Data Collection Policy

How Onside collects, uses, protects, and processes personal information in Brazil, including user rights under LGPD and information about international data transfers and privacy requests.

Commitment to User Privacy

At Onside, we are committed to protecting your privacy and ensuring transparency in how your personal information is collected, used, and managed. This policy explains our data collection and processing practices in accordance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD) and other applicable laws and regulations.

Onside is operated by Onside.io B.V.

1. Collection And Use Of Personal Information

We collect and use personal information only to the extent necessary to operate the marketplace and provide related services.

1.1 User Authorization And Marketplace Access

To provide access to the Onside app marketplace, we collect the following personal information during account creation and authentication:

• Full name – to identify the user and manage the account

• Date of birth – to verify age eligibility and comply with applicable legal requirements

• Phone number – to identify and authenticate users

• Email address – to communicate with users regarding their account, security, and marketplace activity

Purpose Of Processing:

• User identification and authentication

• Account creation and management

• Age verification and compliance with legal requirements

• Security, fraud prevention, and customer support

Legal Basis:

Personal information is processed in accordance with one or more legal bases provided under LGPD, including:

• Performance of a contract or procedures related to a contract

• Compliance with legal or regulatory obligations

• Legitimate interests of Onside, provided that such interests do not override the rights and freedoms of users

• User consent, where required by applicable law

1.2 Marketing And Marketplace Communications

With your consent, where required, we may use personal information to send information related to the marketplace, including product updates, service announcements, and promotional materials.

For this purpose, we may collect and use:

• Full name – to personalize communications

• Email address – to deliver communications

• Usage data – to understand user preferences and improve the relevance of marketplace content

Legal Basis:

• User consent, where required by LGPD

• Legitimate interests related to improving and promoting marketplace services, where permitted by law

Users may opt out of marketing communications at any time.

2. Management And Protection Of Personal Information

We implement appropriate technical and organizational measures to prevent unauthorized access, loss, alteration, disclosure, or misuse of personal information. Access to personal data is limited to authorized personnel and trusted service providers who require such access for operational purposes.

We regularly review our security measures and implement safeguards appropriate to the nature of the personal information processed.

3. User Rights Under LGPD

In accordance with LGPD, users have the following rights regarding their personal information:

3.1 Right To Confirmation And Access

Users may request confirmation of whether we process their personal information and obtain access to such information.

3.2 Right To Correction

Users may request correction of incomplete, inaccurate, or outdated personal information.

3.3 Right To Deletion, Anonymization, Or Blocking

Users may request deletion, anonymization, or blocking of personal information processed in violation of applicable law or no longer necessary for the stated purpose.

3.4 Right To Data Portability

Users may request portability of their personal information to another service provider, where technically feasible and as permitted by applicable law.

3.5 Right To Information About Data Sharing

Users may request information regarding the public and private entities with which their personal information has been shared.

3.6 Right To Withdraw Consent

Where processing is based on consent, users may withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

3.7 Right To Opt Out Of Marketing

Users may object to the use of their personal information for marketing purposes at any time.

4. International Transfers Of Personal Information

Personal information may be processed or stored outside Brazil, including in the European Union and other jurisdictions where Onside or its service providers operate.

Where personal information is transferred internationally, we implement appropriate safeguards and ensure that such transfers are conducted in accordance with LGPD and applicable data protection requirements.

5. Contact And Inquiries

For questions, requests, or complaints regarding personal information, data processing activities, or this policy, please contact us:

Data Controller: Onside.io B.V.

Email: [e-mail]

Mailing Address:

Onside.io B.V. Keizersgracht 555 1017 DR Amsterdam The Netherlands

We will respond to requests without undue delay and in accordance with applicable law.

Users may contact us to exercise their rights under LGPD, including requests for access, correction, deletion, portability, or information regarding the processing of personal data.

6. Changes To This Policy

We may update this Data Collection Policy from time to time to reflect changes in legal requirements, marketplace operations, or our data processing practices. Any material changes will be communicated through the marketplace or via email where required by applicable law.

Acknowledgment

By using Onside, you acknowledge that you have read, understood, and agree to this Data Collection Policy.