1. Data Controller Identification

This website (euterpecultural.com.br) is operated by Euterpe Cultural, registered as a Microempreendedor Individual (MEI, Brazilian individual micro-entrepreneur classification) under CNPJ 41.027.003/0001-20, held by Julia Antunes Requião, with registered address in Brazil.

Euterpe Cultural provides fundraising and artistic production services to companies and independent artists, both in Brazil and in Europe.

Because this is a sole proprietorship (MEI), the data controller for the purposes of applicable data protection law is the individual titular herself, Julia Antunes Requião, acting under the trade name Euterpe Cultural. There is no separate legal entity, board, or data protection officer distinct from the titular.

Contact for privacy related matters: info@euterpecultural.com.br

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2. Applicable Legal Frameworks

This policy is drafted with reference to the following data protection regimes:

• LGPD, the Brazilian General Data Protection Law (Federal Law No. 13.709/2018), applicable because the controller is established and operates in Brazil;

• GDPR, the European Union General Data Protection Regulation (Regulation (EU) 2016/679), applicable insofar as Euterpe Cultural offers services to, and processes personal data of, individuals located in the European Union.

Where these two frameworks impose differing obligations, Euterpe Cultural applies whichever standard offers the data subject greater protection, to the extent reasonably practicable for an operation of this size and structure.

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3. Categories of Personal Data Collected

Euterpe Cultural collects only the categories of personal data reasonably necessary to operate the website, communicate with visitors, and deliver contracted services:

• Contact and inquiry data: full name, email address, telephone number, and any additional information voluntarily submitted through website contact forms;

• Account and registration data: in cases where a visitor creates a user account or profile on the website;

• Payment related data: where a client subscribes to or purchases a service, payment information necessary to process the transaction. This data is processed directly by the third party payment processing platform used at checkout, and is not retained by Euterpe Cultural itself;

• Navigation and usage data: basic technical information regarding site visits, such as pages accessed and approximate visit volume, collected solely to understand overall site usage;

Euterpe Cultural does not intentionally collect special category or sensitive personal data, including health data, biometric data, or data relating to children and adolescents. Euterpe Cultural does not engage in automated profiling, behavioral targeting, or any processing intended to influence or manipulate the behavior of data subjects.

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4. Purposes and Legal Bases for Processing

Personal data is processed for the following specific, limited purposes:

• Responding to inquiries and requests submitted through website forms;

• Managing user accounts and administering the services contracted;

• Processing payments for subscriptions or purchased services;

• Understanding, at a basic aggregate level, how many visitors access the site;

• Complying with applicable legal or regulatory obligations, where relevant.

Depending on the specific processing activity, the applicable legal bases include performance of a contract, legitimate interest of the controller in operating and improving the website, consent (particularly with respect to non essential cookies), and compliance with a legal obligation.

Euterpe Cultural does not sell, rent, or otherwise commercially disclose personal data to third parties for their own marketing purposes. Personal data is not used for any purpose beyond what is reasonably necessary to deliver the contracted service and operate the website.

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5. Data Storage, Processors, and International Transfers

Collected personal data is stored in the following locations:

• Locally, on the personal computer of the controller; and

• Within the Notion platform, used internally as a contact and project management tool.

Notion is a cloud based service operated by a company headquartered outside Brazil, in the United States. The use of this platform therefore constitutes an international transfer of personal data for purposes of the LGPD and, where applicable, the GDPR, notwithstanding that the data is used exclusively for internal organizational purposes and is not shared with additional third parties or used for commercial resale.

The website itself is hosted on the Wix platform, which may independently process certain technical, navigational, and cookie related data in accordance with its own privacy policy and its role as a technical service provider.

Where required by applicable law, Euterpe Cultural relies on standard contractual safeguards offered by these service providers (Notion and Wix) to legitimize such international transfers, to the extent such safeguards are made available by those providers.

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6. Data Retention Period

Personal data is retained for a period of up to five (5) years, or for the duration that the website domain and hosting remain active, whichever period is shorter. Upon expiration of this period, or upon a valid deletion request from the data subject, the relevant personal data will be deleted or irreversibly anonymized.

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7. Data Subject Rights

Under both the LGPD and the GDPR, data subjects may, at any time, exercise the following rights:

• Confirm whether their personal data is being processed;

• Request access to their personal data;

• Request correction of incomplete, inaccurate, or outdated data;

• Request deletion or anonymization of their personal data;

• Request portability of their data to another service provider, subject to applicable technical limitations;

• Withdraw previously given consent, without affecting the lawfulness of processing carried out prior to withdrawal;

• Obtain information regarding any third parties with whom their data has been shared;

• Object to processing carried out on the basis of legitimate interest.

To exercise any of these rights, please contact: info@euterpecultural.com.br. Requests will be addressed within a reasonable timeframe, taking into account the individual nature of the operation.

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8. Security Measures

Euterpe Cultural adopts reasonable technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or misuse, proportionate to the size and nature of a sole proprietorship (MEI) operation. These measures include, where applicable, password protection, restricted access to storage tools, and reliance on the security infrastructure of established third party platforms (Notion, Wix, and the payment processor used at checkout). No system can guarantee absolute security, and Euterpe Cultural cannot warrant that personal data will be completely free from risk of unauthorized access.

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9. Cookies

This website uses cookies and similar tracking technologies. For a detailed description of the categories of cookies used, their purposes, and how to manage cookie preferences, please refer to the separate Cookie Policy.

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10. Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in applicable law, in the services offered, or in the manner in which the website operates. The date of the most recent revision will always be indicated at the top of this document. Continued use of the website following any update constitutes acknowledgment of the revised policy.

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11. Contact Information

Questions, requests, or complaints relating to this Privacy Policy may be directed to:

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admin@euterpecultural.com.br