Brazil LGPD Privacy Addendum

1. Scope

This addendum applies to users in Brazil where the Lei Geral de Proteção de Dados (LGPD) applies.

2. Controller

Controller: Subjective Technologies™ (trade name and technology stack operating WorkTwins™ and related services) DPO / Encarregado: [email protected] Contact: [email protected]

3. Purposes

WorkTwins processes personal data for:

• account access;
• WorkFootPrint creation;
• compatibility matching;
• collaboration;
• chat;
• service security;
• support;
• billing;
• legal compliance.

4. Legal Bases

Depending on feature, processing may rely on:

• consent;
• contract;
• legitimate interests;
• legal obligation;
• exercise of rights in legal proceedings;
• other lawful basis reviewed by counsel.

5. Data Subject Rights

Brazil users may have rights to:

• confirmation of processing;
• access;
• correction;
• anonymization, blocking, or deletion of unnecessary/excessive data;
• portability where regulated;
• deletion of consent-based data;
• information about sharing;
• withdrawal of consent;
• review of certain automated decisions where applicable.

6. Sensitive Data

WorkTwins is designed to avoid sensitive non-work data and exclude non-work activity from WorkFootPrints.

7. International Transfers

Transfers outside Brazil must be supported by appropriate mechanisms where required.

8. Contact

Privacy contact: [email protected]