We at Shining Services want you to have great satisfaction visiting our website and to know that the confidentiality of the information left here is assured in accordance with this Privacy Policy.

By browsing this website or providing personal information, you will automatically be agreeing to the rules established here. Therefore, please read this Policy carefully.

All information provided by you will be kept confidential and will be used to improve our products and services and strengthen our relationship. They will be used to develop studies on the interests, needs, behaviors and demographics of those who access our website, in order to better understand the profile of our Customers.

By accessing our website, you may also choose to receive messages about our products, services, advertising, promotions and news about Shining Service.

Collection, Use, Processing and Transfer of Personal Information

Personal information may be requested in some places on this website to verify your identity, ensure your navigation in restricted access areas and guarantee your participation in promotions and contests, in addition to the use of “online” services.

As personal information requested on this website, we consider personal qualification data, such as first and last name, personal identification numbers, your address, telephone number, as well as e-mail address and possibly other information necessary to fulfill the purpose of this policy.

All personal information registered on this website will be used to improve the products and services that Shining Service offers you and to try to meet your needs and expectations. This information will be stored in a secure and controlled environment, confidentially and will never be disclosed without your prior authorization, except when required by law or by court order. This information may also be shared with the companies that are part of Shining Service, especially with our headquarters, located in Portugal, with the same guarantee of confidentiality and security in its storage and also for the purposes already mentioned. Our consultants, marketing team and advertisers, with whom we work, may also have access to personal information and comply with this Privacy Policy. Your personal information provided on this website will never be transferred, sold or rented to third parties, except in the cases specified above. Information will not be considered personal, privileged and/or confidential, and is therefore not subject to confidentiality: (a) that was already in the public domain at the time it was received, or becomes in the public domain without violating the obligations herein assumed;

(b) that come to the knowledge of the parties in a non-confidential manner, received from third parties, whose access and disclosure have been completely independent, without violating any of the obligations assumed herein and without any confidential nature; or

(c) whose disclosure is required by law, regulation or administrative, judicial or arbitration decision.

Shining Service adopts all precautions and cautions to protect the information that travels on its website using modern, complete and effective computer security mechanisms.

The pages where your information is collected are encrypted with technology to protect your data during capture. Encryption is performed using technology for browsers that support SSL (Secure Socket Layer). You can check the encryption using the closed padlock or a full key in your browser.

When registering your data, you can indicate whether you wish to receive information from Shining Service. You will only receive emails and communications with institutional information, offers and promotions if you select this option when registering.

If you later no longer wish to receive information from Shining Service, you may select this option directly in our communications or through the channels provided by Shining Service, such as the Customer Service Center: +351 910 119 233 or the Online Chat, and you may also request the deletion of your data from our records.

When registering on our website, we will collect and store your IP data, as well as the date and time of access, for a minimum period of 6 (six) months, in accordance with current legislation. Such data will be stored confidentially, in a controlled and secure environment and will only be provided in the event of a court order. Even if you request the deletion of your data, such data will remain stored for the minimum period required by law.

During your visit to our website, you may find links to third-party websites. Shining Service, however, is not responsible for the privacy, security and content policies of such websites, and cannot be held responsible for any losses or damages suffered as a result of the use of such links or frames.

We recommend that you read the Privacy Policy of any website before starting to browse.

Some personal information registered on this website is sent over the Public Internet. At all data collection points on the website, we seek to remain alert so that no data may travel in an unsecured environment without your prior knowledge.

At any time, you may request the permanent deletion of your data from Shining Service’s files, except in the cases of maintenance provided for by law. To do so, use one of the channels provided by Shining Service, such as the Customer Service Center: (+351 910 119 233) or the Online Chat.

Shining Service cannot be held responsible for illegal interceptions or violations of its systems or databases by unauthorized persons, nor will it be responsible for the improper use of information obtained by these means.

For your security, it is important to emphasize that at no time do we request information such as your Credit Card number, your Account number and bank password, nor do we send any communication requesting this type of data through the website or registered email.

If any of this information is requested, We advise you not to provide them under any circumstances. Finally, we recommend that you never provide your access password to third parties. If this happens, change your password immediately, preventing strangers from accessing your data.

Use of Cookies

During your visit to our website, a navigation data collection system may be used through the use of “cookies”.

By browsing our website, you acknowledge and authorize this use.
A cookie is a small text file transferred to your computer’s hard drive that will help in many ways to make your visit to our website more enjoyable and efficient. Cookies are used to learn about the behavior and demographics of those who visit our website, and in this way, better understand their needs and interests and provide them with a better service or provide them with related information. For example, cookies prevent you from having to authenticate yourself every time you return to our website and allow us to personalize the page according to the content and services that interest you.

There are several different types of cookies. Some disappear as soon as you close all your browser windows or when you turn off your computer. Others are stored on your computer’s hard drive and will disappear on a specific date, or when they expire, or when they are replaced by newer cookies, or through manual removal. The installation, permanence and existence of cookies on your computer will depend exclusively on your will and can be deleted from your computer whenever you wish. You can also configure your computer to notify you when a cookie is downloaded.

Shining Service may use a third party service provider to enable and/or manage the functionality of the website through the use of cookies. This third party may use a click tracking analysis tool to capture click statistics.

They may also use other instrumentation tools that will help us determine, for example, whether a page has been viewed or not and, if so, how many times, but they will never have access to any personal information when applying such tools.

Emails or electronic newsletters that may be sent may use tools to collect email metrics and information to improve the reader experience, such as how many of the emails are opened, whether they were printed or forwarded, the type of device used to access the message (e.g., mobile phone or PC), in which state and municipality associated with the applicable IP address the access was made and through navigation on communication channels owned by Shining Service.

On our website we also use a “session recording” tool that helps us determine how people navigate through the composeresincourses website. In this way, we can structure our page so that the most visited information is easier to find. By monitoring how visits to pages occur, we can determine whether the information we are providing is of interest to our Customers, benefiting their navigation. To enable this monitoring, the only data collected is the IP address. (Internet Protocol) where you came from, the website you refer to, the pages visited and the date and time of those visits. Shining Service will not use cookies for purposes unrelated to its operation.

Interest-based behavioral advertising

On some pages of our website we may allow our marketing and advertising partners to set web tracking tools to collect anonymous

– non-personally identifiable

– information about your activities on those pages, such as the page(s) visited and time.

These partners may use this information (and combine it with information collected from other websites, applications or other digital services) for the purpose of delivering targeted advertisements in the future when you interact with other websites (that are not from Shining Service), mobile applications or digital services within their networks. This practice is commonly referred to as “interest-based advertising.”

Options to opt-out of interest-based behavioral advertising

The process for opting out of interest-based advertising is different for web browsers and mobile apps.

1. Options to opt-out of interest-based ads on website pages in major browsers.
   1. a) Google Chrome
   • 1. On your computer, open Chrome.
   • 2. In the top-right corner, click More.
   • 3. Click More Tools, then Clear Browsing Data
   • 4. At the top of the screen, choose a time range. To clear everything, select All Time.
   • 5. Check the boxes next to “Cookies and other site data” and “Cached images and files.”
   • 6. Click Clear Data.
2. b) Mozilla Firefox
   • 1. On your computer, open Mozilla Firefox.
   • 2. In the upper left corner, click Firefox.
   • 3. Select Preferences
   • 4. Go to the Privacy tab and select the Clear Your Recent History option.
   • 5. Determine the period you want to erase and what data you want to delete.
   • 6. Click Clear Now to delete the data saved by the browser.
3. c) Internet Explorer
   • 1. On your computer, open Internet Explorer.
   • 2. In the upper right corner, click Settings.
   • 3. Click on Security and then click on Delete Browsing History.
   • 4. A window will open and show your Browsing History.
   • 5. Click on the Delete button to delete all data saved by the Internet Explorer browser.
4. d) Safari
   • 1. On your computer, open Safari
   • 2. In the upper left corner, click on Preferences.
   • 3. Go to the Privacy tab and select the option Remove All Website Data.
   • 4. When you confirm your decision, all data saved by your browser will be deleted.

2. Options to opt out of interest-based ads on your smartphone.

iOS and Android mobile device users, and potentially users of other mobile devices, can control in-app advertising by disabling or resetting the advertiser ID on their mobile device. Below are links to instructions on controlling advertising IDs on iOS and Android devices.

For instructions on controlling advertising IDs for the iOS system, please visit: https://support.apple.com/en-us/HT202074

For instructions on controlling advertising IDs for the Android system, please visit: https://support.google.com/googleplay/answer/3405269

See the “Opting Out of Website Pages” section in the link above to opt out of interest-based advertising related to your browser. mobile phone.

During your access to our website, we may use a tool called Mouseflow to analyze clicks, touches, mouse movement, page navigation and other behavioral information during your access. To stop being part of the Mouseflow database of the Shining Service website, follow these steps:

• • 1) Access this website:

“https://mouseflow.com/opt-out/”>https://mouseflow.com/opt-out/

2) Click on the “disable” button.

• 1. With this brief action, we will not collect your data, which contributes to a platform with relevant information according to your interests and browsing profile.

The website’s Privacy Policy may be changed whenever necessary by Shining Service. Therefore, we suggest that you check it and update yourself periodically when accessing our website.

If you have any questions regarding the Privacy Policy, please contact us through one of the channels we provide, such as the Customer Service Center +351 910 119 233 or the Online Chat.

Date of last update of this Policy: December 2024