Privacy Policy and Terms of Use

1. Identification and Qualification

This policy is issued by HUNTERS MIDIA ATIVIDADES DE PUBLICIDADE LTDA, a private legal entity registered under Brazilian Corporate Taxpayer Number (CNPJ) 46.302.516/0001-91, headquartered at Avenida Paulista, no. 1,471, room 1,110, Bela Vista, postal code 01311-927, city of São Paulo, State of São Paulo, Brazil, hereinafter referred to as the "CONTROLLER" or "Hunters Mídia". For the purposes of this policy, the CONTROLLER acts as controller of the personal data processed within the application, pursuant to article 5, VI, of Brazilian Federal Law no. 13,709/2018 ("LGPD").

2. Definitions

For the purposes of this instrument, the following definitions apply: (i) "Application": the software solution made available by the CONTROLLER on mobile platforms and its related interfaces; (ii) "Tattoo-Artist User" or "User": a natural person, self-employed professional or representative of a legal entity, duly registered and accessing the application within the scope of a services agreement in force with the CONTROLLER; (iii) "End Client": a natural person whose data is processed by the User within the application by reason of the commercial relationship between the User and such person; (iv) "Data Subject": the natural person to whom personal data refer; (v) "Personal Data": any information relating to an identified or identifiable natural person, pursuant to article 5, I, of LGPD; (vi) "Processing": any operation carried out with personal data, pursuant to article 5, X, of LGPD.

3. About the Application

The application is intended to support the Tattoo-Artist User in managing their professional activity, including, without limitation, appointment scheduling, preparation and dispatch of quotes, maintenance of a portfolio with images and videos of works, financial control of receivables, and performance indicators. Access is restricted to Tattoo-Artist Users duly enrolled by the CONTROLLER as a result of the marketing and technology services contracted with Hunters Mídia.

4. Personal Data Processed

In the course of providing the services, the CONTROLLER processes the following data categories: (a) User registration data: full civil name, social or artistic name, taxpayer registration number (CPF and/or CNPJ), e-mail address, telephone, business address, and profile picture; (b) Operational data: appointment schedule, quotes prepared, messages exchanged within the application, financial information on receivables, productivity records, and professional metrics; (c) End Client data entered by the User: name, contact information, service history, preferences and other information provided by the User for the purpose of delivering the tattoo service; (d) Authorial content: images, videos and descriptions of works composing the User's portfolio; (e) Technical and usage data: IP address, device identifiers, mobile push notification tokens, operating system type and version, language, time zone, access logs, and cookies essential to the session.

5. Legal Bases for Processing

Processing of personal data is based on the following legal grounds set forth in article 7 of LGPD: (i) performance of a contract to which the data subject is a party (item V); (ii) compliance with a legal or regulatory obligation (item II); (iii) the regular exercise of rights in judicial, administrative or arbitration proceedings (item VI); (iv) the legitimate interests of the CONTROLLER or of a third party (item IX), provided that the fundamental rights and freedoms of the data subject are observed; (v) consent of the data subject, where applicable (item I), notably for promotional communications.

6. Purposes of Processing

Personal data are processed for the following purposes, all tied to service delivery: (a) to enable and maintain User enrollment and authentication; (b) to provide the application's features; (c) to support the contractual relationship between the User and the CONTROLLER; (d) to provide technical support, handle requests, and resolve incidents; (e) to prevent fraud and ensure information security and operational integrity; (f) to comply with legal and regulatory obligations and orders from competent authorities; (g) to continuously improve the application through aggregated and de-identified usage analysis; (h) to communicate with the User about operational updates and the services agreement.

7. Sharing with Third Parties

The CONTROLLER does NOT sell personal data. Sharing will occur only when strictly necessary for service delivery, subject to applicable contractual and legal safeguards, notably with: (i) cloud-hosting providers and technical infrastructure providers; (ii) Cloudflare, Inc., for purposes of attack mitigation, content delivery, and approximate country-level location detection; (iii) Apple Push Notification Service (Apple Inc.) and Firebase Cloud Messaging (Google LLC), exclusively to deliver notifications to the application; (iv) transactional e-mail service providers; (v) public authorities, when required by law, judicial decision, or legitimate administrative request.

8. Cookies and Similar Technologies

The application and its related web interface use cookies essential to its operation, notably: (a) session cookie, indispensable for authentication; (b) "hm_locale" cookie, used to remember the language selected by the data subject. No third-party behavioural advertising cookies are used within the scope of this page.

9. Storage, Security, and International Transfers

The CONTROLLER adopts reasonable technical and administrative measures to protect personal data against unauthorized access and accidental or unlawful destruction, loss, alteration, communication, or dissemination, including, without limitation, in-transit encryption (TLS), role-based access control, two-factor authentication available to the User, backup routines, and access logging. Any international transfer of data shall comply with the requirements of article 33 of LGPD.

10. Data Subject Rights

Pursuant to article 18 of LGPD, the data subject is entitled to: (i) confirmation of the existence of processing; (ii) access to data; (iii) correction of incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion of unnecessary or excessive data, or of data processed in non-compliance with LGPD; (v) portability of data to another service or product provider, subject to commercial and industrial secrets; (vi) deletion of personal data processed with consent, except in the cases of article 16 of LGPD; (vii) information about public and private entities with which the CONTROLLER has shared data; (viii) information about the possibility of refusing consent and the consequences thereof; (ix) revocation of consent, pursuant to article 8, §5, of LGPD. Requests shall be addressed to the Data Protection Officer in item 21 below.

11. Retention and Deletion

Personal data shall be retained for as long as necessary to fulfil the purposes for which they were collected, during the term of the agreement between the User and the CONTROLLER. After termination of the contractual relationship, data may be retained for the applicable statute-of-limitations periods, in particular: (i) five years for tax purposes; (ii) five years for the regular exercise of rights in judicial proceedings. After such periods, data shall be deleted, anonymized, or blocked, as applicable.

12. Children and Adolescents

The application is intended exclusively for natural persons aged 18 (eighteen) years or older, with full legal capacity. The CONTROLLER does not knowingly process personal data of children or adolescents. Should inadvertent collection be detected, the CONTROLLER shall promptly delete such data, except where required by law to retain them.

13. Terms of Use — Acceptance and Term

Any use of the application, to any extent, constitutes full and irrevocable acceptance of these Terms of Use. Should the User disagree with any clause, the User must refrain from using the application. This instrument remains in force for an indeterminate term, throughout the duration of the relationship between the User and the CONTROLLER.

14. Account, Credentials, and User Responsibility

The User is solely responsible for the safekeeping and confidentiality of their access credentials, and sharing them with third parties is prohibited. Any activity performed in the application using the User's credentials shall be presumed to have been performed by the User. The User undertakes to keep their registration data up to date and to immediately notify the CONTROLLER of any suspected misuse of their account.

15. Prohibited Conduct

The User is expressly prohibited from: (a) using the application for any unlawful or fraudulent purpose or in violation of third-party rights; (b) uploading content owned by third parties without proper authorization, particularly copyrighted images and videos; (c) uploading or distributing discriminatory, violent, obscene, defamatory, or libellous content, or any content contrary to morality and good practice; (d) reverse-engineering, decompiling, modifying, or creating derivative works of the application; (e) running unauthorized automated routines (bots, scripts or similar); (f) attempting unauthorized access to accounts, systems, or networks of the CONTROLLER or third parties; (g) collecting personal data from other Users without authorization.

16. Intellectual Property

The authorial content uploaded by the User to the application, in particular the images and videos comprising the portfolio, remains the exclusive property of the respective User, and the CONTROLLER is authorized to host, reproduce, display, and store such content only to the extent necessary for service delivery. The "Hunters Mídia" trademark, graphical elements, source code, structural databases, and any other elements of the application are the exclusive property of the CONTROLLER, and the User is granted a personal, non-transferable, non-exclusive, limited, and revocable licence of use, exclusively for the purposes set forth herein.

17. Suspension and Termination

Access to the application is bound to the term of the services agreement between the User and the CONTROLLER. Upon breach of these Terms or of the services agreement, the CONTROLLER may, at its sole discretion, suspend or terminate access, without prejudice to applicable legal remedies. Upon termination, the User may request the portability of their data in a structured, commonly used format within 30 (thirty) days counted from termination.

18. Limitation of Liability

The CONTROLLER shall make best efforts to maintain the availability and integrity of the application, but shall not be liable for: (a) unavailability arising from acts of God, force majeure, connectivity failures, or infrastructure provider failures; (b) misuse of the application by the User or by third parties; (c) indirect damages, lost profits, or loss of opportunity; (d) events attributable solely to the conduct of the User or of third parties. In any event, the CONTROLLER's liability is limited to direct, duly demonstrated damages.

19. Amendments to the Policy

The CONTROLLER may amend this instrument at any time, upon prior notice to the User, with a minimum of 15 (fifteen) days' advance notice in case of material amendments regarding personal data processing. The version in force shall always be available at https://huntersmidia.com/privacy, and the User shall consult it periodically.

20. Governing Law and Jurisdiction

This instrument is governed by the laws of the Federative Republic of Brazil, in particular by Federal Law no. 13,709/2018 (LGPD) and Federal Law no. 12,965/2014 (Brazilian Internet Civil Framework). The parties elect the courts of Ibitinga, State of São Paulo, to settle any disputes arising from this instrument, expressly waiving any other forum, however privileged it may be.

21. Contact and Data Protection Officer

The official channel for exercising the rights set forth in item 10, as well as for any inquiries regarding this policy, is the e-mail address contato@huntersmidia.com. Requests shall be answered within a reasonable period, subject to applicable technical and legal limits.

22. Prevailing Language Version

This policy is available in multiple languages, for convenience only. In the event of an interpretative discrepancy between versions, the Brazilian Portuguese (pt-BR) version, established herein as the official version, shall prevail for all purposes.