Xscale Lancamentos LTDA

Information Security Policy

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

Purpose

This policy defines how Xscale Lancamentos LTDA ("Xscale") protects the confidentiality, integrity and availability of the information it handles, including data obtained through the TikTok Shop Open API.

Scope

Applies to all Xscale systems, accounts, devices and people with access to them. Today Xscale operates a single internal tool used by its own staff to manage its own TikTok creator account (product selection, showcase, content publishing and affiliate performance). The tool is not offered to third parties.

Roles

Security Owner: Carlos Henrique Ferreira Guimaraes (Managing Partner) is accountable for this program, approves access, owns incident response and is the Data Protection Officer (Encarregado under LGPD). Contact: [email protected].

Principles

Related policies

Network Security, Endpoint Protection, Security Baseline, Access Control, Data Classification and Encryption, Incident Response, Vulnerability Management and Data Protection. All are published at xscalelancamentos.com/security.

Compliance

Xscale complies with the Brazilian General Data Protection Law (LGPD, Law 13.709/2018) and with the TikTok Shop Partner terms and data policies. Violations of this policy lead to immediate revocation of access.

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