1. Introduction and Glossary The protection of personal data privacy is a fundamental commitment of E-goi to the personal data subject who uses the E-goi Website and E-goi Service. E-goi respects this privacy and is committed to protecting the personal information it collects. This Privacy and Cookies Statement explains how E-goi collects, uses, and shares personal information, and the data subject's rights regarding that information. The Statement is global, meaning it applies to the entire E-goi Service. The main terms used in this document are defined and explained in detail in the Glossary (attached to this agreement). It is advisable to consult it for a better understanding of the concepts and definitions applied here. 2. Data Controller E-goi Lda, headquartered at Avenida Menéres, no. 834, 4450-190 Matosinhos, corporate entity 514727420, is the data controller for the personal data of visitors, subscribers, and Clients on the E-goi Website and E-goi Service regarding its use and acquisition of the Service and the management of their relationship with E-goi. 3. Personal Data Subject The personal data subject is the natural person to whom the data pertains and who uses or has used the E-goi Website and E-goi Service. 4. Information E-goi Collects E-goi collects information in two ways: 4.1 Information provided directly by the visitor or Client Name, email address, phone contact number, and other information provided when creating an account, subscribing to services, participating in surveys, or filling out forms on the E-goi Website. Data related to transactions, such as billing and payment information. 4.2 Information collected automatically Technical details about the device and browser used by the visitor or Client, such as IP address, operating system, language, and browser preferences. Data about interaction with the Service, such as pages visited, time spent, clicks, and other activities. 5. How and Why Information is Used 5.1. Main Purposes To provide the contracted Service, such as marketing automation, multichannel campaigns, and reporting. To improve the Service based on usage patterns and feedback from the visitor or Client. To respond to support requests and communicate information related to the Service. To send marketing communications, when permitted by the visitor or Client. 5.2 Legal Bases for the Data Processing Executed by E-goi Execution of a contract: to provide the contracted Service. Consent: for marketing communications or certain types of processing. Legitimate interest: for security, analysis, and continuous improvement of the Service. 6. Information Sharing E-goi shares information only in the following circumstances: Third-party service providers: E-goi contracts trusted third parties to help provide essential services, such as payment processing, performance analysis, and technical support. Legal obligation: E-goi may disclose information when required by law or necessary to protect E-goi's legal rights. Prior consent: When the visitor or Client explicitly authorizes the sharing of their information. 7. Cookies and Similar Technologies E-goi uses cookies and other technologies to: Improve the functionality of the site and personalize the visitor's or Client's experience. Collect analytical data to understand how the Service is used. Offer relevant advertising based on the visitor's or Client's preferences. The visitor or Client can configure their browser to reject cookies, though this may limit some functionalities of the E-goi Website. 8.1. What are cookies? Cookies are small data files placed on the visitor's or Client's computer or mobile device. They are widely used by online service providers to ensure the functionality of their websites or services or to make them operate more efficiently, as well as to provide statistical information. Cookies set by E-goi are called "first-party cookies." Cookies set by third parties, which are not E-goi, are called "third-party cookies." Third-party cookies enable third-party features or functionalities to operate on the E-goi Website (such as advertising, interactive content, and analytics). The third parties that set these cookies can recognize the visitor's or Client's computer both when visiting the E-goi Website and certain other websites or services. 8.2. Why does E-goi use cookies and other tracking technologies? E-goi uses both first-party and third-party cookies for various reasons. Some cookies are required for technical reasons, to ensure that the E-goi Website and E-goi Service operate (cookies that are "essential" or "strictly necessary"). Other cookies allow E-goi and third parties with whom E-goi collaborates to determine the interests of visitors or Clients and direct them to the E-goi Website ("performance" or "functionality" cookies). For example, E-goi uses cookies to personalize the content and information that might be sent or displayed to the visitor or Client, to customize their experience while interacting with the E-goi Website, and to improve the Service. We also allow E-goi Clients to apply cookies and similar tracking technologies in connection with the use of the Service so that Clients can track their Contacts or visitors. 8.3. Cookies sent through the E-goi Website Both first-party and third-party cookies sent specifically through our E-goi Sites: Necessary: Fundamental cookies to provide the services and features available through the E-goi Website. As they are essential, they cannot be refused without affecting the function of the E-goi Website. The visitor or Client can block or delete them by changing their browser settings. Preferences: With these cookies, the E-goi Website can remember information that changes the behavior or appearance of the E-goi Website and the Service, such as the preferred language of the visitor or Client or the region they are located in. They are important, but not essential for using the E-goi Website. Without them, however, some functionalities might be unavailable. Statistics: Cookies that collect information anonymously are used to help E-goi understand how the E-goi Website is used or how effective E-goi marketing campaigns are, or to help E-goi personalize the E-goi Website and the Service, in order to enhance the experience for the visitor or Client. Marketing: Used to track the visitor or Client through the E-goi Website, so that advertising messages are more relevant to the visitor or Client according to their interests and, thus, more valuable to independent publishers and advertisers. 8.4. Other Tracking Technologies E-goi and E-goi's third-party partners may use other similar technologies from time to time, such as “web beacons,” SDKs, pixels (or "clear GIFs"), link identification, and other tracking technologies (like wifi or Client login). Pixels are small graphic files that contain a unique identifier with which it is possible to recognize the visitor or Client of the E-goi Website or, in the case of “web beacons,” if the visitor or Client opened an email that E-goi sent. Although it is not possible to specifically reject or disable these tracking technologies, they often depend on cookies to function correctly. Therefore, refusing cookies will impair the functionality of these technologies. 8.5. How to Control Cookies? The Visitor or Client has the right to choose whether to accept or refuse cookies. E-goi Website Cookie Preferences Tool: the visitor or Client can set their cookie preferences on the E-goi Website through the cookie settings preference center, available on any page of the E-goi Website. Browser: the visitor or Client can set or change their browser to accept or refuse cookies. If they choose to refuse cookies, they can still use the E-goi Website, but their access to some features and areas will be more limited. Interest-Based Advertising Opt-out: most advertising networks provide a way to opt-out of interest-based advertising. Mobile Advertising: to opt-out of certain mobile advertising identifiers used for certain types of interest-based advertising, including those performed by E-goi, the visitor or Client should set the appropriate settings on their Apple or Android mobile device. If they choose to opt-out, all data about the visitor or Client will be removed. Do Not Track: some internet browsers, like Edge, Firefox, and Safari, have the ability to transmit "Do Not Track" or "DNT" signals. As uniform standards for "DNT" signals have not been adopted, the E-goi Website does not currently process or respond to "DNT" signals. E-goi prioritizes privacy and choice freedom and is committed to continuing to monitor the DNT topic and the implementation of a standard. 9. Data Retention E-goi retains the information of the visitor or Client for the necessary time for the purposes for which they are processed. The period for which information is kept depends on the purposes for which it was collected and used, and the choices of the visitor or Client, after which E-goi may delete and/or aggregate. E-goi may also retain and use this information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements. After this period, the data will be deleted or anonymized, unless E-goi is legally required to keep it longer. In the Data Processing Agreement (attached to this Agreement) specific retention periods for certain types of information are indicated. The retention of personal data may be canceled if the visitor or Client exercises their right of opposition, right to be forgotten, or revokes their consent. However, all legal and contractual obligations defining these acts will always be observed. 10. Security E-goi applies appropriate technical and organizational measures to protect the personal data of the visitor or Client against unauthorized access, misuse, loss, or alteration. Data is collected encrypted and managed securely in a data center located in Portugal, in the European Union, according to the E-goi Security Policy (attached to this Agreement). 11. International Data Transfer The storage and data processing servers of E-goi are located in Portugal, within the European Economic Area (EEA). E-goi does not store any data outside the EEA. Therefore, the information of the visitor or Client will not be transferred or processed by E-goi outside the EEA and will always be handled securely and in accordance with this Privacy Statement, as well as the Data Processing Agreement (attached to this Agreement) and applicable data protection laws. If, by any reason or exceptional situation, E-goi transfers this information outside the EEA, E-goi will ensure that adequate safeguards are implemented to protect the visitor's or Client's data, such as the use of standard contractual clauses or other appropriate legal measures. 12. Rights of the Visitor or Client The Visitor or Client has the following rights regarding their personal data: Right of access: Request a copy of the personal data that E-goi holds and obtain from the data controller confirmation as to whether or not personal data concerning them is being processed and, if so, the right to access their personal data and the following information: The purposes of data processing; The categories of data in question. The recipients or categories of recipients to whom the personal data has been or will be disclosed, specifically recipients established in third countries. Right to rectification: Update incorrect or incomplete information. The visitor, Client, or Client's Contact can also access and edit their data directly and autonomously via the data editing link available in each marketing message sent by E-goi or the Client through E-goi; Right to erasure (or right to be forgotten): Request the deletion of their personal data, except in situations where retention is required by law. The visitor, Client, or Contact should request total removal of their data by sending an email to privacy@e-goi.com with their identification and removal request. Right to object: Object to processing based on legitimate interests. The visitor, Client, or Client's Contact can also object or limit directly and autonomously via the removal link available in each marketing message sent by E-goi or the Client through E-goi; Note that each message contains the option to limit/oppose through the “remove” link; Right to restrict processing: Restrict how data is processed, especially in situations where the accuracy or necessity of data processing is questioned. Right to data portability: Request the transfer of their data to another organization. To exercise these rights, the visitor or Client can contact E-goi through the means available in the "Contact" clause of this Statement. 13. Exclusions This Privacy and Cookies Statement does not apply to certain processing activities where E-goi is not the Data Controller. When E-goi acts as a Processor or service provider, the Data Processing Agreement (attached to this Agreement) applies instead of this Statement. If there are any questions about personal information E-goi processes on behalf of a specific Client or if it is necessary to exercise privacy rights related to that personal information, the Client should be contacted directly. 14. Data Protection Officer E-goi has a Data Protection Officer (DPO), who provides information and advises on matters related to processing, cooperating with the CNPD (National Data Protection Commission). The Data Protection Officer of E-goi can be contacted via email at dpo@e-goi.com. 15. Disclaimer E-goi cannot be held liable for any damages or losses under civil liability (including, but not limited to, consequential damages, lost profits, and moral damages, whether caused directly or indirectly) arising from the use, correct or incorrect, of the Service, E-goi Website, and respective contents by the visitor or Client, including unauthorized access to the visitor's or Client's computer and computer system by third parties. The information disclosed should be considered in its informative aspect. 16. Changes to this Statement E-goi may periodically update this Privacy and Cookies Statement to reflect changes in E-goi's Service or legislation. Changes will be published on the E-goi Website. The visitor or Client is encouraged to regularly review this page. 17. Applicable Law and Jurisdiction This Privacy and Cookies Statement is governed and interpreted in accordance with Portuguese law. The court of Matosinhos area shall have exclusive jurisdiction over any conflicts arising from the interpretation and application of this Statement. 18. Contact For questions or inquiries about this Policy, the visitor or Client can contact E-goi through: "Contact us" section at the E-goi web site E-goi platform Help widget email: privacy@e-goi.com