Privacy and Data Protection Policy

This Policy applies to:

• browsing RADIAL’s institutional website;
• contact forms made available on the website;
• communications resulting from requests submitted by visitors;
• technical data required for the security, operation, and functioning of the website.

This Policy is not intended to govern every form of data processing that RADIAL may perform while providing services to clients.

When RADIAL processes personal data on behalf of a client, including in marketing, development, hosting, technology, performance, communication, or digital service activities, its role and responsibilities will be determined according to the nature of each operation, the applicable agreement, and the instructions of the respective client.

Accordingly, this Policy is limited to processing carried out directly by RADIAL in connection with its institutional website, commercial contacts, requests sent through its own channels, and operations necessary for the functioning and security of this digital environment.

For personal data processing covered by this Policy, the controller is:

Struckel Serviços d.f.Ltda — Trade name: RADIAL Design Gráfico — CNPJ: 07.929.674/0001-14 — Campinas — São Paulo — Brazil.

Data Protection Officer / person in charge of personal data processing: Thomaz Struckel.

Privacy and Data Protection channel: dpo@radialdesign.com.br.

Security and Technical Incidents channel: noc@radialdesign.com.br.

RADIAL seeks to collect only information necessary for the purpose of the contact.

Through the website form, visitors may provide:

• name;
• company;
• email address;
• telephone number;
• area or service of interest;
• content of the message submitted.

The server may also automatically record technical information required for the functioning and security of the website, such as:

• IP address;
• date and time of access;
• browser and device information;
• request logs;
• technical session data;
• information required to prevent abuse, spam, and exploitation attempts.

Visitors are requested not to submit sensitive personal data or confidential information through the general contact form unless such information is necessary for the requested service.

Data may be used for the following purposes:

a) Responding to requests

Contacting individuals who requested information, submitted a demand, requested a proposal, or initiated a potential commercial relationship.

b) Preparing proposals and commercial procedures

Understanding the context presented and carrying out preliminary procedures related to a potential engagement requested by the data subject.

c) Maintaining website security

Preventing abuse, spam, malicious automation, fraud, exploitation attempts, attacks, and other behavior capable of compromising the website, its infrastructure, or its users.

d) Complying with legal obligations

Responding to applicable legal, administrative, or judicial requirements.

e) Exercising or protecting rights

Preserving information necessary for the regular exercise of RADIAL’s or third parties’ rights.

RADIAL will not automatically use a message submitted through the form to add the visitor to promotional lists, newsletters, or recurring marketing campaigns.

If newsletters or promotional communications are offered in the future, a specific and separate option will be made available for that purpose.

Depending on the purpose and context, personal data processing may rely on legal bases provided by applicable law, including:

• preliminary procedures related to a contract, when requested by the data subject;
• compliance with a legal or regulatory obligation;
• regular exercise of rights;
• legitimate interest, when applicable and compatible with the rights and expectations of the data subject;
• consent, when required for a specific and optional purpose.

Consent will not be used as a generic justification for every form of processing performed through the website.

RADIAL does not sell personal data.

Information may be accessed or processed by providers necessary for website operation and business communications, such as:

• hosting infrastructure;
• email infrastructure;
• security and abuse-prevention services;
• technical services used for website maintenance;
• providers required for the operational continuity of the solution.

Such access should occur only to the extent necessary to provide the respective services.

Data may also be shared when required by law, court order, valid request from a competent authority, or for the regular exercise of rights.

Some technological components used by the website may be provided by third-party companies.

Depending on the infrastructure used, certain technical data may be processed on servers located outside Brazil.

Where an international transfer of personal data occurs, RADIAL will seek to use providers and mechanisms compatible with applicable data-protection legislation.

Data will be retained only for a period compatible with its purpose.

Commercial contacts that do not result in an engagement may be retained for up to 24 months after the last interaction, for service continuity, commercial history, and possible resumption of the conversation.

After this period, data may be deleted or anonymized, except where retention is necessary for:

• compliance with a legal or regulatory obligation;
• regular exercise of rights;
• prevention or investigation of incidents;
• audit and security;
• another legitimate basis provided by law.

Technical and security records may have different retention periods according to their purpose and applicable legal obligations.

Under applicable legislation, the data subject may request, as appropriate:

• confirmation that processing exists;
• access to personal data;
• correction of incomplete, inaccurate, or outdated data;
• information about use and sharing;
• anonymization, blocking, or deletion where applicable;
• portability, where applicable;
• objection to processing carried out in certain circumstances;
• withdrawal of consent where processing is based on consent;
• information about the consequences of refusing consent, where applicable.

Requests may be sent to: dpo@radialdesign.com.br.

We may request additional information strictly necessary to confirm the identity of the requester and prevent data from being improperly disclosed to third parties.

The person in charge of personal data processing for Struckel Serviços d.f.Ltda — RADIAL Design Gráfico is Thomaz Struckel.

This person acts as a communication channel for matters related to privacy and personal data protection within the scope of this Policy.

Requests related to rights under Brazil’s General Data Protection Law (LGPD), questions about personal data processing, or other privacy matters may be sent to: dpo@radialdesign.com.br.

RADIAL adopts technical and administrative measures compatible with the characteristics of the website to reduce risks of:

• unauthorized access;
• improper use;
• unauthorized alteration;
• destruction;
• loss;
• improper disclosure;
• automated abuse;
• spam;
• exploitation of vulnerabilities.

Despite these measures, no environment connected to the internet can be considered completely risk-free.

Communications regarding security incidents, vulnerabilities, abuse, or technical matters may be sent to: noc@radialdesign.com.br.

RADIAL’s institutional website is not specifically directed at children.

We do not intentionally conduct campaigns through this website aimed at collecting children’s personal data.

The website may contain links to third-party platforms or websites.

RADIAL does not control the privacy practices of these external environments. When accessing them, we recommend reviewing their respective privacy policies and terms of use.

This Policy may be updated to reflect legal, technical, operational, or tool-related changes affecting the website.

The current version will be the one made available on this website, together with its last-updated date.

Privacy, LGPD, and data subject rights: dpo@radialdesign.com.br.

Security, technical incidents, and vulnerabilities: noc@radialdesign.com.br.

Struckel Serviços d.f.Ltda — RADIAL Design Gráfico — CNPJ: 07.929.674/0001-14 — Campinas — São Paulo — Brazil.