Privacy Policy

1.1. This Privacy Policy describes how iGameChat collects, uses, stores, shares and protects personal data in the provision of its services.

1.2. This Policy applies to all personal data processed by iGameChat, including data from Clients, End Users and website visitors.

1.3. By using the Service, you confirm that you have read and understood this Privacy Policy.

2.1. For data protection purposes, iGameChat acts as:

(a) Data Controller — in relation to data from its Clients and operational data; (b) Data Processor — in relation to personal data of End Users, processed on behalf of and under instruction from the Client.

2.2. iGameChat, registered under CNPJ No. XX.XXX.XXX/0001-XX, headquartered in São Paulo/SP, is the entity responsible for the processing of personal data described in this Policy.

2.3. Regarding End Users' data, the Client is the Controller and iGameChat acts as the Processor, processing data according to the Client's instructions and under the terms of the data processing agreement.

3.1. iGameChat collects the following categories of personal data:

(a) Registration data: name, email, CNPJ/CPF, company, position — provided by the Client during registration;

(b) Usage data: information about how the Service is used, including features accessed, frequency of use, configuration preferences;

(c) Content data: messages, polls, reactions and other content published by End Users within the Service;

(d) Device data: information about the device used to access the Service, including browser type, operating system, screen resolution;

(e) IP data: End Users' IP address, collected for security and fraud prevention purposes;

(f) Cookie data: cookies strictly necessary for the Service to function.

3.2. iGameChat does NOT collect:

(a) financial or payment data (processed by PCI-DSS certified partners); (b) precise geolocation data; (c) biometric data; (d) health data; (e) browsing data outside the Service.

4.1. The processing of personal data by iGameChat is based on the following legal bases of the LGPD:

(a) Contract execution (Art. 7, V): processing necessary for the execution of the service contract;

(b) Legitimate interest (Art. 7, IX): processing necessary for iGameChat's legitimate purposes, such as product improvement, fraud prevention and security;

(c) Consent (Art. 7, I): when applicable, the data subject's consent for specific purposes;

(d) Legal obligation (Art. 7, II): when processing is necessary for compliance with a legal or regulatory obligation.

4.2. For End Users' data processed as Processor, the legal basis is determined by the Client (Controller), who is responsible for informing and obtaining the necessary consent from its End Users.

5.1. Personal data is used exclusively for the following purposes:

(a) Service provision: operation, maintenance and improvement of the communication widget, API and administrative panel;

(b) Communication: sending notifications about the Service, updates, responses to support requests;

(c) Security: fraud prevention, detection and prevention of attacks, protection against unauthorized use;

(d) Metrics and analytics: generation of aggregate and anonymous reports on Service usage;

(e) Legal obligations: compliance with fiscal, regulatory and legal obligations.

5.2. iGameChat does NOT:

(a) sell personal data to third parties; (b) use personal data for targeted advertising; (c) perform automated profiling with legal effects; (d) use data for purposes incompatible with those described in this Policy.

6.1. iGameChat may share personal data in the following circumstances:

(a) Service providers: companies that provide cloud infrastructure (hosting), payment processing, email and technical support services, strictly to the extent necessary for the provision of their services;

(b) Legal obligations: when required by law, court order or competent authority;

(c) Rights protection: when necessary to protect the rights, safety or property of iGameChat, its Clients or the public;

(d) Merger or acquisition: in the event of merger, acquisition or sale of assets, data may be transferred to the new controller, with prior notice.

6.2. All service providers are contractually obligated to maintain the confidentiality and security of personal data.

7.1. Personal data may be transferred to and stored on servers located outside Brazil, including in the European Union and the United States.

7.2. For international transfers, iGameChat guarantees that:

(a) the destination country has an adequate level of data protection, as assessed by the ANPD; (b) standard contractual clauses for international transfer are adopted; (c) appropriate technical and organizational measures are implemented for data protection; (d) the data subject is informed about the transfer and its risks.

7.3. For transfers to the European Union, the GDPR applies and the adequacy decisions and standard clauses of the European Commission are observed.

8.1. Personal data is retained for the period necessary to fulfill the purposes for which it was collected:

(a) Account data: for the entire duration of the contract and for 5 years after termination; (b) Content data: for the duration of the contract, according to the Client's instructions; (c) Usage and metrics data: for up to 24 months in identifiable format, then in anonymized format; (d) Communication data: for up to 12 months; (e) Access logs: for up to 6 months.

8.2. After the retention periods, data is deleted or irreversibly anonymized.

8.3. Data may be retained for additional periods when required by law, regulation or ongoing judicial proceedings.

9.1. iGameChat implements technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure or destruction, including:

(a) TLS 1.3 encryption for data in transit; (b) AES-256 encryption for data at rest; (c) role-based access control (RBAC); (d) multi-factor authentication (MFA) for administrative access; (e) continuous security monitoring; (f) periodic vulnerability testing; (g) backup and disaster recovery policies.

9.2. In the event of a security incident that poses a risk or relevant harm to data subjects, iGameChat will notify the ANPD and affected data subjects within the timeframe established by applicable legislation.

10.1. In compliance with the LGPD, personal data subjects have the following rights:

(a) Confirmation of the existence of data processing; (b) Access to personal data being processed; (c) Correction of incomplete, inaccurate or outdated data; (d) Anonymization, blocking or deletion of unnecessary, excessive or non-compliant data; (e) Portability of data to another service provider; (f) Deletion of personal data processed with consent; (g) Information about sharing with third parties; (h) Information about the possibility of not providing consent and its consequences; (i) Revocation of consent.

10.2. To exercise your rights, the data subject must request via email to contato@igamechat.com. The request will be processed within 15 business days.

10.3. In case of dissatisfaction, the data subject may register a complaint at the ANPD website (www.gov.br/anpd) or with PROCON.

11.1. The Service uses exclusively cookies strictly necessary for its functioning:

(a) Session cookies: to maintain user authentication during the session; (b) Preference cookies: to store language and theme settings; (c) Security cookies: for fraud prevention and attack protection.

11.2. iGameChat does NOT use:

(a) cross-site tracking cookies; (b) targeted advertising cookies; (c) third-party tracking pixels; (d) device fingerprinting.

11.3. The cookies used do not store personally identifiable data and have a duration limited to what is strictly necessary.

12.1. The Service is not intended for minors under 18 years of age and iGameChat does not intentionally collect personal data from minors.

12.2. If iGameChat becomes aware that data from minors has been collected without proper legal consent, the data will be immediately deleted.

12.3. The Client is responsible for ensuring that its End Users meet the applicable minimum age requirements and for obtaining consent from legal guardians when necessary.

13.1. iGameChat reserves the right to modify this Privacy Policy at any time, with 30 days prior notice by email or notification in the administrative panel.

13.2. Changes will take effect on the date indicated in the notice. Continued use of the Service after the effective date constitutes acceptance.

13.3. In the case of substantial changes, iGameChat will use additional means to inform data subjects, including a highlighted banner in the Service.

14.1. For questions, requests or complaints regarding the processing of personal data, please contact iGameChat's Data Protection Officer (DPO):

Email: contato@igamechat.com DPO: contato@igamechat.com Address: São Paulo/SP, Brazil

14.2. Complaints may also be registered with the National Data Protection Authority (ANPD):

Website: www.gov.br/anpd Email: encarregado@anpd.gov.br