Last Update: January 11th, 2022.

Software platform developed by STRM INOVACAO E PROJETOS MUSICAIS LTDA., registered

at CNPJ/ME unde no. 23.180.503/0001-91, with address at Rua Roque Petrella, no. 46,

conjunto 902 A, Vila Cordeiro, CEP 04581-050, São Paulo/SP (“STRM”).

This Privacy Policy is intended to help you understand what information we collect, why we

collect it, and how you can update, manage, export, and exclude this information.

COLLECTED INFORMATION

We collect information from the Company and artists to register them on the STRM Platform

and to provide better services to all and enable the development of STRM's activities. The

collected information includes:

1) Full name or Corporate Name: Collected for the identification of the artist or company and

registration on the platform.

2) Individual Taxpayer Identification Number (CPF) / Corporate Taxpayer Identification

Number (CNPJ): Used for registration and login purposes.

3) Date of birth: Used for registration and login purposes, as well as to ensure that the user is

of legal age.

4) Phone number: Used as a communication channel between STRM and the user.

5) Address: Used for registration and login purposes, as well as for communication and

delivery of relevant information.

6) Banking information: Used to manage the contracting of STRM services, especially

regarding royalty payments and other financial transactions.

7) Login: Information used to allow the user access to the STRM Platform.

8) Login password: A secret code created by the user during the first access to the Platform,

which allows secure access to the services offered.

The information collected by STRM is used to create, develop, operate, provide, and improve

our Services, content, and advertising, as well as to prevent losses and avoid fraud. We may

also use your personal information for purposes related to network and account security,

including protecting our Services for the benefit of all our users.

We also use personal information for conducting studies and user classification to enable

better recommendations of targets and content, which will also depend on how you use our

Platform and manage privacy controls.

We may use your personal information to confirm your identity, assist in user identification,

and determine appropriate services.

From time to time, we may use your personal information to send important notices, such

as communications regarding changes in our terms, conditions, and policies. As this

information is crucial for your interaction with STRM, you cannot opt-out of receiving such

communications.

We may also utilize personal information for internal purposes, such as auditing, data analysis,

and research to improve STRM's services and user communications.

When you are not logged into your STRM account, we store the information we collect with

unique identifiers linked to the browser, application, or device you are using. This helps us

maintain the preferences you have previously selected, for example.

LOCATION INFORMATION AND OTHER PERMISSIONS

When you access the Platform, with your permission, we may collect certain information

automatically, including but not limited to:

i. Registration Data: Collection of information to create and modify user accounts.

ii. Demographic Data: Collection of demographic data about users, including by surveys with

users. Used to generate reports on the application's usage.

iii. Transaction Data: Collection of transaction-related information regarding the user's use of

Services, including the type of service, user orders, date and time of service rendering, and

the amount charged.

iv. User Content: Collection of information that users submit when contacting customer

support.

v. Location Information: Depending on the smartphone's settings or permissions, collection

of exact or approximate location determined by data such as GPS, IP address, and Wi-Fi.

vi. Usage Information: Collection of information about how the User interacts with our

Services. Among this information are, for example, date and time of access, app features or

pages visited, app crashes, and other system activities, type of browser, and third-party

websites you were using before interacting with our Services. In some cases, we do this

through the use of cookies, pixel tags, and similar technologies that create and keep unique

identifiers.

vii. Cookies: STRM may use cookies for various purposes, such as: to avoid the need for you

to enter information like username and password every time you log in; to facilitate your

navigation on our Platform; to collect statistical information; to customize our Platform

according to your personal preferences; and to provide greater information security.

a. Some cookies expire as soon as the session ends and you close your browser. Others are

saved on your computer. Cookies do not contain sensitive information, and we do not

exchange cookies with any third-party websites or external data providers.

b. User can disable cookies through the settings options of their respective browser.

However, by choosing to prohibit cookies, the User is aware and acknowledges that it may

impact the full functionality of the Site and/or Application.

DATA SHARING

All data, information, and communications collected are considered confidential by us and will

not be provided to third parties, except as provided for in this Policy.

To develop and improve the Services provided by STRM, we may engage third-party service

providers to perform various business operations on behalf of STRM. In doing so, we may need

to share your personal information with them. We provide our service providers with only the

personal information they need to perform the services we request, and we require them to

protect this information and not use it for any other purpose.

In addition, we may disclose your data in the following cases: by court order, order of

competent authority, or when necessary to defend our rights in judicial or administrative

proceedings.

We share aggregated and/or anonymous information that does not identify you for STRM's

business purposes. For example, we may disclose the number of visitors to STRM's websites

or services. We may also share aggregated or anonymous information with our business

partners for their own business purposes.

STRM and our third-party service providers may use a variety of technologies to evaluate how

our services, websites, or applications are used, to personalize your experience, and to provide

you with advertisements, including online content, customized for your interests. Some of the

technologies we may use include cookies, web beacons, and JavaScript.

We may allow third parties, including business partners and advertising networks, to display

ads on STRM's websites. Some of these companies may recognize your device through cookies

or other technologies every time they send you an online ad.

STRM's websites may include links to third-party websites. STRM does not control these third-

party websites, and we encourage you to read the privacy policy of each website you visit.

Additionally, it is possible that some of the above-mentioned data transfers may occur to

recipients located outside the national territory. In this circumstance, the companies

undertake to do so only to countries that provide a level of protection for personal data in line

with best practices, always in compliance with applicable laws, thus providing users with

guarantees for safeguarding their data, with specific contractual clauses, without prejudice to

obtaining their respective specific consent, when applicable.

COMPLIANCE WITH LAWS

The security of your personal information is important to us, but please be aware that no

method of transmission over the Internet or electronic storage is 100% secure. We strive to

adopt best development practices and engage the best necessary suppliers for the secure

furnishing of our Services to protect your Personal Information; however, we cannot

guarantee its absolute security.

This Privacy Policy applies to all services offered by STRM. This Privacy Policy does not apply

to services that have separate privacy policies from third parties that do not incorporate this

This Privacy Policy does not apply to:

a) Information collection practices of other companies and organizations that advertise our

Services;

b) Services offered by other companies or individuals, including products or websites that may

include STRM services, displayed to you in search results or linked in our services.

STRM allows you to easily keep your personal information accurate, complete, and updated.

We will withhold your personal information for the period necessary to fulfill the purposes

described in this Privacy Policy and in our specific privacy summaries. To determine these

periods, we carefully examine the need to collect personal information, and once we identify

a relevant need, we retain the information for the shortest possible period necessary to

complete the purpose of the collection, unless a longer retention period is required by law.

CORRECTION AND EXCLUSION OF INFORMATION

In some cases, we store data for limited periods when it is necessary for legitimate business

or legal purposes.

We make efforts to ensure that our Services protect information from accidental or

malicious deletion. Due to this, there may be a time gap between when you delete

something and when copies are removed from our active systems and backups.

If you believe that STRM holds any inaccurate information about you, you have the right to

request the correction of that information. Updating your registration data, as well as

requesting information stored by STRM, can be done by sending an email to

suporte@strm.com.br. This process usually takes around 72 (seventy-two) hours from the

time of the correction request.

To delete data from your Account on the Platform, the user should request it from the STRM

team through the email suporte@strm.com.br. Then, we initiate a process designed to

completely and securely delete the data from our storage systems.

A secure deletion is important to protect our users against accidental data loss. Complete

deletion of data from our servers is equally important for the peace of mind of our users

and our protection. This process usually takes around 15 (fifteen) days from the time of the

deletion request.

After the deletion of your account, the possibility of STRM retaining information and/or data

may still exist due to legal requirements or when its maintenance is necessary for (i)

compliance with a judicial order within the scope of legal and/or administrative processes, (ii)

study by a research organization, in accordance with applicable laws, (iii) transfer to a third

party, provided that the requirements of the applicable legislation are respected, and (iv)

exclusive use by STRM, provided that the data is anonymized.

In the above scenario, STRM ensures that any third parties with whom User data has been

shared will also undertake the same deletion and non-processing measures regarding the

User's data.

STORAGE AND PROCESSING

Your information collected through our Service may be stored and processed in Brazil or any

other country where STRM, its service providers, or partners maintain facilities, always in

countries that provide an adequate level of protection for personal data, as required by law.

By registering and using the Service, you agree to the transfer of information to any country

where STRM, service providers, or partners maintain facilities, as well as the use and

disclosure of information about you as described in this Privacy Policy. We use protections to

help keep the information collected through the Platform secure, so to take measures to

verify your identity before granting you access to your account.

Please do your part to help us. You are responsible for maintaining the confidentiality of your

account information and controlling access to emails between you and STRM. Your privacy

settings may also be affected by changes in the social media services you use to connect to

STRM. We are not responsible for the functionality, privacy, or security measures of any other

organization.

STRM ensures the protection of personal data from the moment users provide their data to

us, whether to enable the contracting of a product and/or service, or to receive

communications, invitations, newsletters, as well as to improve and optimize your browsing

experience on the website. If you choose to delete your personal data from the storage

database at any time, STRM may retain some personal information for an additional period

for the purpose of fulfilling legal or regulatory obligations, as well as for the regular exercise

of STRM's rights, and for the purposes of audits and compliance standards. The retention of

personal data will be done for the period necessary to fulfill the aforementioned obligations,

always respecting the period established in the applicable legislation.

RIGHTS AS DATA SUBJECT

As STRM grants the respective users the possibility to exercise the rights provided by the LGPD

(Brazilian General Data Protection Law), allowing them to make requests related to their

personal data, such as:

a) Confirmation of the existence of data processing;

b) Access to personal data;

c) Correction of incomplete, inaccurate, or outdated data;

d) Anonymization, blocking, or elimination of unnecessary, excessive, or allegedly processed

data in non-compliance with the LGPD, except in cases provided by law;

e) Data portability to another service or product provider, upon express request by the user;

f) Deletion of processed data with the user's consent, except in cases provided by law;

g) Obtaining information about the entities with which the user's data has been shared;

h) Information about the possibility of not providing consent, as well as being informed about

the consequences in case of refusal;

i) Information related to the processing, storage, and destination of personal data, under the

scope of the LGPD;

j) Revocation of consent.

To exercise these rights or obtain more information about how your personal data is

processed, you can contact us through the email suporte@strm.com.br. We will be available

to attend to your requests in accordance with the applicable legislation and the deadlines

established by the LGPD (Brazilian General Data Protection Law).

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by

posting the new Privacy Policy on this page.

We recommend that you review this Privacy Policy periodically for any changes. Changes to

this Privacy Policy become effective when they are posted on this page, and we will keep users

informed of any changes to the content of this Privacy Policy.

COMMUNICATIONS

We will not use your Personal Information to contact you with newsletters, marketing or

promotional materials, and other information without your prior consent. However, we may

send necessary notifications related to the furnishing of the Service, including but not limited

to maintenance, updates, account termination, target recommendations, actions

recommendations, and marketing materials related to targets and actions based on your

content choices on our Platform.

If you have any questions regarding this Privacy Policy, please feel free to contact us at

suporte@strm.com.br. This communication channel is available for requests related to

correction, deletion, or for accessing the data we have about users, and the response may

take up to 10 (ten) days.

STRM is the data controller, and our contact/person in charge is: Leonardo Rossi -

suporte@strm.com.br.