Solution DiveSolution Dive

LGPD COMPLIANCE PROGRAM – SOLUTION DIVE

Applicable law: Lei Geral de Proteção de Dados Pessoais (LGPD)

Last updated: 28/04/2026

1. OBJECTIVE

This document establishes Solution Dive's compliance guidelines with the LGPD, ensuring:

  • Personal data protection
  • Transparency in processing
  • Information security
  • Respect for data subjects' rights

2. CONTROLLER AND RESPONSIBLE PARTY

Controller: Solution Dive

Legal representative: Luiz Felipe Klincevicius Nascimento

The company acts as the controller of data processed within the platform.

3. DATA PROTECTION OFFICER (DPO)

Solution Dive designates as DPO:

Responsible for:

  • Assisting data subjects
  • Interacting with regulatory authorities
  • Monitoring internal compliance

4. PERSONAL DATA PROCESSED

4.1 Registration data

  • Name
  • Email
  • Phone

4.2 Professional data

  • Position
  • Company
  • Diving operational information

4.3 Technical data

  • IP
  • Device
  • Access logs

5. PURPOSE OF PROCESSING

Data is processed for:

  • Operation of the Solution Dive platform
  • Dive simulation and planning
  • Technical operation records
  • Report generation
  • Security and system improvement

6. LEGAL BASIS

Processing is based on:

  • Contract execution
  • User consent
  • Legitimate interest
  • Compliance with legal obligations

7. LGPD PRINCIPLES APPLIED

Solution Dive follows the LGPD principles:

  • Purpose
  • Adequacy
  • Necessity
  • Free access
  • Data quality
  • Transparency
  • Security
  • Prevention
  • Non-discrimination
  • Accountability

8. DATA SUBJECTS' RIGHTS

The user may request:

  • Confirmation of processing
  • Access to data
  • Data correction
  • Anonymization or deletion
  • Portability
  • Consent withdrawal

Requests via:

9. INFORMATION SECURITY

Solution Dive adopts measures such as:

  • Data encryption
  • Access control
  • User authentication
  • Activity monitoring
  • Regular backups

10. INCIDENT MANAGEMENT

In the event of a security incident:

  • The event will be analyzed immediately
  • Affected users will be notified
  • Competent authorities may be informed

11. DATA SHARING

Data may be shared with:

  • Technology and hosting providers
  • Legal authorities, when required

Data is never sold.

12. RETENTION AND DISPOSAL

Data will be:

  • Kept only for as long as necessary
  • Deleted when no longer needed
  • Anonymized when applicable

13. PRIVACY BY DESIGN AND BY DEFAULT

Solution Dive adopts:

  • Privacy by Design
  • Privacy by Default

Meaning:

  • Minimum data collection
  • Secure settings by default

14. USE IN DIVING OPERATIONS

Due to the technical nature of the platform:

  • Data may include sensitive operational information
  • Access should be restricted to authorized professionals
  • The user is responsible for access management

15. INTERNATIONAL DATA TRANSFERS

If required:

  • Transfers will be made with providers that guarantee adequate protection
  • In compliance with the LGPD

16. AUDIT AND ONGOING COMPLIANCE

Solution Dive commits to:

  • Regularly reviewing processes
  • Updating security policies
  • Continuously improving data protection

17. PENALTIES AND INTERNAL RESPONSIBILITY

Users or collaborators who violate this policy may be subject to:

  • Access suspension
  • Account termination
  • Applicable legal measures

18. CONTACT

For LGPD-related matters:

19. COMMITMENT DECLARATION

Solution Dive reaffirms its commitment to:

  • ✔Information security
  • ✔Transparency
  • ✔Continuous system evolution
  • ✔User protection

20. DOCUMENT OWNER

Luiz Felipe Klincevicius Nascimento

CEO and Dive Supervisor

Solution Dive

21. CONCLUSION

This compliance program demonstrates that Solution Dive:

  • Is aligned with Brazilian legislation
  • Acts responsibly in data processing
  • Seeks technical excellence and operational safety