PRIVACY POLICY– INVESTMIND

PLEASE CAREFULLY READ THIS DOCUMENT, AS THE USE OF THE INVESTMIND PLATFORM BY YOU DEMONSTRATES THAT YOU AGREE WITH THIS POLICY.

The InvestMind website and application (jointly, the “InvestMind Platform”) are a service offered by NW CONSULTORIA E DESENVOLVIMENTO DE SOFTWARE LTDA., a limited liability company [sociedade limitada], enrolled in the National Register of Legal Entities (CNPJ) under No. 27.642.494.0001-64, with its principal place of business at Av. Santo Amaro, n. 1.159, 8º andar, cj. 84, City of São Paulo, State of São Paulo (“InvestMind,” “we” or “our”). This Privacy Policy, together with the Terms of Use of the InvestMind Digital Platform, describe the terms and conditions applicable to access and use the InvestMind Platform by user.

UPON CLICKING THE BOX “I HAVE READ AND ACCEPT” OR “I ACCEPT”, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY, OR UPON BROWSING THROUGH THE INVESTMIND PLATFORM, YOU WILL BE EXPRESSLY STATING THAT YOU AGREE WITH THE TERMS OF THIS POLICY. BE AWARE THAT THE PROVISIONS HEREIN SHALL REGULATE THE RELATIONSHIP BETWEEN INVESTMIND AND YOU. IF YOU DO NOT AGREE WITH ALL TERMS BELOW, YOU CANNOT USE OR ACCESS THE INVESTMIND PLATFORM IN ANY WAY. Therefore, we suggest that you carefully read this document, as well as any updates hereto, before deciding to use or continue using the InvestMind Platform and to engage the Services.


1. InvestMind’s commitment to user’s privacy

1.1. This Privacy Policy (“Policy”) deals with processing of personal data, or other information such as: the cookies used, how we can disclose your information, your right to access, correct, update and delete your personal information, among others (“Information”) provided by Users (“Users,” “user,” “you,” “your”) on browsing, accessing and/or using the InvestMind Platform.

1.2. InvestMind’s activities consist, among others, in matching, through the InvestMind Platform, (i) users registered as securities analysts, individuals or legal entities, authorized to act and accredited with an entity duly authorized by the Brazilian Securities Commission (CVM) pursuant to CVM Ruling No. 598 of May 3, 2018, as amended, interested in providing analysis reports on securities that may assist the decision-making in investment (“Analysts”), experts in macroeconomics, experts in politics, experts in specific economic sectors, and investor relations officers (“Experts”), and jointly with the Analysts (“Users”); and (ii) individuals or legal entities wishing to have access to those analysis reports (“Subscribers”). InvestMind, therefore, only makes available the InvestMind Application and elements that enable and foster this matching of Users and Subscribers through the InvestMind Platform (“Intermediation”).

1.3. InvestMind’s policy includes respecting its Users’ privacy. Although the InvestMind Platform’s environment is monitored for security reasons, InvestMind will not edit or disclose its Users’ private information, without prior authorization, except in the events expressly set forth in this Privacy Policy, or unless InvestMind is required to do so by a court order or by operation of law.

1.4. We do not collect or knowingly request Information from minors under the age 18.

1.5. InvestMind will use its best efforts to protect your privacy. This Privacy Policy explains how InvestMind uses and protects the information it collects, and applies to any personal information that you provide to InvestMind.

1.6. InvestMind may amend this Privacy Policy at any time. In case of amendments to the Privacy Policy, InvestMind undertakes to inform InvestMind Platform Users about such amendments by notice on the InvestMind Platform, thirty (30) days before making such amendment. For your convenience, the date of last amendment is included in this Privacy Policy. For this reason, we invite Users to always access the Privacy Policy when using the InvestMind Platform.

1.7. If InvestMind Platform Users do not agree with the Privacy Policy, they may reject it without any burden. The rejection of a new version of the Privacy Policy, however, unfortunately means that the user may no longer use the InvestMind Platform. The fact that you accept the terms or continue accessing InvestMind after the update means that you have agreed with the amendments to this Privacy Policy.


2. Storage, use and protection of Users’ information

2.1. InvestMind protects the privacy rights of Users that register with or that, otherwise, browse, access, or use the InvestMind Platform and/or use services through the InvestMind Platform, pursuant to applicable laws and in accordance with the provisions in this Policy.

2.2. InvestMind is committed to the security and privacy of InvestMind Platform Users during the whole process of browsing and engagement of products and services through the InvestMind Platform. For this reason, Users’ information is maintained in strict confidentiality, and is not sold, exchanged or disclosed to any third parties, except in the events expressly established in this Privacy Policy.


3. Information collected by the InvestMind Platform

ON ACCEPTING THIS PRIVACY POLICY, THE USER AGREES AND AUTHORIZES THAT INVESTMIND COLLECTS THE INFORMATION SET FORTH IN ITEM 3.1., WHICH WILL BE USED TO ENABLE THE USER TO USE THE INVESTMIND PLATFORM.


3.1. Information collected from registered Users

When the user registers on the Platform, we may collect the following Information:

• Personal Information: such as, full name, individual taxpayer number (CPF), postal address, e-mail address, telephone number, user’s face images or selfie videos for authentication purposes, or other physical characteristics for any biometric recognition and authentication.

• Personal Financial Data and Bank Data: the registration on the InvestMind Platform also entails to provide User’s bank account data (data on bank, branch, account number, and type of account) for payment of User’s compensation in consideration for the services provided to Subscribers.

• Personal Data on Social Media: on registering and accessing the platform through any social media, such as facebook, twitter, linkedin, google or others (if this functionality is available), the user authorizes us to collect, store and use user’s information and content available on such social media, including, if possible, information from user’s contact list.

• Copies of Documents: we can collect, through our own or a service provider functionality, as a part of the procedure for registration and analysis of application for registration on the InvestMind Platform by InvestMind Platform Users, a copy of the identity card (RG), proof of residence, and other certificates necessary for acting as Analysts or Experts.

• Browsing information: information on user’s mobile phone/smartphone, IP address, type of browser used, operating system version, reference source, duration of the visit on the InvestMind Platform, pageviews, page browsing tracks, internet band, operator, pageview behavior, geolocation, visited pages.


4. Update and other information on your registration

4.1. Changes in data files

The ownership of the registration is personal. The User can make changes in data files in User’s account. However, some specific data (such as name and CPF, for example), are considered key and may be only changed by InvestMind upon request to the email compliance@investmind.com.br. For other data, if you want to make any change, please access your account and adjust the data.

4.2. Information on data held by InvestMind

If You have any reason to believe or suspect that any information we have about you is incorrect or incomplete, we kindly request that you contact our service center or write an e-mail to our team at the address: Compliance@investmind.com.br. The InvestMind team will be ready to respond to your request and correct any incorrect information.

5. Place of storage of Users’ Information and Use of collected Information
On accepting this Privacy Policy, You are aware and agree that the information collected upon access or use of the InvestMind Platform may be transferred and stored at a destination outside Brazil, to the extent permitted by law. In addition, You are aware and agree that, on accessing, using the InvestMind Platform, and sending us your personal data, your Information will be transferred, stored, processed and used in the format exposed in this Privacy Policy. We take all reasonably necessary care to ensure that your data be processed in a safe manner and pursuant to this Privacy Policy.


6. Use of collected information

6.1 InvestMind Platform Users’ information will be used for the purposes established in this Policy, whether to enable the use of the InvestMind Platform, detect possible fraud, produce statistics, and implement marketing and relationship campaigns:

• In the registration and identification of Users on the InvestMind Platform;
• In the analysis of the application to act as User on the InvestMind Platform;
• In the measures deemed necessary or recommended by InvestMind for constant improvement of InvestMind Platform’s functionalities and actions performed to offer services through the InvestMind Platform, as well as to better understand the Users’ needs;
• In a notice to Users about changes in the InvestMind Platform and/or in services, as well as to meet obligations arising from law and assumed on accessing and using the InvestMind Platform; and
• To report transactions, storage of information, data, communications and others related to the access and use of the InvestMind Platform and use of services, as well as to meet other legal and regulatory obligations imposed on the InvestMind Platform.


6.2. Statements, testimonies, or comments

ON AGREEING WITH THIS POLICY, USERS ALSO AUTHORIZE INVESTMIND TO USE, COPY, REPRODUCE, PROVIDE, TRANSMIT, SHARE, TRANSLATE INTO OTHER LANGUAGES, INSERT IN OTHER MATERIALS (INCLUDING, WITHOUT LIMITATION, ON ITS WEBSITE, VIDEOS AND ADVERTISING MATERIALS) FOR ANY PRUPOSES, INCLUDING FOR BUSINESS, ADVERTISING AND INSTITUTIONAL PURPOSES, ANY STATEMENTS, TESTIMONIES, OR COMMENTS OF USERS, IN WHOLE OR IN PART, RELATED TO THE INVESTMIND PLATFORM AND/OR TO THE SERVICES IN SPECIFIC RESOURCES MADE AVAILABLE FOR SUCH PURPOSES ON OUR PLATFORM, SENT BY E-MAIL, TEXT MESSAGE, OR POSTED ON SOCIAL MEDIA, SUCH AS FACEBOOK, TWITTER, INSTAGRAM, YOUTUBE, AND OTHERS. USERS ALSO RECOGNIZE THAT WE MAY USE ANY SUCH STATEMENTS, TESTIMONIES, OR COMMENTS IN ASSOCIATION WITH USERS’ FULL NAME AND SOCIAL MEDIA PROFILE PICTURE.


7. Data sharing

7.1. UPON AGREEMENT WITH THE TERMS OF THIS PRIVACY POLICY, THE USER AGREES AND CONSENTS ALSO IN AN EXPRESS AND CLEAR MANNER TO THE GRANTING OF ACCESS AND SHARING OF USER’S INFORMATION WITH INVESTMIND, AS WELL AS WITH SELECTED THIRD PARTIES, AS LISTED BELOW, FOR ACHIEVEMENT OF THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY:

(a) Employees and companies of the group, investors, business partners, partner banks, agents and/or service providers, in Brazil or abroad, of InvestMind, for the purposes of maintenance of the InvestMind Platform, service provision to InvestMind and/or in case of other necessary procedures.
(b) Governmental authorities and/or judicial courts that may require, by operation of law or of a court order, full or partial disclosure of the information.
(c) Any other third parties with whom we are obliged to share the information by virtue of legal and regulatory obligations and/or the disclosure of information of which is necessary or recommended for proper, effective and efficient operation of the InvestMind Platform and its functionalities, as well as for the offer of services.


7.2. Agents

We may employ other companies and individuals (“Agents”) to carry out tasks in our name and, therefore, we may need to share InvestMind Platform Users’ Information with such Agents to provide Users with access and use the InvestMind Platform and/or engagement of Services. The Agents are not entitled to use the Information we shared with them beyond what is necessary to assist us in their tasks and/or for proper, effective and efficient operation of the platform and its functionalities.


8. Miscellaneous

8.1. InvestMind’s Protection

8.1.1. We reserve the right to store, access, read, preserve, and disclose any information we deem necessary to comply with the law or a court order to the extent required by applicable laws and regulations, this Privacy Policy and any other agreements, or terms with which Users agreed, as well as to protect the rights, ownership or security of InvestMind, of the InvestMind Platform and of its employees, service providers, Users, clients, and others.


8.2. Cookies

8.2.1. A cookie is a small file added to user’s device or computer to provide a personalized experience of accessing the InvestMind Platform. The cookies help analyzing the internet traffic or allow us to know when the user at issue has visited a specific website. A cookie does not give access to a computer or reveal information in addition to the data that the user chooses to share with us. On accepting this Privacy Policy, the user is aware and agrees that InvestMind may install cookies.

8.2.2. WHENEVER THE USER INTERACTS WITH THE INVESTMIND PLATFORM, WE WILL AUTOMATICALLY RECEIVE AND STORE INFORMATION FROM THE BROWSER OR DEVICE OF SUCH USER IN OUR SERVER RECORDS (“RECORD DATA”), WHICH INCLUDES: IP ADDRESS, DEVICE IDENTIFICATION, VISITED WEBPAGE OR RESOURCE, TIME SPENT ON EACH OF THESE PAGES, TIMES AND DATES OF ACCESS, TYPE OF BROWSER AND DEVICE USED, THE PAGE OR RESOURCE THAT WAS USED TO FIND THE INVESTMIND PLATFORM AND THE INFORMATION SEARCHED FOR THIS PURPOSE.

8.2.3. The user’s browser can offer the option to disable cookies. If a user opts to disable cookies when attempting to access and/or use the InvestMind Platform, the user at issue will not succeed in accessing and/or using the InvestMind Platform or part of its functionalities.

8.2.4. The Advertisers – the Platform’s partners, as applicable – do not transmit cookies to Users’ browser or device when the InvestMind Platform is used. However, when the user clicks on advertisements or links that lead to a third-party website or service, such third party can transmit cookies to such user. We remind that this Policy does not cover the use of cookies by any third parties, and we assume no liability for any third-party practices and privacy policies.


8.3. Security

8.3.1. An user’s account on the InvestMind Platform is protected by a personal and non-transferrable password, which exists for Users’ privacy and security. The User shall prevent the unauthorized access to User’s account and to User’s Information by properly selecting and protecting User’s password, and limiting the access to User’s computer or device and browser, and the User at issue shall sign off from the InvestMind Platform after ending accessing User’s account and using the InvestMind Platform.

8.3.2. The password to access User’s account on the InvestMind Platform is stored on our databases using the most modern forms of encryption and, to ensure User’s security, nobody has access to such databases. THIS MEANS THAT INVESTMIND WILL NEVER REQUEST THE PASSWORD TO ACCESS USERS’ ACCOUNT MAINTAINED ON THE INVESTMIND PLATFORM BY E-MAIL OR TELEPHONE.

8.3.3. If a User has any reason to believe or suspect that any third party had access to user’s password to access the User’s account, we kindly request that the User contact Compliance@investmind.com.br.

8.3.4. We will endeavor to protect the privacy of our Users’ account and other Information that we keep in our records. The unauthorized access or use, hardware or software failure, and other facts may compromise the security of user’s information at any time. ACCORDINGLY, THE TRANSMISSION OF INFORMATION THROUGH THE INTERNET IS NOT COMPLETELY SECURE FOR SEVERAL FACTORS, INCLUDING NETWORK AND OPERATION FACTORS.

8.3.5. According to our obligations to maintain records and in keeping with the purposes described in this Privacy Policy, we will retain your personal information for at least five (5) years after closing of your account, mainly, by virtue of any legal and regulatory obligations and protection in judicial defenses.


8.4 Controlling your Information

8.4.1. To have access to your data, you need only to contact us by e-mail Compliance@investmind.com.br. InvestMind will analyze and respond to your request, provided that it is not incompatible with our Terms of Use of the InvestMind Digital Platform and other legal and regulatory obligations. We will provide the requested data within fifteen (15) days after receipt of your request.


9. Confirmation of understanding and consent
I have read and accept the terms of this Privacy Policy, and expressly agree with the collection, storage, sharing, and use of my personal information.

SÃO PAULO

21/03/2018

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