Terms and Privacy

Executive Summary — Terms of Use and Privacy Policy

Last updated: October 25, 2025

Machine Maker Ltd. is the controller responsible for processing personal data and operating the eMiner, Snout, Prospecta platforms, among other solutions in its portfolio.

This document brings together, in a clear and complete manner, the Terms of Use and Privacy Policy applicable to all products and services made available by the company, in accordance with Applicable Data Protection Laws.

1. Terms and Conditions of Use

1.1. Acceptance of Terms

These Terms of Use constitute a binding legal agreement between the User and Machine Maker Ltd., a limited liability company. This document governs the use of the platforms, products, services, and features offered by the company, including, but not to, eMiner, Prospecta, and Snout, accessible through the domains https://eminer.app, https://prospectawhats.com, https://snout.pro, and other websites and subdomains maintained by the company.

By accessing, registering, or using any functionality offered by Machine Maker Ltd., the User declares to have read, understood, and fully agreed to these Terms and Conditions of Use, as well as the Privacy Policy, which is an integral part of this document. If the User does not agree with any provision set forth herein, they must refrain from using the platforms and services.

The continued use of the platforms after the publication of any changes implies automatic and unrestricted acceptance of the updated versions of these Terms. It is recommended that the User periodically review this document, available at https://eminer.app/terms, to stay informed about any modifications.

These Terms apply to all Users, whether natural or legal persons, including unregistered visitors, subscribers, corporate clients, and legal representatives of contracting companies. The User acknowledges that the use of the services is done in their own name and under their sole responsibility, committing to respect all Applicable Laws, including Applicable Data Protection Laws.

Machine Maker Ltd. reserves the right, at any time and without prior notice, to modify, suspend, or discontinue, temporarily or permanently, any part of its platforms, services, or functionalities, for technical, legal, or operational reasons. In such cases, Users will be notified electronically or through the platforms themselves.

Acceptance of these Terms implies the acknowledgment that:

1. The User meets the age and capacity requirements set forth in Section 1.4.1;
2. All information provided is true, complete, and up-to-date;
3. The User understands that improper use of the platforms may result in suspension, account cancellation, and civil and criminal liability;
4. Machine Maker Ltd. may conduct audits, security updates, and operational reviews to preserve the integrity of the services provided.

The use of the platforms, therefore, constitutes a free, informed, and unequivocal manifestation of the User's will to be bound by all provisions of this legal instrument.

1.2. Definitions

For the purposes of interpreting and applying these Terms of Use and the Privacy Policy, the terms below have the following meanings, applicable in both singular and plural:

1. Machine Maker Ltd. – The private legal entity responsible for the development, management, operation, and maintenance of the eMiner, Prospecta, and Snout platforms, as well as any other associated products, domains, and services.
2. User – Any natural or legal person who accesses, uses, or interacts with the platforms, regardless of having a registered account, active subscription, or free use. It also includes legal representatives, employees, and service providers who use the platforms on behalf of third parties.
3. Platforms – The set of websites, web applications, extensions, APIs, and other digital interfaces controlled or operated by Machine Maker Ltd., including its subdomains, complementary services, databases, functionalities, and third-party integrations.
4. Services – All technological, functional, and commercial resources offered by Machine Maker Ltd., including lead prospecting automation, public contact searching, automated communication, data analysis, and any other functionality described on the respective product pages.
5. User Account – A unique digital registration that identifies the User within the Machine Maker Ltd. platforms, containing personal data, access credentials, usage history, and contractual information. Account creation implies full acceptance of these Terms and the Privacy Policy.
6. Controller – Machine Maker Ltd., when it determines the purposes and means of processing personal data of users, clients, partners, and visitors to its platforms, as set forth in Applicable Data Protection Laws.
7. Processor – Machine Maker Ltd., when it processes personal data on behalf of corporate clients, according to the instructions received and in compliance with the principles and obligations set forth in Applicable Data Protection Laws.
8. Personal Data – Any information relating to an identified or identifiable natural person, including, but not limited to, name, email address, IP address, telephone number, payment information, and platform usage data.
9. Processing of Data – Any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, storage, deletion, evaluation, or control of information.
10. Payment Processors – Third-party companies responsible for processing financial transactions, issuing invoices, and validating payment methods used on the platforms. Machine Maker currently uses the following processors:
    • Stripe, Inc., subject to the Terms of Use available at https://stripe.com.
11. Data Protection Officer (DPO) – The person or function designated by Machine Maker Ltd. to act as a communication channel between the company, data subjects, and the relevant Supervisory Authority, available via email at support@eminer.app.
12. Partners and Authorized Third Parties – Natural or legal persons who act on behalf of Machine Maker Ltd. or under its supervision to perform operational, commercial, or technological activities, always bound by contracts that ensure confidentiality and compliance with data protection legislation.
13. Applicable Law – The set of current legal standards governing the matter, especially Applicable Data Protection Laws (including, where relevant, the General Data Protection Regulation - GDPR, and using other frameworks like Brazil's LGPD as a best-practice reference) and other relevant legal and regulatory provisions.

These definitions apply to the entire document and serve as an interpretive reference for the correct understanding and application of the provisions herein.

1.3. Description of Services

Machine Maker Ltd. develops and maintains an ecosystem of digital solutions focused on the automation of commercial prospecting, lead generation, and intelligent communication between companies and potential clients. The services provided by the company are offered under the principles of transparency, security, and compliance with applicable laws.

1.3.1. Products and Platforms

Machine Maker operates different specialized platforms that make up its portfolio of technological solutions:

• eMiner – An automation tool for capturing public contacts available from open sources, such as search engines, maps, and social networks, with a focus on the global public. It allows companies to build segmented lead lists for marketing and sales actions.
• Snout – A solution focused on searching for contacts of people and companies on professional social networks, with a focus on authenticity and communication efficiency.
• Prospecta – A tool that automates message sending and communication between companies and their potential clients, integrating digital channels and optimizing the commercial approach process.

In addition to these main services, Machine Maker may offer ancillary functionalities, integrations with third-party systems, and complementary tools (including those referred to as bonus tools), as described on the official pages of each product.

1.3.2. Nature of Services and Responsibility

The services of Machine Maker Ltd. are of a technological and automated nature, intended for professional and commercial use. The tools operate on public data obtained from open sources and do not collect, store, or process sensitive personal data without a legal basis or consent when necessary.

The User acknowledges that they are solely responsible for:

1. Defining the usage parameters and search criteria within the tools;
2. Analyzing and validating the data obtained;
3. Ensuring that the use of captured information complies with Applicable Law, including Applicable Data Protection Laws;
4. Maintaining ethical and respectful conduct when using the information obtained for commercial purposes.

Machine Maker is not responsible for decisions, communications, or commercial actions taken based on the information generated by the platforms. Improper or illegal use of the tools by the User may result in immediate account suspension and civil and criminal liability. The User's responsibility for their use of the data does not limit or negate Machine Maker Ltd.'s own obligations as a Data Controller or Processor under Applicable Data Protection Laws regarding the data it processes.

1.3.3. Technical and Operational Limitations

Machine Maker uses its best efforts to ensure the continuous and secure operation of its platforms but acknowledges that, as it is a digital environment, interruptions, failures, or technical limitations may occur due to external factors, such as:

• Instability of third-party networks (such as internet providers and external APIs);
• Changes in the access policies of partner platforms (e.g., Google, Meta, LinkedIn);
• Technological updates, scheduled maintenance, and security corrections.

The company reserves the right to perform updates, improvements, and infrastructure adjustments whenever necessary, aiming to improve the User experience and the security of the processed data.

1.3.4. Scope of Professional Use

Machine Maker's tools are intended exclusively for professional use by companies, entrepreneurs, salespeople, autonomous professionals, and consultants involved in prospecting, marketing, and B2B sales activities. Personal, recreational, or any use involving a purpose different from the original constitutes a violation of these Terms.

The User declares to be aware that Machine Maker Ltd. is not characterized as a marketing agency, data broker, or commercial intermediary, acting only as a technology provider that enables automated and legitimate access to public information.

1.3.5. Update and Evolution of Services

Machine Maker Ltd. may, at its sole discretion, introduce new functionalities, change existing features, discontinue tools, or adjust plans and commercial conditions. These changes do not constitute a breach of contract, provided that access to the contracted service is maintained for the current period.

Users will be previously notified of substantial changes via email or through the platforms themselves. New features may be made available for free, temporarily, or through additional contracting.

In all cases, the company commits to maintaining contractual balance and transparency in its relationships with clients and users.

1.4. Access and Eligibility

1.4.1. Access Requirements

To access the Platforms and Services, the User must be at least the legal age of majority in their jurisdiction (e.g., 18 years of age in many locations). If the User is not of legal age, they may only use the Services with the valid consent and under the supervision of a parent or legal guardian who agrees to be bound by these Terms on the User's behalf.

In the case of access on behalf of a legal entity, the individual accessing the platform declares and warrants that they have sufficient representative powers to bind the contracting company to all obligations arising from this instrument.

The creation of an access account, whether free or paid, requires the provision of true, complete, and up-to-date information. The User commits to keeping their registration data updated, including email, telephone, and payment information, and is solely responsible for any consequences arising from incorrect or outdated information.

1.4.2. Credentials and Access Security

The User is solely responsible for maintaining the confidentiality of their credentials (login and password) and for all activities carried out under their account. It is expressly prohibited to share access credentials with third parties, whether natural or legal persons, without prior written authorization from Machine Maker Ltd.

In case of suspected unauthorized access, loss, or theft of credentials, the User must immediately notify Machine Maker Ltd. at support@eminer.app, to allow for preventive blocking and investigation of the incident.

Machine Maker adopts appropriate technical and organizational measures to protect the information and accounts of its Users, including secure authentication, encryption, and access monitoring. However, the User acknowledges that, due to the nature of the internet, no system is absolutely free from vulnerabilities.

1.4.3. Suspension and Cancellation of Accounts

Machine Maker Ltd. reserves the right to suspend, limit, or cancel, at its sole discretion and without prior notice, the access of Users who:

• violate these Terms or applicable law;
• use the platform improperly, fraudulently, or in a manner harmful to third parties;
• attempt reverse engineering, copying, redistribution, or improper manipulation of the services;
• cause technical, reputational, or commercial damage to the company or other Users.

The cancellation of an account may imply the permanent deletion of associated data and content, in accordance with the rules of the Privacy Policy. The User may request the voluntary termination of their account at any time, subject to contractual conditions and legal retention periods.

1.4.4. Usage Limits and Responsibility

Each User account is personal and non-transferable. Simultaneous access by multiple individuals, resale of licenses, or shared use of credentials constitutes a contractual violation.

The User is responsible for ensuring that the use of the platforms respects laws on data protection, privacy, intellectual property, and ethical communication practices. Machine Maker Ltd. is not responsible for any improper or illegal use by its Users.

1.4.5. Platform Updates and Availability

Machine Maker uses its best efforts to ensure the full operation of its platforms 24 hours a day, 7 days a week. However, it may perform preventive or corrective maintenance, with or without prior notice, aiming for the continuous improvement of services.

In exceptional situations, such as technical failures, security incidents, or legal requirements, the company may temporarily suspend access to the platforms, committing to restore it as soon as possible. Temporary suspension for such reasons does not entitle the User to compensation or indemnification.

1.4.6. Legal Compliance and Ethical Use

The User commits to using the Machine Maker Ltd. platforms exclusively for lawful purposes, respecting good faith, commercial ethics, and current legislation. It is expressly forbidden to:

1. use the services to collect or process personal data irregularly;
2. send unsolicited communications (spam) or engage in abusive marketing practices;
3. violate copyrights, image rights, privacy, or any other third-party rights;
4. perform acts that may compromise the security or integrity of the platforms.

Failure to comply with these obligations may result in the immediate suspension of access and, if applicable, the adoption of appropriate legal measures.

1.5. Contracting and Payment

1.5.1. Subscription Modalities

Machine Maker Ltd. offers different subscription plan modalities for access to its platforms and services. The plans may be classified according to the billing frequency and the level of access to functionalities:

• Monthly Plan – active access for 30 (thirty) days, with specific promotional conditions and optional automatic renewal;
• Quarterly Plan – active access for 90 (ninety) days, with specific promotional conditions and optional automatic renewal;
• Semi-Annual Plan – active access for 180 (one hundred and eighty) days, with progressive discounts and the possibility of automatic renewal;
• Annual Plan – active access for 365 (three hundred and sixty-five) days, with the best cost-benefit conditions and an option for automatic renewal.

In all plans, the User may opt for automatic recurring billing, expressly authorizing the payment processor used (Stripe) to perform renewals automatically at the end of each cycle, according to the payment method saved in the registration. The User may deactivate the recurrence at any time through their account or via a support request.

1.5.2. Contracting Process

The contracting of services occurs electronically, upon acceptance of these Terms and the complete filling out of the registration form available on the Machine Maker Ltd. platforms. The User declares to have read and understood all conditions before confirming the purchase.

The electronic contract is formalized the moment the transaction is completed and confirmed by the payment processor. From that moment, the User acquires the right to access the service corresponding to the chosen plan, according to the commercial conditions in effect at the time of contracting.

Plans may include trial periods or specific promotional conditions, which are optional and granted at the sole discretion of Machine Maker Ltd. The use of such benefits is subject to the same rules of use and conduct provided in these Terms.

1.5.3. Payment Methods

Machine Maker Ltd. uses certified and secure payment processors to intermediate all financial transactions. Currently, the following processors are used:

• Stripe, Inc., headquartered in the United States, subject to the Terms of Use at https://stripe.com/legal/ssa;

Transactions are processed directly by the respective platforms, which have exclusive access to payment data. Machine Maker Ltd. does not store credit card information or other payment methods.

1.5.4. Issuance of Invoices and Proof of Payment

For each contract, an electronic invoice will be issued in the User's name, based on the data provided during registration. The User is responsible for ensuring the accuracy and updating of this information, under penalty of making the issuance of the fiscal document unfeasible.

Proof of payment is available on the processors' platforms and can be consulted at any time. Machine Maker Ltd. recommends that the User keep their proofs of payment archived for eventual checks.

1.5.5. Payment Failures and Access Suspension

If payment is not confirmed by the processor for any reason (insufficient funds, expired card, authentication failure, etc.), access to the account may be temporarily suspended until the pending issue is resolved.

Machine Maker Ltd. reserves the right to cancel the plan after 5 (five) calendar days of non-payment, and may reactivate it upon new payment. Cancellation for non-payment does not entitle the User to a refund or proportional credits.

1.5.6. Change of Plans and Update of Values

The User may change the contracted plan (upgrade or downgrade) by request in the client area or via contact with support. The new value will be applied in the next billing cycle.

Machine Maker Ltd. reserves the right to readjust the values of its plans, observing market conditions and operational costs. Price changes will be communicated at least 15 (fifteen) days in advance, applying only to new contracts or future renewals.

1.5.7. Promotional Conditions and Bonus Tools

Machine Maker Ltd. may offer ancillary tools or additional functionalities as a promotional bonus in certain subscription modalities (monthly, quarterly, semi-annual, or annual). These tools are granted as a courtesy and have no guarantee of availability or continuity, and may be modified or discontinued at any time without prior notice.

In the future, such functionalities may be transformed into independent products or plans, subject to specific contracting and their own values.

1.5.8. Cancellation and Refund Policy (Initial Purchase)

As part of our customer satisfaction policy, a User may request a full refund within seven (7) calendar days from the date of their initial purchase. This refund policy is detailed further in Section 1.6.

After this 7-day period, no refunds will be issued, except in exceptional situations evaluated individually by Machine Maker Ltd., such as duplicate billing, proven error in the transaction, or significant, prolonged technical failure recognized by the company.

The cancellation of a recurring plan will prevent future charges but will not generate a proportional refund for the period already used or remaining in the billing cycle.

This refund policy does not supersede any mandatory, non-waivable statutory rights (such as those under the EU Digital Content Directive, which may grant a 14-day withdrawal right that can be waived upon access to digital content) that may apply in the User's jurisdiction.

1.5.8.1. Partial Cancellation and Proportional Requests

Machine Maker Ltd.does not perform partial cancellations or proportional refunds at the User's request during the contracted period.

By adhering to a monthly, quarterly, semi-annual, or annual plan, the User acknowledges that the payment corresponds to the entirety of the contracted cycle, regardless of the total or partial use of the platform.

Only in cases where the company itself decides, at its discretion, to interrupt the service for technical, maintenance, or other justified reasons, may a proportional refund or compensatory credit be granted, at the sole discretion of Machine Maker Ltd.

Thus, the User may not request cancellation in the middle of the contracted period and claim a proportional refund of values referring to the remaining unused time.

1.5.8.2. Effects of Cancellation

The cancellation of a subscription implies:

1. Interruption of future automatic charges;
2. Maintenance of active access until the end of the cycle already paid for;
3. Extinction of bonuses, credits, and ancillary tools linked to the plan;
4. Preservation of the User's data according to the retention and deletion rules provided in the Privacy Policy (item 2.8).

1.5.8.3. User's Responsibility for Automatic Renewal and Lack of Use

The User acknowledges that the plans offered by Machine Maker Ltd. operate in automatic recurring billing mode, according to the frequency selected at the time of contracting (monthly, quarterly, semi-annual, or annual).

It is the User's entire responsibility to request, expressly and within the desired timeframe, the cancellation of the automatic renewal of their subscription, through the official channels indicated in this document.

The absence of this request will imply a valid automatic renewal, with regular billing of the value corresponding to the active plan.

1.5.8.3.1. Allegations of Non-Use

Machine Maker Ltd. does not provide refunds or credits for periods in which the User chose not to use the tool, kept the subscription active, and did not formally communicate the desire for cancellation.

The mere fact of not accessing or not using the functionalities does not constitute cancellation, withdrawal, or contractual suspension.

Thus, there is no provision for a refund of amounts already paid referring to periods in which the service remained available, even if not used.

The User agrees that the subscription grants the right of access to the platform during the contracted cycle, regardless of its effective use.

1.5.9. Proof of Contracting and Communications

The electronic confirmation of the transaction, confirmation emails, and electronic records maintained by Machine Maker Ltd. and its payment processors constitute valid and sufficient proof of the contract, dispensing with additional formalities.

All communications related to billing, renewal, cancellation, or contractual changes may be made via the email registered by the User or by notifications within the platform.

The contracting of services implies the User's acknowledgment that they have understood and fully accept the financial and operational conditions described in this item.

1.6. Cancellation and Refund Policy

1.6.1. Subscriptions, Automatic Renewal, and Cancellation Policy

1.6.1.1. Plan Modalities and Recurring Billing

Machine Maker Ltd. offers subscription plans with different frequencies, which may be Monthly, Quarterly, Semi-Annual, or Annual, as chosen by the User at the time of contracting.

By adhering to any plan, the User expressly and unequivocally authorizes the automatic and recurring billing of the corresponding amount, using the registered payment method and processed by the official intermediaries integrated into the company's platforms.

Billing will be carried out recurrently on the same day of each contracted cycle, until the User requests cancellation, subject to the conditions provided in this document.

1.6.1.2. Consent and Automatic Renewal

By contracting one of the available plans, the User expressly consents to the automatic renewal of the subscription at the end of each cycle, under the same conditions previously contracted, until a contrary manifestation is made.

The User may cancel the automatic renewal at any time, directly on the platform or by request to the official support, through the email support@eminer.app.

1.6.1.3. Cancellation and Refund Policy

The User may cancel the subscription at any time, subject to the following conditions:

1. Cancellation interrupts the automatic billing of future cycles, maintaining access until the end of the period already paid for;
2. If the cancellation occurs within seven (7) calendar days following the initial purchase, the User may be eligible for a full refund in accordance with our refund policy (see Section 1.6.2);
3. After this period, there will be no proportional refund, except in specific cases of proven failure in the provision of the service, to be evaluated individually by Machine Maker Ltd.

Requests must be sent to the official customer service channel.

1.6.1.4. Payment Intermediation and Security

Financial information is processed exclusively by the payment intermediaries integrated into the company's platforms, such as Stripe, according to their respective Privacy Policies and Terms of Use.

Machine Maker Ltd.does not store, process, or have access to credit card data or bank credentials of Users, maintaining full compliance with Applicable Data Protection Laws and international security standards (PCI-DSS).

1.6.1.5. Consequences of Non-Payment

In the event of non-payment, delay, or failure in recurring billing, Machine Maker Ltd. may:

1. Temporarily suspend access to the platform and contracted services until the payment is regularized;
2. Automatically cancel the subscription, if the debt is not regularized within 2 (two) calendar days after the due date;
3. Not perform automatic renewal until confirmation of the new payment;
4. Forward the outstanding amount to the billing intermediary for recovery measures or definitive cancellation of the subscription.

During the period of non-payment, the User will remain responsible for the amounts due, without prejudice to charges or monetary correction.

1.6.1.6. Update of Values and Conditions

Machine Maker Ltd. reserves the right to adjust prices, plans, or conditions of use at any time, upon prior communication to the User, at least 7 (seven) calendar days before the next renewal.

If the User does not agree with the new conditions, they may choose not to renew their subscription or request cancellation before the automatic renewal date.

1.6.1.7. Voluntary Termination and Effects

The cancellation of the subscription does not imply the immediate deletion of the User's personal data, which will continue to be stored according to the terms and conditions provided in the Privacy Policy (item 2.8).

After termination, the User loses the right of access to premium functionalities and any bonuses linked to the contracted plan.

1.6.2. Refund Policy (Initial Purchase)

Machine Maker Ltd. offers a 7-day refund policy for a User's first subscription purchase. A refund request must be submitted via email to support@eminer.app within seven (7) calendar days of the initial payment confirmation.

This policy applies only to the initial purchase and not to any subsequent renewals, upgrades, or plan changes.

Once the request is received, it will be analyzed and processed within 10 (ten) business days, respecting the operational deadlines of the payment processors (Stripe). The refund will be made using the same original payment method, except in exceptional cases duly justified.

1.6.3. Limitations on Refund Policy

This refund policy does not apply to Users who:

1. Are renewing an existing subscription;
2. Are upgrading or changing an existing plan;
3. Have already received a refund in previous contracts;
4. Have already significantly used the platform's functionalities (e.g., performed extensive data exports or automations) during the 7-day period, as determined at our reasonable discretion;
5. Have benefited from specific promotional conditions or courtesy access that explicitly excluded refunds.

These restrictions aim to prevent abuse of the policy and ensure contractual balance, considering that access to digital tools implies immediate consumption of technological resources.

1.6.4. Cancellation of Recurring Subscriptions

The User acknowledges that the plans offered by Machine Maker Ltd. operate under automatic recurring billing, according to the frequency chosen at the time of contracting (monthly, quarterly, semi-annual, or annual).

It is the User's entire responsibility to request the cancellation of the automatic renewal of their subscription when they wish to end the contractual relationship.

The cancellation must be requested exclusively in writing, through the official support: support@eminer.app.

The request will be analyzed and processed within 10 (ten) business days after receipt.

Cancellation prevents future charges, but does not generate a proportional refund for the period already contracted or in progress.

Access to the platform will remain active until the end of the current cycle, unless the User requests immediate termination.

After cancellation, access will be automatically suspended, and the data linked to the account will be maintained according to the terms and conditions provided in the Privacy Policy.

1.6.5. Cancellation for Non-Payment or Violation of Terms

Machine Maker Ltd. may suspend or cancel the User's access in cases of:

• Payment failure not regularized within 5 (five) calendar days;
• Violation of these Terms of Use;
• Improper, fraudulent use, or use that causes damage to the company, third parties, or the integrity of the platforms.

In such cases, the company reserves the right to not grant a refund and may take appropriate administrative or legal measures. Cancellation for non-payment or misconduct does not exempt the User from pending financial obligations.

1.6.6. Cancellation by Initiative of Machine Maker Ltd.

Machine Maker Ltd. may, at its discretion, terminate the offer of certain plans or functionalities. In these situations, affected Users will be notified at least 15 (fifteen) days in advance and will have the right to full use of the service until the end of the contracted period.

In exceptional cases, such as the definitive discontinuation of a service, the User may be offered a proportional refund for the unused time or migration to an equivalent product, according to the client's choice and technical availability.

1.6.7. Refund Procedures and Deadlines

Refunds, when applicable according to the conditions of this Term, will observe the following parameters and deadlines:

• Processing time: Approved requests will be processed within 10 (ten) business days, counted from confirmation by Machine Maker Ltd.;
• Credit card payments: The amount will be refunded directly to the invoice linked to the card used, according to the rules and deadlines of the administrator;
• Bank Transfer or Direct Debit Payments: The refund will be made via deposit into a bank account informed by the User, provided that it is in the name of the same holder as the original payment;
• Instant Payment Methods (e.g., PIX): The amount will be refunded to the same bank account that made the payment, where technically feasible;
• Responsibility of intermediaries:Machine Maker Ltd. is not responsible for delays, unavailability, or failures arising from financial intermediaries, payment gateways, or banking institutions, as such deadlines are subject to external clearing policies.

1.6.8. Special Cases and Contractual Good Faith

Machine Maker Ltd. reserves the right to analyze exceptional situations in which the User alleges relevant damage or operational error. In these cases, the company may, at its sole discretion, grant compensatory credits, access extension, or partial refund, always guided by good faith and reasonableness.

1.6.9. Effects of Cancellation

Cancellation, whether by initiative of the User or Machine Maker Ltd., implies:

1. Suspension of access to platforms and premium functionalities;
2. Progressive inactivation or deletion of the account, according to the legal data retention period;
3. Loss of any bonuses, promotions, or courtesy functionalities linked to the canceled plan;
4. Maintenance of the obligation to settle outstanding amounts up to the effective date of termination.

1.6.10. Transparency and Communication

Machine Maker Ltd. will maintain clear and accessible communication about cancellation and refund procedures, providing dedicated service channels and records of all requests made.

The User will be informed, via registered email, about the progress of any cancellation or refund request, including confirmations, deadlines, and final results.

This policy aims to balance the rights and duties between the parties, ensuring the legal security of the contractual relationship and the responsible continuity of the digital services offered by Machine Maker Ltd.

1.6.11. Chargeback and Re-contracting Policy

1.6.11.1. Definition

For the purposes of this instrument, chargeback is considered the procedure of disputing a payment with the credit card operator, bank, or payment intermediary, through which the User requests the reversal of amounts already charged and processed.

While chargebacks are a legitimate consumer protection tool, their improper use (e.g., requesting a chargeback after having legitimately used the services, or as a means to bypass the refund policy) characterizes a contractual breach and causes direct financial loss to Machine Maker Ltd.

1.6.11.2. Consequences of Improper Chargeback

If it is identified that the User used the services, had access to the platform, and subsequently initiated a chargeback without first attempting to resolve the issue with our support team, or in a manner deemed fraudulent or in bad faith, Machine Maker Ltd. reserves the right to:

1. Immediately block the User's access to the platform and contracted functionalities;
2. Register the event internally and associate the occurrence with the User's account details and email;
3. Contest the chargeback by providing evidence of service access and use to the payment intermediary;
4. Suspend or refuse future services to the User until the reversed amount (and any associated chargeback fees) is reimbursed.

1.6.11.3. Re-contracting and Compensation of Values

If a User who initiated an improper chargeback attempts to re-contract the services in the future, the following rules may apply at our discretion:

1. Full use of the previous period: If the User used the entire contracted period before the chargeback, any new payments may be first applied to settle the outstanding debt. Service may not be reactivated until the previous financial loss is fully compensated.
2. Partial use of the previous period: If the User used only part of the previous cycle, the value of the new payment may be applied to cover the debt, and any remaining amount may be proportionally converted into credit for future use.
3. Recurring chargebacks: Repeated instances of improper chargebacks may result in the permanent refusal of service, at our sole discretion, to mitigate financial risk.

1.6.11.4. Communication and Transparency

The User will be notified by email about any suspension of access or application of funds resulting from a chargeback.

The communication will be made through the email address registered at the time of contracting and will be considered valid for all legal purposes.

1.6.11.5. User Responsibility

The User acknowledges that, by using the platform and subsequently disputing a legitimate charge improperly, they incur a contractual violation and are liable for the resulting financial damages.

Machine Maker Ltd. reserves the right to protect its legitimate interests, including by using lawful collection methods or adopting appropriate administrative or judicial measures to recover losses.

1.6.11.6. Good Faith and Reversal of Chargebacks

We urge Users to contact our support team at support@eminer.app to resolve any billing disputes. In cases where a chargeback is proven to be the result of a genuine mistake, technical failure, or bank error, Machine Maker Ltd. will cooperate fully to resolve the issue, re-establish the User's access, and reverse any blocks upon regularization with the payment intermediary.

1.7. User Obligations

1.7.1. General Conduct and Ethical Use

The User agrees to use the platforms, tools, and services of Machine Maker Ltd. ethically, responsibly, and in compliance with current legislation. The use of the services must respect the principles of good faith, transparency, legitimate purpose, and respect for third-party rights.

It is expressly prohibited for the User to:

1. Use the services for illicit, abusive, defamatory, fraudulent, or purposes contrary to morals and good customs;
2. Employ any means to circumvent technical restrictions, exploit vulnerabilities, or perform reverse engineering on the platforms;
3. Use data obtained through the tools for spam, harassment, discrimination, fraud, or any type of unethical commercial approach;
4. Copy, reproduce, distribute, or commercialize, in whole or in part, any content or code belonging to Machine Maker Ltd. without express authorization;
5. Share access credentials with third parties, unless formally and in writing authorized by the company.

Failure to comply with these obligations may result in the immediate suspension of the account, without prejudice to applicable administrative, civil, and criminal measures.

1.7.2. Responsibility for the Use of Information

The tools provided by Machine Maker Ltd. offer automated access to public information. It is exclusively the User's responsibility to ensure that the use of this information occurs within legal and ethical limits.

The User acknowledges and accepts that:

• The use of the information obtained is their sole responsibility;
• Any communication, offer, or contact derived from this information must respect data protection, privacy, and advertising regulations;
• The processing of third-party personal data requires an appropriate legal basis, in accordance with Applicable Data Protection Laws;
• Machine Maker Ltd. is not responsible for the content, accuracy, or updating of public information obtained through its tools.

The User's responsibility for their use of data does not limit or negate Machine Maker Ltd.'s own statutory obligations as a Data Controller or Data Processor under Applicable Data Protection Laws.

1.7.3. Data Updates and Account Security

The User is responsible for keeping their registration information up-to-date, including email, telephone, and billing data. Omission or incorrect provision of information may lead to suspension of the service, impediment of communication, or billing failures.

Access credentials are personal and non-transferable. The User must take appropriate measures to ensure the confidentiality of their password and prevent unauthorized access. If any improper use is identified, they must immediately notify Machine Maker Ltd. at support@eminer.app.

1.7.4. Respect for Intellectual Property

The User acknowledges that all elements of the platforms (codes, design, logos, trademarks, databases, content, texts, images, interfaces, and algorithms) are the exclusive property of Machine Maker Ltd. or its licensors, and are protected by copyright, trademark, and industrial property rights.

The User is prohibited from:

• Reproducing, modifying, distributing, or creating derivative works from any part of the platforms;
• Using the name, logo, or visual identity of Machine Maker Ltd. for promotional purposes without authorization;
• Registering domains, applications, or products that may cause confusion with the company's brands or products.

Violation of such rights will subject the infringer to the civil, administrative, and criminal sanctions provided by law.

1.7.5. Cooperation and Communication

The User agrees to cooperate with Machine Maker Ltd. in the event of audits, security investigations, or incidents related to the use of the platforms. This cooperation includes providing relevant information, preserving records, and transparent communication about any irregularities.

All official communications between the User and the company must occur through the official channels informed on the website or corporate emails with the domain @eminer.app. The company is not responsible for communications made outside these channels.

1.7.6. Liability in Case of Violation

The User agrees to indemnify and hold harmless Machine Maker Ltd., its administrators, partners, and employees from any losses, damages, claims, liabilities, costs, and expenses (including attorneys' fees) resulting from:

• Violation of these Terms or any applicable legislation;
• Improper or illegal use of the platforms;
• Third-party claims (including from data subjects) arising from the User's abusive communications or data handling practices;
• Damages caused to the company's reputation, operation, or technological infrastructure.

Machine Maker Ltd. reserves the right to suspend, terminate, or restrict the access of Users who violate these Terms, without obligation of prior notice or refund of amounts paid.

1.7.7. Best Practices and Professional Ethics

The User must observe the principles of transparency, respect, empathy, and integrity in interactions carried out through the Machine Maker Ltd. platforms. The use of the tools must contribute to building ethical and sustainable commercial relationships, without abusive or invasive practices.

Machine Maker encourages its Users to adopt internal policies of compliance and data governance, reinforcing the commitment to privacy, security, and the responsible use of accessed information.

1.7.8. Bonus Tools and Ancillary Functionalities

1.7.8.1. Definition and Promotional Nature

Machine Maker Ltd. may offer Users certain additional tools, functionalities, or integrations as a bonus, courtesy, or experimental feature, linked to paid plans or specific promotions.

These resources are provided at no additional cost and do not constitute an essential part of the contracted services, being considered promotional benefits offered at the company's discretion.

1.7.8.2. Absence of Obligation of Continuity

Bonus tools and ancillary functionalities may be interrupted, modified, replaced, or discontinued at any time, at the sole discretion of Machine Maker Ltd., without this generating any right to compensation, value reduction, refund, or reimbursement for the User.

The removal of such resources will not affect the validity or continuity of the main contracted service.

1.7.8.3. Communication and Transparency

Whenever possible, Machine Maker Ltd. commits to communicating previously to Users any changes, replacements, or deactivations of bonus tools.

However, this communication is optional and may occur through official support channels, notifications on the platform, or updates to the Terms of Use and Privacy Policy.

1.7.8.4. Experimental Phase and Warranty Limitations

Bonus functionalities may be in a beta or experimental phase, and may present instabilities, technical limitations, or performance variations.

Machine Maker Ltd. does not guarantee the continuous operation, compatibility with all browsers, or full technical support for these tools.

The User acknowledges that the use of these resources is voluntary and at their own risk, agreeing that their eventual deactivation does not constitute a contractual breach.

1.7.8.5. Contractual Independence

The inclusion or removal of bonus tools does not alter the values, conditions, or terms of the contracted subscription plans.

The continuity of these functionalities will depend on the company's strategic decision and may, in the future, be converted into an autonomous service through a formal offer and specific contract.

1.8. Intellectual Property

1.8.1. Ownership of Rights

All content, software, design, logos, interfaces, databases, algorithms, texts, images, videos, sounds, graphics, technical documentation, and other elements that make up the platforms of Machine Maker Ltd. are protected by intellectual, industrial, and copyright property rights, in accordance with applicable international and local legislation.

The full ownership of these rights belongs to Machine Maker Ltd., or is duly licensed by third parties. No property right is transferred to the User, who is granted only a limited, revocable, non-exclusive, and non-transferable license to use, strictly for the purpose of using the services according to these Terms.

1.8.2. Limits of Use

The User is expressly prohibited, except with formal written authorization from Machine Maker Ltd., from:

1. Reproducing, copying, modifying, translating, adapting, or creating derivative works from any part of the platforms;
2. Distributing, reselling, sublicensing, renting, assigning, or commercializing, in whole or in part, the company's products and services;
3. Removing or altering copyright notices, trademarks, trade names, or property notifications;
4. Engaging in reverse engineering, decompilation, disassembly, code interception, or attempting unauthorized access to the company's systems;
5. Registering domains, applications, or services that may cause confusion with the brands or products of Machine Maker Ltd.

The improper use of any protected material may result in immediate termination of the contract and the adoption of legal measures for compensation of material and moral damages.

1.8.3. Trademarks, Trade Names, and Visual Identity

The trademarks Machine Maker, eMiner, Snout, Prospecta, and other distinctive signs related to its platforms are the exclusive property of Machine Maker Ltd., registered or in the process of registration with the relevant national and international intellectual property offices.

No right to use the trademarks or elements of visual identity is granted to the User, except when expressly authorized by a partnership, license, or affiliate program contract. Any unauthorized use constitutes an infringement of trademark rights and subjects the infringer to the penalties provided by law.

1.8.4. User-Generated Content

The User may insert or generate content on the platforms (such as messages, texts, images, or client data), provided that applicable laws and good usage practices are observed. By submitting any content, the User:

• Declares to be the owner of the rights to the submitted material or to have valid authorization for its use;
• Grants Machine Maker Ltd. a non-exclusive, free, worldwide, and indefinite license to store, process, and use the content strictly for the purpose of executing the contracted services;
• Assumes full civil and criminal liability for any violations of copyright, privacy, image, or intellectual property rights of third parties.

Machine Maker reserves the right to remove, without prior notice, any content that violates these Terms or that may compromise the security, reputation, or operation of the platforms.

1.8.5. Licensing and Technological Partnerships

Certain functionalities of the platforms may use libraries, APIs, third-party software, or technologies licensed under specific contracts. Machine Maker Ltd. ensures that such integrations occur in compliance with the applicable licenses, and that use by Users remains restricted to the contracted purposes.

Integrations with external platforms (such as Google, Meta, LinkedIn, or other data and authentication providers) follow the respective Terms of Use and Privacy Policies of those companies, which the User declares to know and accept when using such resources.

1.8.6. Violations and Penalties

Violation of the intellectual property rights of Machine Maker Ltd. or third parties may lead to:

• Immediate suspension or termination of the User's account;
• Civil, administrative, and criminal liability of the infringer;
• Compensation for losses and damages, including lost profits and legal costs;
• Communication to the competent authorities and the affected rights holders.

Machine Maker Ltd. may, at its discretion, take extrajudicial and judicial measures to protect its intangible assets, including infringement notifications, domain blocking, and registration of digital evidence.

1.8.7. Respect for Innovation and Originality

Machine Maker Ltd. continuously invests in research, innovation, and development of its own solutions. The User acknowledges and values this investment, committing to respect intellectual rights and not to reproduce, directly or indirectly, the concepts, methodologies, architectures, or technical solutions used in the platforms.

Respect for intellectual property constitutes an essential pillar of the relationship between Machine Maker Ltd. and its Users, being indispensable for maintaining trust and the integrity of the digital ecosystem.

1.9. Warranty and Limitation of Liability

1.9.1. Nature of Services and Absence of Absolute Warranty

The services offered by Machine Maker Ltd. are provided "as is", based on a high-availability technological infrastructure and good information security practices. However, the User acknowledges that, due to their digital nature and dependence on external factors, it is not possible to guarantee continuous, uninterrupted, or error-free operation.

Machine Maker Ltd. is not responsible for temporary unavailability, delays, performance failures, or interruptions resulting from:

1. Technical problems in communication networks, internet providers, third-party APIs, or data centers;
2. Updates or scheduled maintenance necessary for the improvement of services;
3. External interferences, cyber attacks, viruses, malware, force majeure events, or fortuitous events;
4. Operational errors committed by the User, their employees, or third parties under their responsibility.

In all cases, the company will make reasonable efforts to restore the normal operation of the systems as quickly as possible and maintain transparent communication with Users.

1.9.2. Limitation of Civil Liability

In no event shall Machine Maker Ltd., its partners, administrators, employees, or collaborators be liable for:

• Indirect, incidental, special, consequential, or punitive damages;
• Loss of profits, revenue, data, business opportunities, or expected savings;
• Commercial or contractual decisions made based on information obtained through the platforms;
• Third-party actions, abusive communications, or illicit conduct carried out by Users.

The total liability of Machine Maker Ltd., in any hypothesis, shall not exceed the amount effectively paid by the User in the 12 (twelve) months prior to the event that gave rise to the claim. This limitation reflects the contractual balance and the digital nature of the service.

1.9.3. Disclaimer of Liability for External Content and Data

The platforms of Machine Maker Ltd. may interact with public or third-party data sources, such as Google Maps, Meta, LinkedIn, Bing, among others. The company does not control or validate the information originating from these sources, and the User is solely responsible for the interpretation and use of the data obtained.

Machine Maker Ltd. does not guarantee:

• The accuracy, integrity, or timeliness of information extracted from external sources;
• The continuous maintenance of integrations with third-party services, which may be modified or discontinued at any time;
• The uninterrupted operation of third-party APIs, plug-ins, integrations, and authentication services.

1.9.4. User's Responsibility for the Use of Tools

The User acknowledges that the tools offered by Machine Maker Ltd. are technological instruments and do not replace human judgment, professional discernment, or critical analysis. The use of the information obtained must always be accompanied by verification, validation, and compliance with applicable regulations.

The User will be fully responsible for:

1. Any commercial action, message, proposal, or contact made based on the data obtained;
2. Ensuring that their activities comply with Applicable Data Protection Laws and other privacy legislation;
3. Complying with marketing, advertising, fair competition, and consumer protection laws;
4. Answering for any damages or infractions resulting from the improper use of the platforms.

This clause does not limit Machine Maker Ltd.'s liability or obligations as a Data Controller or Processor where mandated by Applicable Data Protection Laws.

1.9.5. Force Majeure Events

Machine Maker Ltd. will not be held responsible for failures or contractual breaches resulting from force majeure or fortuitous events, as provided for in applicable civil law, including, but not limited to:

• Natural disasters, pandemics, strikes, fires, floods, sabotage, cyber attacks, wars, infrastructure collapses, or government decisions;
• Suspensions or restrictions imposed by regulatory authorities or essential service providers.

During the occurrence of such events, contractual deadlines may be suspended, and the effects of liability attenuated or extinguished, according to the severity and duration of the event.

1.9.6. Procedures in Case of Incidents

In the event of a technical or security incident that affects the availability or integrity of the services, Machine Maker Ltd. will:

• Immediately adopt containment and risk mitigation measures;
• Inform affected Users about the situation, whenever there is a relevant impact;
• Cooperate with authorities and regulatory bodies, when applicable;
• Take the necessary steps to restore operational normality.

These procedures follow the guidelines of the relevant Data Protection Authorities and industry best practices.

1.9.7. Limited Warranties

Machine Maker Ltd. warrants that:

1. Its platforms are developed based on legitimate and secure technology;
2. The processing of personal data observes high standards of security and confidentiality;
3. The company acts in good faith and with diligence to ensure the quality and continuity of services.

Nevertheless, the company does not guarantee specific commercial results, increase in sales, profit generation, or minimum performance in campaigns or actions carried out by Users. The success of using the tools depends on factors external to the company, including commercial strategy, market, segmentation, and execution of actions.

1.9.8. Communication and Support

Machine Maker Ltd. offers official support and asynchronous communication channels, available during business hours and via email. Support aims to clarify technical doubts and guide the proper use of the tools, not including personalized consulting or manual interventions in the User's operations.

The User acknowledges that the company has no obligation of real-time support, except in plans that expressly provide for this type of service.

1.9.9. Contractual Balance and Good Faith

The provisions of this item aim to ensure contractual balance and predictability in the relationship between the parties. Machine Maker Ltd. commits to acting with transparency, diligence, and good faith, preserving the User's trust and the continuity of services within the applicable technical and legal limits.

1.9.10. Disclaimer for Third-Party Platforms

1.9.10.1. Interaction with External Services

The platforms operated by Machine Maker Ltd., including eMiner and other solutions in the ecosystem, may integrate or interact with third-party services, such as Google Maps, Google My Business, LinkedIn, Instagram, Facebook, WhatsApp, and other public or commercial platforms.

These integrations occur through the legitimate use of information that is public or made available by the data subjects themselves and are subject to the terms of use and privacy policies of these external platforms.

1.9.10.2. Absence of Affiliation or Warranty

Machine Maker Ltd.has no corporate, contractual, or representative affiliation with the aforementioned platforms.

The User's use of the prospecting and automation tools offered must respect the policies, guidelines, and technical limitations imposed by each external service.

The company does not guarantee the continuity, stability, or compatibility of integrations with such platforms, which may modify their systems, APIs, or policies without prior notice.

1.9.10.3. Blocks, Suspensions, and Penalties

Machine Maker Ltd.is not responsible for blocks, suspensions, bans, or account restrictions imposed by third-party platforms (such as Google, Meta, WhatsApp, or LinkedIn), resulting from:

1. Improper, abusive, or automated use of the tools;
2. Violation of the terms of use of such platforms;
3. Technical or policy changes external to the company's control.

The User acknowledges that the use of integrations and automations is carried out at their own risk, and they must strictly observe the best practices and usage recommendations provided by Machine Maker Ltd.

1.9.10.4. Recommendations for Responsible Use

Machine Maker Ltd. provides technical and security guidelines for the responsible use of its tools, including volume limits, intervals, and good prospecting practices.

Failure to comply with these recommendations may result in a temporary or permanent restriction of access to the platform, without the right to a refund, if the use results in a violation of third-party terms or causes damage to the operation of the services.

1.10. Termination

1.10.1. Grounds for Termination

This agreement for the use of the platforms and services of Machine Maker Ltd. may be terminated by either party, at any time, under the following circumstances:

1. By User's initiative, through a formal request for account cancellation or interruption of the subscription;
2. By Machine Maker Ltd.'s initiative, in cases of violation of the Terms of Use, non-payment, improper use, illicit practice, or contractual breach;
3. By mutual agreement between the parties, formalized electronically;
4. By legal or judicial determination, when there is a requirement to suspend activities or mandatory termination of the service.

1.10.2. Termination by User's Initiative

The User may terminate this contract at any time by requesting the closure of their account through the tools available on the platform itself or by written communication to Machine Maker Ltd. support at support@eminer.app.

Account closure does not imply a refund of amounts paid for the period already contracted, except in the cases provided for in the Cancellation and Refund Policy (item 1.6). The User will remain responsible for any outstanding financial obligations up to the effective date of termination.

The request for account deletion will also imply the deletion or anonymization of personal data, as provided in the Privacy Policy, respecting the legal data retention periods.

1.10.3. Termination by Machine Maker Ltd.'s Initiative

Machine Maker Ltd. may unilaterally terminate the contract and suspend the User's access, with or without prior notice, in the following situations:

• Improper or fraudulent use of the platforms;
• Failure to comply with any clause of these Terms;
• Practice of acts that may cause technical, reputational, or financial damage to the company or third parties;
• Non-payment for more than 5 (five) calendar days;
• Actions that contravene the law, ethics, morals, or contractual good faith.

In such cases, termination will not entitle the User to a refund, compensation, or restitution of amounts already paid. The company may also take appropriate legal measures and communicate to the competent authorities if it identifies signs of fraud, bad faith, or rights violations.

1.10.4. Effects of Termination

Contractual termination, regardless of the cause, produces the following immediate effects:

1. Termination of access to platforms and premium functionalities;
2. Progressive inactivation or deletion of the User's account, according to data retention rules;
3. Loss of bonuses, credits, courtesy functionalities, or promotional access linked to the terminated plan;
4. Maintenance of financial obligations already due;
5. Extinction of the license to use granted to the User over the company's systems and products.

Termination does not prejudice Machine Maker Ltd.'s right to seek compensation for damages caused by the User during the term of the contract.

1.10.5. Temporary Suspension

Before definitive termination, Machine Maker Ltd. may apply a temporary suspension of the account, total or partial, when it identifies conduct that potentially violates these Terms. The suspension is preventive and may be reversed if the User proves the regularity of their conduct.

During the suspension period, the User will not have access to restricted functionalities and will not be entitled to financial compensation or extension of the subscription period.

1.10.6. Reactivation and Re-contracting

The User may request the reactivation of their account after regularizing contractual or financial pending issues. Reactivation will be subject to analysis and approval by Machine Maker Ltd., which may require a new contract or acceptance of the Terms of Use in effect at the time.

The company reserves the right to refuse new contracts from Users who have a history of fraud, contractual violation, misconduct, or improper use of the platforms.

1.10.7. Service Discontinuation

Machine Maker Ltd. may, by strategic, technical, or legal decision, discontinue, in whole or in part, its platforms or certain products, provided that it communicates this to Users at least 15 (fifteen) days in advance.

In these cases, the company may offer alternatives such as:

• Proportional refund for the unused period;
• Migration to another equivalent product;
• Maintenance of access until the end of the current cycle.

The discontinuation of products or functionalities does not generate the right to additional compensation, provided that contractual and legal guarantees are observed.

1.10.8. Survival of Clauses

Even after the termination of the contract, the provisions that, by their nature, must survive, will remain in full force and effect, including those related to:

• Intellectual property (Section 1.8);
• Confidentiality and data protection (Section 2);
• Limitation of liability (Section 1.9);
• User Obligations and Indemnification (Section 1.7);
• Pending financial obligations;
• Jurisdiction and applicable law (Section 1.11).

1.10.9. Good Faith and Transparency

Machine Maker Ltd. commits to conducting all termination processes with transparency, good faith, and respect for the User, ensuring that any contractual termination is duly justified and communicated through official means.

The User, in turn, acknowledges that the continuity of access and use of the platforms depends on the full compliance with their contractual and legal obligations.

1.10.10. User Support and Service

1.10.10.1. Official Support Channel

Technical and operational support for Users of Machine Maker Ltd. products and services is provided exclusively by email, through the address support@eminer.app, or other channels expressly informed on the official platforms.

The company does not offer support by phone, WhatsApp, or real-time chat, except in exceptional and previously communicated situations.

1.10.10.2. Service Hours

Service is provided during business hours, from Monday to Friday, 9:00 AM to 6:00 PM (UTC-3), except on national or regional holidays.

Requests received outside these hours will be automatically registered and analyzed on the next business day.

1.10.10.3. Response Time

Machine Maker Ltd. commits to responding to all requests within 2 (two) business days after receiving the message, observing the chronological order of entry and the nature of the demand.

In cases that require more in-depth technical analysis, the deadline may be extended, and the User will be informed about the progress of the service.

1.10.10.4. Scope and Limitations of Support

Support exclusively covers issues related to the regular operation of the platforms and Users' operational questions.

The scope of support does not include:

1. Personalized consulting on marketing, sales, or prospecting;
2. Configuration of external accounts (such as emails, servers, WhatsApp, or third-party integrations);
3. Specific technical adjustments in the User's environment;
4. Problems arising from improper use, unauthorized installations, or modifications to the tool.

1.10.10.5. Communication and Registration

All support interactions are registered and archived by Machine Maker Ltd. for auditing, quality control, and legal security purposes.

The User agrees that contact via email is sufficient and appropriate to meet their communication needs related to the contracted service.

1.10.10.6. Good Communication Practices

To expedite service, the User must provide clear and complete information about the reported problem, including:

• Email address registered in the account;
• Detailed description of the situation;
• Screenshots or evidence, when applicable.

Generic, incomplete, or offensive messages may be disregarded, and the company reserves the right to terminate abusive or bad-faith communications.

1.11. Jurisdiction and Applicable Law

1.11.1. Governing Law

These Terms of Use and all legal relationships between the User and Machine Maker Ltd. shall be governed and construed in accordance with the laws of England and Wales, without regard to its conflict of law provisions.

1.11.2. Dispute Resolution

Any dispute, controversy, or claim arising out of or relating to these Terms, or the breach, termination, or invalidity thereof, shall be settled by arbitration in accordance with the UNCITRAL Arbitration Rules as at present in force.

1. The appointing authority shall be the London Court of International Arbitration (LCIA).
2. The number of arbitrators shall be one.
3. The place of arbitration shall be London, United Kingdom.
4. The language to be used in the arbitral proceedings shall be English.

This clause applies to all contractual disputes, unless prohibited by mandatory consumer protection law in the User's jurisdiction, in which case the User's local courts may have jurisdiction.

1.11.3. Amicable Dispute Resolution

Before resorting to arbitration, the parties commit to seeking an amicable solution to any disagreement through direct communication or intermediation of the Machine Maker Ltd. service channel, available at support@eminer.app.

The company commits to analyzing and responding to all formal requests, notifications, and complaints within a maximum period of 15 (fifteen) business days, seeking conciliation and contractual balance between the parties.

1.11.4. Validity and Contractual Interpretation

The eventual nullity, invalidity, or ineffectiveness of any clause of these Terms shall not prejudice the other provisions, which will remain in full force and effect.

In case of doubt in interpretation, the reading most favorable to the preservation of the contractual object and good faith between the parties shall prevail. No omission shall be interpreted in a way as to generate a waiver of rights by Machine Maker Ltd.

1.11.5. Update Date and Effectiveness

These Terms of Use come into effect on the date of their publication and will remain valid for an indefinite period, as long as they are not replaced by a new version.

The date of the last update will always be informed at the beginning of the document and on the official channels of Machine Maker Ltd., serving as a reference for identifying the most recent version.

1.11.6. Final Provisions

The tolerance of Machine Maker Ltd. regarding non-compliance with any obligation provided in these Terms will not imply novation, waiver, or contractual alteration.

These Terms constitute the entire agreement between Machine Maker Ltd. and the User, superseding all previous understandings or communications, whether verbal or written, related to the use of the company's platforms and services.

The User declares to have read, understood, and fully accepted these Terms, committing to respect all their provisions during the use of the digital platforms of Machine Maker Ltd.

2. Privacy Policy

2.1. Controller and Processor

2.1.1. Legal Framework

Machine Maker Ltd. acts as a Data Controller and, in certain situations, as a Data Processor of personal data, in accordance with Applicable Data Protection Laws (such as the GDPR).

The company's classification in one condition or the other depends on the nature of the relationship with the data subject:

• As Controller, Machine Maker determines the purposes and means of processing the personal data of Users, clients, partners, and visitors to its platforms.
• As Processor, Machine Maker processes personal data on behalf of its corporate clients (contractors), who act as Controllers, performing technical activities according to their specific instructions and always within the legal limits established by Applicable Data Protection Laws.

2.1.2. Role and Responsibilities

Machine Maker Ltd., as Controller, is responsible for:

1. Determining the purpose and legal basis for the processing of personal data;
2. Implementing technical and administrative measures to ensure the security, confidentiality, and integrity of the data;
3. Responding to requests from data subjects regarding the exercise of their rights under Applicable Data Protection Laws;
4. Ensuring that data is processed lawfully, fairly, and in a manner compatible with the informed purposes;
5. Communicating to the relevant Supervisory Authority (SA) and data subjects any security incidents that may pose a significant risk or harm.

When acting as Processor, Machine Maker:

1. Will process personal data only on documented instructions from the client (Controller);
2. Will ensure that persons authorized to process personal data are subject to duties of confidentiality;
3. Will adopt all appropriate security measures to protect the processed data;
4. Will cooperate with the Controller to fulfill legal obligations related to data protection;
5. Will ensure the deletion or return of data at the end of the contractual relationship, as requested by the Controller.

2.1.3. Data Protection Officer (DPO) Contact Details

The Data Protection Officer (DPO) is responsible for communication between Machine Maker Ltd., data subjects, and the SA. The DPO can be contacted through the following official channels:

• Email: support@eminer.app
• Form:https://machinemaker.com.br/privacidade

All requests regarding the processing of personal data, questions about this Privacy Policy, or requests to exercise rights should be directed to this channel, which will be duly registered and responded to within the legal timeframes.

2.1.4. Shared Responsibility and Cooperation

In cases where data processing involves partners, suppliers, or sub-processors, Machine Maker Ltd. ensures that all are contractually obligated to adopt equivalent standards of security, confidentiality, and legal compliance.

The company may share personal data with third parties only when there is a legitimate legal basis, a specific purpose, and a formal commitment to data protection.

2.1.5. Transparency and Review

Machine Maker Ltd. maintains governance and compliance practices in data protection, including:

• Periodic reviews of its Privacy Policy;
• Continuous training of its team on good information security practices;
• Internal and external compliance audits;
• Updating processes and controls according to guidance from Supervisory Authorities and international privacy standards (such as the GDPR).

These measures ensure that the processing of personal data is carried out ethically, securely, transparently, and with continuous improvement.

2.2. Categories of Personal Data Collected

2.2.1. Principle of Necessity and Purpose

Machine Maker Ltd. collects only the personal data strictly necessary for the operation of its platforms, execution of contracts, compliance with legal obligations, and continuous improvement of services. All processing observes the principles of purpose limitation, data minimization, adequacy, and transparency, as established by Applicable Data Protection Laws.

The data collected varies according to the type of User interaction with the company—whether as a visitor, client, business partner, or merely interested in information.

2.2.2. Data Provided Directly by the User

This data is provided voluntarily by the User when creating an account, making a purchase, filling out forms, using the platform, or contacting support channels. It includes, but is not limited to:

• Full name;
• Company name or business name;
• Email address and telephone number;
• Tax ID number (where required for invoicing);
• Billing and payment information, such as transaction identifiers, payment method, date, and amount;
• Messages sent via contact forms, email, or chat;
• Communication preferences, language, and contracted plan;
• Business segment or area of commercial interest, provided to personalize communications, materials, and recommendations within the platform;
• Target client profile, such as companies, freelance professionals, or individuals, to adapt the tool's use to the User's prospecting needs;
• Origin of contact or how they learned about Machine Maker Ltd. services, such as social media, ads, Google search, referrals, or other discovery channels.

This data is used to identify and authenticate the User, process payments, issue invoices, offer technical support, personalize commercial communications, and improve the overall user experience of the platforms.

The information provided may also be used, in an aggregated and anonymized form, for statistical analysis, marketing, and continuous improvement of products and services.

2.2.3. Data Collected Automatically

While browsing the eminer.app platforms, technical and usage information is automatically collected through cookies, scripts, logs, analysis technologies, and anti-fraud mechanisms.

This data includes, but is not limited to:

• IP address and approximate location;
• Browser type and version;
• Operating system and access device;
• Language configured in the browser;
• Pages visited, time spent, and actions taken;
• Date and time of access;
• Performance data, errors, and User behavior metrics;
• Email address associated with the Google account, when the User is authenticated in the Google Chrome browser and authorizes integration or automatic detection;
• Unique digital identifier (device fingerprint), automatically generated for security, authentication, and prevention of improper sharing of access.

This information is processed in an aggregated and anonymized manner whenever possible, and used exclusively to:

• Ensure the security of platforms and User accounts;
• Prevent simultaneous or improper access;
• Identify usage patterns and potential fraud;
• Conduct technical audits and performance analyses;
• Improve the browsing experience and personalization of services.

None of this information is commercialized or shared with third parties for advertising purposes outside the Machine Maker Ltd. ecosystem.

2.2.4. Data Obtained from Third Parties and Public Sources

Machine Maker Ltd. may receive data from legitimate third parties and public sources, observing the limits of current legislation and a purpose compatible with the original context of the collection. This includes:

• Authentication platforms (Google, Meta, LinkedIn, among others);
• Commercial partners, affiliates, and API integrators;
• Public databases, such as company registries, business profiles, business directory listings, and data available in search engines;
• Payment processors (Stripe, among others) responsible for validating transactions and financial transfers.

Such data is used to confirm the User's identity, prevent fraud, process transactions, and offer technical or commercial support.

2.2.5. Data Related to Payments and Billing

Financial transactions are processed by specialized companies, such as Stripe, which have their own Privacy Policies and Terms of Use.

Machine Maker Ltd. does not directly store sensitive payment data, such as credit card numbers. Processing is carried out exclusively by certified processors, in compliance with the PCI DSS (Payment Card Industry Data Security Standard).

2.2.6. Communication and Support Data

During contact with technical, commercial, or legal support, additional data necessary for resolving requests may be collected, such as:

• History of interactions and support tickets;
• Messages exchanged with the support team;
• Screenshots or files sent voluntarily by the User;
• Technical performance or system error data related to the case.

These records are kept for the time necessary for auditing, prevention of recurrence, and compliance with legal obligations.

2.2.7. Data Relating to Bonus Tools and Experimental Functionalities

Machine Maker Ltd. may offer, temporarily and as a courtesy, experimental tools or functionalities linked to active plans (monthly, quarterly, semi-annual, or annual). These tools may collect usage data, performance metrics, and feedback for product improvement purposes.

The User acknowledges that such tools are offered without guarantee of continuous or permanent operation, and may be deactivated, modified, or made paid at any time, upon prior communication.

2.2.8. Aggregated and Anonymized Data

For statistical, analytical, and research purposes, Machine Maker Ltd. may process data in an anonymized form, i.e., without it being possible to directly identify the data subject. This data is not considered personal data under Applicable Data Protection Laws and may be used freely for generating reports, usage metrics, and behavioral studies.

In all cases, the processing respects the principles of ethics, security, and proportionality, ensuring that no identifiable information is disclosed without a legal basis or the express consent of the data subject.

2.3. Purposes of Processing Personal Data

2.3.1. General Principles

Machine Maker Ltd. processes personal data according to specific, explicit, and legitimate purposes informed to the data subject, in accordance with the principles of Applicable Data Protection Laws. No data is processed in a manner incompatible with the original purposes informed at the time of collection.

The processing is conducted ethically, proportionally, and transparently, always respecting the fundamental rights and freedoms of the data subjects.

2.3.2. Primary Purposes

The personal data collected is used to enable the regular operation of the platforms and services of Machine Maker Ltd., including:

1. Performance of Contracts: processing registrations, identifying Users, providing access to tools, processing payments, and issuing invoices.
2. Technical Support and Customer Service: answering questions, registering requests, tracking tickets, and maintaining support history.
3. Account and Plan Management: controlling the subscription lifecycle (monthly, quarterly, semi-annual, or annual), automatic renewal, recurring billing, and eventual contractual adjustments.
4. Compliance with Legal and Regulatory Obligations: issuing fiscal documents, complying with judicial orders, cooperating with public authorities, and maintaining compliance records.
5. Institutional and Contractual Communication: sending notifications about service updates, policies, and conditions of use.
6. Information Security: preventing fraud, monitoring access, auditing logs, and protecting platforms against cyber attacks.
7. Customer Relationship Management: maintaining a history of interactions and offering personalized experiences.
8. Analysis and Continuous Improvement: collecting feedback, conducting usability tests, optimizing performance, and enhancing the user experience.

2.3.3. Secondary Purposes and Legitimate Interests

In addition to the primary purposes, Machine Maker Ltd. may process personal data for complementary and legitimate purposes, always observing compatibility with the original context of the collection and ensuring the possibility of objection by the data subject. Such purposes include:

1. Sending marketing communications and educational materials, when the User shows interest or gives consent;
2. Personalized offers of products and services compatible with the User's profile and history;
3. Elaboration of metrics and statistical reports to evaluate commercial performance and satisfaction;
4. Market research and development of new functionalities;
5. Detection and prevention of fraud, abuse, or unauthorized access;
6. Compliance with contractual obligations with partners and sub-processors, including audits and security certifications.

When processing is based on legitimate interest, Machine Maker Ltd. will ensure that the activity does not violate the rights and reasonable expectations of the data subject, conducting, when necessary, a Legitimate Interest Assessment (LIA).

2.3.4. Purposes Related to Communications and Support

Data collected through contact channels (forms, email, chat, WhatsApp, and other means) is processed to:

• Identify the requestor and validate their identity;
• Provide information about products, plans, and functionalities;
• Resolve doubts and register technical or commercial occurrences;
• Ensure the traceability and security of communications.

All communication records are stored for the time necessary for auditing and defense of legitimate interests, according to the deadlines defined in Applicable Data Protection Laws and other applicable norms.

2.3.5. Purposes of Improving and Personalizing the Experience

Machine Maker Ltd. may use browsing data, usage metrics, and User feedback to:

• Personalize the content displayed on the platforms;
• Recommend relevant functionalities according to the User's profile;
• Identify behavioral trends and improve usability;
• Conduct A/B tests and controlled experiments for interface and performance optimization.

These activities are conducted anonymously whenever possible, in order to preserve the privacy of the data subject.

2.3.6. Purposes Related to Bonus Tools and Experimental Functionalities

In plans that include bonus tools or functionalities in the testing phase, Machine Maker Ltd. may process usage and performance data in order to:

• Evaluate the engagement and usefulness of these tools;
• Correct failures, adjust algorithms, and improve functionalities;
• Determine the feasibility of making the functionality permanent or including it in future plans.

The User will be clearly informed about the experimental nature of these tools and may opt-out, when applicable.

2.3.7. Purposes of Compliance, Audit, and Governance

To ensure compliance with its legal and contractual obligations, Machine Maker Ltd. may process personal data to:

• Perform internal and external security and compliance audits;
• Respond to requests from regulatory, fiscal, and control bodies;
• Maintain accounting and administrative records;
• Manage internal compliance, ethics, and information security policies;
• Ensure traceability of operations and transactions.

These activities are carried out in accordance with recognized corporate governance standards and based on the accountability principle of Applicable Data Protection Laws.

2.3.8. Anonymized and Statistical Purposes

Data processed in an anonymized form may be used for:

• Generating reports and usage indicators;
• Market studies and research;
• Performance and trend analyses;
• Development of business intelligence and technological innovation.

In these cases, it is not possible to identify the data subject, and the information is used exclusively for legitimate and non-discriminatory purposes.

2.4. Legal Bases for Processing Personal Data

2.4.1. Legal Foundations

Machine Maker Ltd. processes personal data based on legitimate legal foundations provided for in Applicable Data Protection Laws (e.g., Article 6 of the GDPR), ensuring that each processing operation is duly justified and compatible with the purposes informed to the data subject. No data is processed without a legal basis or in a manner incompatible with the original purpose of collection.

The main legal bases used include:

1. Performance of a Contract or Pre-contractual Procedures (e.g., Art. 6(1)(b) GDPR): when processing is necessary for the provision of services, processing subscriptions, platform access, and issuing invoices.
2. Compliance with a Legal or Regulatory Obligation (e.g., Art. 6(1)(c) GDPR): to observe fiscal, accounting, consumer, and data security duties.
3. Legitimate Interest (e.g., Art. 6(1)(f) GDPR): when processing is essential for technical support, platform improvement, fraud prevention, and communications related to contracted services, always observing the balance between the rights of the data subject and those of the controller.
4. Consent of the Data Subject (e.g., Art. 6(1)(a) GDPR): in cases where processing depends on express authorization, such as sending promotional communications or participating in voluntary surveys.
5. Exercise of Legal Claims (e.g., Art. 6(1)(f) GDPR): for the defense of legitimate interests of the company or third parties in judicial, administrative, or arbitration proceedings.
6. Protection of Credit: when necessary to validate registration information and financial transactions.
7. Protection of Vital Interests: applicable in exceptional situations involving the physical or digital security of the data subject or third parties.

2.4.2. Processing of Sensitive Data

Machine Maker Ltd. does not intentionally collect or process special categories of personal data (racial or ethnic origin, religious convictions, political opinions, genetic data, biometric data, or data related to health or sex life).

If the processing of sensitive data becomes necessary for compliance with specific legal obligations, it will be carried out in strict observance of the legal requirements for processing special categories of data (e.g., Article 9 of the GDPR) and with prior and transparent communication to the data subject.

2.4.3. Processing Data Based on Legitimate Interest

When based on legitimate interest, data processing will be preceded by a proportional impact analysis, taking into account:

• The legitimate purpose of the processing operation;
• The reasonable expectation of the data subject;
• The nature and volume of the data processed;
• The risk mitigation measures and safeguards adopted.

2.4.4. Consent and Revocation

In cases where the processing of personal data is based on the consent of the data subject, it will be collected in a free, informed, and unequivocal manner, through specific forms, checkboxes, or digital acceptances.

The data subject may, at any time, revoke their consent by sending a request to the official channel support@eminer.app, without this affecting the lawfulness of the processing carried out previously.

Revocation may imply limitations on access to certain functionalities or services that depend on the collection and use of authorized data.

2.4.5. Compliance with Legal and Regulatory Obligations

Certain processing operations are carried out to meet legal obligations imposed by fiscal, judicial, regulatory, or data protection authorities. Examples include:

• Issuing and storing invoices;
• Registering and controlling financial transactions;
• Communicating security incidents to the relevant Supervisory Authority;
• Maintaining application access logs, as required by certain applicable telecommunications or internet laws.

These activities are mandatory and independent of consent, as determined by the applicable legislation.

2.4.6. Exercise of Legal Rights and Judicial Protection

Machine Maker Ltd. may process personal data when necessary for the exercise of rights in judicial, administrative, or arbitration proceedings, including for the defense of legitimate interests in contractual disputes, consumer complaints, or legal audits.

This processing will be limited to what is strictly necessary and carried out in accordance with the principles of proportionality and confidentiality.

2.4.7. International Data Transfer

When there is a need for the international transfer of personal data—for example, to hosting providers, cloud services, email, or analytical tools located outside the User's country—Machine Maker Ltd. will ensure that such transfers occur only to countries or international organizations that provide adequate levels of data protection, according to criteria from the relevant Supervisory Authority and Applicable Data Protection Laws (e.g., Chapter V of the GDPR).

Specific international transfer agreements containing standard data protection clauses will be signed, ensuring that the rights of data subjects are preserved regardless of the server's jurisdiction.

2.4.8. Updating and Review of Legal Bases

Machine Maker Ltd. conducts periodic reviews of the legal bases applicable to each processing operation, especially in light of regulatory changes, the introduction of new functionalities, or changes in the purposes of data use.

2.5. Sharing and Transfer of Personal Data

2.5.1. Principles of Sharing

Machine Maker Ltd. shares personal data only when strictly necessary, observing the principles of purpose limitation, data minimization, transparency, and security provided for in Applicable Data Protection Laws. No data is commercialized, sold, or exchanged with third parties for purposes unrelated to the company's operations.

All sharing is preceded by a risk analysis and supported by contracts that guarantee compliance with data protection norms and respect for the rights of data subjects.

2.5.2. Hypotheses of Sharing

The sharing of personal data may occur in the following situations:

1. With Service Providers and Sub-processors: for the execution of technical support, hosting, system maintenance, email automation, communication, and payment processing.
   • Examples: Stripe, Google, Meta, LinkedIn, Amazon Web Services (AWS), OpenAI, Grok, Twilio/SendGrid, and Cloudflare.These partners act according to documented instructions and are contractually bound by confidentiality and data security obligations.
2. With Commercial and Marketing Partners: in joint campaigns or affiliate programs, upon prior consent from the data subject.
3. With Governmental and Judicial Authorities: when necessary to comply with legal obligations, formal requisitions, or judicial decisions.
4. In Cases of Audit, Merger, Spin-off, or Acquisition: in eventual corporate operations involving Machine Maker Ltd., provided that the continuity of data protection and prior communication to data subjects are guaranteed, whenever applicable.
5. With Consultants and Legal Offices: for the defense of rights, exercise of contractual guarantees, or compliance with legal duties.

2.5.3. International Data Transfer

Personal data may be transferred to servers located outside the national territory, especially in cloud computing providers, analytical tools, and automation.

These transfers will observe the criteria defined by the relevant Supervisory Authority and Applicable Data Protection Laws (e.g., Article 44 et seq. of the GDPR), ensuring that:

• The destination country has an adequate level of data protection as required by the originating legislation;
• There are specific contractual clauses (such as Standard Contractual Clauses) ensuring the rights of the data subject;
• The processing occurs in accordance with legitimate and documented purposes.

Machine Maker Ltd. ensures that its external suppliers adopt technical measures compatible with the required security standards.

2.5.4. Sharing between Platforms of the Machine Maker Ecosystem

Machine Maker Ltd. operates a portfolio of integrated digital solutions, including the eMiner, Snout, Prospecta, Lead Chat, Lead Explorer platforms, and others in development.

User data may be shared internally among these platforms in order to:

• Ensure continuity and interoperability between products;
• Allow unified login, centralized support, and an integrated user experience;
• Optimize campaigns, notifications, and legitimate communications related to the contracted services.

This internal sharing is governed by the same security and confidentiality rules described in this Policy, and never has external commercial purposes.

2.5.5. Security and Control Measures

Before any sharing, Machine Maker Ltd. ensures that:

• The third-party recipient is subject to confidentiality and data protection contracts;
• The information is transmitted securely, preferably through encryption or protected connections (HTTPS/TLS);
• Only the strictly necessary data is shared, according to the minimization principle.

The company conducts periodic audits of its suppliers and partners, ensuring continuous compliance with Applicable Data Protection Laws and international best practices.

2.5.6. Transparency and Right to Information

The data subject may request detailed information about:

• Which third parties received their personal data;
• What data was shared;
• The specific purposes of the sharing.

These requests can be sent directly to the Data Protection Officer (DPO), via email support@eminer.app.

Responses will be provided within a reasonable timeframe, in accordance with Applicable Data Protection Laws (e.g., Article 15 of the GDPR), ensuring full transparency and traceability of sharing operations.

2.6. Security and Storage of Data

2.6.1. Commitment to Information Security

Machine Maker Ltd. adopts strict technical, administrative, and organizational measures aimed at protecting personal data against unauthorized access, improper disclosure, loss, alteration, inappropriate processing, or any form of illicit use.

These measures follow recognized information security standards and comply with Applicable Data Protection Laws and other relevant industry standards, such as ISO/IEC 27001 and the NIST Cybersecurity Framework.

2.6.2. Technical and Administrative Protection Measures

Machine Maker Ltd. applies multiple levels of security and digital governance, including:

1. Data Encryption: all sensitive transmissions and storage are protected by standard TLS/SSL encryption and modern security algorithms.
2. Access Control: use of multi-factor authentication, profile management, and minimum privileges for employees and partners.
3. Monitoring and Auditing: access logs, event traceability, and periodic compliance audits.
4. Firewall and Intrusion Protection: use of network security layers and intrusion detection and prevention systems (IDS/IPS).
5. Backup and Recovery: encrypted backup policies and contingency plans for business continuity.
6. Training and Awareness: regular training of employees on information security, privacy, and best practices for handling personal data.

2.6.3. Data Storage and Retention

Personal data is stored on secure servers, located locally and/or abroad, always in compliance with Applicable Data Protection Laws and current data protection norms.

Machine Maker Ltd. maintains retention and disposal policies based on the following criteria:

• Contractual term: while the User maintains an active relationship with the company;
• Compliance with legal obligations: for fiscal, accounting, auditing, and rights defense purposes;
• Legitimate interest: when necessary to maintain historical records and fraud prevention;
• Consent of the data subject: until express revocation, when applicable.

After the applicable deadlines, the data is anonymized or securely eliminated, through digital sanitization and cryptographic destruction procedures.

2.6.4. Security in Data Transfer and Processing

During the transit of information between Machine Maker Ltd. systems and those of third parties (such as payment processors, cloud providers, and external APIs), secure communication protocols (HTTPS, OAuth 2.0, encrypted API Keys) are used.

Data is transmitted only after validated authentication and express authorization, ensuring the integrity and confidentiality of the information.

2.6.5. Security Incidents and Communication to the Data Subject

In the event of a security incident that may pose a significant risk or harm to data subjects, Machine Maker Ltd. will:

1. Notify the affected data subjects and the relevant Supervisory Authority (SA) without undue delay, as required by law;
2. Adopt technical measures to contain and mitigate the effects of the incident;
3. Make communication channels available for clarifications and guidance to Users;
4. Maintain a detailed record of all occurrences and corrective actions taken.

2.7. Rights of Data Subjects

2.7.1. Legal Guarantees

In accordance with Applicable Data Protection Laws (such as the GDPR), Machine Maker Ltd. ensures the data subject the full exercise of their rights, guaranteeing transparency, access, and control over the processed information.

Rights can be exercised at any time, through a formal request sent to the Data Protection Officer (DPO), at support@eminer.app.

2.7.2. Rights Guaranteed by Law

The data subject has the right to request, as per Applicable Data Protection Laws (e.g., Chapter III of the GDPR):

1. Confirmation of the Existence of Processing: to know if Machine Maker Ltd. processes their personal data.
2. Access to Data: to obtain a copy of the personal data processed and information about its origin, purpose, and retention period.
3. Rectification of Incomplete, Inaccurate, or Outdated Data: to request the correction of information held in the company's systems.
4. Anonymization, Blocking, or Erasure ('Right to be Forgotten'): to request the suspension or deletion of unnecessary, excessive, or non-compliant data.
5. Data Portability: to receive their personal data in a structured, commonly used, and machine-readable format, for transfer to another service provider, as regulated by the Supervisory Authority.
6. Erasure of Data Processed with Consent: to request the deletion of data collected based on consent, except when legal retention is necessary.
7. Information about Sharing: to know with which public or private entities their data has been shared.
8. Revocation of Consent: to withdraw previously granted authorization, interrupting processing for purposes that depend on this legal basis.
9. Objection to Processing: to object to processing carried out based on legitimate interest, when there is a violation of fundamental rights.
10. Review of Automated Decisions: to request a review of decisions made solely based on automated processing that affect their interests, such as behavioral profiles or personalized recommendations.

2.7.3. Procedure for Exercising Rights

To ensure the security and authenticity of requests, Machine Maker Ltd. may:

• Request additional information to verify the identity of the data subject;
• Require authentication via registered email or other secure means;
• Register all interactions and response times in an internal control system;
• Respond to requests within the legal timeframe (e.g., one month, as per Article 12 of the GDPR).

If the request is technically unfeasible or involves information protected by commercial secrecy, the company will inform the data subject of the factual or legal reasons preventing its fulfillment.

2.7.4. Situations Where Data Deletion is Not Possible

The immediate deletion of personal data may not occur when:

1. There is a legal or regulatory retention obligation;
2. The data is necessary for the performance of a current contract;
3. There are legitimate interests or rights of Machine Maker Ltd. subject to legal defense;
4. Deletion affects records necessary for fraud prevention, audits, or security control.

In these cases, the data will remain stored securely, with restricted access and for a limited period as necessary.

2.7.5. Exercise of Third-Party Rights

If the processing involves third-party data collected by clients or partners of Machine Maker Ltd., the company will act as a Processor, processing requests in cooperation with the responsible Controller.

The data subject will be guided to contact the Controller (contracting client) directly, according to the limits established in the service provision contract.

2.7.6. Communication and Transparency

Machine Maker Ltd. commits to:

• Maintaining clear, accessible, and objective language in all privacy-related communications;
• Providing permanent contact channels for exercising rights;
• Adequately informing about changes in privacy policies and processing processes;
• Recording all interactions with data subjects in an auditable and verifiable manner.

2.7.7. Guarantee of Non-Discrimination

The exercise of any right provided in Applicable Data Protection Laws may not result in discrimination, blocking of essential services, or undue prejudice to the data subject.

Machine Maker Ltd. ensures equal treatment for all Users, regardless of the nature of the request, and will maintain support channels to resolve doubts and complaints transparently and collaboratively.

2.8. Data Retention and Deletion

2.8.1. Principle of Limited Retention

Machine Maker Ltd. adopts a policy of minimum necessary retention of personal data, according to the data minimization principle of Applicable Data Protection Laws.

Data is kept only for the time essential to fulfill the purposes that justified its collection, observing applicable legal, contractual, and regulatory obligations.

2.8.2. Retention Criteria

The storage period varies according to the type of data and its purpose, and may include:

1. Performance of Contracts and Services: during the term of the contract and for up to 5 (five) years after its termination, for auditing and rights defense purposes.
2. Compliance with Legal Obligations: according to deadlines defined by fiscal, accounting, and consumer legislation.
3. Legitimate Interest: as long as there is a need to maintain historical records, access security, and fraud prevention, respecting the rights of the data subject.
4. Consent: until the express revocation by the data subject or as long as the authorized purposes persist.
5. Claims and Litigation: as long as the applicable statute of limitations for any judicial or administrative dispute lasts.

2.8.3. Deletion and Anonymization Processes

Once the legitimate processing purposes have ended, personal data is:

• Securely eliminated, through definitive deletion or cryptographic destruction of digital records; or
• Anonymized, so that it cannot be directly or indirectly associated with an identifiable data subject, allowing its use for statistical, analytical, and system improvement purposes.

Disposal procedures follow information security norms and are periodically audited.

2.8.4. Exceptions to Deletion

Machine Maker Ltd. may retain certain personal data even after a deletion request, in the following hypotheses:

1. Compliance with a legal or regulatory obligation;
2. Transfer to a legitimate third party, provided that the requirements of Applicable Data Protection Laws are respected;
3. Exclusive use by the company, with restricted access and through anonymization, for auditing, security, and fraud prevention purposes.

In these situations, the data subject will be informed about the reason for retention and the estimated conservation period.

2.8.5. Retention of Logs and Access Records

In compliance with applicable local internet or data retention laws, Machine Maker Ltd. maintains access logs to its applications for a minimum of 6 (six) months, securely and confidentially.

These records include technical data such as IP address, date, time, and duration of the connection, and are stored with restricted access control and cryptographic protection.

2.8.6. Procedure for Requesting Deletion

The data subject may request the deletion of their personal data via email at support@eminer.app.

The request will be analyzed and processed within 15 (fifteen) business days, or as otherwise required by law, observing the legal exceptions described in this Policy.

If the request involves data processed by third parties (such as payment processors or integrated platforms), Machine Maker Ltd. will assist in communicating and coordinating the deletion with the respective responsible parties.

2.8.7. Audit and Retention Control

Machine Maker Ltd. maintains documented records on retention and disposal deadlines, including:

• Internal storage and deletion policies;
• Audit records of deletions and anonymizations;
• History of data subject requests and their respective responses.

These controls ensure traceability, transparency, and continuous compliance with the requirements of the Supervisory Authority.

2.9. Use of Cookies and Tracking Technologies

2.9.1. Concept and Purpose of Cookies

Cookies are small text files stored on the User's device during their navigation on the Machine Maker Ltd. platforms.

The purpose of these files is to improve the user experience, optimize site performance, personalize content, and collect statistical data for the continuous improvement of services.

In addition to cookies, other tracking technologies may be used, such as pixels, tags, scripts, and local storage, which assist in behavior analysis and the execution of essential functionalities.

2.9.2. Analysis and Tracking Tools Used

Machine Maker Ltd. uses analytical and monitoring tools compatible with data protection norms, including:

• Google Analytics: for statistical analysis and performance reports (Privacy Policy: https://policies.google.com/privacy);
• Meta Pixel (Facebook and Instagram): to measure conversions and optimize marketing campaigns (Privacy Policy: https://www.facebook.com/privacy/policy);
• LinkedIn Insight Tag: for audience analysis and B2B campaign effectiveness (Privacy Policy: https://www.linkedin.com/legal/privacy-policy);

All these integrations respect the User's consent and offer opt-out mechanisms directly in their respective policies.

2.9.3. Data Collected by Cookies

Cookies and related technologies may collect information such as:

• IP address and approximate location;
• Browser type and version;
• Operating system and screen resolution;
• Pages accessed and time spent;
• Actions taken (clicks, scrolling, navigation between sections);
• Traffic origin and source marketing campaign.

This data is processed in an anonymized and aggregated manner, and used exclusively for legitimate purposes of security, performance analysis, and continuous improvement.

2.9.4. Retention and Storage of Cookies

Cookies can be classified according to their retention time:

• Session Cookies: temporary, automatically removed when the browser is closed;
• Persistent Cookies: remain stored for a limited period, defined according to their purpose (generally between 30 and 365 days), or until they are manually deleted by the User.

Third-party cookies are subject to the privacy policies of the responsible providers, who determine their own retention periods.

2.9.5. User Preference Management

The User can review their privacy preferences and choose not to authorize the use of non-essential cookies. Instructions for management in popular browsers include:

• Google Chrome: Settings > Privacy and Security > Cookies and other site data;
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data;
• Microsoft Edge: Settings > Cookies and site permissions;
• Safari: Preferences > Privacy > Block all cookies.

Additionally, the User can visit https://optout.aboutads.info to deactivate behavioral advertising cookies from multiple providers.

2.9.6. Transparency and Updates

Machine Maker Ltd. periodically reviews its Cookie Policy to reflect technological, legal, or operational changes. Any relevant changes will be communicated to Users through official channels and the updated consent banner.

Continued use of the platforms after such communications will be interpreted as agreement with the applicable modifications, always in compliance with the data subject's rights.

2.10. Use of Artificial Intelligence and Process Automation

2.10.1. Principles of Ethics and Transparency

Machine Maker Ltd. uses Artificial Intelligence (AI) and process automation resources ethically, responsibly, and in full compliance with Applicable Data Protection Laws and the principles of transparency, purpose limitation, and non-discrimination.

These technologies are applied exclusively to improve the User experience, optimize operations, and increase the efficiency of the services offered.

The company ensures that no decision based solely on automated processing will be made without human supervision when such a decision could produce legal effects concerning the User or similarly significantly affect them.

2.10.2. Purposes of Using Artificial Intelligence

The AI and automation tools employed by Machine Maker Ltd. have the main objectives of:

1. Optimizing searches and lead generation on platforms like eMiner;
2. Identifying and enriching public data available on the internet, always observing legal and ethical limits;
3. Detecting patterns and anomalies for fraud prevention, unauthorized access, or abusive use of systems;
4. Personalizing experiences and recommendations within the platforms, according to the User's usage profile and preferences;
5. Automating communications (emails, notifications, and support responses), aiming for efficiency and speed in service;
6. Predictive analysis and performance metrics, always in aggregated and anonymized format, for continuous improvement of products and services.

2.10.3. Limits and Guarantees of Human Supervision

Machine Maker Ltd. maintains continuous human supervision over all critical automated processes, especially those involving the analysis of personal data.

No AI system operates autonomously in decisions that could:

• Deny access or restrict the use of services;
• Influence contractual, financial, or legal decisions without human validation;
• Produce discriminatory effects or compromise the integrity of any data subject.

The company conducts regular internal audits of its algorithms and automated workflows, verifying accuracy, impartiality, and adherence to principles of digital ethics and AI governance.

2.10.4. Data Sources and Transparency in Model Training

When using AI models for data analysis or insight generation, Machine Maker Ltd. ensures that:

• The sources used are public, lawful, and compatible with the original collection purposes;
• No sensitive personal data is used in training algorithms without consent or an appropriate legal basis;
• Information is anonymized whenever possible;
• Processing is restricted to controlled environments with access monitoring.

The company does not commercialize, share, or use third-party databases obtained irregularly for training or AI enrichment purposes.

2.10.5. Automated Decisions and the Right to Review

In accordance with Article 22 of the GDPR, the data subject has the right to request a review of decisions made solely based on automated processing that affect their interests.

Machine Maker Ltd. guarantees that:

• Relevant automated decisions include human intervention or a simple mechanism for the User to request it;
• The User can request clarification on the criteria and logic used in automated processes;
• The channel to exercise this right is the email support@eminer.app, with a response time of up to 15 (fifteen) business days, or as otherwise required by law.

2.10.6. Security and Audit of Automated Systems

The AI systems of Machine Maker Ltd. are subjected to security tests, integrity validation, and access control, including:

• Encryption of input and output data;
• Registration of decision logs and model auditing;
• Continuous verification of algorithmic bias and impartiality in results;
• Periodic technical reviews to prevent failures and abuses.

In case of detection of anomalous behavior or risk to privacy, the automated system is immediately interrupted until a complete review and revalidation.

2.10.7. Transparency and Communication with the User

Machine Maker Ltd. commits to informing its Users, clearly and accessibly, whenever they interact with systems automated or AI resources that significantly impact their experience.

These communications may occur through notifications in the platform interface, explanatory messages, or descriptions in the Terms of Use and Privacy Policy.

The company will also provide channels for clarification on the operation of its technologies, reinforcing trust and ethical governance in the use of Artificial Intelligence.

2.10.8. Technological Evolution and Best Practices

Machine Maker Ltd. adopts a model of continuous governance in AI, based on the principles of ethics, transparency, accountability, and security.

The company follows the guidelines of the OECD, UNESCO, and international AI Governance Standards, committing to:

• Implementing responsible and auditable practices;
• Preventing algorithmic biases and discrimination;
• Constantly updating internal policies according to regulatory and technological evolution.

These measures ensure that the use of Artificial Intelligence by Machine Maker Ltd. remains aligned with the highest standards of ethics, legality, and personal data protection.

2.11. Governance, Audit, and Compliance

2.11.1. Governance Policy on Privacy and Data Protection

Machine Maker Ltd. adopts a Governance Program in Privacy and Data Protection aimed at continuous compliance with Applicable Data Protection Laws and international best practices, such as the GDPR.

This program integrates principles of ethics, transparency, security, and accountability, seeking to ensure that all operations involving personal data are under permanent control and monitoring.

The governance policy includes guidelines on:

• Organizational structure for data protection;
• Roles and responsibilities of employees, suppliers, and partners;
• Procedures for risk management and incident mitigation;
• Internal audits, impact assessments, and periodic reviews;
• Continuous communication with the relevant Supervisory Authority (SA).

2.11.2. Internal Privacy and Security Committee

Machine Maker Ltd. maintains an Internal Privacy and Information Security Committee, responsible for overseeing compliance actions and ensuring that internal practices comply with applicable regulations.

The Committee's functions include:

1. Assessing risks related to the processing of personal data;
2. Monitoring security incidents and proposing corrective measures;
3. Supervising compliance audits and vulnerability tests;
4. Updating internal policies and best practice guides;
5. Supporting the Data Protection Officer (DPO) in their functions and communications with the SA.

2.11.3. Risk Management and Internal Controls

The company adopts an integrated risk management model that covers technological, operational, legal, and reputational aspects.

Internal controls include:

• Continuous monitoring of access and audit logs;
• Review of user and administrator permissions;
• Policies for segregation of duties and dual control in sensitive operations;
• Contingency and incident response plans.

These mechanisms aim to prevent failures, abuses, and leaks, ensuring complete traceability of all processing activities.

2.11.4. Training and Awareness

All employees, service providers, and partners of Machine Maker Ltd. receive periodic training in privacy, data protection, and information security.

The objective is to disseminate a culture of compliance and responsibility, enabling each member of the organization to:

• Identify risks and vulnerabilities;
• Adopt secure behaviors in handling personal data;
• Act preventively and collaboratively in the face of incidents.

The company also promotes educational campaigns and support materials to reinforce the collective commitment to ethics and digital security.

2.11.5. Accountability

In line with the accountability principle (e.g., Article 5(2) of the GDPR), Machine Maker Ltd. maintains detailed records of all personal data processing activities, including:

• Legal basis applied;
• Purpose of use;
• Retention period;
• Partners and sub-processors involved;
• Security measures implemented.

These records are auditable and can be made available to the SA or competent authorities upon formal request.

2.11.6. Policy Review and Updates

Machine Maker Ltd. conducts periodic reviews of its privacy, security, and governance policies, especially in light of:

• Changes in applicable legislation;
• Launch of new products or functionalities;
• Identification of new risks or vulnerabilities;
• Recommendations from the SA or international regulatory bodies.

Any relevant update will be communicated to Users through the company's official channels, ensuring full transparency.

2.11.7. International Compliance

Machine Maker Ltd. seeks continuous alignment with global data protection best practices, including the principles of the GDPR and the OECD (Organisation for Economic Co-operation and Development).

This includes the commitment to:

• Principles of lawfulness, minimization, and proportionality;
• Implementation of technical standards compatible with equivalent foreign legislation;
• Cooperation with international data protection authorities, when applicable.

2.11.8. Compliance and Whistleblowing Channel

Machine Maker Ltd. provides a compliance and whistleblowing channel for communicating irregularities, non-compliance, or incidents related to privacy and information security.

Reports can be sent, identified or anonymously, to the email support@eminer.app.

All reports are analyzed with confidentiality, impartiality, and diligence, resulting in corrective measures when applicable.

2.11.9. Permanent Commitment to Compliance

Machine Maker Ltd. reaffirms its commitment to act with integrity, transparency, and respect for the rights of data subjects.

The governance program is continuously improved to ensure lasting compliance and organizational resilience, staying up-to-date with the technological and regulatory transformations of the digital environment.

2.12. Policy Updates and Effective Date

2.12.1. Continuous Update Policy

Machine Maker Ltd. reserves the right to change, review, or update this Terms of Use and Privacy Policy document at any time, to reflect legislative, technological, operational, or commercial changes.

Updates aim to ensure that the company's practices remain aligned with current legislation, especially Applicable Data Protection Laws, as well as complementary norms issued by the relevant Supervisory Authorities and other competent bodies.

2.12.2. Communication of Changes

Whenever there are substantial changes in data processing practices or Users' rights, Machine Maker Ltd. will:

• Post a notice on the official platforms;
• Update the effective date at the beginning of this document.

Continued use of the platforms after the publication of changes will be interpreted as full acceptance of the new terms, except when legal requirements for additional consent exist.

2.12.3. Periodic Review

The document will be reviewed at least every 12 (twelve) months, or whenever there is:

1. A relevant regulatory update;
2. Introduction of new functionalities or products involving personal data processing;
3. Significant modification in security policies or technological infrastructure.

Reviews will be conducted by the Data Protection Officer (DPO) and the Internal Privacy and Security Committee, ensuring compliance and consistency.

2.12.4. Effective Date

This updated version of the Machine Maker Ltd. Terms of Use and Privacy Policy comes into effect on the date of its official publication, superseding all previous versions entirely.

2.12.5. Final Acceptance

By using any service, product, or platform linked to Machine Maker Ltd., the User declares to have read, understood, and fully accepted the terms established herein.

If they do not agree with any provision, the User must immediately stop using the platforms and, if desired, request the deletion of their personal data.

2.12.6. Final Provisions

Any doubts, suggestions, or requests related to this document may be sent to the official channel: support@eminer.app

Machine Maker Ltd. reaffirms its commitment to transparency, security, and respect for privacy, ensuring that all relationships with Users, clients, and partners are conducted with integrity and regulatory compliance.

2.13. Audit and Compliance with Supervisory Authorities

2.13.1. Commitment to the Supervisory Authority

Machine Maker Ltd. maintains a permanent commitment to cooperation, transparency, and compliance with the relevant Supervisory Authority (SA) and other regulatory bodies.

Any and all formal requests from the SA will be treated with the highest priority, ensuring compliance with applicable legal, technical, and administrative determinations.

2.13.2. Internal and External Audits

Machine Maker Ltd. conducts periodic internal audits to assess the compliance of its practices with Applicable Data Protection Laws and corporate security and privacy policies.

Whenever necessary, independent external audits may be contracted to validate technical and administrative controls, as well as to certify the integrity of data protection processes.

Audit reports may be made available to the SA or other competent authorities, upon formal request and within the limits of commercial confidentiality and information security.

2.13.3. Continuous Update and Improvement

Machine Maker Ltd. maintains a continuous program of improvement and governance in privacy, regularly reviewing its procedures to ensure adherence to legislation and national and international best practices.

This includes:

• Adoption of recognized information security standards;
• Annual review of internal policies and compliance manuals;
• Periodic training of the technical and legal team on data protection;
• Constant evaluation of suppliers, sub-processors, and strategic partners.