To facilitate understanding, we divided the Policy as follows:

PRIVACY POLICY

1. What types of data does Asksuite collect?

1.1. Site visitor

1.2. Asksuite client collaborators

1.3. Asksuite client consumers

2. How do we use Cookies?

2.1. What are cookies?

2.2. Why do we use cookies?

2.3. Table of Cookies Used

3. With whom does Asksuite share your data?

4. What are the rights of the data holders?

5. How long will the data be stored?

6. How does Information Security work at Asksuite?

7. International Transfers

8. How to contact Asksuite

9. Policy Updates

1. What types of data does Asksuite collect?

The amount and type of information collected by Asksuite varies depending on the Client or the Consumer’s use of our Platform. Most purposes for using the personal data collected by the chatbot are under the responsibility of our Clients, who qualify as personal data “controllers”. That is, in general, we carry out the data processing on behalf of the Clients and meet the purposes that they define.

1.1 Site visitor

If you are a visitor to our website, we will use your personal data as follows:

1.2. Asksuite Client Collaborators

If you are an Asksuite Client Collaborator who uses our Platform – for example, employee of a hotel or resort – we will use your personal data as shown below:

1.3. Asksuite Client Consumer

If you are a Consumer of an Asksuite Client (e.g. a hotel guest), your personal data can be directly accessed on the Platform by the Client and their Employees.

However, it is important to specify that Asksuite does not control the form and purpose of using much of the information collected by the Clients through our Platform. Such data belongs to Asksuite Clients who use, disclose, and protect in accordance with their respective privacy policies. In some cases, we may use the data collected for Asksuite’s own purposes, as in the case of developing new products and services, as highlighted in the table below. In these instances, we assume the role of data controller.

We recommend that the Consumers carefully read the privacy policy of the Client to which they are linked. In addition, if you have any questions about how your personal data will be handled, we recommend that you contact the Client who is offering the services to you.

In general, our Platform is used for the following purposes:

2. How do we use Cookies?

2.1 What are cookies?

Cookies are small text files stored on your browser or device. Cookies allow us to collect certain personal data about you. It is through a cookie, for example, that we identify you as a unique user when you make subsequent visits to our Platform, even after you close your browser.

Cookies generally have an expiration date. Some cookies are automatically deleted when you close the browser (so-called session cookies), while others can be stored on the device for a longer time until they are manually deleted (so-called persistent cookies).

2.2 Why do we use cookies?

Asksuite uses the following types of cookies on its Platform and website:

(i) strictly necessary cookies, so that our Platform works correctly, identifying your language, for example. Therefore, it is not possible to refuse these cookies if you want to visit our Platform.

(ii) preference cookies, so that our Platform can remember preferred information related to the user, in view of improving the browsing experience, such as the region of those who are accessing the Platform.

(iii) analysis cookies, to enhance our Platform and your user experience, allowing us to develop new products and services. These cookies automatically collect certain personal data to provide us with information about how our Platform is being used, identifying, for example, how many times a particular page has been visited.

(iv) social media cookies, to enable plugins from certain social networks when you choose to access our Platform through these networks. These plugins use cookies and other technologies to provide analytics and recognize you on these social networks to connect with our services.

(v) marketing cookies, so that we can provide you with the best offers of products and services, according to your interests.

The use of cookies is based on Asksuite’s legitimate interest. Thus, if you wish to refuse the installation of these cookies on your device and / or choose to remove cookies, you can do so by configuring your browser. You will find further explanations on how to proceed by clicking

on the links below. To find information related to other browsers, visit the browser’s developer website.

Firefox

Chrome

Safari

Internet Explorer

It is important to clarify that Asksuite is not responsible for the use of cookies by third parties. Be aware that cookies placed by third parties may eventually continue to monitor your online activities even after you have left our Platform. It is recommended that you clear your browsing data regularly.

2.3 Table of Cookies Used

3. With whom does Asksuite share your data?

Asksuite will be able to operate in conjunction with other companies in a wide range of activities, including hosting, data storage, analytics, among others. Accordingly, we reserve the right to share your information, including personal data, as indicated below. Whenever possible, we will adopt mechanisms for the anonymization and pseudonymization of this data and retain strict clauses in our contracts, aiming to preserve your privacy to the fullest.

Thus, we may share your personal data in the following cases:

Our Suppliers: We hire several suppliers to operate our Platform and offer our services, some of which handle the personal data collected on behalf of the Client. For example, we use hosting services, data storage, and hire analytics services to analyze the use of our Platform. We strive to protect the privacy of your personal data, but unfortunately, we cannot guarantee the correct handling of personal data by third parties, who use, disclose, and protect in accordance with their respective privacy policies.

Our Clients: For the correct development of the Platform and Client service, we may share the information collected by our chatbot with the Client who is linked to you.

Integration with other platforms: Asksuite offers integration services among software through APIs (Application Programming Interface), as contracted by our Client. Thus, we can integrate the information collected by our chatbot with third-party platforms, as in the case of CRM services (client relationship management) or online sales platforms (e.g. making room reservations).

To safeguard and protect the rights of Asksuite: Asksuite reserves the right to access, read, preserve and provide any data and information about you, including your interactions, if necessary, to comply with a legal obligation or court order; to enforce or apply our Contracts and other agreements and / or contracts; or protect the rights, property or safety of Asksuite, as well as our employees and / or other users. For example, we may share certain information with the Public Prosecutor’s office and / or the Civil Police when requested by these bodies, only to the extent expressly requested.

4. What are the rights of the data holders?

You can always choose not to disclose your personal data to us; however, this data may be necessary to take advantage of some resources made available on our Platform. Regardless, you will always have rights regarding the privacy and protection of your personal data. In this case, we recommend that you, as a Consumer, directly contact the hotel, resort, inn that is offering the service to you. If you are a hotel, resort, or inn employee, it is also recommended that you directly contact your employer if you want to exercise your rights as a holder.

Accordingly, explanations and examples of these rights are briefly outlined below:

_{Request for access to your personal data.} This right allows you to request and receive a

copy of your personal data that Clients have

about you.

Request for rectification of your personal data.

Request to delete or cancel your personal data.

Right to object personal data processing.

Request portability.

Right to withdraw consent at any time.

Right to review automated decisions.

This right allows you, at any time, to request the correction and / or rectification of your personal data from Clients in case you identify that it is incorrect. However, for this correction to take effect, it may be necessary to check the validity of the data you provide to us.

This right allows you to request the deletion of your personal data from Clients, unless there is any other reason for its maintenance, such as any legal obligation to retain data or the need to preserve it to protect rights.

This right allows you to challenge where and in what context the Client handles your personal data for different purposes. In certain situations, the Client can demonstrate that they have legitimate reasons to handle your data, which override your rights, if, for example, they are strictly essential for the functionality of the Platform.

This right allows you to ask the Client to have your personal data delivered to you, or to third parties of your choice, in a structured and interoperable format.

This right allows you to withdraw your consent, however, this will not affect the legality of any processing carried out before you withdraw your consent. If you withdraw your consent, certain services may be stopped. If that is the case, we will notify you.

This right allows you to ask the Client to review decisions made solely based on automated processing of your personal data that affects your interests.

We may need to ask you or the Client for specific information to help us confirm your identity and ensure your right to access your personal data (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We may also contact the Client for more information regarding their request to expedite our response.

If you have any questions about these issues and how you can exercise these rights, we recommend that you contact the Client with whom you will be linked.

5. How long will the data be stored?

We will keep your personal data only as long as necessary to fulfill the purposes for which we collect it, including compliance with any legal, contractual, accountability or request from competent authorities.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of personal data, the potential risk of damage from unauthorized use or disclosure of your personal data, the purpose of processing your data and whether we can achieve these purposes through other means, as well as the applicable legal requirements. In general, data is processed for the duration of the contract with our Clients.

After concluding all purposes that justified your data processing on our Platform, this data will be eliminated, observing the technical means available. Additionally, we may continue to

process personal data if we have an adequate legal basis, especially to legally protect Asksuite.

6. How does Information Security work at Asksuite?

Asksuite takes technical and administrative measures to protect your personal data from loss, unauthorized use, or other abuse. The data is stored in a secure operating environment that is not accessible to the public.

To guarantee the security of your personal data in our services, we have adopted the best information security practices available, including:

▪ Asksuite uses the HTTPS protocol to traffic personal data via the internet;

▪ Asksuite uses standard and market methods for the security of your collected data, such as managing and controlling access to the database and encrypting passwords;

▪ Asksuite has protection against unauthorized access to its systems; and

● The adoption of preventive procedures against information security incidents.

We strive to protect the privacy of your account and other personal data that we maintain in our records, but unfortunately, we cannot guarantee complete security. Unauthorized account entry or use, hardware or software failure and other factors can compromise the security of your personal data at any time, so please help us maintain a safe environment for everyone. In addition to adopting good security practices in relation to your account and your data, if you identify or become aware of something that compromises the security of your data, please contact us.

7. International Transfers

The data we collect is stored on Amazon Web Services servers located in the United States.

By accessing or using our Platform, or providing your personal data, you consent to the processing and transfer to Asksuite. This data may be subject to local legislation and relevant rules.

8. How to contact Asksuite

If you have any other questions about how we use your data, comments or suggestions related to this Policy, or, you believe that your personal data was used in a manner incompatible with this Privacy Policy or with your choices as this personal data holder, you can contact our team via e-mail: privacy@asksuite.com

9. Policy Updates

As we continually strive to improve our Platform, this Policy may undergo updates, aiming to provide you with more security, convenience, and an enhanced user experience. Hence, we recommend that you access our Policy periodically, so that you are aware of any changes. For your convenience, we indicate the date of the last update at the end of the document. If

relevant changes are made that require new authorizations, we will publish this update and contact you for a new consent.

Last Update: November 10, 2020