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These terms and conditions of use ("Terms of Use") are intended to regulate operations carried out through any of the virtual channels ("Virtual Channels") made available to the general public by LINGOPASS CURSOS ON LINE LTDA. - ("LINGOPASS"), a limited liability company, registered with CNPJ/MF No. 42.567.596/0001-56, with address at Rua Fernão Dias, n. 106, conj. 07, bairro Pinheiros, São Paulo, SP, CEP 05427-010, with the purpose of enabling the trade of licenses, using a virtual platform.

Please read the following terms and conditions of use ("Terms of Use") carefully, as these provisions are supported by Law 8.078/1990 (Consumer Protection Code), Decree 7.962/2013 (""E-commerce Law""), Law 12.965/2014 (Civil Rights Framework for the Internet) and Law 13. 709/2018 (General Personal Data Protection Law - LGPD), will establish the rules for accessing and using the Virtual Channels, as well as the information and conditions applicable to commercial transactions, services and products ("Virtual Platform Licenses") made available through them to users in general.

To facilitate analysis of the Terms of Use, we present below a summary of their respective topics.

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1. CONDICIONES GENERALES APLICABLES A TODOS LOS USUARIOS DE LOS CANALES VIRTUALES LINGOPASS

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1. GENERAL CONDITIONS APPLICABLE TO ALL USERS OF LINGOPASS VIRTUAL CHANNELS

1.1 Access licenses to the LINGOPASS platform

LINGOPASS provides access keys (licenses) using a virtual platform containing various contents, interaction channels, resources and functionalities.

Through its Virtual Channels, LINGOPASS provides detailed information on the characteristics of the virtual platform or software used - including its resources and functionalities - as well as the respective prices and payment methods for the licenses purchased.

Any promotional values, such as discounts on the value of the licenses, will be informed in advance on the Virtual Channels and applied during the contracting process.

Please read all the information carefully before purchasing any licenses to ensure that our services fully meet your expectations. If you have any questions, LINGOPASS is at your disposal at contato@lingopass.com.br.

LINGOPASS reserves the right to change the modalities, characteristics, prices and payment methods of its licenses at any time, subject to the terms and conditions previously contracted.

1.2 Registration

To start using our services, the user must complete an online registration form, providing their full name, CPF (Individual Taxpayer Registration Number), full address, telephone number and e-mail address, as well as creating a password for their personal account for future access to each access key to the virtual platform they have contracted.

The user will be entirely responsible for the veracity of the data entered by him/her when filling in his/her registration form, and the e-mail address provided will be officially used by LINGOPASS to forward all information and notices regarding the contracted license, which is why any subsequent change must be immediately communicated by the user, under penalty of the information passed on to the e-mail address originally provided being presumed to have been duly received by him/her.

The user is solely responsible for their login and password in their personal account with LINGOPASS, and is liable for all acts carried out through their access account. It is therefore the user's duty to ensure the safekeeping and confidentiality of their password and not to provide it to third parties, thus avoiding potential problems. The user must immediately notify LINGOPASS by e-mail at sucessodoaluno@lingopass.com.br of any unauthorized use of their access account, as well as any breach of security or abnormality in the use of the system.

Minors under the age of 18 must register exclusively through their legal guardians, who are responsible for the veracity and sharing of the minors' information with LINGOPASS.

1.3 Acceptance of the Terms of Use

After registering, the user must read and expressly accept (by clicking on ""I have read and accepted"" in the process of purchasing the Site and/or accessing the virtual platform) the full content of the Terms of Use. Once accepted by the user, the Terms of Use will become binding and enforceable for both parties and will govern the relationship between them.

1.4 Prohibition of sharing and unauthorized reproduction of educational content

The didactic content made available on the virtual platform must only be used by the contracting user, and it is forbidden to share it with third parties or any form of reproduction not expressly and previously authorized in writing by LINGOPASS.

1.5 Performance

LINGOPASS does not guarantee the achievement of objectives or goals by the user, depending exclusively on their performance, commitment and personal ability to make use of the service, and LINGOPASS only undertakes to deliver its services under the exact terms and conditions agreed between the parties.

1.6 Recording and monitoring communication with LINGOPASS

All communications between LINGOPASS and the user, including telephone conversations, e-mails, WhatsApp messages (or similar), video conferences, etc., may be monitored and recorded by the company for security, quality assurance, legal or training purposes.

1.7 Use of material produced by the user during interactions on the platform

LINGOPASS encourages the production of materials and content by the user on the platform, reserving the right to use them at a later date, which is expressly authorized by the user free of charge.

1.8 Infrastructure required to access the Lingopass platform

The educational content made available online will require the User (or the entity to which he/she is linked) to provide access to the Internet via his/her own equipment, under his/her sole responsibility, by hiring a provider and other suppliers necessary for this purpose.

Some of the services or tools made available on the platform, especially in the case of online video, 3D video immersion experiences, among others, may require the installation of third-party software, and the User (or the entity to which they are linked) undertakes to do so on their own, without this constituting, under any circumstances, cause for cancellation or termination of the Terms of Use.

1.9 Problems accessing the Lingopass platform

In the event of problems accessing the Lingopass platform, the user should contact sucessodoaluno@lingopass.com.br to report the occurrence. Once contacted, LINGOPASS will check whether the request has been made and, if so, will take the appropriate measures to resolve the problem, including, if necessary, contacting the user during business hours (from 8 a.m. to 6 p.m.), from Monday to Friday on working days.

Problems in accessing the platform are not considered to be any interruptions resulting from preventive maintenance of the software, or any occurrence beyond the control and diligence of LINGOPASS, such as, but not limited to, the lack of power provided by the electricity utility, failures caused by the providers of access to the world wide web, events of force majeure and acts of God, among others.

The technical support provided by LINGOPASS is restricted to the operational issues of its platform, exclusively in the environment of its platforms, and does not cover problems related to the equipment and devices used by the user, nor any kind of residential assistance.

LINGOPASS cannot be held responsible for the following:
a. Equipment infected or invaded by hackers;
b. Equipment malfunctioning at the time of service consumption;
c. Computer protection;
d. Protection of information based on users' computers;
e. Abuse of users' computers;
f. Clandestine monitoring of users' computers;
g. Vulnerabilities or instabilities in users' systems;
h. Insecure perimeter;

i. Personal data breach incidents;
j. Fines or sanctions imposed by the National Data Protection Authority;
k. Legal actions resulting from incidents involving personal data.

Under no circumstances will LINGOPASS be responsible for the installation of malicious code (viruses, trojans, malware, worm, bot, backdoor, spyware, rootkit, or any other that may be created) on the user's or third party's equipment as a result of the user's browsing the Internet.

1.10 Intellectual property

By granting access to the Lingopass platform, or to any functionality available on its platform, LINGOPASS does not assign to the user any property rights over components, creations, computer programs (and their respective source code, descriptive memorial, internal functional specifications, diagrams, flowcharts), images, drawings, or any other item available on its Virtual Channels, with the exception of the right to access the contracted resources and functionalities, under the terms, conditions and limits established at the time of contracting.

1.11 User responsibilities

The login and password can only be used by the registered user. The user undertakes to maintain the secrecy of the password, which is personal and non-transferable, and it is not possible, under any circumstances, to allege improper use once it has been shared.

The user of the platform is responsible for updating their personal information and the consequences of omitting or making errors in the personal information registered.

The user is responsible for repairing any and all damages, direct or indirect (including those arising from the violation of any rights of other users, third parties, including intellectual property rights, confidentiality and personality rights), that are caused to LINGOPASS, any other user, or any third party, including as a result of non-compliance with the provisions of these Terms of Use and Privacy Policy or any act practiced from their access to the Internet and the website https://www.lingopass.com.br/.

2. CONDITIONS APPLICABLE TO INDIVIDUAL USERS PURCHASING LICENSES TO ACCESS THE LINGOPASS PLATFORM

2.1 Payment and confirmation of purchase

After registering and expressly accepting the Terms of Use, the user may make payment by bank slip or credit card by registering their details on the Mundipagg online payment management platform (http://www.mundipagg.com.br) made available during the contracting process through the Virtual Channels.

By entering your details to purchase a license by credit card, the user automatically authorizes the charging of the full price of the contracted service, under the exact terms and conditions of payment previously informed by the Virtual Channels.

For greater user security, credit card data is not stored on LINGOPASS servers. This information is entered by the user through encrypted operations directly on the aforementioned payment platform(s), which is why the user, by agreeing to the Terms of Use, expressly consents to the collection and sharing of personal data, including the credit card number for validation of the payment method (with the Mundipagg platform).

Once payment has been approved and completed, the user will receive a confirmation via e-mail to the e-mail address provided when registering.

LINGOPASS reserves the right not to confirm the purchase or to cancel the purchase of the license in the event that it finds (i) that the user has included incorrect or invalid registration information, or (iii) that there has been fraud, bad faith, non-compliance with any of the conditions and policies of the Site or other situations that imply a violation of the Law.

Some of the contracting stages may be altered or partially adapted with prior notice to the user due to the peculiarities of the virtual platform access service contracted.

Any promotional values, such as discounts on the value of any licenses, are not cumulative.

2.2 Access to the Lingopass platform

Online access to the Lingopass platform will be granted to the user within 2 working days of confirmation of payment, as per the previous topic, and must necessarily be done by logging in and entering the user's personal password.

LINGOPASS reserves the right, at any time and at its sole discretion, to modify the conditions of access to its Virtual Channels or its virtual platform, altering its design and/or its form of presentation, including or suppressing resources and/or functionalities and/or information that do not compromise the benefits and characteristics of its virtual platform.

2.3 Right of withdrawal

The user will have a period of up to 7 calendar days from the date of contracting and online payment to exercise their right of withdrawal, with a full refund of the amount paid.

To exercise their right of withdrawal, within the legal period of 7 days from the date of payment, the user must contact LINGOPASS at cancelamento@lingopass.com.br, expressly expressing their interest in canceling their license.

As soon as LINGOPASS receives the user's request to cancel, in the event of a credit card contract, LINGOPASS will request - within 72 working hours - the respective administrator to refund the payment, which will be processed in accordance with the policy practiced by the user's credit card administrator, over which LINGOPASS has no management, and with which the user declares to understand and consent.

In the event of payment by bank slip, the amount will be refunded within 10 working days by bank deposit into an account to be informed by the user.

2.4 Cancellation after the statutory cooling-off period

Even after the legal period of 7 days for withdrawal has elapsed, the user may cancel the contracted license by sending an e-mail to cancelamento@lingopass.com.br, expressly expressing their interest in canceling the contracting of our services.

Once LINGOPASS is aware of the user's interest in canceling the contracted license, it will reply to the e-mail offering the following options:
a) Cancellation with partial refund of the price; or
b) Cancellation with credit for use in the future contracting of another license.

If the user chooses to cancel with (a) partial refund of the price, LINGOPASS will withhold a percentage of 30% (as a fine of 10% plus damages of 20%) of the amount due for the outstanding monthly fees.

If the user chooses to cancel with (b) credit, LINGOPASS will retain the amount of the monthly fees due up to the date of receipt of the cancellation request, giving the user a credit in the amount equivalent to the remaining balance of the amount paid, which may be used to contract a new license, within one (1) year of cancellation.

Once cancellation with credit has been requested, the user cannot subsequently request cancellation with a partial refund of the price.

The user has a period of up to 30 calendar days from receipt of the e-mail with LINGOPASS' reply offering the 2 cancellation options available, to opt for one of them (a) partial refund or (b) credit. Once the above-mentioned period has elapsed without a response from the user, the cancellation will be considered as a credit, with no possibility of a subsequent change to a partial refund.

If the user is found to be in debt to LINGOPASS, he/she will be obliged to immediately settle the debt in order to cancel in the above-mentioned manner.

Specific considerations for access to synchronous interaction sessions:

a) If the user is late or absent on the days on which synchronous interaction sessions are scheduled, he/she will not be entitled to a refund of the amount relating to the missed session, and will not be able to make them up without paying extra for the session to be made up; and

b) If the user is late or absent on days when synchronous sessions are scheduled, he/she will not be entitled to a refund of the amount of the lost session, and will not be able to reinstate it without paying extra for the session to be reinvested, unless he/she requests the cancellation of the session at least 24 working hours in advance, always in writing, via the e-mail pedagogico@lingopass.com.br, duly confirmed.

In the event of cancellation of your license to access the Lingopass platform, the user will not be entitled to a refund of the amount paid for services provided and accesses made when the services were contracted.

2.5 Cancellation of access at the initiative of LINGOPASS

LINGOPASS may cancel the user's access to the Lingopass platform at any time:
a) in the event of non-payment of fees;
b) for violation by the user of the Terms of Use or any other specific rule of the contracted license;
c) for committing an illegal act or violating current legislation, or
d) in the case of synchronous sessions, if the minimum number of users required to make them viable is not reached.

3. CONDITIONS APPLICABLE TO EMPLOYEES OF COMPANIES CONTRACTING OUR CORPORATE PLANS

3.1 About LINGOPASS corporate plans

LINGOPASS corporate plans offer companies the possibility of providing their employees with access licenses to the Lingopass platform.

To do this, the company selects the Lingopass plan that best suits its needs and conditions, informs its employees of the program and the terms of participation. LINGOPASS will send the employees previously nominated by the company an email with their access details to the Lingopass virtual platform. Each nominated employee then takes a preliminary assessment and begins their journey of accessing the platform, whose progress will be constantly followed up and monitored by a manager nominated by the company.

LINGOPASS corporate plans can be (i) fully funded by the company or (ii) partially subsidized by the company, requiring its employees to pay for a portion of the licenses purchased, or (iii) the company can contract a special discount with LINGOPASS for its employees and/or their families to contract licenses individually.

3.2 Access to the Lingopass platform and its features and functionalities

In corporate plans paid for in full or in part by the company, only those employees who have previously registered with LINGOPASS (providing their full name, CPF, telephone number and e-mail address) and who personally signify their agreement to the Terms and Conditions of Use sent to them will have access to Lingopass.

In corporate plans in which the company contracts with LINGOPASS a special discount for its employees and/or their families to contract the licenses individually, the employee's access will follow the provisions of item 2.2.

The company contracting the LINGOPASS corporate plan will be entirely responsible for the veracity of its employees' data entered when filling in the registration form and/or the respective application form, and the e-mail address provided will be officially used by LINGOPASS to forward all information and notices regarding the access licenses contracted, which is why any subsequent changes must be immediately communicated by the employee and/or the contracting company, otherwise the information passed on to the e-mail address originally provided will be deemed to have been duly received by the employee.

Employees are solely responsible for their login and password in their personal Lingopass account, and are liable for all acts carried out through their access account. It is therefore the employee's duty to ensure the safekeeping and confidentiality of his or her password and not to provide it to third parties, thus avoiding potential problems.

Regardless of the above, the employee's access to Lingopass must also comply with any specific provisions contained in the contract signed between the contracting company and LINGOPASS.

3.3 Didactic content made available to employees

3.3.1 The educational content to be made available to employees will comply with the Terms and Conditions of the contract between the contracting company and LINGOPASS.

3.3.2 Specific conditions for licenses with attendance, progress and performance obligations to obtain certification:

a) each module or track made available on the Lingopass virtual platform will previously and clearly inform the user of the volume and minimum conditions of attendance, progress and performance in order to obtain the certification relating to the respective module or track.

b) The rules regarding the fulfillment of goals by the collaborator and/or the non-attendance of the collaborator in synchronous sessions may be stipulated in a contract with the contracting company.

3.4 Specific considerations for access to synchronous interaction sessions and the possibility of excluding collaborators

3.4.1 Specific considerations for access to synchronous interaction sessions:

a) If the user is late or absent on the days on which synchronous interaction sessions are scheduled, the company will not be entitled to a refund of the amount relating to the lost session, and will not be able to reinstate them without extra payment for the session to be recovered, unless the user requests the timely cancellation of the session at least 24 working hours in advance, always in writing, via the e-mail pedagogico@lingopass.com.br, duly confirmed.

b) In the event of the cancellation of your license to access the Lingopass platform by your own decision, the user will not be entitled to a refund of the amount paid for services provided and accesses made when the services were contracted.‍ 3.4.2.

3.4.2 LINGOPASS reserves the right to cancel the access of all employees of a company and/or a specific employee at any time:

a) in the event of contractual default by the contracting company;
b) for violation by the employee of the Terms of Use or any other specific rule relating to the contracted license; or even;
c) the practice of an illegal, immoral act or an act in violation of current legislation, either by the employee or by the contracting company.

3.5 Employee declaration

The employee declares that he/she has been previously instructed by the company to which he/she is linked regarding all the terms and conditions of participation in the corporate plan, aware that his/her performance and dedication will be constantly monitored and evaluated by a manager of the contracting company.

The employee also declares that he/she has previously authorized the contracting company to send his/her contact and registration details to LINGOPASS, with the aim of accessing the Lingopass virtual platform, which is the object of the corporate plan.

4. CONDITIONS APPLICABLE TO BENEFICIARIES OF THE EMPOWERING TALENTS PROGRAM

4.1 About Empowering Talents

The Empowering Talents program was conceived by LINGOPASS in partnership with a council of organization leaders to exchange learning and connections with the ultimate goal of positively impacting people and businesses.

Empowering Talents is a language learning support program aimed at professionals in situations of social and economic vulnerability and/or at the beginning and/or transition of their careers from all over Brazil, nominated by private and public partner organizations, following predefined criteria detailed in each program notice, such as: age, location, family income, diversity, level of proficiency in foreign languages, level of education, availability of time, access to the internet and computer, social engagement and motivation.

Empowering Talents beneficiaries will receive full or partial free and/or discounted access to the Lingopass virtual platform (www.lingopass.com.br) owned by LINGOPASS.

Fully capable individuals (over 18 years of age) and legal entities may be donors to the program.

4.2 Criteria for selecting Empowering Talents beneficiaries

LINGOPASS will be responsible for selecting the candidates nominated by the partner organizations, and may accept or reject the nominations according to the criteria and objectives of Empowering Talents, as well as its own capacity to provide access to the Lingopass platform, which may even result in the rejection of all the candidates pre-selected by the organizations.

4.3 Didactic content and functionalities provided by the Empowering Talents program

The didactic content and functionalities made available by the Empowering Talents program will follow what is stated in each call for proposals.

4.4 Program phases

The program includes several phases previously defined in each call for proposals:

Phase 1 - Selection process
Phase 2 - Acceleration Bootcamp, with a Lingopass access period defined in each call for proposals.

To take advantage of Phase 2, the candidate must have been approved by LINGOPASS in the selection phase.

4.5 Assessment criteria

LINGOPASS alone will be responsible for evaluating, with absolute autonomy and independence, the performance of the recipients of teaching grants from the Empowering Talents program.

4.6 Access to the Lingopass platform

Access to the Lingopass platform for beneficiaries of the Empowering Talents program will be granted to the user within 10 working days of confirmation of their registration and acceptance of the Terms of Use, and must necessarily be done by logging in and entering the user's personal password.

LINGOPASS reserves the right, at any time and at its sole discretion, to modify the conditions of access to its Virtual Channels, altering their design and/or presentation, including or suppressing functionalities and/or information that do not compromise the benefits and characteristics of its virtual platform.

Access to the Lingopass platform within the scope of the Empowering Talents program will be personal and non-transferable, and the user is prohibited from reproducing or sharing the respective content with unauthorized third parties.

4.7 Exclusion of beneficiaries

Empowering Talents beneficiaries may be excluded from the program and consequently lose their right to access the Lingopass platform in the following cases:
a) if the beneficiary, during the program, has not complied with the requirements regarding dedication, deadlines or others that have been previously established as criteria for engagement in the program by LINGOPASS;
b) if the beneficiary, after completing the 1st selective phase of the program, withdraws from the 2nd phase;
c) eventually, in the event of default by the program, in the event of non-payment of the donation installments by the donor;
d) for violation by the beneficiary of any of the rules and conditions of the Empowering Talents program, of the Terms of Use;
e) for committing an illegal act or an act in violation of current legislation.

With the exception of case "c" above, in all other cases of exclusion from the program, the funds originally intended for the beneficiary of the scholarship will be allocated to another beneficiary or beneficiaries of Empowering Talents.

4.8 Declaration and commitment by the beneficiary

The beneficiary of Empowering Talents declares that he/she has been previously informed of the objectives and conditions of participation in the program, and undertakes to make every effort to deserve the benefit granted to him/her, in the knowledge that his/her performance and dedication will be constantly monitored and evaluated.

5. PRIVACY POLICY

5.1 What are the objectives of our data protection policy?

Our privacy policy serves to explain to the user of all the virtual channels ("Virtual Channels") made available to the general consumer public by LINGOPASS CURSOS ON LINE LTDA. - ("LINGOPASS"), how and why the data and information provided by him/her (""collected data"") is collected, processed, stored and handled by LINGOPASS, in order to meet specific requirements of data protection legislation and privacy regulations.

Our Privacy Policy applies to LINGOPASS as the recipient of any personal data provided by the user(s) and for which LINGOPASS becomes responsible - as soon as it is collected - for the use, storage and protection as the controller of the information provided in accordance with the legal definition.

5.2 What is LINGOPASS' commitment to data protection?

LINGOPASS considers the protection of the privacy of personal data to be extremely important, and undertakes to safeguard the privacy of all those who make their personal information available to it in any way, under the terms of the legislation in force.

5.3 Who is responsible for processing the data collected?

LINGOPASS is exclusively responsible for processing, storing and handling the data collected.

5.4 What data is collected?

For the purposes of the LINGOPASS privacy policy, the data collected is considered to be the information provided by the user when registering (full name, date of birth, CPF, home address, e-mail address, telephone number, level of proficiency in foreign languages), as well as that obtained by carrying out assessments and activities within the platform (attendance records, evaluation scores), as well as that obtained when paying online for our services.

Our websites use browsing cookies, i.e. small text files that are stored on the user's computer and can be retrieved during browsing. However, cookies do not store any personal information, they only contain tracking data that allows the site to recognize its presence through the user's browser, offering a more customized browsing experience and offers. These cookies are previously authorized by the user of the site and can be deleted or blocked at any time, according to the specific instructions of the respective browser.

5.5 When is data collected?

LINGOPASS may collect your personal data when you register, throughout your journey by carrying out assessments and activities on the platform, and when you pay to purchase a license to access the Lingopass platform, or even, occasionally, when you contact LINGOPASS for a query or technical support.

5.6 Why is the data collected used?

The data collected will be used for:
a) Pre-qualification and identification of the user wishing to access the Lingopass platform;
b) To enable communication regarding the services to which the user has access as a result of the contracted license;
c) Enable the payment process (and respective issuance of invoices) for the contracted license;
d) To carry out marketing analyses and customer profiles for statistical purposes;
e) For possible LINGOPASS promotional and institutional campaigns;
f) Compliance with legal and regulatory obligations;
g) To carry out other activities essential to the regular operation of LINGOPASS, within the scope of its corporate purpose;
h) For academic purposes (art. 4, II, b) and to carry out studies by research bodies (art. 5, XVIII), in which case arts. 7 and 11 of the LGPD apply.

5.7 With whom is the data collected shared and/or transferred?

LINGOPASS does not sell or rent the data collected to third parties, nor does it use or share it in any way other than that described in this Privacy Policy, without the user's prior consent, unless there is a court order to the contrary.

The data collected may be shared with third parties exclusively in the following cases:
a) Throughout the credit card payment process, the data subject's details are entered directly into the online payment management platform;
b) By court order or legal provision.
c) We work with third parties who provide services, which may include hosting the site, running the promotion, processing orders, releasing credit cards, analyzing data and other services of an administrative nature.
d) We work in partnership with public research bodies for scientific, historical, statistical or technological research in the public or general interest, guaranteeing the anonymization and pseudonymization of data whenever possible.

Personal information, including financial information, may be shared with third parties for the purposes of providing such services to you.

We seek to impose confidentiality obligations on these service providers. In addition, companies affiliated with Lingopass may use your personal information under the terms of this Privacy Policy.

We also reserve the right to disclose personal information to third parties when we believe in good faith that the law requires it, to enforce our Terms of Service, to protect the rights, property, safety or security of Lingopass or the public, to respond to an emergency, or as otherwise indicated in this Privacy Policy.

5.8 How does LINGOPASS protect the data it collects?

LINGOPASS adopts strict data protection, privacy and security measures and controls in order to safeguard the data collected, including among them data encryption on its websites, data backup in external locations.

5.9 How long is the data collected stored for?

LINGOPASS will store the data collected for as long as it deems necessary to fulfill the purposes for which it was collected.

LINGOPASS will respect the minimum legal period for storing user information, as set out in Law no. 12.965/2014.

5.10 How can I access, change or restrict the use of the personal data collected?

Users have the right to access their personal data whenever they wish, and can (and should) correct or update it at any time by selecting the "Register/Change" option in the top menu of the Virtual Learning Environment.

Eventually, LINGOPASS may retain some personal data for an additional period for the purposes of complying with legal or regulatory obligations, as well as for the possible regular exercise of LINGOPASS' rights, as well as for the purposes of academic and scientific research, and for the purposes of audits and compliance.

Personal data will be retained for the period necessary to fulfill the aforementioned obligations, always respecting the deadlines established in the applicable legislation.

5.11 How do I express my consent to the use of my personal data?

By providing the data collected in any of the LINGOPASS Virtual Channels, the visitor is automatically consenting to the rules and limits of use, protection and security established herein, as well as the other provisions contained in the Terms of Use.

5.12 Can I withdraw my consent to the use of my personal data.

Yes, the user can ask dpo@lingopass.com.br.

To cancel the use of their personal data. LINGOPASS will stop using and processing data for institutional and promotional activities within 48 working hours if the user expressly withdraws their consent to do so, counting from the confirmation of receipt by LINGOPASS of such a request.

5.13 What rights do users have as holders of personal data?

LINGOPASS reserves to its users the possibility of exercising the rights provided for in the General Personal Data Protection Law ("LGPD"), being able to submit requests related to their personal data, such as:
a) Confirmation of the existence of processing;
b) Access to personal data;
c) Correction of incomplete, inaccurate or outdated data;
d) Anonymization, blocking or deletion of unnecessary, excessive or allegedly processed data that does not comply with the LGPD, except in the cases provided for by law;
e) Portability of data to another service or product provider, upon express request by the user;
f) Deletion of data processed with the user's consent, except as provided by law;
g) Obtaining information about the entities with which you have shared your data;
h) Information on the possibility of the user not providing consent, as well as being informed of the consequences in the event of refusal;
i) Information related to the processing, storage and destination of personal data, within the scope of the LGPD;
j) Revocation of consent.

To exercise the rights indicated above, please contact dpo@lingopass.com.br.

6. COMMITMENT TO DIVERSITY AND SUSTAINABILITY

6.1 Introduction

This section of the Terms and Conditions governs the commitment of LINGOPASS, an innovative Edtech, to ethical, environmental, social and governance (ESG) practices, emphasizing our dedication to diversity, inclusion, sustainability, social justice and corporate governance.

6.2 Our commitments

6.2.1 Diversity, inclusion and combating discrimination

In accordance with Law 7.716/89, we reiterate our commitment to a discrimination-free environment. We firmly believe in the intrinsic value of every individual, regardless of their race, gender, age, sexual orientation, disability, religion or any other characteristic. Discrimination has no place at Lingopass, and we believe as a company that a safe and respectful virtual environment is essential for everyone's success. For this reason, the company takes strict measures to ensure that all employees, customers, suppliers and the like behave in a professional and ethical manner.

If there is a breach of this commitment in the form of behavior that violates these principles between the parties to the contract, Lingopass reserves the right to terminate the contract, whether with the employee, supplier or client. It is worth noting that to report any improper behavior, in addition to email, we recommend our Ombudsman Channel (ouvidoria@lingopass.com.br), which is anonymous.

6.2.2 Sustainability

LINGOPASS is deeply committed to integrating sustainable and responsible practices into all its operations. This commitment manifests itself in several main areas:

• Environmental: We are dedicated to adopting and promoting practices aimed at conserving the environment, minimizing our environmental impact and fostering sustainability at all levels of our operation. This includes, but is not limited to, the efficient use of resources, waste reduction and the implementation of environmentally friendly policies.

• Social: We strive to promote fair and safe working conditions, respect human rights and contribute positively to the communities where we operate. This involves not only the well-being of our employees, but also the support and development of the localities around us.

• Governance: We maintain high standards of transparency, ethics and regulatory compliance in all our operations and decision-making processes. This is fundamental to guaranteeing trust and integrity in all our commercial and institutional relationships.

6.3 User Responsibilities

By using Lingopass services, you agree to:

• Respect and adhere to the policies and practices established by LINGOPASS.

• Act ethically and responsibly in all interactions within the Lingopass platform and with other interested parties.

• Report any concern or practice that may contravene the Terms or the ethical standards established by LINGOPASS, using the channel ouvidoria@lingopass.com.br for such communications.

6.4 Transparency and Communication

We are committed to maintaining a posture of transparency about our practices aimed at sustainability, diversity and inclusion and combating discrimination, providing up-to-date information through our official website (www.lingopass.com.br) and/or through publications on our communication channels.

In addition, we value open dialog and encourage active communication with all stakeholders, with a view to continuously improving our practices.

By accepting these Terms and Conditions, you acknowledge and agree to LINGOPASS' commitment to promoting sustainable and responsible practices, reflecting our ongoing effort to contribute positively to the world.