Xscale Lancamentos LTDA

Personal Data Protection Policy (LGPD)

Effective date: November 6, 2026 · Owner: Carlos Henrique Ferreira Guimaraes · Reviewed every 12 months or after any material change

Legal framework

Xscale processes personal data according to the Brazilian General Data Protection Law (LGPD, Law 13.709/2018), only for legitimate, specific purposes, with data minimization.

Data Protection Officer

Carlos Henrique Ferreira Guimaraes is the appointed Data Protection Officer (Encarregado). Contact: [email protected].

Where data is processed

Data is processed and stored in Brazil, on the operator workstation in São Paulo. TikTok data stays in TikTok's own systems and is accessed only through the official API.

Data subject rights

Xscale will help TikTok Shop and sellers access, correct, export or delete data at a user's request within 15 days.

End of relationship

When the relationship with TikTok Shop or a seller ends, or the app authorization is revoked, all data obtained through the API is deleted within 30 days.

Breach notification

Suspected or confirmed breaches are reported to TikTok Shop within 48 hours and handled under the Incident Response Policy.

Review

This policy is reviewed at least every 12 months. The public privacy policy is at xscalelancamentos.com/privacidade.html.

Approved by Carlos Henrique Ferreira Guimaraes, Managing Partner, on November 6, 2026.