Privacy policy

Effective date: 31/12/2028

1. Who we are

We are Newsun Energy Brazil S.A., CNPJ 28.422.260/0001-74. Our
registered office is at Rua Canadá, 873, Sala 01, Village São Vicente, Franca, SP,
CEP 14.400-260.

Contact e-mail: contato@newsun.energy

Telephone: 16 3409-2569

2. What data we collect

Personal data provided: name, e-mail, telephone,
address.

Digital data: IP address, device identifiers,
cookies, browsing logs.

Interaction data: messages, forms,
comments.

3. Purposes of data use

We use data to:

• Generate and qualify leads in Meta Ads marketing campaigns.

• Send authorised communications: promotions, newsletters,
offers.

• Carry out usage, performance and behavioural analysis (pixels,
analytics).

• Improve products, services and user experience.

• Comply with legal or regulatory obligations.

4. Legal basis for processing

We process data on the basis of:

• Data subject consent (Article 7 of the LGPD).

• Performance of a contract or pre-contractual measures.

• Compliance with a legal or regulatory obligation.

• Legitimate interest, provided that the data subject's rights do not prevail.

5. Data sharing and transfer

We may share data with service providers (marketing
platforms, CRM, analytics). Such sharing shall be carried out under
agreements that impose confidentiality and use restrictions.

We may also share data with public authorities, regulatory
bodies or judicial authorities whenever required by law, court order
or administrative request.

In cases of international transfer, we shall inform you of the countries,
safeguards and applicable rights.

6. Storage and security

We implement technical and organisational measures against
unauthorised access, leaks and improper alteration.

Data shall be retained for the minimum period necessary to fulfil
the purposes and legal obligations. After that period, data shall be deleted or
anonymised.

7. Data subject rights

You may, at any time, request:

• Confirmation of the existence of processing.

• Access to processed data.

• Correction of incorrect or outdated data.

• Anonymisation, blocking or deletion of unnecessary data.

• Data portability to another provider.

• Review of automated decisions.

• Objection to processing.

• Withdrawal of consent.

Requests shall be reviewed and responded to within fifteen (15) business days,
in accordance with Article 19 of the LGPD. Send your request to
contato@newsun.energy or another designated internal channel.

8. Cookies and tracking

We use first-party and third-party cookies to measure access, traffic and
advertising.

You may disable or configure cookies in your browser; however,
this may limit website functionality.

9. Changes to the Policy

We may revise this policy at any time.

We shall publish the new version with a revision date and notify you when
applicable.

10. Data Protection Officer (DPO)

Name: Luciano Querido

Position: Data Protection Officer (DPO)

E-mail: dpo@newsun.energy

Telephone: 16 3409-2569

11. Responsibilities and obligations

You must provide true and up-to-date data.

We process data with transparency and security, in compliance with
applicable legislation.

In the event of a security incident, we shall notify the National Data
Protection Authority (ANPD) and affected data subjects as provided by
law.

12. Applicable law and jurisdiction

This policy is governed by the General Personal Data Protection Law (Law No 13.709/2018)
and other applicable Brazilian legislation.

Any disputes shall be resolved in the courts of the district of Franca, SP,
unless otherwise required by law.