PGCS TECNOLOGIA PRIVACY POLICY

Last updated: March 18, 2026
Effective date: March 18, 2026

Welcome to PGCS Tecnologia!

If you indicate that you are a minor, you should consult our Privacy Information for Young Players.
If you are the parent or guardian of a minor, please see Section 2 (How do we handle minors' information?).
PGCS Tecnologia is headquartered in Natal, Rio Grande do Norte. We have offices and operations to create and deliver some of your favorite products and services, including games such as Mateo Paratodos and research projects such as the Photogrammetry Research.
This PGCS Tecnologia Privacy Policy (this "Policy") describes the different ways in which we may collect, use, protect, retain, disclose, and otherwise process information that may be used to identify you when you use, access, or interact with PGCS Services (defined below).
Please read this Policy carefully in its entirety and any other agreements applicable to your use of PGCS Services, and confirm that you understand and accept its terms before using any PGCS Services. If you have any questions, you can always contact us using the contact information provided in Section 12 (How can you contact us?).

1. WHAT DOES THIS POLICY COVER?
When this Policy uses the term "PGCS" (or similar terms such as "we", "us", or "our"), it refers to the PGCS entity that controls and is responsible for your data, such as PGCS Tecnologia LTDA. This Policy applies when PGCS acts as the controller of your data. You will find more information about the data controller in Section 12 (How can you contact us?).
We use the term "PGCS Services" to refer to any PGCS products and services that directly link to this Privacy Policy, including:

• our games (e.g., Currais em Chamas and Super Betinho Together);
• our digital platforms (e.g., PGCS Tecnologia Store);
• our development research projects (e.g., Photogrammetry Research);
• our films (e.g., Programando o Seridó);
• our website and subdomains (e.g., www.pgcstecnologia.com.br and itch.io/pgcstecnologia); and
• live events where this Privacy Policy is published.

It is important to note that your use of PGCS Services is also subject to additional terms and conditions. For example, you must read and accept the PGCS Tecnologia Terms of Service before playing Currais em Chamas and Mente em Movimento.

2. HOW DO WE HANDLE MINORS' INFORMATION?
PGCS is developing PGCS Services designed for users of all ages worldwide. This means we collect information about users' ages and some PGCS Services offer a different experience based on the user's age and location. The following information is intended to help parents and guardians understand our privacy practices relating to minors (under 13 years of age, or the minimum age for digital consent in the user's region, whichever is higher).
When a user indicates they are a minor, they are assigned a "Restricted Account" until they are no longer considered a minor as defined above, or until their parent or guardian grants additional privacy permissions and enables parental controls. Users with Restricted Accounts can play PGCS games (e.g., Currais em Chamas and Mente em Movimento), but certain features such as voice chat and real-money purchases are disabled. PGCS collects only a limited amount of personal data from Restricted Accounts in order to operate them, in accordance with applicable privacy and youth protection laws:

• the user's date of birth and country of residence, to determine their age and apply appropriate settings;
• the user's email address used for login (stored only in unreadable, hashed and salted form); and
• persistent identifiers such as IP address, gaming platform account IDs, device IDs, and similar information collected through website monitoring technologies, used to provide and maintain PGCS Services (including analytics to improve them), protect user safety and integrity, comply with legal and regulatory requirements, and facilitate in-game personalization to maintain user-defined preferences (e.g., game progress and avatar choice); and
• the email address of the parent or guardian, to notify them and request their consent to activate additional features (deleted if there is no response within 14 days).

If a user with a Restricted Account contacts us with a question or request, any personal data provided will be deleted after the matter is resolved. When we disclose personal data from Restricted Accounts to third parties, we do so only to fulfill these limited purposes.

A. Notice, Consent, and Parental Controls
We collect the email address of the minor's parent or guardian to send them an email notifying them that the minor has created a Restricted Account. This notice also allows them to review our privacy practices applicable to Unrestricted Accounts, give their consent for the minor to have an Unrestricted Account with access to additional features, and configure Parental Controls. Please note that parents or guardians must complete the parental verification process in order to give their consent for an Unrestricted Account.
When a parent or guardian consents to the minor having an Unrestricted Account, Parental Controls are automatically enabled. From that point, Parental Controls can be accessed via a PIN and allow the parent or guardian to review and modify the settings for selected features during the consent process, as well as further customize the minor's experience.
Once the parent or guardian authorizes an Unrestricted Account for the minor, the privacy practices described elsewhere in this Privacy Policy generally apply. However, younger users may not have access to all content or features (due to default privacy settings, age requirements for certain services and features, and/or active Parental Controls). For example, depending on the Parental Control settings selected and the user's age, they may access communication features (such as voice and text chat) and interact with most PGCS Services (including downloading other games or applications from the PGCS Tecnologia Store). For more information about our privacy practices, see Sections 3 (What information do we collect and how?), 4 (Why do we process information?) and 5 (To whom do we disclose information?). If you have any questions about the disclosure of personal data by PGCS, please contact us using the contact details in Section 12 (How can you contact us?).

B. Privacy rights of minors, parents, and guardians
In addition to the Parental Controls that allow parents or guardians to modify the choices they have made regarding the minor's use of certain features, such as voice and text chat, minors using a PGCS Account and their parents or guardians may exercise their individual privacy rights as described in Section 9 (What are your choices and control mechanisms?). These rights include the right to review the minor's personal data held by PGCS and to delete the minor's PGCS Account (which involves the deletion of their personal data and the cessation of any future collection). To exercise these rights or to raise any questions about how we handle minors' personal data, use the contact information provided in Section 12 (How can you contact us?) or access the Parental Assistance Request Form directly.

3. WHAT INFORMATION DO WE COLLECT AND HOW?
The types of information we collect depend on how you interact with PGCS Services. Generally, we collect information in three ways: A) when you provide it to PGCS; B) automatically, when you use PGCS Services; and C) from third parties.
This Policy aims to help you understand how we process information that may be used to identify you. In some cases, we may also create or collect information that does not personally identify you, such as anonymized or aggregated information. If we combine this type of information with data that identifies you, we will treat the combined information as data that may be used to identify you, and it will be subject to this Policy.

A. Information you provide
Depending on how you interact with PGCS Services, you may choose to provide us with different types of information. In some cases, we may ask you for specific data because it is required for the PGCS Services or their features. If you choose not to provide the requested data, you may be unable to access those PGCS Services or certain features may not work correctly. For example:

• When you access PGCS Services, we may collect your date of birth to determine your age and adjust the appropriate settings. If you indicate you are a minor, we will also collect your parent's or guardian's email address to send them a notice and request their consent to enable additional features.
• When you create a PGCS Account, we may collect basic registration data (e.g., name, public display name, password, country, and email address) to create and maintain your account, provide the PGCS Services you requested, enforce the terms or policies governing the use of PGCS Services, and maintain appropriate records documenting how we provide PGCS Services to you.
• When you make a purchase at the PGCS Tecnologia Store, we may collect your payment details (e.g., credit card number and expiry date, name, and region information) to complete the transaction, depending on the payment method used.
• When you subscribe to email alerts, we collect your email address to keep you informed about the updates you have opted into.
• When you enable two-factor authentication, we may collect your phone number and email address to help protect your account, depending on the authentication method used.
• When you use social features such as our forums or chat, we may collect the information you choose to share in or through those spaces (e.g., posts you make in our forums). When you use our voice chat feature and the voice reporting feature is enabled in a voice channel, voice chat snippets will be stored on your device and on the devices of other participants in that channel. If a violation of our terms or policies is reported (e.g., the Community Rules), those snippets may be transmitted to PGCS for review of the reported infringement and for enforcement of our terms and policies.
• When you use features based on AI technology, we use the data you provide (e.g., information that may identify you) to generate outputs (e.g., responses).
• When you use MetaHuman to create in-game characters, we collect images of your face solely to generate a facial mesh and provide the requested feature, and not to identify you.
• When you use our other development tools, we collect the information, including any content you create and publish.
• When you register for our events or pre-launch workshops for our games, we collect your registration data.
• When you submit a content removal request, we collect the data you provide us (e.g., name, contact information, signature, and evidence supporting your claim) in order to evaluate and respond to those requests.
• When you complete our surveys or questionnaires, we may collect your responses and your comments and suggestions.
• When you contact us through Player Support or another support channel, we collect your communications and contact details.

B. Information we collect automatically
We collect certain information when you visit, access, or use PGCS Services. The information collected includes, for example, your gameplay experience or application usage, which are typically associated with your PGCS Account, a third-party account (if you access PGCS Services through it), or an identifier we assign to your device or profile. While the types of information we collect automatically may vary, they generally include:

• usage information and statistics about how you interact with PGCS Services, including the application or game used, duration and time of use, game attempts, progress and results, saved preferences (e.g., language), crash reports, URLs of our sites visited, source and exit page URLs, pages viewed, time spent on each page, number of clicks, and platform type;
• technical information about the computer, device, hardware, or software you use to access PGCS Services, including IP address, device identifier, internet service provider, browser plug-ins, and other transactional or identifying information (e.g., device make and model, operating system, browser type, or other system-related specifications); and
• general location information about your device, typically inferred from its IP address.

PGCS Services use technologies such as cookies, log files, and web beacons to automatically collect the types of information mentioned above. Some of these technologies may create small files or logging tools that are stored on your device. These technologies help us recognize your device and collect information about how you interact with PGCS Services. We use this information, for example, to provide and operate PGCS Services (e.g., to authenticate you and save your preferences); monitor PGCS Services (e.g., detect and report errors); understand and improve PGCS Services (e.g., conduct data analysis); personalize PGCS Services (e.g., display local currencies); and promote PGCS Services (e.g., manage advertising).
When certain PGCS Services features are provided by third parties, those third parties may also use automatic information collection technologies and collect information about your use of PGCS Services, their services, or third-party websites over time. For example, when you use PGCS Services that incorporate third-party software, those third parties may collect your data through their technologies. Features provided by third parties are subject to their applicable privacy notices and policies.

C. Information we receive from third parties
In some cases, we may receive information about you from third parties in connection with your use of PGCS Services or your interactions with us through third-party platforms, websites, or services. For example:

• When you purchase, download, or access our games on third-party websites (such as itch.io), we may receive information from those websites to facilitate the purchasing experience, manage your digital rights, and assist with your use of PGCS Services.
• When you interact with an advertisement for PGCS Services on a third-party website or service, we may receive information from the company operating that website or service related to that interaction.
• If another user reports that you have violated our terms or policies, we may receive information about you from that user. If you are the parent or guardian of a minor with a PGCS Account, we may receive your email address directly from the minor in order to contact you to obtain verifiable parental consent.

Your privacy settings on third-party platforms, websites, and services generally determine what information is disclosed to PGCS, so we recommend that you review and update those settings regularly. While our use of information provided by third parties complies with this Policy, we do not control how those third parties collect or use your information. For more information, please refer to the privacy notices and policies of those third parties.

4. WHY DO WE PROCESS INFORMATION?
We process the information we collect, either individually or in combination with other information, as described in this Policy, for the purposes set out below. If you are located in the European Economic Area, the United Kingdom, or Switzerland, the relevant legal bases are identified below in brackets. For more information on legal bases, see Section 11 (Additional notice for persons located in the European Economic Area, the United Kingdom, or Switzerland).

• To provide and operate PGCS Services (contractual necessity or legitimate interests): For example, we may use your information to create and maintain your PGCS Account, grant you access to PGCS Services (including verifying your identity), enable PGCS Services features such as cross-progress features that allow gameplay experiences across multiple platforms and AI-based features, complete and manage your transactions, save your preferences, enforce our terms and policies, notify you of changes to them, and contact you regarding your PGCS Account, your transactions, and other service-related communications necessary for the operation of PGCS Services.
• To ensure and monitor PGCS Services (legitimate interests or contractual necessity): For example, we may use your information to respond to support requests and general questions you send us, as well as to detect and report errors.
• To improve security and protect PGCS Services and third parties (legitimate interests, contractual necessity, or legal obligations): For example, we may use your information to detect and prevent fraud, piracy, account theft, misuse, and other unauthorized activities in PGCS Services, as well as to protect the rights, assets, and safety of PGCS, our users, and third parties.
• To moderate PGCS Services (legitimate interests, legal obligations, or contractual necessity): For example, we may use your information to detect, moderate, and respond to content and behavior reported as illegal, harmful, toxic, or fraudulent, violating applicable law or our terms and policies.
• To develop PGCS Services (legitimate interests): For example, we may use your information to manage testing during alpha, beta, and early access phases, as well as to collect feedback and suggestions.
• To understand and improve PGCS Services (legitimate interests): For example, we may use your information to analyze how you use PGCS Services, support auditing processes, and improve features, technologies, and procedures, including by training machine learning technologies designed to detect and moderate illegal, harmful, toxic, or fraudulent behavior and content that violates applicable law or our terms and policies.
• To personalize PGCS Services (legitimate interests): For example, we may use your information to present content, features, and recommendations tailored to you or inferred from your activity, such as suggesting games from genres you frequently purchase, highlighting game islands and levels based on your gameplay history, and improving the machine learning technologies that help deliver those personalized recommendations.
• To promote PGCS Services (consent or legitimate interests): For example, we may use your information to manage, personalize, and evaluate the effectiveness of our advertising campaigns, promotional offers, surveys, and events.
• To facilitate corporate operations (legitimate interests): For example, we may transfer your information within our corporate group in the event of a company restructuring, or to a third-party entity in connection with a sale, merger, divestiture, reorganization, dissolution, insolvency, liquidation, or other transfer of some or all of our assets, or during negotiations thereof, as well as in any other similar corporate transaction.
• To assert, exercise, or defend rights in legal proceedings (legitimate interests or legal obligations): For example, if you bring legal action against us, we may use your information to investigate and respond to that action and present our defense; and if we detect misuse of PGCS Services, we may use your data to assert and enforce our rights in legal proceedings.
• To comply with applicable laws, regulations, and legal processes (legal obligations): For example, we may use your information to respond to legitimate requests from law enforcement and government authorities, including subpoenas, court orders, and search warrants; and we may use your date of birth to facilitate compliance with laws protecting minors and young people.
• For purposes to which you have consented (consent): For example, with your consent, we may use your information to send you marketing communications. You are not required to give your consent and may withdraw it at any time.

We may also process your information for additional purposes in the future, provided they are compatible with those described above, and we may explain such purposes to you at the time of collection. In addition, we may use information that does not personally identify you, such as anonymized or aggregated information, for commercial, operational, or other purposes permitted by applicable law.

5. TO WHOM DO WE DISCLOSE INFORMATION?
We may disclose some of your information to our subsidiaries and affiliates, our service providers, and other third parties for the purposes indicated above.
When we disclose information to our service providers, we seek to ensure that those providers maintain appropriate information protection safeguards that are identical or substantially similar to those described in this Policy (e.g., limiting their use of your information to the services provided). Our service providers include:

• database hosting and storage providers;
• customer relationship management tool providers;
• email service providers;
• payment processors;
• large language model technology providers, which enable the integration of AI features; and
• marketing and advertising partners.

Depending on the PGCS Services you use and how you interact with them, third parties include:

• gaming websites (e.g., Itch.io);
• social media platforms (e.g., Instagram) and digital game stores (e.g., Steam), if you link your PGCS Account to a third-party platform;
• other users (e.g., when you use social features such as chat), in which case certain information such as your display name, game statistics, and content created or shared may become publicly accessible;
• our lawyers, consultants, accountants, business advisors, and other similar third parties who have confidentiality obligations to us;
• a buyer or other successor in the event of a sale, merger, divestiture, restructuring, reorganization, dissolution, or other transfer of some or all of our assets, whether as a going concern or as part of an insolvency, liquidation, or similar proceeding, in which the information we hold about PGCS Services users is among the transferred assets;
• law enforcement authorities, government entities, or others as required to comply with applicable laws, regulations, or legal processes, or if we believe disclosure is necessary to protect the rights, assets, or safety of PGCS, our users, or third parties (e.g., to investigate fraud or other illegal activities, enforce our terms and policies, or protect our users or third parties from the risk of death or serious harm); and
• others with your authorization (e.g., if you use your PGCS Account to sign in to third-party products or services, participate in cross-promotional events, or use certain payment methods).

No mobile phone number provided to PGCS for security purposes will be shared with third parties or affiliated entities for marketing or promotional purposes.

6. WHERE DO WE PROCESS INFORMATION?
PGCS Tecnologia LTDA is headquartered in Brazil but operates globally to provide users around the world with a better PGCS Services experience. This means PGCS may process, retain, and transfer your information outside the country where you reside.
Data protection laws in those countries may differ from those in effect in the country where you reside. When we transfer your information outside the country where it was collected, we use appropriate legal mechanisms to legitimize the transfer and implement technical, organizational, and physical safeguards to protect your information. These mechanisms or measures include standard contractual clauses (such as the European Commission's Standard Contractual Clauses) and, where applicable, adequacy decisions by supervisory authorities.
Where permitted by law, your use of PGCS Services authorizes us to process your information in any country in which we operate, including the United States. To learn more about the location of the PGCS entity responsible for operating the PGCS Services you use, see Section 12 (How can you contact us?) below.

7. HOW DO WE HANDLE INFORMATION?

A. Retention
Since the specific data we process and the reasons for processing it often vary depending on how you use PGCS Services, the period for which we retain your data may also vary. Generally, we retain data for as long as we need it for the purposes described in Section 4 (Why do we process information?), unless the law requires or permits a longer retention period. For example, if you create a PGCS Account, we will typically retain the data associated with your account (e.g., name, public display name, password, country, and email address) for as long as necessary to maintain your account, provide the PGCS Services you requested, ensure compliance with the terms applicable to your use of PGCS Services, and record how we provide PGCS Services to you.

The main criteria we consider in determining specific retention periods often include the minimum requirements under applicable law, relevant industry standards, the type of data in question (e.g., its level of sensitivity), the purposes for which we process that data (e.g., compliance with our legal obligations, internal recordkeeping, ensuring compliance with our terms and policies, and dispute resolution), whether those purposes can be achieved by other means, the potential risk of harm from unauthorized use or disclosure of the data, the relevance of that data to any pending or similar legal proceedings (e.g., for presenting our defense in legal proceedings), and the need to retain data to prevent fraud or abuse of PGCS Services (e.g., to enforce bans related to cheating and other unauthorized behavior).
You may ask PGCS to delete your data. For more information on how to request deletion of your data, see Sections 9 (What are your choices and control mechanisms?) and 10 (Additional notice for persons located in the European Economic Area, the United Kingdom, or Switzerland).

B. Security
We implement appropriate administrative, technical, contractual, and physical safeguards to protect your data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use, as well as against any other form of unlawful processing. In certain cases, your data may become accessible to other users or the public when you use PGCS Services. To help keep your data secure, you should keep your login credentials confidential. If we become aware of an unauthorized disclosure of your data, we will notify you as required by law and take appropriate measures to help protect your data.

8. WILL THIS POLICY BE UPDATED?
Yes. We will periodically update this policy to reflect changes in our practices or applicable law. Whenever we do so, we will change the date at the beginning of this Policy. In some cases, we may also notify you of relevant changes by email or through the applicable PGCS Services. Please review this Policy regularly to make sure you understand your relationship with PGCS and the ways in which we collect, use, protect, retain, disclose, and otherwise process data that may be used to identify you in connection with PGCS Services.

9. WHAT ARE YOUR CHOICES AND CONTROL MECHANISMS?
We seek to provide you with relevant options regarding the data we collect. The options available to you often vary depending on the nature of your relationship with us, such as the PGCS Services you use. Common examples include:

• You can correct your data directly through your PGCS Account.
• You can request access to, rectification of, or deletion of the data we have collected from you.
• You can change your email marketing preferences at any time (e.g., by using the opt-out mechanism in our marketing communications, updating your PGCS Account settings, or contacting us directly).
• You can change your privacy settings on third-party platforms, websites, and services to limit the data they disclose to us.
• You can manage cookies and other automatic data collection technologies through your browser or device settings (e.g., by blocking, deleting, or limiting those technologies). Please note that disabling cookies may prevent some parts of PGCS Services from working correctly and may cause some features to become unavailable.
• You may contest or request human review of decisions made by automated means, as provided by applicable law.
• If you are under 18 and have a PGCS Account, you may ask us to delete or anonymize certain content you have provided through PGCS Services.
• Parents or guardians may adjust the minor's PGCS Account settings through Parental Controls.

To submit a request, contact us using the contact information provided in Section 11 (How can you contact us?). We may request additional data to confirm your identity before acting on your request.
In some parts of the world, local law grants individuals certain rights regarding their data. For more information, see Section 10 (Additional notice for persons located in the European Economic Area, the United Kingdom, or Switzerland).

10. ADDITIONAL NOTICE FOR PERSONS LOCATED IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM, OR SWITZERLAND
The General Data Protection Regulation (GDPR), together with similar laws in the United Kingdom and Switzerland, requires us to provide persons located in the European Economic Area (EEA), the United Kingdom, or Switzerland with information about their personal data in a different format. The terms used in this subsection have the meanings assigned to them in the GDPR.
If you are located in the EEA, the United Kingdom, or Switzerland, you have the right to:

• access your personal data;
• rectify your personal data;
• request the erasure of your personal data;
• request a temporary restriction on our use of your personal data;
• object to certain types of processing, including processing for direct marketing purposes and processing based on our legitimate interests;
• request data portability, including the right to receive a copy of your personal data; and
• withdraw your consent, where our processing is based on that consent (withdrawal of your consent does not affect the lawfulness of any processing carried out on the basis of your consent prior to its withdrawal).

We may ask you for additional data to verify your identity before acting on a rights request. We may also limit the scope of our response to a request in certain circumstances, namely when:

• the request is manifestly unfounded or excessive;
• the request adversely affects the rights and freedoms of third parties;
• there are compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or
• the processing is necessary for the establishment, exercise, or defense of a right in legal proceedings, for the performance of a contract with you, or for compliance with our legal obligations.

You also have the right to lodge a complaint with the data protection supervisory authority in your location (see links below) or to contact us directly to lodge any complaint (see Section 11 (How can you contact us?)). We would appreciate the opportunity to address your concerns in the first instance.

• EEA: European Data Protection Authorities
• United Kingdom: Information Commissioner's Office (ICO)
• Switzerland: Federal Data Protection and Information Commissioner

The legal bases on which we rely to process your personal data depend on the PGCS Services you use and how you interact with them. These legal bases are:

• Contractual necessity: when we process your personal data to provide the PGCS Services you requested under our Terms of Service or other similar contractual agreements entered into with you.
• Legitimate interests: we process personal data to pursue PGCS's business interests, weighed against the potential impact on your privacy rights.
• Legal obligations: when we process your personal data to comply with our legal obligations.
• Consent: when you give us your consent to process your personal data. You are not required to give your consent and may withdraw it at any time.

For more information on how these legal bases apply to different processing purposes, see Section 4 (Why do we process information?).

11. HOW CAN YOU CONTACT US?

A. Support requests
If you have questions or concerns related to PGCS Services (e.g., questions about a game, access to your PGCS Account, bugs, payments, content, or rights), please contact the corresponding support channel using the links below.
• Currais em Chamas
• Super Betinho Together
• Mateo Paratodos
• Araci Brasil
• Cinzel e Mar
• Mente em Movimento
• Hefesto

B. Privacy requests
If you would like more information about our privacy practices or this Policy, or to exercise your rights as a data subject, please send an email to pgcstecnologia@hotmail.com.

Contact details
PGCS Tecnologia LTDA

• Address: Rua Raimundo Chaves, 2182, Suite 501, Condomínio Empresarial Cand. Empresarial, Candelária, Natal - RN, ZIP 59064-390