IMCoach, Unipessoal, Lda. (hereinafter referred to as the "Company", "we", "us", or "our"), corporate tax identification number (NIPC) 513516204, headquartered in Portugal, European Union, respects the privacy concerns of the users of its website, www.opbsys.com, and the services provided therein (collectively referred to as the "Site").

The Company provides this Privacy Policy in full compliance with the European General Data Protection Regulation (GDPR) and applicable Portuguese data protection laws (such as Law no. 58/2019), to explain what information is gathered during your visit to the Site and how such information may be used.

By using the Site, you signify your free, explicit, and informed consent to the collection and use of your data as described in this policy. If you do not agree with these terms, please do not use the Site.

1. Information Collected and Basis for Processing

As a general policy, no personally identifiable information (such as your name, address, or email address) is automatically collected during your visit to the Site.

However, certain non-personal technical information is recorded by the standard operation of our internet servers managed via our infrastructure provider (Systeme.io), including your browser type, operating system, and IP address, strictly to enhance your online experience and maintain technical security.

We collect personal data only when you voluntarily provide it to us, such as when you sign up for our 7-day free trial, request digital downloads, or contact support.

This information includes your Name and Email Address.

Our legal basis for processing your personal data is:

• Your Consent: When you sign up for our 7-day free trial or opt-in to our communications.

• Performance of a Contract: To grant you temporary access to the OPB System Blueprint learning portal.

• Legitimate Interests: To improve our services, prevent fraud, and manage our business relationships.

2. Use and Sharing of Information

Personally identifiable information is never sold, rented, or leased to third parties.

With your explicit permission, we will use your contact information to send you technical notices, invoices, updates regarding the OPB System Blueprint, and promotional communications.

You can opt-out of these communications at any time by clicking the "unsubscribe" link found at the bottom of every email.

We share your information with trusted third-party service providers only as necessary to deliver our services, specifically:

• Systeme.io (ITACWT LTD): Our software infrastructure provider for course hosting, email delivery, and user management.

• Payment Gateways (e.g., Stripe/PayPal): If you choose to purchase OPB System Blueprint, the Company does not store or have access to your credit card details.

We may disclose your information if required by law or in special cases where we have reason to believe that disclosure is necessary to protect our legal rights, property, or the safety of our users.

3. Choice / Opt-Out (Unsubscribe Policy)

You have the absolute right and opportunity to opt-out of receiving communications from us at any time.

Every marketing or informational email sent by the Company includes a direct "unsubscribe" (opt-out) link in the footer.

If you wish to discontinue future communications, simply click that link for immediate automated removal from our mailing list.

If you encounter any technical difficulties during this process, you may email us directly at info@imcoach.pt stating that you wish to be removed, and our team will process your request manually.

4. Third-Party Software and Independent Data Controllers

The OPB System Blueprint program includes educational content and recommendations regarding the Systeme.io platform.

If you choose to register, create a workspace, or buy a subscription directly from Systeme.io (ITACWT LTD), they act as an independent Data Controller for the personal data processed within your personal workspace.

This Privacy Policy only concerns the processing for which IMCoach, Unipessoal, Lda. is the data controller.

5. Protection of Minors (Under Age 16)

The Company recognizes the obligation to protect personal data obtained from minors. In compliance with European standards, if you are 16 years old or younger, you must not submit any personal information to this Site.

If we discover that a minor under 16 has provided us with personal data without verifiable parental consent, we will immediately delete that information from our records.

6. Use of Cookies and Tracking Technologies

Cookies are small text files transferred to your device to enhance your browsing experience, remember your preferences, and track marketing metrics.

This Site utilizes two types of cookies:

A) Functional and Native Cookies (Provided by Systeme.io): these are technically mandatory for the correct operation of the software infrastructure. they include session cookies (so you do not need to re-login continuously inside the student portal) and affiliate tracking tokens (necessary to identify and attribute referral commissions in accordance with the platform's affiliate program).

B) Marketing and Analytics Cookies (Deployed by Us): we utilize tracking scripts to optimize our advertising campaigns and understand user behavior:

• Meta Pixel (Facebook): to measure advertising effectiveness and serve relevant ads based on your interactions with the Site.

• Google Analytics / Google Tags: to collect anonymous traffic data and analyze how visitors navigate the Site.

Since our infrastructure provider (Systeme.io) does not deploy a built-in cookie consent banner, you can control or block the installation of marketing and tracking cookies directly through your internet browser settings (by blocking third-party cookies) or by using privacy-focused browser extensions (such as ad-blockers or tracking blockers).

Please note that completely disabling essential functional cookies may prevent you from accessing the student learning portal properly.

7. International Data Transfers

The servers and databases utilized by our platform provider (Systeme.io) may be located outside the European Economic Area (EEA), including the United States.

To ensure your personal data remains fully protected, all such transfers are covered by appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring an equivalent level of data protection to that within the EU.

8. Your GDPR Rights

As a resident of the European Union, you hold the following rights regarding your personal data under the GDPR:

• Right of Access: You have the right to request a copy of the personal data we hold about you.

• Right to Rectification: You can request that we correct any inaccurate or incomplete data.

• Right to Erasure ("Right to be Forgotten"): You can request that we completely delete your personal data and student account from our systems.

• Right to Restrict or Object to Processing: You can object to your data being used for direct marketing.

• Right to Data Portability: You can request that your data be transferred to another provider.

To exercise any of these rights, please send an email to our official support team at info@imcoach.pt with your specific request in the subject line (e.g., "GDPR Delete My Account").

We will process your request free of charge within 30 days.

9. Data Security

Data security is extremely important to us. We implement appropriate technical, administrative, and physical security measures to protect your personal information from unauthorized access, loss, or misuse.

Access to your data is restricted strictly to authorized team members who require it to perform specific customer support duties. However, please acknowledge that no digital transmission over the Internet can be guaranteed to be 100% secure.

10. Right to Lodge a Complaint

If you believe that IMCoach, Unipessoal, Lda. has processed your personal data in violation of applicable data protection regulations, you have the right to lodge a formal complaint with the supervisory authority in Portugal:

• CNPD - Comissão Nacional de Proteção de Dados (https://www.cnpd.pt).

11. Contact Information for Privacy Concerns

For any questions, complaints, or requests regarding this Privacy Policy, please contact us at:

• Via Email: info@imcoach.pt

• Via Mail: IMCoach, Unipessoal, Lda., Attn: Privacy/Legal Department, Setúbal, Portugal.

12. Updates to this Policy

The Company reserves the right to update or modify this Privacy Policy at any time without prior notice, simply by posting the revised version on this page.

You are bound by any such revisions and should therefore check this page periodically.

Last Updated: June 27, 2026