Creator Data Protection Addendum (DPA)

This DPA governs the processing of personal data by Creators in the context of using the Platform, especially when there is access to, collection, or use of data from:

• buyers;
• subscribers;
• event attendees;
• users who interact directly or indirectly with the Creator.

For the purposes of Law No. 13,709/2018 (LGPD):

Platform: acts, as a rule, as the Controller of the data necessary for the technical operation of the services.

Creator: acts as an independent Controller whenever:

• accessing personal data for own purposes;
• conducting external communications;
• performing deliveries, events, support, or after-sales services;
• processing data outside the strictly technical scope of the Platform.

There is no subordination relationship between the Platform and the Creator regarding data processing decisions made by the Creator.

The following data may be covered by this DPA, as applicable:

• name, email, and buyer/subscriber identifiers;
• contact data for delivery or communication;
• purchase, ticket, or participation records;
• data necessary for check-in, product shipping, or event execution;
• any other data legitimately accessed by the Creator.

The Creator may only process personal data for strictly necessary purposes, including:

• execution of the advertised offer;
• product delivery;
• event execution;
• purchase-related support;
• operational communication linked to the transaction.

The use of data for the following purposes is prohibited:

• unauthorized external marketing;
• improper sale, assignment, or sharing;
• creation of parallel databases;
• any purpose incompatible with the original offer.

The Creator undertakes to:

• process personal data in compliance with the LGPD;
• ensure a valid legal basis for each processing activity;
• limit processing to the minimum necessary;
• adopt technical and organizational security measures;
• not retain data longer than necessary;
• respond to data subject requests, when applicable;
• immediately notify the Platform of any security incident;
• maintain records of processing operations under their responsibility.

The Creator shall adopt reasonable measures to protect personal data against:

• unauthorized access;
• data breaches;
• improper loss, alteration, or destruction.

The Creator is fully liable for security failures under their control.

In the event of an incident, the Creator shall:

• immediately notify the Platform;
• provide complete information about the occurrence;
• cooperate with investigations and corrective measures.

Failure or delay in notification constitutes a serious violation of this DPA.

The Creator is responsible for fulfilling data subject requests regarding data processed as an independent Controller, including access, correction, or deletion, when applicable.

The Platform may, at its discretion, forward requests received directly to the Creator.

The Platform may:

• request clarifications;
• require proof of compliance;
• limit or suspend access to data;
• adopt preventive measures in case of risk.

The Creator shall fully indemnify the Platform for any losses, damages, fines, sanctions, costs, or judgments arising from:

• irregular data processing;
• violation of this DPA;
• data subject complaints;
• incidents under their responsibility.

Non-compliance with this DPA may result, at the Platform's discretion, in:

• suspension of features;
• withholding of funds;
• account termination;
• legal action.

If the Creator transfers personal data outside Brazil, they shall be solely responsible for ensuring an adequate legal basis and appropriate safeguards.

The Platform is not responsible for transfers made directly by the Creator.

This DPA shall remain in effect as long as the Creator uses the Platform and as long as data remains under their responsibility.

This DPA supplements the Terms of Use and the Privacy Policy. In case of conflict, the provisions that ensure greater protection for the Platform and data subjects shall prevail.

For matters related to this DPA:

Email: atendimento@myclose.fan