website. Changes will only be made with the approval of the person responsible for the privacy program.

Jurisdiction

This Privacy Policy is governed by the laws of the Federative Republic of Brazil. Any disputes arising from the relationship between the client and ClickOne will be resolved in the Court of São Paulo, State of São Paulo.