In accordance with Articles 8, 13, 14, and 21 of the General Data Protection Regulation (GDPR).

1. Data Controller The entity responsible for the processing of personal data is Bethera, Lda., located at Rua Pinhal Cotelo, nº5, with NIF 515478830, which can be contacted at [email protected] for any questions related to the processing of your personal data.

2. Legal Framework The processing of personal data by Bethera, Lda. complies with Regulation (EU) 2016/679, of April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data. The data collected will be used for the purpose that motivated its collection and for which it was authorized by the respective data subject. With the explicit consent of the data subjects, the data may also be used for contacts with information related to the purpose of the processing.

3. Data Collection and Forms In filling out forms, the communication of your personal data is optional, free, and voluntary. However, in certain forms, the information marked with an asterisk (*) is mandatory. The absence of this information will result in the inability to analyze the request and, consequently, to provide the requested information or services. In filling out and submitting forms, in addition to the name, email, and phone contact, the system records the IP address, date, time, communication service provider, browser, and equipment used.

4. Categories of data processed In the provision of services and the offering of products, Bethera, Lda. processes the following categories of personal data of Clients and non-Clients: civil identification data (for example, name, gender, date of birth, signature); tax identification data (for example, tax identification number); digital identification data (for example, IP address); address and contact data; and professional and academic qualification data, when applicable.

5. Location Data Our mobile application can access precise location data from your device, including in the background (when the application is not actively being used). This collection occurs only with your express consent, granted through the operating system permissions, and only when you use features that depend on location. We use this data to record your geographical location at the time you check in and check out, and to present you with the history of those records. Location data is not shared with third parties and is stored exclusively on the servers of Bethera, Lda. You can disable location access at any time in your device settings, which may limit some functionalities of the application, particularly the automatic location recording during check-in/check-out.

6. Purposes and grounds for processing Bethera, Lda. processes personal data under one of the following purposes: execution of contracts entered into or pre-contractual measures at the request of the data subject; compliance with legal obligations to which it is subject; and pursuit of its legitimate interests (namely, the management of business contacts and the improvement of services). Other situations require the consent of the data subject, provided freely, specifically, informed, and unequivocally.

7. Communication of data to third parties To fulfill its duties and provide quality service, Bethera, Lda. may share your personal data with the following categories of recipients: Tax Authority and service providers that support its activities (for example, hosting, communications, and statistical analysis).

8. Data Retention The processing will continue as long as necessary or required for the stated purposes. Once the contractual relationship has ended, the data will be retained for the mandatory legal periods or until the rights arising from them expire, in accordance with the law.

9. Rights of the data subjects Under applicable legislation, data subjects have the following rights:

1. Right of access: to access your data, obtain information about its processing, and a copy of the processed data.
2. Right to rectification: to request the correction or completion of incomplete or incorrect data.
3. Right to erasure: request the deletion of your data in cases provided for by law, without prejudice to legal obligations that may limit this right.
4. Right to limit processing: request limitation in cases provided for by law.
5. Right to data portability: to receive the data you provided in a structured, commonly used, and machine-readable format, and to transmit it to another controller, when applicable.
6. Right to object: to oppose, at any time and for reasons related to your particular situation, the processing of data based on legitimate interest, as well as to oppose processing for direct marketing purposes.
7. Right to withdraw consent: when the processing is based on consent, it can be withdrawn at any time, without affecting the lawfulness of the previous processing.
8. Right to complaint: submit a complaint to the National Data Protection Commission (www.cnpd.pt).

10. Security Bethera, Lda. implements appropriate technical and organizational measures to protect personal data, including two-factor authentication (2FA) for account access, encrypted storage of passwords, protection of access points against unauthorized access attempts, and regular backups on redundant servers..

11. Changes This Policy may be updated. We recommend checking it periodically at www.bethera.pt. For any questions, contact [email protected].

Last updated: 07/31/2026