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Tocha, Chaves & Associados, SROC, Lda. (hereinafter, TCA), with registered office at Avenida Infante D. Henrique, Nº 333H – Offices 21 and 25, 1800-282 Lisbon, and corporate taxpayer number (NIPC) 506 410 331, is a professional services firm providing Statutory Audit services, and is the owner of the domain tcasroc.com, where its website is hosted.

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TCA is committed to protecting the privacy and personal data of its clients and website users, and has therefore drawn up and adopted this policy and the practices described herein. This Privacy Policy explains how your personal data is collected and processed, and we therefore recommend that you read it to understand the conditions under which your personal data is collected and used.

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WHAT IS THIS POLICY ABOUT?

This Privacy Policy explains how we collect and process the personal data necessary to provide the services available through the website, such as the distribution of a newsletter. The aim is for these services to be provided swiftly and without inconvenience, describing the practices adopted for this purpose.

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WHAT IS PERSONAL DATA?

Personal data is any information relating to a person that identifies them, or makes them identifiable, regardless of the nature or medium of the information, including the person's voice and image. Examples of personal data we collect: name, phone number, email. "Identifiable" means a person who can be identified, directly or indirectly, in particular by reference to an identification number or to other elements specific to their physical, physiological, mental, economic, cultural or social identity.

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HOW WILL WE USE YOUR PERSONAL DATA?

TCA will use the personal data you provide us to: analyze and respond to your messages, customer support and information requests; analyze and follow up on your job application to work with TCA; send newsletters or other publications you have requested and/or that may be of interest to you; operate and manage the website; and keep a record of your contact details. These operations are an essential tool for your satisfaction and for TCA's activity, and are carried out in accordance with applicable legislation and best practices. Your personal data will not be reused for purposes unrelated to those for which it was initially collected.

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WHAT ARE THE GROUNDS FOR PROCESSING THE PERSONAL DATA WE COLLECT?

The personal data processed by TCA has specific legal grounds depending on the purposes involved: for sending newsletters or other publications of interest to you, the ground is your consent for that specific purpose; for the operation and management of the website, the ground is consent for that purpose (cookies) and TCA's legitimate interests; for keeping a record of your contact details, the ground is your consent for that specific purpose; and for the adaptation, improvement and modification of services — namely by identifying usage trends or determining the effectiveness of promotional campaigns — the ground is consent for that purpose (cookies) and TCA's legitimate interests.

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WHAT PERSONAL DATA DO WE COLLECT?

The personal data collected and processed by TCA is only that which is necessary and appropriate for the purposes indicated above: for the job application process with TCA, we collect your email; for sending newsletters, for the operation and management of the website, and for keeping a record of your contact details, we collect your name and email.

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HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data through the forms available on the website, as well as through the website and its communication with your device, and through the emails you send us — namely through your newsletter subscription, your browser, cookies, pixel tags and other similar technologies, your IP address and your user data. TCA is committed to processing your data lawfully and legitimately, and will not sell, rent or share it with third parties, except in the cases identified in this Privacy Policy (see "When do we disclose data to third parties?"). TCA's services are not directed at minors, and personal data of minors is not intentionally processed.

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WHAT ARE COOKIES?

Cookies are small information files that help identify your browser and that can store user settings and preferences. TCA stores cookies on your device to personalize and facilitate browsing, for troubleshooting, statistics, quality assurance and system security monitoring. With the exception of cookies necessary for the website's performance, the storage of other cookies always depends on the user's acceptance and consent, which can be withdrawn at any time through specific browser tools. To learn more, please see our Cookie Policy.

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WHAT ARE PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES?

Pixel tags (also known as web beacons and clear GIFs) may be used in connection with certain services to track user actions (including email recipients), measure the success of marketing campaigns and compile statistics on the use of services and response rates. To learn more, please see our Cookie Policy.

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HOW DO WE PROTECT YOUR PERSONAL DATA?

Your personal data is kept secure through technical and organizational measures that ensure that only authorized staff and processes have access to it. We only use data center providers that offer adequate and documented security measures, with servers maintained in controlled, access-restricted environments. Personal data is kept on secure servers at TCA's offices, protected against disclosure, loss, misuse, alteration or unauthorized access. Even so, no security system is impenetrable — for this reason, please keep your password confidential, notify us immediately if you suspect any misuse, and always remember to log out when closing your browser.

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HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal data is kept for as long as necessary for the purposes for which it was collected: 1 year in the case of messages, customer support and information requests; job applications; sending newsletters; operation and management of the website; and keeping a record of contact details. Where the law provides for a specific or mandatory period, that period shall prevail. Once the retention period has ended, the personal data collected is deleted.

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HOW CAN YOU EXERCISE YOUR RIGHTS?

The law grants you the following rights: Access, to confirm whether your data is being processed and to access it; Rectification, to correct inaccurate data or complete incomplete data; Erasure, where one of the grounds provided for by law applies; Restriction of processing, in the situations provided for by law; Objection, to the processing of your data at any time; and Portability, to receive your data in a structured, commonly used and machine-readable format. You also have the right to lodge a complaint with the National Data Protection Commission (www.cnpd.pt). To exercise these rights, please contact TCA by email at dpo@tcasroc.com. If you request the deletion of your data, some services may no longer be provided to you, and TCA will retain the data necessary to comply with its legal obligations.

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WHEN DO WE DISCLOSE DATA TO THIRD PARTIES?

TCA may use third parties to provide maintenance, technical support, marketing, billing or payment management services, who may have access to the data necessary for these purposes. TCA ensures that these entities offer adequate protection guarantees, never providing them with more data than necessary, and remains responsible for the data made available. TCA may also disclose data to third parties in the context of judicial or administrative investigations or proceedings, pursuant to a court order to that effect.

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THIRD-PARTY WEBSITES

The website may contain links to other websites, the processing of personal data of which is the sole responsibility of their respective owners — for example, the Tax Authority or the Institute of Statutory Auditors, through the buttons available on the website. TCA has no responsibility for the policies or practices of these third parties.

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DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

Should data transfers to countries outside the European Union occur, TCA will comply with applicable legal rules, namely regarding the adequacy of the destination country in terms of personal data protection, and will not transfer data to jurisdictions that do not offer adequate security and protection guarantees.

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MINORS

The website is not directed at minors under the age of 16, and we therefore ask that they do not provide us with personal data through the website, application, social media or email.

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SENSITIVE PERSONAL DATA

We ask that you do not send us or disclose sensitive personal data — information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation. Should you do so, such data will be immediately deleted.

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CHANGES TO THE PRIVACY POLICY

TCA reserves the right to adjust or amend this Privacy Policy at any time, and any changes will be duly publicized.

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OUR CONTACT DETAILS

For any questions related to this Privacy Policy, please contact us in writing at dpo@tcasroc.com.

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LATEST VERSION

September 2026

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