Azevedo Prado Investments will have access to personal data in the following situations:

• Through interaction with a client: When the Client provides and inputs personal data necessary for the provision of services and use of the products provided by Azevedo Prado Investments.
• Interaction with its employees: When its employees and collaborators of any nature use its systems and platforms to fulfill duties and obligations arising from their contractual relationship.

Without prejudice to the data commonly collected and processed from its employees for the purposes of their legal relationship, Azevedo Prado Investments may also collect the following personal data:

• Names and contact details, such as first and last name, email address, postal address, phone number, and other similar types of contact data, such as banking details;
• Device information, such as information about your device, including IP address, location, or provider;
• Usage information and browsing history, such as information on how the User navigates within our services, their browsing history, and which elements of Azevedo Prado Investments' services are most frequently used;

Any sensitive personal data that may be collected by Azevedo Prado Investments will have its purpose separately communicated to the User, who must consent to Azevedo Prado Investments using it for that specific purpose. In case of disagreement, the data will be automatically deleted from Azevedo Prado Investments' databases.

Azevedo Prado Investments does not collect data from minors, except with parental or guardian authorization. If collected without authorization, as soon as Azevedo Prado Investments becomes aware, it will immediately delete the collected data, in accordance with the rules of the Terms of Use and this Privacy Policy.

When collected, Azevedo Prado Investments will use personal data to:

• Provide and improve contracted services;
• Comply with a legal or regulatory obligation;
• Manage the relationship with Users;
• Set up and administer User accounts;
• Provide technical assistance, support, and training to the User;
• Contact Users;
• Internal research and development purposes, and to improve, test, and enhance features and functions of Azevedo Prado Investments' services;
• Provide Users with marketing, advertising, and promotional materials, including from Partner companies of Azevedo Prado Investments, as permitted by law;
• Meet internal and external audit requirements, including information security obligations of Azevedo Prado Investments;
• Send email messages to: a) confirm or cancel requests made through the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, additions of new data sources, and platform improvements.
• Exercise the rights of Azevedo Prado Investments, including, but not limited to, privacy, security, networks, systems, and property of Azevedo Prado Investments and/or third parties;
• Comply with requests from courts, law enforcement agencies, regulatory bodies, and other public institutions and governmental authorities, including, but not limited to, applicable rules outside the user's country of residence;
• Exercise the rights of Azevedo Prado Investments and defend against potential legal claims, as well as comply with any legislation or regulation applicable to Azevedo Prado Investments or third parties with whom we work, and for the proper execution of contracts entered into between Azevedo Prado Investments and its users;

The User accepts and agrees that Azevedo Prado Investments may share their personal data with the following categories of recipients:

• Companies that provide access or are responsible for the account/registration on which the user depends;
• Partner companies, such as third-party service providers and other companies that assist us in offering our services or that may take action on our behalf, protecting our rights, users, systems, and services;
• Third parties to whom Azevedo Prado Investments is required or authorized by law to disclose information (e.g., governmental bodies, regulatory agencies, the judiciary, and other public authorities);
• Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, or transfer of part or all of Azevedo Prado Investments' business, in which case the User's data will be considered an asset and transferred in a potential transaction;
• Third parties who require the data to protect the rights of Azevedo Prado Investments;
• Any natural or legal person to whom the User requests data portability.

Azevedo Prado Investments does not intend to transfer any of the User's personal data collected outside of Brazil. Except for the cases outlined below, Users will be informed in advance by email, at which point the User may choose to accept or reject the transfer; in case of disagreement, their access rights may be restricted by Azevedo Prado Investments.

The international data transfer provided for in the General Data Protection Law (LGPD) depends on guidelines to be established by the National Data Protection Authority (ANPD), and once defined, Azevedo Prado Investments commits to complying with them in full.

Azevedo Prado Investments uses appropriate technologies and procedures to protect any collected personal data (including administrative, technical, and physical safeguards) according to the level of risk and the service provided, maintaining a legally responsible team to handle the secure management of data in compliance with legal provisions, regulatory requirements, technology changes, and other relevant factors that may influence how personal data is protected.

Azevedo Prado Investments employs all reasonable market efforts to ensure the security of its systems and collected data, utilizing highly qualified and reputable internet service providers, database and storage servers, as well as security certificates (SSL) and software to protect against unauthorized system access, alongside standard methods to encrypt and anonymize collected data.

This Policy represents Azevedo Prado Investments' effort to safeguard User information. However, due to the inherent nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing stored information, which is why, should this occur, Azevedo Prado Investments shall be liable within the limits provided by Law.

Azevedo Prado Investments, within a reasonable timeframe to be defined by the National Data Protection Authority (“ANPD”), shall communicate to the ANPD and to the affected User the occurrence of any security incident that may result in relevant risk or damage to the affected User, specifying at least:

• the description of the nature of the affected personal data;
• information regarding the data subjects involved;
• the technical and security measures used for data protection, respecting commercial and industrial secrecy;
• the risks related to the incident;
• the reasons for the delay, in the event the communication was not immediate; and
• the measures that have been or will be adopted to reverse or mitigate the effects of the loss.

Azevedo Prado Investments will hold processing liability as follows:

• Regarding personal data provided directly by its Clients, Azevedo Prado Investments will act as a Processor, operating without interference in the processing instructions established by the Controller, but in compliance with the LGPD;
• Azevedo Prado Investments will act as the Controller of its employees' Personal Data, processing it based on the Execution of Contracts, Compliance with legal or regulatory obligations, and, in specific and defined situations, Consent.

Azevedo Prado Investments may adopt different legal bases for distinct personal data processing activities.

Azevedo Prado Investments calculates the personal data retention period according to the following criteria:

• The time necessary to fulfill the purpose of the collection;
• The moment when the Client/User stops using Azevedo Prado Investments' services;
• The moment when consent is revoked or a request for erasure of personal data is made by the Data Subject;
• The time required to demonstrate compliance with the duties and obligations of Azevedo Prado Investments;
• The required period established by law, regulations, judicial decisions, etc.;
• Determinations issued by the National Data Protection Authority;
• Compliance with a legal or regulatory obligation by the Controller;
• Proper execution of the contract;
• Needs related to compliance with the legal order, as well as for potential legal disputes;
• Transfer to a third party, provided that data processing requirements set forth by law are respected; or
• Exclusive use by the controller, prohibiting access by third parties, provided the data is anonymized.

In accordance with the Brazilian General Data Protection Law, the User will have the following rights regarding the processing of their personal data:

• Right to Confirmation: the User may confirm whether Azevedo Prado Investments processes any of their personal data;
• Right of Access: the User may submit a written request to obtain details regarding how their information is being used, as well as to receive a copy of said information;
• Right to Correction: the User may correct or update any of their data that is incomplete, inaccurate, or out of date;
• Right to Anonymization, Blocking, or Erasure: the User may request the anonymization, blocking, or erasure of unnecessary, excessive data or data processed in non-compliance with the purposes for which consent was given, in accordance with applicable legal rules;
• Right to Deletion: the User may request the deletion of certain data, except where retention is authorized by law;
• Right to Information: the User may request information regarding public and private entities with which Azevedo Prado Investments has shared their data, as well as information on the consequences of withholding consent for the collection and processing of their personal data;
• Right to Opt Out of Marketing: the User may, at any time, unsubscribe from promotional messages and materials through the link provided in marketing emails;
• Right to Data Portability: the User may request that their personal data be transferred to themselves or to a third party, except for data that has already been anonymized or deleted by Azevedo Prado Investments;
• Right to Revoke Consent: the User may revoke any consent previously granted to Azevedo Prado Investments to use their personal data. The User acknowledges that revocation will not affect the use or sharing of data carried out prior to the revocation request.

The rights outlined in this section are not absolute. To exercise them, the User must contact Azevedo Prado Investments via email at: This email address is being protected from spambots. You need JavaScript enabled to view it.

Azevedo Prado Investments commits to fulfilling such requests as promptly as possible and free of charge to the User, within a maximum period of 15 (fifteen) days from receipt of the request, unless a longer period is required due to complexity, factual, or legal reasons, in which case the User will be notified.

Azevedo Prado Investments will immediately notify processing agents with whom it has shared User data regarding any correction, deletion, anonymization, or blocking of data so that they may replicate the same procedure.

Confirmation of existence or access to the User's personal data provided in this section will be delivered electronically or in writing, in a simplified format or through a clear and complete statement indicating the origin of the data, absence of records, criteria used, and the purpose of processing, always respecting Azevedo Prado Investments' commercial and industrial secrets.

Azevedo Prado Investments and any potential partners may use cookies and other similar technologies to store and manage User preferences, deliver targeted advertising, enable content, and collect analytical and usage data, for example. The use of cookies and other tracking technologies is a standard practice across websites and platforms, through which information regarding the User's activities on the platform, websites, or other services is collected.

A cookie is a small text file placed on a computer or other device used to identify the User and the device used, as well as to collect information, and can perform the following functions:

• Necessary Cookies: These are essential to enable the User to navigate a platform and use its features.
• Performance Cookies: They collect information about how the User uses Azevedo Prado Investments' platform and serve to improve navigation and enhance the user experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the previously visited website, the number of visits, average visit duration, and pages viewed.
• Functional Cookies: They allow the platform to remember choices made by the User (such as username or ID, language preference, or the area/region where the User is located) and provide enhanced, more personalized features.
• Advertising Cookies: They track the User's browsing habits and are used to deliver targeted advertising. These cookies also limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They also remember that the User has visited a website, and this information is shared with other organizations, such as advertisers.

Azevedo Prado Investments uses necessary and performance cookies.

At any time, the User may disable Cookies through their browser settings, by installing commercially available plug-ins, or by using other technologies they deem necessary.

In addition to cookies, Azevedo Prado Investments uses other tracking technologies, such as:

Web Server and Platform Logs: Azevedo Prado Investments' servers automatically collect certain information to assist, administer, and protect the services offered, as well as to analyze usage and improve the User experience. The information collected includes:

• IP address and browser type;
• Device information, including Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA), and similar identifiers assigned by us or third parties;
• The device's operating system and other technical data;
• The city, state, and country from which you are accessing the platform, including for fraud prevention purposes;
• Information or text entered;
• Links and buttons clicked;

Social Media Connections: Some of Azevedo Prado Investments' services may include social media features, such as Facebook “Like” buttons and widgets, “Share” buttons, and interactive mini-programs.

Azevedo Prado Investments may allow the User to choose to use logins from their own social media networks to access some of the services offered, in which case Azevedo Prado Investments may receive and store authentication information from those services.

Questions, comments, suggestions, and/or complaints regarding this Privacy Policy, as well as any requests for information, modification, or deletion of personal data, may be directed by the User directly to Azevedo Prado Investments by email at: This email address is being protected from spambots. You need JavaScript enabled to view it.

Azevedo Prado Investments seeks continuous updates and improvements, so this Privacy Policy may be updated at any time, always aiming for better service provision and user protection.

In the event of changes affecting the purpose and duration of the processing of the User's personal data, the User will be notified via the email registered in our services or through the platform itself 30 (thirty) days in advance. Should the User disagree with the changes, they may revoke the consent provided, thereby becoming unable to use the services of Azevedo Prado Investments.

If, in the future, Azevedo Prado Investments updates its policy to allow data sharing with third parties, a notice will be sent 30 (thirty) days in advance to the User via their registered email. The User may object to such sharing, in which case they will continue to use the services of Azevedo Prado Investments.

Users are advised to read this policy periodically to stay updated on its content.

This Policy shall be governed, interpreted, and enforced in accordance with the laws of the Federative Republic of Brazil, without regard to conflicts of law principles. The Courts of the Judicial District of São Paulo shall have exclusive jurisdiction to resolve any disputes arising from this instrument, to the exclusion and waiver of any other forum, no matter how privileged it may be.

All rights reserved.