Terms of Use

Hello, we are AdOpt! ¹

These Terms of Use of GO ADOPT LLC ^{1 2} – and the other companies within its corporate group, including its direct or indirect parent companies and subsidiaries, affiliates, and entities under common control – or simply "AdOpt," were created to establish the rules governing access to, use of, and all other conditions applicable to the AdOpt Platform, as described below:

Through its Consent Management Platform technology – CMP, which we will refer to herein as the "AdOpt Platform" – AdOpt provides the User with a customizable consent and privacy management tool that enables and facilitates browser configuration to disable the collection and storage of cookies ³.

To access and use the services we provide through the AdOpt Platform under the Software as a Service – SaaS model, you must provide the information required to complete your registration through the registration form, thereby becoming a "User." The following shall be considered a User:

• (i) the individual or legal entity contracting the services provided by AdOpt, to whom a license to use the AdOpt Platform will be granted in accordance with the conditions established herein; and
• (ii) any person, whether authorized or not, who uses the software on behalf of the User by entering a valid login and password.

The AdOpt Platform enables the User to:

• a) manage the available preference settings for internet users – hereinafter referred to as "data subjects" – who visit the User's websites, whether in web and/or mobile versions;
• b) maintain records of data subjects' decisions regarding the consent granted for the processing of personal data or the withdrawal of such consent; and
• c) configure hierarchical levels of User access to the features available on the AdOpt Platform, at the User's discretion.

Access to the AdOpt Platform is provided through a software license granted by AdOpt to the User on a (i) personal, (ii) non-transferable, (iii) non-exclusive, (iv) free or paid, depending on the selected Plan, and (v) temporary basis. The license to use the AdOpt Platform DOES NOT include:

• a) the assignment or licensing, under any title, of intellectual property rights or economic and moral rights relating to the Software/Platform, since only a license to use the Software/Platform is granted; nor does it include the assignment or licensing of industrial property rights relating to trademarks, graphic elements, or similar assets;
• b) the granting of any right to sublicense, reverse engineer, adapt, or translate the source code;
• c) the provision of services of any nature by AdOpt to the User, except for those expressly provided for under this agreement; or
• d) the provision of the programs and equipment required to access the Software/Platform.

The services provided through the AdOpt Platform will be delivered according to the features and prices offered by AdOpt, as described on the Plans page. AdOpt reserves the right to change the features, conditions, and prices of the Plans offered, provided that the User receives at least 30 (thirty) days' prior notice and retains the right to terminate the agreement at no cost if the User does not wish to remain bound by the new terms of the subscription.

The services provided by AdOpt will be considered contracted by the User upon completion of the following actions:

• a) submission of the User registration form and creation of one or more accounts – "login" or "logins" – and passwords to access the AdOpt Platform;
• b) selection of any Plan for the use of the services provided by AdOpt, according to the features and criteria described on the Plans page, within the AdOpt Platform itself, or in a valid Commercial Proposal submitted by an authorized AdOpt salesperson or partner; and
• c) acceptance of the Terms of Use and Privacy Policy through the User's electronic signature.

The following specific conditions will apply to any User who creates a new account on the AdOpt Platform on or after July 22, 2026, and wishes to test the AdOpt Platform without commitment under the "Free Trial":

• a) free registration, without the requirement to provide payment information – such as credit card details – which will only be requested if the User expressly chooses one of the paid Plans available on the Plans page;
• b) access to a trial version of the AdOpt Platform for a maximum period of 30 (thirty) days, with the right to use the tool with limited features, as made available by AdOpt;
• c) during the Free Trial period, the User will be contacted by AdOpt's sales team, which may recommend a paid Plan compatible with the User's identified use of the AdOpt Platform. Such recommendation will not be binding, and the absence of such contact will not create any right or entitlement for the User; and
• d) at the end of the Free Trial period, if the User does not select any of the paid Plans offered by AdOpt and/or does not complete the actions required to contract AdOpt's services under this section, access to the AdOpt Platform will be discontinued and the agreement will be automatically terminated in accordance with these Terms of Use, at no cost or liability to either party.

Any Plan migration requested by the User after the subscription has been completed will be processed within 24 (twenty-four) hours after the User's registered payment method has been validated.

The relationship between the parties is ongoing, taking effect on the subscription date and renewing automatically and successively according to the billing cycle of the Plan selected by the User.

The Plans offered by AdOpt are available on a monthly or annual basis and will be provided continuously until the User expresses a desire to terminate the subscription by submitting a written request to [email protected] or directly through the Platform.

Following a cancellation request, the services – and, consequently, access to the Platform – will be discontinued on the final day of the User's current subscription period.

Until the User expresses an intention to terminate the agreement, the services will continue to be provided regularly, and all payments due under the applicable Plan will remain fully payable, even if the User does not use the services for any reason.

AdOpt will be entitled to receive the monthly fee corresponding to the Plan selected by the User. The User must register and activate the desired payment method directly through the Platform to allow AdOpt to charge the amounts due for the provision of the services.

The monthly price of the Plans may be adjusted at any time. Increases resulting from annual inflation adjustments, limited to 7% (seven percent), will be communicated to the User in writing and will only take effect on the subscription renewal date. Increases exceeding the inflation adjustment may be implemented when negotiated and agreed upon by both Parties.

IF THE USER CONTINUES TO USE THE ADOPT PLATFORM AFTER THE NEW TERMS AND CONDITIONS BECOME EFFECTIVE, THE PRICES WILL BE DEEMED TACITLY ACCEPTED BY THE USER. In such case, the User will only retain the right to request the discontinuation of the renewal and/or termination of the subscription, in accordance with the terms and deadlines established herein and at no cost, before the end of the applicable period.

In the event of non-payment, a penalty equal to 2% (two percent) of the outstanding amount will automatically apply, together with interest of 1% (one percent) per month, in addition to the outstanding charge.

The services provided to the User may be interrupted by AdOpt under the following circumstances:

• a) failure to pay any amount owed to AdOpt for more than 10 (ten) days, without prejudice to AdOpt's right to collect the overdue amounts, monetary adjustments, late-payment interest, and the penalties established herein;
• b) violation of any provision of these Terms of Use or AdOpt's Privacy Policy;
• c) use of the AdOpt Platform, data, and/or information for any purpose that violates the law, morality, or generally accepted standards of conduct; or
• d) the User being declared bankrupt or insolvent or becoming subject to out-of-court reorganization proceedings.

Once the services have been interrupted, if the violation cannot be remedied or if, after being notified by AdOpt, the User fails to take the necessary steps to resolve the matter within a maximum period of 5 (five) days, the agreement between the parties will be deemed automatically terminated as a matter of law.

The parties establish, as a Service Level Agreement – SLA, that AdOpt must maintain the AdOpt Platform available for access for at least 99% (ninety-nine percent) of the time during which the relationship between the parties remains in effect. The 1% (one percent) excluded from the SLA will not be considered an interruption.

THE SOFTWARE AND SERVICES ARE PROVIDED BY ADOPT ON AN "AS IS" BASIS, WITHOUT ANY EXTRAORDINARY WARRANTIES OR CONDITIONS NOT EXPRESSLY PROVIDED FOR IN THESE TERMS OF USE. IN PARTICULAR, OUR SERVICES MAY NOT BE FREE FROM INTERRUPTIONS OR ERRORS. THE USER WAIVES ANY AND ALL CLAIMS FOR COMPENSATION AGAINST ADOPT FOR INDIRECT, NON-ECONOMIC, OR ECONOMIC DAMAGES. ADOPT IS NOT RESPONSIBLE FOR THE QUALITY OF THE USER'S INTERNET CONNECTION OR FOR THE USER'S EQUIPMENT, SOFTWARE – WHETHER UPDATED OR NOT – TECHNICAL NETWORK INFRASTRUCTURE, OR CYBERSECURITY INFRASTRUCTURE.

The User acknowledges that the User is solely responsible for the actions performed by its representatives while using the Software/Platform and for determining whether such actions are consistent with the expected results. AdOpt will not be responsible for any actions performed by the User or for any information entered or registered by the User.

Reservation of Rights: AdOpt reserves all rights, title, and interest in and to its Platform, including all associated Intellectual Property rights.

AdOpt grants the User a worldwide, non-exclusive license for a term linked to the continued maintenance of the User's subscription with AdOpt. This license is granted strictly for the User's own use, and any form of sublicensing is prohibited unless expressly authorized by AdOpt. This grant is subject to these Terms, any applicable exhibits or attachments, and any applicable Purchase Order.

The service is provided with limited access and without any transfer of ownership to the User. AdOpt owns and retains all rights, title, and interest, including intellectual property rights, relating to the Platform, including all modifications, updates, improvements, extensions, components, and derivative works of the AdOpt Platform. All rights not expressly granted under these Terms of Use are reserved by AdOpt.

AdOpt and its Affiliates may use the Data collected to create anonymized information and metrics for the purpose of improving the Services and performing product development, diagnostics, and corrections in connection with the Solutions. Such Data will be used in an anonymized form without being directly associated with the User.

The User grants AdOpt and its Affiliates a worldwide, perpetual, irrevocable, and royalty-free license to use and incorporate into the Platform any suggestion, enhancement request, recommendation, correction, or other feedback provided by the User or any third party regarding the operation of the Platform. Such feedback may be provided through official public communication channels, such as software review websites, or through communications between the User and AdOpt's operating team.

AdOpt may use the User's name and logo on its website to identify the User as a user of the AdOpt Platform. AdOpt may also refer to the User publicly in other promotional materials, press releases, events, or case studies without the User's prior express consent. If the User has any objection to this authorization, the User may contact AdOpt at [email protected].

AdOpt's Solutions may include tools designed to interoperate with services provided through the AdOpt Platform. If the User chooses to use these tools, the User may be required to obtain access to the relevant service and grant AdOpt access to the User's account for that service to ensure proper integration.

Any acquisition of White-label products, solutions, or services, as well as any exchange of data between the User and any White-label Application, is the User's sole responsibility. AdOpt does not warrant or provide support for White-label Applications or other third-party products or services unless expressly specified in the documentation formalizing the acquisition of the relevant platforms between AdOpt and its White-label provider partner.

As established in the Privacy Policy, if the User installs or activates a White-label Application for use together with the AdOpt Platform, the User agrees that the provider of the White-label Application may access the User's data as necessary to integrate the White-label Application with the AdOpt Platform. In this context, AdOpt will not be responsible for any incident, disclosure, modification, or deletion of data resulting from access by a White-label Application.

AdOpt will only process the personal data of the User – and of individuals within the User's organization – that is strictly necessary to fulfill the contractual obligations undertaken by AdOpt, in accordance with AdOpt's Privacy Policy.

With respect to the personal data of third parties – including, but not limited to, visitors to the User's websites – the User acknowledges that the AdOpt Platform does not collect or otherwise process such data, except when AdOpt is contacted directly by a data subject exercising the right to withdraw consent provided through the AdOpt Platform and/or any of the rights established under Article 18 of Brazilian Law No. 13,709/2018 – LGPD, as further described in AdOpt's Privacy Policy.

In the circumstances described above, AdOpt, acting as a data processor, will collect only the data subject's name and email address for the purpose of fulfilling the data subject's rights, particularly the withdrawal of consent.

When data subjects exercise rights granted by law – subject to the determinations of the applicable data protection authorities – and such exercise affects the activities performed by AdOpt, the User must notify AdOpt of the request immediately or within a maximum period of 24 (twenty-four) hours after receiving it, so that AdOpt may take the appropriate measures. Failure to do so may result in the User being held responsible for any losses and damages caused to AdOpt.

The User acknowledges that AdOpt has no responsibility for any personal data collected and processed by the User and/or third parties that have access to such data. The User will be responsible to AdOpt for ensuring the lawfulness of the processing of third-party personal data carried out through the consent management services provided by the AdOpt Platform.

In the event of a formal request from any competent Authority or duly authorized party, or as required by any legal or regulatory obligation, AdOpt may provide the requested information and disclose the requested data without requiring authorization from the User or the respective data subjects.

AdOpt may engage specialized third parties to process Personal Data – the "Sub-processors." AdOpt is responsible for ensuring that its Sub-processors agree to maintain a level of security equal to or greater than the level described in these Terms before any Personal Data is transferred or any sub-processing is authorized.

AdOpt must also conduct periodic reviews to verify compliance with privacy laws, as listed above and also made available in our Privacy Policy, and with any other applicable laws. AdOpt will be fully, jointly, and severally liable for any violation, irregularity, or unlawful conduct committed by its Sub-processors.

AdOpt guarantees and is responsible for the reliability of its employees, agents, and representatives who may have access to Personal Data, taking into consideration the nature of such data and the need for access.

AdOpt guarantees and ensures the confidentiality and integrity of the information shared by the User by implementing appropriate technical and administrative information security measures designed to prevent the improper and unauthorized use of Personal Data, including:

• (i) providing timely and appropriate responses to requests from the User relating to the processing of Personal Data and taking into consideration the guidance issued by state or national data protection authorities;
• (ii) maintaining written records of processing activities in compliance with applicable law, including a detailed inventory of access to Personal Data and records of connections and access to applications, containing information regarding the time and duration of access, the identity of the employee or person responsible for the access, and the file accessed, as required by law or by determinations issued by competent authorities;
• (iii) authorizing access to Personal Data only for qualified individuals responsible for processing such data;
• (iv) processing Personal Data in full compliance with the rights of the data subject and in accordance with the established purposes, including all operations involving Personal Data;
• (v) ensuring the right to receive information regarding any processing of the data subject's data, access to the data subject's own data, and the rationale used in automated decision-making, among other rights provided under applicable law;
• (vi) maintaining records of activities involving international transfers of Personal Data, identifying the destination country or organization and adopting the safeguards necessary to comply with applicable laws and the guidance of competent authorities; and
• (vii) responding to information requests submitted by the User within 36 (thirty-six) business hours and providing justification for any delays.

AdOpt agrees to establish contingency mechanisms to prevent data breaches, which will be regularly tested and updated. AdOpt also agrees to provide the User, upon request, with access to its Business Contingency and Continuity Plan – BCCP, whether to respond to requests from competent authorities or in connection with potential legal proceedings.

AdOpt will not disclose Personal Data to third parties except under the following circumstances:

• (i) in accordance with the sub-processing rules described above;
• (ii) with the User's prior written authorization; or
• (iii) in accordance with applicable data protection law, provided that only the minimum amount of Personal Data necessary for a specific purpose is shared and that the User is notified in advance, as provided for under this Agreement.

In the event of an actual or suspected breach or potential threat to the protection and security of Personal Data, or if there is any suspected loss, destruction, deletion, damage, corruption, impairment, use, or disclosure of Personal Data to unauthorized third parties, AdOpt must notify the User within a minimum period of 36 (thirty-six) business hours after becoming aware of the incident.

Such notification must contain full details of the breach, including:

• a) the date and time of the incident;
• b) the date and time on which the affected party became aware of the leaked data;
• c) the types of data affected by the incident;
• d) the data subjects affected by the incident, where applicable;
• e) the nature and details of the breach, including information about the Personal Data subjects, where possible;
• f) the contact information of the individual responsible for data protection or of the representative appointed to handle data breaches within the company, who will be responsible for providing additional information regarding the incident;
• g) the likely and/or potential consequences of the incident; and
• h) the measures adopted or proposed by AdOpt or by the individual responsible for protecting the Personal Data to remedy the breach and mitigate any adverse effects, together with the implementation dates for such measures – the action plan.

If AdOpt receives any court order or official communication requiring the provision or disclosure of personal information, unless expressly prohibited by law, regulation, court order, or administrative order, AdOpt will notify the User within a maximum period of 36 (thirty-six) business hours, enabling the User to take timely legal measures to prevent or mitigate the effects resulting from the disclosure of the Personal Data covered by the request.

AdOpt's support regarding any privacy and data protection laws can be contacted at [email protected] and [email protected].

In the event of a data breach or incident, AdOpt will act promptly in accordance with the instructions provided by the User to remedy or mitigate the adverse consequences. AdOpt will also take all measures necessary to contain the breach, recover and/or restore the Personal Data, where possible, and respond to any request, notification, or investigation conducted by the competent state or national data protection authority.

AdOpt will cooperate in responding to requests from data subjects by using the appropriate technical and organizational measures, in accordance with the User's instructions.

If either Party, to the extent of its respective actions, fails to implement the mitigation measures established under these Terms and/or any other measures required by applicable Law and thereby causes any losses, damages, fees, expenses, and/or judgments arising from:

• (i) an actual violation of applicable Personal Data Protection laws;
• (ii) actions or omissions involving gross negligence, lack of professional skill, or willful misconduct;
• (iii) improper processing or processing performed in violation of applicable Personal Data Protection laws; and/or
• (iv) incidents involving the other Party's Confidential Information and Personal Data,

the Innocent Party will be entitled to indemnification from the Breaching Party that caused the losses, damages, and penalties of any nature suffered by the Innocent Party, provided that they are duly established in court.

The User is responsible for updating and maintaining the accuracy of all information provided to AdOpt in connection with the User's account, as well as the banking information provided to enable payment for the services.

AdOpt may amend these Terms of Use, including the Plans and their features and prices, whenever AdOpt deems necessary. ANY CHANGES WILL BE COMMUNICATED TO THE USER AT LEAST 30 (THIRTY) DAYS BEFORE THEY BECOME APPLICABLE.

AdOpt may assign or transfer the rights and obligations under this agreement at any time, and the User agrees to cooperate with AdOpt in connection with any such assignment or transfer.

Any tolerance or concession granted by AdOpt to the User will not constitute a waiver, novation, or implied or express amendment and will not prevent AdOpt from requiring compliance with the provisions of this agreement at any time.

AdOpt's Terms of Use apply exclusively to the services provided by AdOpt. AdOpt is not responsible for any other services that may be governed by equivalent and independent third-party instruments that do not form part of this document.

The Parties – the User and AdOpt – are independent. These Terms do not create a partnership, franchise, association, joint venture, agency, fiduciary relationship, or employment relationship between the parties.

For purposes of interpreting these Terms of Use, if the User is domiciled outside the United States, these Terms will be governed by and construed in accordance with the laws of the State of Delaware, United States.

With respect to the venue for resolving disputes, if the User is domiciled in Brazil, the Central Court of the Judicial District of Curitiba, State of Paraná, Brazil, will have jurisdiction over any dispute, question of interpretation, or claim arising out of or relating to these Terms, regardless of any other jurisdiction, however favorable it may be.

For Users domiciled outside Brazil, the parties irrevocably and unconditionally submit to the exclusive jurisdiction of the courts located in Dover, Delaware, United States.

These Terms will be interpreted in accordance with Brazilian law, with the Brazilian Civil Code applying on a supplementary basis to any matters not expressly addressed herein.

This instrument will be binding upon the contracting parties and their respective successors and heirs with respect to all of its provisions, terms, and conditions.

If any provision or condition of this instrument is, for any reason, held to be null, invalid, or unenforceable by any court or tribunal, the validity of the remaining provisions will not be affected. The remaining provisions will remain fully valid, binding, and enforceable to the maximum extent permitted.

This version of the Terms of Use of the AdOpt Platform becomes effective on:

• (i) July 22, 2026, for Users whose registrations are submitted on or after that date; and
• (ii) August 22, 2026, for Users who already had an active agreement with AdOpt as of July 21, 2026, in compliance with the 30 (thirty)-day notice period following the publication of this version.

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Footnotes

1. AdOpt's legal entity in the United States is GO ADOPT, LLC, EIN: 86-3965064, with its registered address at 7345 W Sand Lake Road, Ste 210, Office 5898, Orlando, FL 32819. ↩ ↩²

2. AdOpt's legal entity in Brazil is GO ADOPT, LTDA, a privately held legal entity registered with the Brazilian National Registry of Legal Entities – CNPJ/MF under No. 51.889.157/0001-50, with its registered office at Av. Sete de Setembro, No. 2775, Rebouças, Curitiba, Paraná, ZIP Code 80.230-010, Brazil. ↩

3. "Cookies" are small text files used to store information about visitors to websites and internet pages. ↩