Privacy Policy - Anestcopilot

Data Privacy and Security | AnestCopilot

We collect personal information that you voluntarily provide when you register on the Services, show interest in obtaining information about us or our products and services, when you participate in activities on the Services or when you contact us.

What information do we collect?

Personal information provided by you

> In summary: We collect personal information that you voluntarily provide to us.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names;

email addresses;

job profile;

company name;

usernames;

phone numbers.

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with it. All payment data is stored by Stripe. You can access their privacy policy at this link.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected automatically

> In summary: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (such as your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, as well as for our internal analytics and reporting purposes.

Like many companies, we also collect information through cookies and similar technologies. You can get more information about this in our Cookies Notice in the menu above Cookies Policies.

The information we collect includes:

Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity on the Services (such as timestamps associated with your usage, pages and files viewed, searches and other actions you take, like which features you use), device event information (such as system activity, error reports - sometimes called "crash dumps" - and hardware settings).

Device Data. We collect device data, such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data, such as information about your device’s location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information by refusing access to the information or by disabling the Location setting on your device. However, if you choose not to allow it, you may not be able to use certain aspects of the Services.

AnestCopilot is not intended to collect or process protected health information (PHI) under HIPAA.

Use of the service to process PHI requires a prior Business Associate Agreement (BAA). The user is responsible for not entering PHI on the platform outside an authorized environment.

How do we process your information?

> In summary: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

Facilitate account creation and authentication and manage user accounts. We may process your information to allow you to create and log in to your account, as well as keep your account access in full working order;

Deliver and facilitate delivery of services to the user. We may process your information to provide the requested service;

Respond to user inquiries/provide support to users. We may process your information to respond to your inquiries and resolve any potential issues you might have with the requested service;

Send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information;

Request feedback. We may process your information when necessary to request feedback and contact you about your use of our Services;

Send marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You may unsubscribe from our marketing emails at any time;

Deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and other criteria. For more information, see our Cookies Notice in the menu above Cookies Policies;

Protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including monitoring and preventing fraud;

Identify usage trends. We may process information about how you use our Services to better understand how they are being used, so that we can improve them;

Determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are more relevant to you;

Save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm;

Fulfill legal obligations and other regulatory obligations.

When necessary for the performance of a contract or pre-contractual procedures related to a contract in which the data subject is a party.

User interactions (prompts, questions, usage history) may also be recorded in an anonymized and aggregated manner for the purposes of: (i) security and audit; (ii) continuous improvement of AI models.

What legal bases do we rely on to process your information?

> In summary: We process your personal information only when we believe it is necessary and we have a valid legal basis to do so in accordance with applicable law, such as your consent, to comply with laws, provide services to you, enter into or fulfill our contractual obligations, protect your rights, or meet our legitimate business interests.

If you are located in the European Union or the United Kingdom, this section also applies to you.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

> Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about how to withdraw your consent.

> Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

> Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, provided that those interests do not override your interests and fundamental rights. For example, we may process your personal information for some of the purposes described below, in order to:

> > Send users information about special offers and discounts on our products and services;

> > Develop and display personalized and relevant advertising content for our users;

> > Analyze how our Services are used to improve them and to engage and retain users;

> > Support our marketing activities;

> > Diagnose problems and/or prevent fraudulent activities;

> > Understand how our users use our products and services to improve the user experience;

Legal Obligations. We may process your information when we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information when we believe it is necessary to protect your vital interests or the vital interests of third parties, such as in situations that involve potential threats to the safety of any person.

If you are located in Canada, this section also applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose or in situations where your consent can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted, under applicable law, to process your information without your consent, including, for example:

If the collection is clearly in the interests of an individual and consent cannot be obtained in a timely manner;

For investigations and detection and prevention of fraud;

For business transactions, provided certain conditions are met;

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;

To identify injured, ill, or deceased persons and communicate with next of kin;

If we have reasonable grounds to believe that an individual has been, is, or may be a victim of financial abuse;

If it is reasonable to expect that collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;

If disclosure is required to comply with a subpoena, warrant, court order, or court rules relating to the production of records;

If it was produced by an individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced;

If the collection is solely for journalistic, artistic, or literary purposes;

If the information is publicly available and specified in the regulations.

If you are located in Brazil, this section also applies to you.

The "Lei Geral de Proteção de Dados" (LGPD) requires us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about how to withdraw your consent.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, provided that those interests do not override your interests and fundamental rights. For example, we may process your personal information for some of the purposes described below, in order to:

> > Send users information about special offers and discounts on our products and services;

> > Develop and display personalized and relevant advertising content for our users;

> > Analyze how our Services are used to improve them and to engage and retain users;

> > Support our marketing activities;

> > Diagnose problems and/or prevent fraudulent activities;

> > Understand how our users use our products and services to improve the user experience;

When and with whom do we share your personal information?

> In summary: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Do we use cookies and other tracking technologies?

> In summary: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is described in the menu above Cookies Policies.

Is your information transferred internationally?

> In summary: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us at our facilities and by third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in Brazil and in other countries that are in compliance with general principles related to data protection.

If you are a resident in the European Economic Area (EEA), in non-EU countries, or in the United Kingdom (UK), then these countries may not have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission Standard Contractual Clauses:

We have implemented measures to protect your personal information, including the use of the European Commission’s Standard Contractual Clauses (SCCs) for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information they process that originates from the EEA or the UK in accordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers and partners, and further details can be provided upon request.

How long will we keep your information?

> In summary: We will keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless a longer retention period is required by law.

We will keep your personal information only for as long as is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal obligations). No purpose in this notice will require us to keep your personal information for longer than twelve (12) months after the termination of the user’s account.

When we no longer have an ongoing legitimate business need to process your personal information, we will delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How will we keep your information safe?

> In summary: We seek to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to circumvent our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should access the Services only within a secure environment.

Do we collect information from minors?

> In summary: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to the minor’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have collected from children under age 18, please contact us at contato@anestcopilot.com.br

AnestCopilot is not intended for minors under 18 and does not knowingly collect data from children under 13, in compliance with the US Children’s Online Privacy Protection Act (COPPA).

What are your privacy rights

> In summary: In some regions, such as the European Union (EU), United Kingdom (UK), Canada, and Brazil, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (such as the EU, UK, Canada, and Brazil), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or deletion, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EU or UK and I believe that we are processing your personal information unlawfully, you also have the right to complain to your Member State data protection authority or to the UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

If you are located in Brazil, you may contact the ANPD.

In any circumstance, you can always contact our DPO, and AnestCopilot will respond to data subject requests within 30 days (GDPR/LGPD) or 45 days (CCPA/CDPA): contato@anestcopilot.com.br.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied, depending on applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or by updating your preferences.

However, please note that this will not affect the lawfulness of the processing before the withdrawal of consent, nor, where permitted by applicable law, will it affect the processing of your personal information conducted on the basis of legal processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, sending an email to support to unsubscribe, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send service-related messages that are necessary for the administration and use of your account, respond to service requests, or for other non-marketing purposes.

Account information:

If you would like to review or change the information in your account or terminate your account, you can:

> Log in to your user account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For more information, see our Cookies Notice in the menu above Cookies Policies.

If you have questions or comments about your privacy rights, you may email us at contato@anestcopilot.com.br

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. Therefore, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Do California residents have specific privacy rights?

> In summary: Yes, if you are a California resident, you have specific rights regarding access to your personal information.

Section 1798.83 of the California Civil Code, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please send your request to us in writing using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the Services, but be aware that the data may not be completely or comprehensively removed from all our systems (for example, backups, etc.).

CCPA Privacy Notice (California Consumer Privacy Act)

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose, and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as "non-residents".

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

Identifiers. We collect information that identifies you when you provide it to us, such as: Contact details, such as real name, alias, postal address, telephone or mobile number, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, and account name.

Categories of personal information listed in the California Customer Records statute. We collect information set out in the California Customer Records statute that you provide to us, such as: Name, contact information, education, employment, employment history, and financial information.

Protected classification characteristics under California or federal law. We do not collect classification characteristics such as: Gender and date of birth.

Commercial information. We do not collect or store commercial information, such as: Transaction information, purchase history, financial details, and payment information.

Biometric information. We do not collect or store biometric information, such as: Fingerprints and voiceprints.

Internet or other similar network activity. We do not collect or store internet or network activity, such as: Browsing history, search history, online behavior, interest data, and interactions with our websites, applications, systems, and advertisements or from other websites and applications.

Geolocation data. We collect geolocation information that you provide to us, such as: Device location.

Audio, electronic, visual, thermal, olfactory, or similar information. We do not collect or store audio, electronic, visual, thermal, olfactory, or similar information, such as: Images and audio, video, or call recordings created in connection with our business activities.

Professional or employment-related information. We collect professional or employment-related information that you provide to us, such as: Business contact details to provide our services at a business level, job title, work history, and professional qualifications, if you apply for a job with us.

Education information. We do not collect or store education information, such as: Student records and directory information.

Inferences drawn from other personal information. We do not collect or store inferences drawn from other personal information, such as: Inferences drawn from any of the personal information collected above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Sensitive personal information. We do not collect or store any type of sensitive personal information.

We may also collect other personal information outside of these categories through situations in which you interact with us in person, online, by phone, or by mail, in the context of:

Receiving help through our customer support channels;

Participating in customer surveys or contests; and

Facilitating the delivery of our Services and responding to your questions.

How do we use and share your personal information?

How do we use and share your personal information? More information about our data collection and sharing practices can be found in this privacy notice and in our Cookies Notice in the menu above Cookies Policies.

You may contact us by email at contato@anestcopilot.com.br or review the contact details at the end of this document.

If you are using an authorized agent to exercise your right to deletion, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes information on our behalf, following the same strict privacy protection obligations set out by the CCPA.

We may use your personal information for our own business purposes, such as for internal research for technological development and demonstration. This is not considered a "sale" of your personal information.

In the last twelve (12) months, we have not disclosed, sold, or shared any personal information to third parties for business purposes. We will not sell or share personal information belonging to website visitors, users, and other consumers in the future.

Your rights regarding your personal data

Right to request deletion of data - Deletion request

You can request the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) another consumer’s exercise of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be necessary to protect against illegal activities.

Right to be informed - Knowledge request

Depending on the circumstances, you have the right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information with third parties;

the categories of personal information that were sold, shared, or disclosed for a business purpose;

the categories of third parties to whom personal information was sold, shared, or disclosed for a business purpose;

the business purpose for collecting, selling, or sharing personal information; and the specific personal information that we collected about you.

Under applicable law, we are not required to provide or delete consumer information that has been de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to non-discrimination for the exercise of consumer privacy rights

We will not discriminate against you if you exercise your privacy rights.

Right to limit the use and disclosure of sensitive personal information

We do not process consumers’ sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine whether you are the same person about whom we have information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided to us. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can match it with information we already have on file, or we may contact you through a method of communication (for example, phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances require.

We will only use the personal information provided in your request to verify your identity or authority to make the request. Whenever possible, we will avoid requesting additional information for verification purposes. However, if we cannot verify your identity from the information already maintained by us, we may ask you to provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information;

You may request correction of your personal data if it is inaccurate or no longer relevant, or request restriction of the processing of information;

You may designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA;

You may request to opt out of future sales or sharing of your personal information to third parties. Upon receiving an opt-out request, we will comply with the request as soon as possible but no later than fifteen (15) days from the date of submission of the request.

To exercise these rights, you can contact us by email at contato@anestcopilot.com.br or review the contact details at the end of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Do Virginia residents have specific privacy rights?

> In summary: Yes, if you are a Virginia resident, you may have specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the State acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition of "consumer" applies to you, we must comply with certain rights and obligations related to your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with us and our services. For more information, please visit the following links:

Personal data we collect;

How we use your personal data;

When and with whom we share your personal data;

Your rights regarding your personal data

Right to be informed whether we are processing your personal data;

Right to access your personal data;

Right to correct inaccuracies in your personal data;

Right to request deletion of your personal data;

Right to obtain a copy of the personal data you previously shared with us;

Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (profiling).

We do not sell any personal data to third parties for commercial or business purposes. We will not sell personal data belonging to website visitors, users, and other consumers in the future.

Exercise your rights as provided by the Virginia CDPA.

More information about our data collection and sharing practices can be found in this privacy notice and in our Cookies Notice in the menu above Cookies Policies. You may contact us by email at contato@anestcopilot.com.br or by reviewing the details at the end of this document.

You may contact us by email at contato@anestcopilot.com.br or by reviewing the details at the end of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may ask you to provide additional information reasonably necessary to verify you and your request as a consumer. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receipt of your request, we will respond without undue delay, but in all cases within forty-five (45) days of receipt. The response period may be extended once by an additional forty-five (45) days when reasonably necessary. We will inform you of any extension within the initial 45-day response period, along with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and the reasons behind it. If you would like to appeal our decision, please email contato@anestcopilot.com.br. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

What if there is a security incident?

AnestCopilot adopts technical and organizational measures aligned with internationally recognized standards, including:

– data encryption in transit (TLS) and at rest (AES-256);

– role-based access control (RBAC) and multi-factor authentication;

– continuous monitoring and regular vulnerability testing;

– secure backup policies and disaster recovery.

(b) Despite such measures, no electronic transmission or storage is fully immune to risks.

(c) In the event of a security incident (Data Breach) that may affect personal data or sensitive information, AnestCopilot will notify:

– the competent data protection authority (e.g., ANPD, EU authorities, FTC in the US) within the applicable legal timeframe;

– the affected data subjects, indicating the nature of the incident, the compromised data, and the corrective measures taken.

(d) AnestCopilot will maintain internal incident records and cooperate with the competent authorities.

Do we make updates to this notice?

> In summary: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Review" date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by sending you a direct notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at contato@anestcopilot.com.br or contact us by post at the address:

Anestcopilit Ltda — Rua Rio Grande do Norte, 1435 Sala 708, Pavimento 7, Savassi, Belo Horizonte/MG CEP 30130-138

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, send an Email to contato@anestcopilot.com.br

This Policy was drafted in September 2025, the terms of which all Users declare to accept, and it may be changed at any time.