Last Update: February 09, 2023

Welcome! Thank you for using Jade Autism!

When you use Jade Autism, you trust us with the data and information of the children and teenagers you are legally responsible for. Jade is committed to maintaining that trust. With this in mind, this Privacy Policy (“Policy”) explains in a clear and accessible way how the information and data of the children and teenagers will be collected, used, shared, and stored through our systems.

Acceptance of our Policy will be made when you access or use the Jade Autism website, app, or services. This will indicate that you are aware of and in full agreement with how we will use your information and data.

This Policy is divided into the following way to make it easier to understand:

1. Information we collect;

2. How we use the information collected;

3. Under what conditions and with whom we can share your information;

4. What rights do you have over the information we collect;

5. How we protect your information; and

6. Applicable law

This document should be read in conjunction with our Terms of Use, which is available on our application and provides an overview of our platform. If you have any questions or need to address any matter related to this Policy, please contact us at:

info@jadeautism.com.

1. INFORMATION WE COLLECT

Jade Autism is a platform that develops gamied therapeutic and educational solutions for children and teenagers with autism. Therefore, we collect the following data from children and teenagers at the time you register them on our platform: registration data (such as name, email address ...), gender, date of birth, diagnosis, date of diagnosis, and other types of information.

• During the use of Jade Autism, sensitive data and children and teenager data may be provided. This data is therefore collected to analyze the evolution of children and teenagers as the platform's content is explored, to develop metrics for specialists' forecasts, and to develop appropriate content for their sceptics.

Through this Policy, you expressly agree to the collection, use, and sharing of this data, as established herein.

• At Jade Autism, we place even greater emphasis on protecting the data of these children and teenagers, and require specic consent, prominently, given by at least one parent or legal guardian. Such consent is guaranteed at the time of registration.

2. YOUR RIGHTS OVER THE INFORMATION WE COLLECT

• You have the right to access, rectify, delete, or limit the use of the information collected from your children or teenagers. Additionally, you have the right to receive a copy of the information collected in a structured, machine-readable, and commonly used format, and the right to transmit this information to another data controller.

• If you would like to exercise any of these rights, please contact us at

info@jadeautism.com. We will respond to your request as soon as possible and under applicable laws.

• We also inform you that, in certain circumstances, we may not be able to fulll your request, for example, when it could compromise the privacy of others or when it is required by law. In these cases, we will inform you of the reasons why we are unable to comply with your request.

3. PROTECTING YOUR INFORMATION

• The security of your information and that of your children and teenagers is of utmost importance to us. We implement appropriate technical and organizational measures to ensure the protection of your information and prevent unauthorized access, use, alteration, destruction, or unauthorized disclosure.

However, please be aware that no method of electronic transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security.

4. APPLICABLE LAW

• This document is governed by and must be interpreted following Brazilian General Data Protection Law ("LGPD"), California Consumer Privacy Act ("CCPA"), General Data Protection Regulation ("GDPR"), Children's Online Privacy Protection Act ("COPPA"), Health Insurance Portability and Accountability Act (HIPAA) and Privacy Shield Framework. The Forum of the Municipality of Vitória/ES, Brazil, is elected as the competent forum to resolve any issues arising from this document, with express waiver of any other, however

privileged it may be.

5. UPDATING THIS PRIVACY POLICY

• We may update this Privacy Policy from time to time to reect changes in our privacy practices. When we make changes, we will update the "Last Update" date above and post the new Privacy Policy on our website and app. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the information we collect.

If you have any questions or concerns about this Privacy Policy, please contact us at

info@jadeautism.com.

6. HOW WE USE YOUR INFORMATION

We highly value privacy, so all information about the child(ren) and adolescent(s) is treated as condential, and we will only use it for the purposes described here and authorized by you, primarily so that they can fully use Jade Autism, always seeking to improve your user experience. In this way, we can use your data to:

a. Allow the child(ren) and adolescent(s) to access and use all the features of Jade Autism;

b. Send messages regarding support or service, such as alerts, notications, and

updates;

c. Communicate with you about products, services, promotions, news, updates,

events, and other topics that you may be interested in;

d. Analyze the user traﬃc on our applications;

e. Conduct targeted advertising based on your likes, interests, and other information collected;

f. Personalize the service to better match the likes and interests of the child(ren) and adolescent(s) using the Jade Autism platform;

g. Create new services, products, and features;

h. Detect and prevent fraud, spam, and security incidents;

i. Verify or authenticate the information provided, including comparing data collected from other sources;

j. Better understand user behavior and build behavioral proles;

k. Select users to access the restricted functionality of the application;

l. For any purpose you authorize at the time of data collection;

m. Meet legal obligations;

• Occasionally, we may use data for purposes not described in this privacy policy, but these will be within your legitimate expectations. The eventual use of the child(ren) and adolescent(s)' data for purposes that do not meet this prerogative will be done with your prior authorization.

• Data Deletion and Termination of Treatment: All collected data will be deleted from our servers when you request it through a free and facilitated procedure, or when they are no longer necessary or relevant to provide our services unless there is any other reason for their retention, such as a legal obligation to retain data or the need to preserve these data to protect Jade Autism's rights.

• Jade Autism informs that all data collected by it are anonymized and, therefore, go through steps to ensure their detachment from the owner. In this sense and under the applicable law, the data will be stored until the purpose has been achieved or until storage is necessary to achieve a specic purpose (article 15, paragraph I, Law 13.709/2018 - LGPD and Section 1798.140(o)(1) of the CCPA that allows for the collection, use, and sharing of anonymous information. As per

Section 1798.145 of the CCPA, witch says companies are required to take reasonable steps to maintain the condentiality and security of collected

personal information, including anonymous information.)

• Monitoring and Exclusion for Rule Violation: Jade Autism reserves the right to monitor the entire platform, mainly to ensure that the rules described in our Terms of Use are being observed, or if there is no violation or abuse of applicable laws.

We reserve the right to exclude a certain user, regardless of type, if this Policy or the Terms of Use are not respected. As we value a good relationship with users, we recognize that they have the right to seek to understand the reasons and even contest them, which can be done by the following email: info@jadeautism.com.

• Information Sharing:All data, information, and content about the child(ren) and adolescent(s) may be considered assets in the case of negotiations in which Jade Autism is a party. Therefore, we reserve the right to include this data among the assets of the company if it is sold, acquired, or merged with another. Using this Policy, you agree and are aware of this possibility.

• Jade Autism reserves the right to provide the data of the child(ren) and adolescent(s) and information about them, including their interactions, if requested by a court, to comply with national laws, or if you explicitly authorize it.

By agreeing to the treatment of personal data collected by Jade Autism, the legal guardian of the child or adolescent understands that this data may be shared with educational institutions in which Jade Autism acts as a contractor. Given that Jade Autism prepares user prognosis reports, which will be used for internal control of the institutions.

• Payment Method: Jade Autism is a freemium platform that provides its services for free, but some extra features require payment to use them.

.The legal guardians of the users who want to use these paid features will be required to make the payment through the "Google Play Store"

Jade Autism does not collect or store nancial data of children and teenagers, nor their legal guardians. Any handling of this nancial data is carried out by "Google" through its online store "Google Play Store", a trusted company in the market with an advanced, secure system that operates following the provisions of the General Data Protection Regulation and California Consumer Privacy Act ("LGPD" and "CCPA").

• Rights of Data Owners: You always have the option of not disclosing the data of children and teenagers to us, but keep in mind that some of this data may be necessary to use the features of our applications. Regardless, both you and the children and teenagers will always have rights related to privacy and the protection of personal data. In this way, we summarize all the rights that the data owners have under Brazilian and United States sectorial laws relating to

data protection and the General Data Protection Regulation ("LGPD", "CCPA" and "GDPR"):

a. Right of Access. This right allows you to request and receive a copy of the personal data that we have about the children and teenagers, for which you are the legal guardian responsible.

b. Right of Correction. This right allows you to request the correction and/or

rectication of the personal data of the children and teenagers at any time if you

identify that some of it are incorrect. However, to eﬀect this correction, we will

need to check the validity of the data you provide us with. You can directly rectify

some of the personal data through email: info@jadeautism.com.

c. Right of Deletion. This right allows you to request the deletion of the personal data of the children and teenagers that we have. All data collected will be deleted from our servers when you make this request or when it is no longer necessary or relevant to oﬀer our services unless there is any other reason for its maintenance, such as any legal obligation to retain data or the need to preserve these data for the protection of Jade Autism's rights. To change personal information or delete it from our database, simply send an email to info@jadeautism.com.

d. Right of Objection to Processing. You also have the right to object to where and in what context we are treating the personal data of children and teenagers. In certain situations, we may demonstrate that we have legitimate reasons to process this data, but in any case, we will always respect your right to object.

e. Right of Data Portability. This right allows you to receive the personal data of the children and teenagers that we have in a structured, commonly used, and

machine-readable format, and to transmit this data to another entity, when

technically feasible.

f. Right of Limitation of Processing. This right allows you to request the limitation of the processing of the personal data of children and teenagers, in which case we will only keep these data to defend or exercise rights.

These rights can be exercised through email: info@jadeautism.com.

• INFORMATION SECURITY

All information regarding children and adolescents is condential and will only be

accessible by authorized individuals. Any use of this information will be under this Privacy Policy. Jade Autism will make all reasonable market eﬀorts to ensure the security of our systems and this information. Our servers are located in diﬀerent locations to ensure stability and security, and can only be accessed through previously authorized communication channels.All information regarding children and adolescents, especially sensitive data, will be encrypted whenever possible, provided that this does not render it unusable by the platform. You may request a copy of the data stored in our systems at any time. We will keep the data and information only for as long as it is necessary or relevant for the purposes described in this Policy, for predetermined periods by law, or for as long as it is

necessary to maintain the legitimate interests of Jade Autism.

Jade Autism considers privacy to be extremely important and will do everything within its power to protect it. However, we cannot guarantee that all information about children and adolescents on our platform will be free from unauthorized access, especially in the event of improper sharing of the credentials necessary to access our application. Therefore, you are solely responsible for keeping your access password in a secure location, and sharing it with third parties is strictly prohibited. You agree to immediately notify Jade Autism through secure means regarding any unauthorized use of your account or unauthorized access by third parties.

6. APPLICABLE LAW

This document is governed by and must be interpreted following Brazilian General Data Protection Law ("LGPD"), California Consumer Privacy Act ("CCPA"), General Data Protection Regulation ("GDPR"), Children's Online Privacy Protection Act ("COPPA"), Health Insurance Portability and Accountability Act (HIPAA) and Privacy Shield Framework.

The Forum of the Municipality of Vitória/ES, Brazil, is elected as the competent forum to resolve any issues arising from this document, with express waiver of any other, however privileged it may be.