Política de Privacidade

PRIVACY POLICY Version 4.0 Effective Date: July 24, 2026 This Privacy Policy ("Policy") is intended to clearly, transparently, and accessibly explain how the Sugar Friends platform collects, uses, stores, shares, retains, protects, and deletes the personal data of its users and visitors. The Sugar Friends platform is operated by SF CONEXÕES, the entity responsible for processing the personal data collected through the application and website. This Policy has been prepared in accordance with Brazilian Federal Law No. 13,709/2018 (General Data Protection Law – LGPD), as well as other applicable Brazilian laws regarding privacy and information security. Sugar Friends recognizes the importance of its users' privacy and is committed to processing personal data lawfully, transparently, securely, and proportionally to the purposes described in this document, strictly observing the principles of purpose limitation, adequacy, necessity, free access, data quality, transparency, security, prevention, non-discrimination, and accountability established by the LGPD. Sugar Friends acts as the Data Controller for the personal data collected, assuming responsibility for determining the purposes and means of processing and for demonstrating compliance with applicable legal principles before data subjects and the Brazilian National Data Protection Authority (ANPD), maintaining records of processing activities and adopting technical and organizational measures designed to safeguard the rights of data subjects. This Policy applies to all users of the platform, including those registered as Sugar and Friend, as well as visitors who access the application or website without creating an account. By using the platform, creating an account, or accessing any functionality made available by Sugar Friends, the user declares that they have read, understood, and fully agreed to this Privacy Policy and the Platform's Terms of Use. Acceptance of this Policy is an essential requirement for using the services provided by Sugar Friends. If the user does not agree with any provision of this Policy, they must not complete their registration or use the Platform's functionalities. This Policy does not apply to third-party websites, applications, or services that may be accessed through links available on the Platform. Such third parties maintain their own privacy policies and data processing practices, for which Sugar Friends is not responsible.

To facilitate the interpretation of this Privacy Policy, the following terms shall have the meanings set forth below. 1.1 Platform or Sugar Friends The Sugar Friends application and website, exclusively intended to provide a technological platform that connects users registered as Sugar and Friend, offering communication tools, activity scheduling, payment processing, content sharing, and other functionalities described in the Terms of Use. 1.2 User Any individual aged eighteen (18) years or older who accesses, browses, registers, or uses any functionality of the Platform, and who may act as a Sugar, a Friend, or both, in accordance with the Terms of Use. 1.3 Visitor Any individual who accesses the application or website without creating an account. Limited technical browsing information may be processed to ensure the proper operation, security, and continuous improvement of the Platform. 1.4 Data Subject The natural person to whom the personal data processed by Sugar Friends relates, including registered users and visitors, as defined by the Brazilian General Data Protection Law (LGPD). 1.5 Personal Data Personal Data means any information relating to an identified or identifiable natural person, including, but not limited to: Full name; Email address; Telephone number; Date of birth; Residential address; Photographs; Videos; Audio recordings; Messages exchanged through the Platform's chat; Banking information required for receiving payments; Approximate location (when authorized by the user); Latitude and longitude coordinates (processed internally and never displayed to other users); Platform usage preferences; User-selected interests (Sightseeing, Travel, Events, Conversations, Gastronomy, Sports, Hobbies, Learning, and Networking); Payment history; Scheduled activity history; Access logs; IP address; Device identifiers; Operating system; Application version; Authentication records; Browsing data; Any other information voluntarily provided by the user or generated during the use of the Platform. Such data shall be processed exclusively to enable the operation of Sugar Friends, improve the user experience, ensure platform security, comply with legal obligations, and perform the contracted services.

2.1 Sugar Friends may collect personal data directly provided by the User during registration, use of the Platform, or profile updates, as well as data automatically generated during the use of the services, always observing the principle of data minimization, whereby only the information strictly necessary for each specific purpose shall be collected. 2.2 The data that may be collected includes, among others: a) Full name; b) Email address; c) Telephone number; d) Date of birth; e) Residential address; f) Photographs, videos, and audio files submitted by the User; g) Profile description and interests registered on the Platform (Sightseeing, Travel, Events, Conversations, Gastronomy, Sports, Hobbies, Learning, and Networking); h) Banking information necessary for receiving payments; i) Information relating to payments processed through Mercado Pago or other authorized payment providers; j) Approximate location, latitude, and longitude when authorized by the User, used exclusively to display compatible profiles and calculate distances, and never displayed to other users as precise geographic coordinates; k) Access records, IP address, browser, operating system, device model, device identifiers, and application version; l) History of conversations, scheduled activities, payments, content purchases, public and private galleries, favorites, notifications, and other Platform features used. 2.3 The Platform may also automatically collect technical data through cookies, electronic identifiers, authentication records, analytics services, push notifications, geolocation tools, Google Maps, cloud storage services, and other technologies necessary for the proper operation of the application. 2.4 Data collection shall always be limited to information strictly necessary for providing the services offered by Sugar Friends, in accordance with the principles of purpose limitation, necessity, adequacy, and data minimization established by the Brazilian General Data Protection Law (LGPD). No personal data shall be collected without a legitimate and specific purpose.

3.1 Personal data collected by Sugar Friends shall be used exclusively to operate the Platform, perform the contracted services, and provide Users with a secure, efficient, and personalized experience, in accordance with the principle of purpose limitation. 3.2 Personal data may be processed for the following purposes: a) Registering and authenticating Users; b) Creating and maintaining Sugar and Friend profiles; c) Enabling approximate geolocation between Users exclusively to display compatible profiles within the same region; d) Providing messaging features, paid chat, public and private galleries, content purchases, activity scheduling, notifications, and other Platform functionalities; e) Displaying compatible profiles to Sugar Users using technological criteria such as approximate location, availability, preferred profile, and shared interests between Sugar and Friend Users; f) Processing payments, refunds, and financial transfers; g) Sending notifications regarding favorite Friends who become online, received messages, profile updates, payments, password recovery, and other communications related to the use of the Platform; h) Preventing fraud, unauthorized access, unlawful activities, and violations of the Terms of Use; i) Complying with legal, regulatory, judicial, or administrative obligations; j) Producing statistics, performance analyses, and continuous improvements to the Platform whenever possible using aggregated or anonymized data. 3.3 Sugar Friends may use automated tools, artificial intelligence, analytics services, performance monitoring systems, and fraud prevention technologies to improve the security, stability, and quality of its services, while respecting data subjects' rights and applicable legal requirements. 3.4 Under no circumstances shall Sugar Friends sell personal data. Personal information shall be processed exclusively for the purposes described in this Privacy Policy or where required by law or expressly authorized by the User.

4.1 Sugar Friends processes personal data in accordance with Brazilian Federal Law No. 13,709/2018 (LGPD), relying solely on the legal bases authorized by applicable legislation. 4.2 Personal data processing may be based on one or more of the following legal grounds: a) Consent of the data subject; b) Performance of the Terms of Use and contracted services; c) Compliance with legal or regulatory obligations; d) Exercise of legal rights in judicial, administrative, or arbitration proceedings; e) Credit protection, where applicable; f) Legitimate interests of Sugar Friends, provided that the fundamental rights and freedoms of data subjects are respected; g) Fraud prevention, platform security, user authentication, and protection of the data subject. 4.3 Whenever processing is based exclusively on consent, the User may withdraw such consent at any time, subject to the legal grounds permitting continued processing. 4.4 Where processing is based on contractual performance, legal obligations, or legitimate interests, withdrawal of consent shall not affect the processing activities strictly necessary for those purposes. 4.5 Sugar Friends undertakes to process only the personal data strictly necessary for each specific purpose, observing the principles of necessity, adequacy, purpose limitation, transparency, security, prevention, and accountability established by the LGPD.

5.1 By registering on the Platform, the User declares that they have read, understood, and fully agreed to this Privacy Policy and the Sugar Friends Terms of Use, providing free, informed, and unambiguous consent whenever required by applicable law. 5.2 Acceptance of this Policy shall occur electronically through the mandatory selection of the option: "I have read and agree to the Sugar Friends Privacy Policy and Terms of Use." displayed during the final stage of the registration process. Without such acceptance, the registration cannot be completed. 5.3 Sugar Friends shall electronically store records of the version of the Privacy Policy accepted by the User, together with the date, time, and other technical information necessary to demonstrate consent whenever required by law. 5.4 The User may, at any time, request information regarding the processing of their personal data, exercise the rights granted under the LGPD, or withdraw previously granted consent, subject to the legal grounds permitting continued processing. 5.5 Whenever this Privacy Policy undergoes material changes, Sugar Friends may require Users to provide renewed electronic acceptance before continuing to use the Platform. 5.6 Continued use of the Platform after acceptance of this Privacy Policy constitutes the User's agreement with all provisions governing the processing of personal data, and both parties undertake to comply with applicable law and the principles of good faith, transparency, and privacy protection.

6.1 Sugar Friends adopts a strict data minimization policy regarding the information displayed between Users. Only the information strictly necessary for social interaction and the scheduling of activities will be visible to other Users of the Platform. 6.2 The following information may be displayed to other Users: a) Profile photo; b) Cover photo; c) First name or nickname; d) Age (calculated from the date of birth without displaying the full birth date); e) Approximate city (municipality and state only, never the residential address); f) Profile description; g) Profession (when voluntarily provided); h) User-selected interests; i) Ratings and reviews received; j) Galleries authorized by the User (public gallery and paid private gallery); k) Availability status (online/offline); l) Badges and achievements (Premium Profile, Featured Profile, Ambassador, Level, Identity Verification). 6.3 Under no circumstances shall the following information be displayed to other Users: a) Brazilian Individual Taxpayer Registry Number (CPF); b) National Identity Card (RG) or any other identification documents; c) Full residential address (street, number, complement, ZIP code); d) Email address; e) Telephone or mobile phone number; f) Exact latitude and longitude coordinates; g) Banking information (bank, branch, account number, PIX key, account holder); h) Identity verification documents; i) Financial history (payments, withdrawals, transfers, refunds); j) IP address; k) Device technical information; l) Precise or real-time location; m) Internal Platform information (access logs, authentication records, reports, security records). 6.4 The restricted data listed in Section 6.3 shall remain under the exclusive control of Sugar Friends and shall only be disclosed to third parties when required by law, court order, or with the express authorization of the Data Subject, in accordance with the Data Sharing Clause. 6.5 A User's precise location shall never be displayed to other Users. The Platform uses only approximate location (city/region) to present compatible profiles within the same geographic area. Latitude and longitude coordinates remain securely protected internally and are used exclusively to calculate the approximate distance between Users, never being disclosed in numerical format.

7.1 Sugar Friends may share Users' and Visitors' personal data only when necessary to enable the operation of the Platform, provide the contracted services, comply with legal, regulatory, or judicial obligations, or ensure the security of the Platform and its Users. 7.2 Personal data may be shared with: a) Companies responsible for platform hosting, cloud storage, database management, user authentication, email delivery, push notifications, performance monitoring, fraud prevention, and technical support; b) Financial institutions and payment service providers, including Mercado Pago or other authorized payment processors, exclusively for payment processing, refunds, reimbursements, financial transfers, and fraud prevention; c) Technology providers responsible for geolocation and mapping services, including Google Maps Platform, Google Places API, Geocoding API, or equivalent services, exclusively to provide approximate user location, address autocomplete, and distance calculations; d) Technology infrastructure providers responsible for authentication, file storage, databases, and the processing of images, videos, audio, and other media used by the Platform; e) Government authorities, regulatory agencies, or judicial authorities whenever required by law, court order, or for the legitimate exercise of legal rights. 7.3 Sugar Friends may use service providers located both in Brazil and abroad, provided they maintain appropriate standards of security and confidentiality consistent with the Brazilian General Data Protection Law (LGPD). 7.4 Under no circumstances shall Sugar Friends sell Users' personal data for advertising purposes or for purposes unrelated to the operation of the Platform.

8.1 Since part of the technological infrastructure used by the Platform may be provided by international companies, personal data may be processed or stored on servers located outside Brazil. 8.2 Such international transfers may occur due to the use of cloud computing services, file storage, push notifications, user authentication, payment processing, mapping services, geolocation, artificial intelligence, performance monitoring, and other technologies necessary for the operation of the Platform. 8.3 Sugar Friends shall implement appropriate technical, administrative, and contractual safeguards to ensure that any international transfer of personal data complies with the requirements of the Brazilian General Data Protection Law (LGPD) and provides an adequate level of protection for Users' personal information. 8.4 By using the Platform, the User acknowledges that their personal data may be processed by technology providers located in other countries solely for the purpose of enabling the operation, security, stability, and continuous improvement of the services provided by Sugar Friends.

9.1 Personal data processed by Sugar Friends shall be stored in secure environments, whether owned by Sugar Friends or provided by authorized third parties, using technologies consistent with current information security standards, including encryption where applicable, access control, and authentication mechanisms. 9.2 Personal data shall be retained only for the period strictly necessary to fulfill the purposes established in this Privacy Policy, the Terms of Use, and applicable legislation, in accordance with the principle of data minimization. 9.3 Even after a User closes their account, certain personal data may remain stored for the period necessary to: a) Comply with legal or regulatory obligations; b) Exercise legal rights in judicial, administrative, or arbitration proceedings; c) Prevent and investigate fraud; d) Protect the security of the Platform and its Users; e) Comply with tax, accounting, and financial obligations; f) Preserve records relating to payments, cancellations, refunds, reports, and Platform usage history. 9.4 Photographs, videos, audio recordings, chat messages, content published in public or private galleries, and any other files voluntarily uploaded by Users may remain stored while the account is active or for as long as necessary to ensure the proper operation of the Platform. 9.5 Deleting an account does not result in the immediate deletion of all personal data. Certain information may be retained for the legally required period or for as long as necessary to protect the rights of Sugar Friends, third parties, and the Users themselves. 9.6 Whenever possible, Sugar Friends may anonymize or pseudonymize personal data for statistical purposes, service improvements, development of new features, and internal analyses, without directly identifying the User. 9.7 Once all legal and contractual purposes have been fulfilled, personal data shall be securely deleted or irreversibly anonymized in accordance with applicable legislation.

10.1 Sugar Friends adopts technical, administrative, and organizational measures designed to protect personal data against unauthorized access, destruction, loss, alteration, disclosure, or any unlawful or improper processing. 10.2 Such measures may include: a) Data encryption, where applicable; b) User authentication; c) Access permission controls; d) Continuous infrastructure monitoring; e) Regular backups; f) Protection against cyberattacks; g) Monitoring of suspicious activities; h) Automated fraud prevention using technological tools and intelligent monitoring systems; i) Logging of user access, authentication, and Platform usage. 10.3 The Platform may use automated technologies, including artificial intelligence, machine learning, and behavioral analysis tools, to identify fraud attempts, unauthorized use of the Platform, suspicious access, fake accounts, spam, activities inconsistent with the Terms of Use, or any conduct that may compromise the security of the Platform or its Users. 10.4 Sugar Friends may temporarily suspend accounts, restrict certain functionalities, request additional identity verification, or permanently block accounts whenever reasonable evidence of fraud, misuse of the Platform, or violation of this Privacy Policy or the Terms of Use is identified. 10.5 Although Sugar Friends adopts high information security standards, no computer system can be considered completely immune to failures or cyberattacks. Therefore, Sugar Friends cannot guarantee absolute security against incidents arising from third-party actions, sophisticated cyberattacks, failures of external service providers, or conduct attributable to the User. 10.6 In the event of a security incident capable of creating a significant risk to data subjects, Sugar Friends shall adopt the necessary measures to mitigate its effects and shall provide all notifications required by applicable law, including notification to the Brazilian National Data Protection Authority (ANPD), whenever applicable. 10.7 Users are responsible for keeping their account credentials confidential and shall be solely responsible for all activities performed through their account. Any suspected unauthorized access must be reported to Sugar Friends immediately.

11.1 Sugar Friends guarantees Data Subjects all rights provided under the Brazilian General Data Protection Law (LGPD) and is committed to providing appropriate means for exercising such rights in a transparent, secure, and free manner, subject to applicable legal limitations. 11.2 The Data Subject may request, at any time: a) Confirmation of whether their personal data is being processed; b) Access to the personal data stored by Sugar Friends; c) Correction of incomplete, inaccurate, or outdated personal data; d) Updating of registration information; e) Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed personal data; f) Portability of personal data to another service provider, where technically feasible and in accordance with ANPD regulations; g) Deletion of personal data processed based on consent, except where retention is required by law; h) Information regarding the public or private entities with whom Sugar Friends has shared personal data; i) Information regarding the possibility of withholding consent and the consequences of such decision; j) Withdrawal of previously granted consent; k) Review of decisions based exclusively on automated processing of personal data, where applicable. 11.3 Requests shall be submitted through the official communication channels made available by Sugar Friends. Additional information may be requested to verify the identity of the Data Subject as a fraud prevention and security measure. 11.4 Deletion of a User account does not result in the immediate deletion of all personal data. Certain information may remain stored for the period necessary to comply with legal, regulatory, tax, financial, fraud prevention, security, and legal defense obligations. 11.5 Users may update their registration information directly through the application at any time, subject to applicable legal and technical limitations affecting certain types of data.

12.1 Sugar Friends may use cookies, local storage, device identifiers, tracking technologies, Software Development Kits (SDKs), Application Programming Interfaces (APIs), and similar technologies to ensure the proper operation of the Platform, improve the User experience, enhance security, and continuously improve its services. 12.2 The Platform may use, among others: a) Essential Cookies, required for authentication, session management, and operation of the Platform's core functionalities; b) Analytics Cookies, used to analyze performance, usage statistics, identify failures, and improve the application; c) Security Cookies, used to prevent fraud, detect suspicious access, and protect User accounts; d) Geolocation Technologies, subject to User authorization, exclusively for displaying nearby compatible profiles, calculating distances, address autocomplete, and location-based features. A User's exact location shall never be displayed to other Users; e) Push Notification Services, used to send communications related to the operation of the Platform, including password recovery, payment confirmations, received messages, activity status updates, favorite Friends coming online, important updates, and security notifications. 12.3 The Platform may use third-party services such as Google Maps Platform, Google Places API, cloud hosting services, monitoring tools, analytics services, fraud prevention technologies, push notification providers, and other technological services necessary for the operation of the application. 12.4 Users may manage certain permissions directly through their device settings, including access to location, camera, microphone, storage, and notifications. Disabling such permissions may limit or prevent certain Platform functionalities from operating properly. 12.5 By using the Platform, the User acknowledges the use of these technologies for the purposes described in this Privacy Policy, always in compliance with the principles of necessity, proportionality, and security established by the Brazilian General Data Protection Law (LGPD).

13.1 Sugar Friends may request permission to access the User's approximate location exclusively for the purpose of displaying compatible profiles within the same geographic region and calculating the approximate distance between Users. 13.2 The User's precise location (exact latitude and longitude coordinates) shall never be displayed to other Users. The Platform displays only the approximate city or region and the relative distance between profiles, without revealing the User's address or exact geographic coordinates. 13.3 Precise geographic coordinates remain securely protected within Sugar Friends' internal systems and are used exclusively for distance calculations and location-based search features. They are never used for real-time monitoring or tracking purposes. 13.4 Users may revoke location permission at any time through their device settings. The User acknowledges that disabling location access may limit the availability of nearby profiles and other location-based Platform features. 13.5 Sugar Friends does not share precise geographic coordinates with third parties except where required by law or court order.

14.1 Messages exchanged between Users through the Platform's chat may be stored and processed exclusively for the following purposes: a) Enabling the operation of the Platform and its communication tools; b) Fraud prevention and detection of unlawful conduct; c) Investigation of reports, complaints, or disputes; d) Compliance with court orders or legal obligations; e) Protection of Users and the security of the Platform. 14.2 Chat messages shall not be used for advertising purposes, nor shared with advertisers or third parties for commercial purposes. 14.3 Messages exchanged through the Platform remain private between the communicating Users. Sugar Friends may access such messages only under the circumstances described in Section 14.1, whenever justified and properly documented. 14.4 Chat content shall not be used to train artificial intelligence models intended for advertising, marketing, or commercialization of personal data.

15.1 Users may publish content in two types of galleries: a) Public Gallery, accessible to all Platform Users; b) Private Gallery, accessible only after payment made by the Sugar User directly through the Platform. 15.2 The Private Gallery is intended exclusively for sharing content created by the Friend User, including, but not limited to: a) Original photographs; b) Videos; c) Artistic performances; d) Skill demonstrations; e) Cultural content; f) Sports-related content; g) Hobbies; h) Educational materials; i) Music; j) Artistic works; k) Intellectual creations; l) Any other content permitted by the Platform. 15.3 Users represent and warrant that they own or possess all necessary rights to the content they publish and shall be solely responsible for any copyright, image rights, or intellectual property violations arising from such content. 15.4 Once Private Gallery content has been unlocked by the Sugar User, it shall remain permanently available in the User's personal library within the application. Refund requests shall not be accepted solely because the purchased content has already been viewed. 15.5 Sugar Friends reserves the right to remove any content that violates these Terms, applicable law, or the rights of third parties.

16.1 The fee charged by the Platform to initiate the Chat is intended exclusively for the use of the communication tool provided by Sugar Friends and shall not be construed as payment for an in-person activity, content, or gift. 16.2 Any amounts subsequently negotiated between the Sugar User and the Friend User are intended to cover expenses related to the contracted activity, which may include, among others: transportation, fuel, tolls, parking, meals, accommodation, admission tickets, materials used during the activity, and any other expenses directly related to the activity. 16.3 Negotiation of such amounts takes place exclusively between the Sugar User and the Friend User within the Platform. All payments continue to be processed exclusively through Sugar Friends using authorized payment service providers. 16.4 Banking information and PIX keys provided by the User are used exclusively for processing transfers, withdrawals, and refunds, and shall never be displayed to other Users. 16.5 The User is solely responsible for the accuracy and ownership of the banking information registered on the Platform.

17.1 Sugar Friends does not sell Users' personal data for advertising purposes. 17.2 The Platform does not display personalized advertising from third-party companies based on Users' personal data, interests, location, chat history, or browsing behavior. 17.3 Communications displayed within the Platform may include: a) Platform features and functionalities; b) Official communications from Sugar Friends; c) New features and application updates; d) Applications belonging to the Sugar Friends corporate group; e) Institutional campaigns promoted by Sugar Friends. 17.4 None of these communications shall involve the sale, sharing, or transfer of Users' personal data to advertisers or third-party companies. 17.5 Communications sent to Users are intended exclusively for informational and operational purposes related to the operation of the Platform. Users may manage certain notification preferences through the application's settings, except for communications that are essential to the security and operation of the services.

18.1 The Sugar Friends Platform is intended exclusively for individuals aged eighteen (18) years or older. Registration, access, or use of the Platform by minors is strictly prohibited. 18.2 During registration, the User declares, under their sole responsibility, that they are at least eighteen (18) years of age and that all information provided is true, complete, and up to date. 18.3 If Sugar Friends identifies, or receives a substantiated report indicating, that an account belongs to a minor or contains false information regarding the User's age, the Platform may immediately suspend or permanently delete the account without prior notice. 18.4 If Sugar Friends becomes aware that personal data belonging to a child or minor has been inadvertently collected or processed, it shall take appropriate measures to cease such processing, delete the information whenever legally permitted, and prevent further access, except where retention is required by law or necessary for the exercise of legal rights. 18.5 Parents, legal guardians, or any third party aware of the unauthorized use of the Platform by a minor may immediately notify Sugar Friends through its official support channels so that the appropriate measures may be taken.

19.1 This Privacy Policy becomes effective on the date of its publication and shall remain in force for an indefinite period. Sugar Friends may amend, update, or replace this Policy at any time to reflect legal, regulatory, operational, technological, or security changes. 19.2 Each version of this Privacy Policy shall have its own version number and effective date, enabling Users to identify which version was accepted during registration or while using the Platform. 19.3 Whenever a material amendment is made to this Privacy Policy or the Terms of Use, Sugar Friends shall require Users to provide renewed express consent as a mandatory condition for continued access to the Platform's functionalities. Users who do not accept the updated version shall not be permitted to access the Platform until such acceptance is provided. 19.4 Acceptance of updated versions shall be mandatory whenever the amendments involve Users' rights or obligations, personal data processing, Platform functionalities, cancellation policies, payment procedures, privacy, or security. 19.5 Version 4.0 of this Privacy Policy, published on July 24, 2026, introduces significant updates, including: i. replacement of the term "meeting" with "activity" throughout the documentation; ii. replacement of "objectives" with "interests", including the official list of nine interests; iii. introduction of Clause 6, specifying which data may and may not be displayed to other Users; iv. introduction of Clause 13, clarifying that Users' precise location is never displayed; v. introduction of Clause 14, establishing limited purposes for chat message processing and prohibiting advertising use; vi. introduction of Clause 15, providing a detailed description of the Private Gallery and the types of original content that may be shared; vii. introduction of Clause 16, clarifying that the Chat fee relates exclusively to the communication tool and that negotiated amounts are intended to cover activity-related expenses; viii. introduction of Clause 17, addressing advertising practices and the non-commercialization of personal data; ix. comprehensive review of the Privacy Policy to ensure compliance with the principles established by the Brazilian General Data Protection Law (LGPD), including purpose limitation, necessity, adequacy, data minimization, transparency, security, prevention, and accountability. Due to the significance of these amendments, all Users must expressly accept Version 4.0 upon their first access following publication before continuing to use any Platform functionality. 19.6 If the User does not agree with the updated Privacy Policy or Terms of Use, they may request closure of their account, subject to the legal data retention requirements described in this Privacy Policy. 19.7 The most recent version of this Privacy Policy shall remain permanently available within the application under More → Application Policies, as well as on the official Sugar Friends website, for consultation at any time. 19.8 Continued use of the Platform after publication of a new version of this Privacy Policy shall not constitute implied acceptance whenever applicable law or the Platform itself requires renewed express consent. Until such consent is provided, access to the Platform's functionalities shall remain restricted.

20.1 This Privacy Policy forms an integral part of and complements the Sugar Friends Terms of Use. Both documents shall be interpreted together and harmoniously. In the event of any conflict between their provisions, the interpretation that provides the greatest protection to the rights of Data Subjects shall prevail, subject to applicable law. 20.2 Any failure or delay by Sugar Friends in enforcing any provision of this Privacy Policy shall not constitute a waiver of rights, amendment, or novation. All remaining provisions shall remain valid and fully enforceable. 20.3 If any provision of this Privacy Policy is declared invalid, illegal, or unenforceable by a final judicial or administrative decision, the remaining provisions shall remain in full force and effect. The parties undertake to replace the affected provision with another that preserves, as closely as possible, its original purpose. 20.4 Sugar Friends may modify Platform functionalities, features, interface, technologies, integrations, authentication methods, payment methods, communication tools, cancellation policies, security criteria, and any other characteristics of the Platform whenever necessary for its continuous improvement, in compliance with applicable law. 20.5 The Platform may use proprietary or third-party technologies, including cloud computing services, geolocation services, artificial intelligence, authentication services, payment processing, push notification systems, media storage, performance monitoring, fraud prevention technologies, and any other technological solutions necessary for the operation of its services. 20.6 This Privacy Policy shall be governed by the laws of the Federative Republic of Brazil, particularly Federal Law No. 13,709/2018 (Brazilian General Data Protection Law – LGPD), the Brazilian Civil Code, the Brazilian Consumer Protection Code, and all other applicable legislation. 20.7 The courts of the judicial district where Sugar Friends maintains its principal place of business shall have exclusive jurisdiction to resolve any disputes arising from this Privacy Policy, with the parties expressly waiving any other jurisdiction, except where exclusive jurisdiction is established by mandatory law.

21.1 Sugar Friends provides dedicated communication channels through which Data Subjects may submit questions, requests, complaints, incident reports, notices, requests related to the Brazilian General Data Protection Law (LGPD), and any other privacy-related matters. 21.2 Users may exercise all rights provided under this Privacy Policy and the LGPD, including requests for access, correction, updating, deletion, anonymization, restriction, portability, withdrawal of consent, and any other rights guaranteed by applicable law. 21.3 To protect its Users, Sugar Friends may request additional information to verify the identity of the requesting Data Subject before processing any request involving personal data. 21.4 All requests shall be reviewed and processed as promptly as reasonably possible, subject to applicable legal deadlines, the complexity of the request, and mandatory data retention requirements under Brazilian law. 21.5 The official contact channels of Sugar Friends are: Support Email: suporte@sugarfriendsapp.com Website: https://sugarfriendsapp.com Application: Menu → Other → Support 21.6 Whenever possible, requests relating to a User's account may be resolved directly within the application through profile editing, password recovery, account deletion, profile updates, and privacy preference management features. 21.7 This Privacy Policy has been approved by the management of Sugar Friends and shall become effective on the date of its publication, remaining in force until officially replaced by a subsequent version published by the Platform.

22.1 The User declares that all information provided during registration and while using the Platform is true, complete, and up to date, and undertakes to keep such information accurate throughout the duration of their account. 22.2 The User is solely responsible for all information, photographs, videos, audio recordings, messages, documents, and any other content published or shared through the Platform, and shall bear full civil, administrative, and criminal liability for any violation of applicable law or third-party rights. 22.3 The use of the Platform for unlawful, fraudulent, discriminatory, offensive, defamatory, misleading, or intellectual property-infringing purposes, or in violation of the Sugar Friends Terms of Use, is strictly prohibited. 22.4 Sugar Friends may suspend, restrict, or permanently terminate accounts that show evidence of fraud, misuse, submission of false information, attempts to circumvent the Platform's security mechanisms, or violations of this Privacy Policy or the Terms of Use. 22.5 Suspension or termination of an account shall not release the User from obligations previously assumed, including pending payments, legal obligations, or liabilities arising from the use of the Platform.

23.1 Acceptance of this Privacy Policy shall be provided electronically by selecting the corresponding acceptance option during the Platform registration process. 23.2 Electronic acceptance shall have the same legal effect as a handwritten signature and shall constitute the User's free, informed, and unequivocal expression of consent. 23.3 Sugar Friends shall maintain an electronic record of the version of the Privacy Policy accepted by the User, together with the corresponding date, time, and technical information necessary to demonstrate consent, in accordance with the Brazilian General Data Protection Law (LGPD) and other applicable legislation. 23.4 Whenever a new version of this Privacy Policy requiring mandatory acceptance is published, Users shall be notified through the Platform and must provide renewed acceptance before continuing to use the services. 23.5 Continued use of the Platform after acceptance of this Privacy Policy constitutes the User's full agreement with all of its provisions and the User undertakes to comply with them throughout the use of the services provided by Sugar Friends.

24.1 The User authorizes Sugar Friends to communicate electronically through the application, website, email, push notifications, SMS, WhatsApp, or any other communication channels provided by the User during registration. 24.2 Such communications may include, among others: a) Password recovery; b) Registration confirmation; c) Payment confirmation; d) Confirmation of scheduled activities; e) Cancellations and refunds; f) Security notifications; g) Updates to the Terms of Use and Privacy Policy; h) Notices regarding the operation of the Platform; i) Notifications when favorite Friends become online; j) Notifications regarding received messages and other contracted Platform features. 24.3 The User is responsible for keeping their email address, telephone number, and other contact information accurate and up to date. 24.4 Sugar Friends shall not be responsible for the non-delivery of communications resulting from incorrect registration information, full email inboxes, spam filters, device restrictions, or failures of third-party service providers. 24.5 Electronic communications sent by Sugar Friends shall have the same legal validity as written communications and shall produce all applicable legal effects.

25.1 This Privacy Policy shall be interpreted together with the Sugar Friends Terms of Use and any other policies that may be published by the Platform. 25.2 The omission of any functionality from this Privacy Policy shall not prevent its future implementation, provided that Users' rights, applicable legislation, and, where necessary, updates to this Privacy Policy are respected. 25.3 Sugar Friends reserves the right to implement new features, integrations, payment methods, technological resources, authentication systems, geolocation services, artificial intelligence solutions, media galleries, security tools, communication services, and any other resources necessary for the continuous improvement of the Platform, in compliance with the Brazilian General Data Protection Law (LGPD). 25.4 Any matters not expressly addressed in this Privacy Policy shall be governed by Brazilian law, particularly Federal Law No. 13,709/2018 (Brazilian General Data Protection Law – LGPD), the Brazilian Civil Code, the Brazilian Consumer Protection Code, and all other applicable legislation. 25.5 This Privacy Policy constitutes the entire agreement between Sugar Friends and its Users regarding the processing of personal data and supersedes all previously published versions. 25.6 By continuing to use the Platform after accepting this Privacy Policy, the User acknowledges that they have read, understood, and agreed to all of its provisions and undertake to comply with them throughout the use of the services provided by Sugar Friends.

Approximate geolocation using Google Maps (the User's exact location is never displayed to other Users). Favorites system. Notifications when a Friend comes online. Public Gallery. Private Gallery (original content created by the Friend User). Purchase of photos and videos. Paid Chat (R$ 50.00 to initiate a conversation – this fee is charged exclusively for the use of the Platform's communication tool). Activity scheduling. Display of compatible profiles based on shared interests, approximate location, and availability. Payments processed exclusively through Sugar Friends using Mercado Pago. Cancellation and refund policies. Email password recovery. Account deletion. Reporting and blocking system. Identity verification (if implemented in the future). Use of Artificial Intelligence for fraud prevention (not for advertising purposes). No sale or commercialization of Users' personal data for advertising purposes.