1. GENERAL INFORMATION AND DEFINITIONS

CESTAROLLI CÂMBIO, which for the purposes of this Privacy and Data Protection Policy will be Protection Policy will be referred to simply as CESTAROLLI CÂMBIO, values the privacy of its customers and users and has created this Privacy and Data Protection Data Protection Policy, pursuant to Law no. 13.709/2018 - General Data Protection Law and other laws on the subject. Protection Act and other laws on the subject, to demonstrate its commitment to protecting the privacy and personal data of all natural persons with whom it has any relationships, as well as describing how their data is handled and protected by CESTAROL. processed and protected by CESTAROLLI CÂMBIO when collecting, processing and storing personal information.

1.1 Definitions

User: all natural persons (individuals) who will use or visit the CESTAROLLI CÂMBIO Website(s) and/or Application(s), who are over 18 years of age or (eighteen) years of age or emancipated and fully capable of performing the acts of civil acts of civil life or the absolutely or relatively incapable duly represented or assisted.

Data Subject / User: natural person to whom the following refer the personal data being processed.

We will therefore refer to the User and the Data Subject as "User" and "Data Subject" respectively. Holder as "User" and "Holder" respectively.

Personal Data: means any information provided and/or collected by CESTAROLLI CÂMBIO and/or its affiliates, by any means, even public (I) identifies or, when used in combination with other information processed by CESTAROLLI CÂMBIO other information processed by CESTAROLLI CÂMBIO identifies a natural person; or natural person; or (II) by means of which the identification or contact information of a natural person can be derived.

Personal Data can be in any media or format, including electronic or computerized records, as well as in paper-based files. paper.

Purpose: the objective, the purpose that CESTAROLLI CÂMBIO wishes to achieve from each act of processing personal information.

Necessity: justification why it is strictly necessary to collect personal data in order to achieve the purpose, avoiding excessive collection.

Legal bases: legal grounds that make it legitimate for CESTAROLLI to process personal data for a specific purpose by CESTAROLLI CÂMBIO.

Consent: express and unequivocal authorization given by the User/Holder of the personal data for CESTAROLLI CÂMBIO to process their personal data for a previously personal data for a previously described purpose, in which the legal basis requires the express authorization of the data subject.

This Privacy Policy applies, in general, to all Holders/Users and potential Holders/Users of the services offered by CESTAROLLI CÂMBIO, including Users of the websites, the Platform, the Mobile App or other means operated by CESTAROLLI CÂMBIO and summarizes how CESTAROLLI CÂMBIO may collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, eliminate, evaluate or control the information, modify, communicate, transfer, disseminate or extract the data collected, including personally identifiable information, in applicable legal bases and all privacy and data protection laws in force. protection laws in force.

By accessing and/or using the CESTAROLLI CÂMBIO Platform, the User declares to be at least 18 (eighteen) years old and to have full and express capacity to acceptance of the Terms of Use and conditions of this Privacy Policy and the Consent Form for all legal purposes.

If the User does not fit the above description and/or does not agree, even in part, with the terms and conditions contained in this Privacy Policy Privacy Policy, they must not access and/or use the services offered by CESTAROLLI CÂMBIO, as well as the Platform, the Mobile App and the service websites operated by it. operated by it.

2. COLLECTION OF PERSONAL INFORMATION

CESTAROLLI CÂMBIO processes the Personal Data of those who are or have been its customers or had any relationship with it, was or is a representative, attorney-in-fact, employee, partner of any client, company or entity with which CESTAROLLI CÂMBIO has a relationship with or has already carried out a transaction with, persons with whom it intends to deal with, employees or collaborators or other holders of Personal Data.

The Holder / User is aware that he/she provides information in a through the Registration Form, documents provided, or through the Platform and the Mobile App or the websites provided, or through the Platform and the Mobile App or the websites operated by CESTAROLLI CÂMBIO.

When the Holder / User registers and/or fills in forms offered by CESTAROLLI CÂMBIO, including on the Platform, the Mobile App or the websites operated by it, certain Personal Data requested will be kept will be kept confidential and will be used only for the purpose for which the registration was made and in accordance with the Consent Form and this Policy.

The Owner / User is aware that in addition to the data provided in the registration form, CESTAROLLI CÂMBIO may collect or confirm data about him/her from from legitimate external sources, such as service providers, other institutions of the financial system, public bodies and/or publicly accessible publicly accessible, such as the Internet and public records, and from other sources, exclusively for the purpose of to comply with current compliance rules and other regulatory rules of the Brazilian foreign exchange market.

3. PURPOSE OF USE OF PERSONAL DATA

CESTAROLLI CÂMBIO processes personal data in accordance with in accordance with the legal bases set out in the General Data Protection Law (LGPD), such as for example, for compliance with legal and regulatory obligations, performance of a contract, to meet the legitimate interests of CESTAROLLI CÂMBIO, its customers, employees and its customers, collaborators, employees and third parties; protection of the life or physical physical safety of the Data Subject or third parties, in situations where the consent of the Data Subject is collected and for the regular exercise of rights. exercise of rights.

CESTAROLLI CÂMBIO processes Personal Data and other information for various purposes related to the performance of its activities, such as:

I. Carry out its activities, provide its services and supply its products;

II. Making and keeping their registration up to date, verifying their identity and any other information;

III. Complying with and carrying out actions related to the Holder's Contract or that of the company of which he is a partner, administrator, manager, attorney-in-fact or employee, including stages prior to contracting, during and after contracting contract;

IV. Comply with legal, regulatory and self-regulatory obligations, such as for example: internal auditing and compliance activities, prevention of crimes such as money laundering, terrorist financing and other illicit activities, know your client (KYC) activities and other risk management activities risk management activities, reporting to the Internal Revenue Service, fraud prevention measures, providing information to the Central Bank and other competent bodies, in Brazil and abroad, for and other competent bodies in Brazil and abroad to comply with regulations, reporting suspicious transactions to Coaf, assessment of legal representatives and company partners, among other activities. activities;

V. Complying with judicial, administrative and arbitration orders and decisions;

VI. Evaluations and regular exercise of rights necessary for execution of contracts;

VII. For the regular exercise of rights, including in contracts and judicial, extrajudicial, administrative or arbitration proceedings;

VIII. Serving its customers, potential customers and third parties, including handling queries, complaints, requests and support through its service channels, enabling channels, making it possible to contact its customers whenever necessary, and vice versa;

IX. Sending communications about products and services contracted by you or your company, necessary for the fulfillment of the contract;

X. Understand your customers and offer products more suited to their needs and profile:

XI. Evaluate the browsing behavior and profile of Users and customers, including to understand whether the User has reached the Sites and Applications through direct access, links or own or third-party cookies, for example third parties, for example;

XII. Carrying out marketing campaigns and also using information technology and technologies and online advertising solutions;

XIII. Carrying out research with the public to improve its products, services, customer service and initiatives;

XIV. Identify, prevent and manage any security risks, physical or cyber security risks to you, CESTAROLLI CÂMBIO or third parties;

XV. Prevent fraud and ensure security, analyze profile, identify, manage and deal with potential risks in the offer and contracting of products and/or services and in CESTAROLLI CÂMBIO's other activities, such as credit risks, operational risks, reputational risks, market risks, etc. market risks, among other risks;

XVI. Other Processing situations based on legitimate purposes, such as the support and promotion of CESTAROLLI CÂMBIO's activities or for the provision of services that benefit its customers;

XVII. Promoting events, sponsorships and other activities and initiatives initiatives; and

XVIII. Selecting and hiring suppliers, employees, collaborators and partners.

4. SHARING AND PROCESSING OF PERSONAL INFORMATION

CESTAROLLI CÂMBIO only shares your information when it is necessary or relevant, for the purposes set out in the contracts with its customers and in this its customers and in this Privacy Policy, within strict security standards. standards, always aiming for the confidentiality of your information and following bank secrecy rules and other data protection and privacy rules. privacy.

CESTAROLLI CÂMBIO may disclose the Personal Data collected to third parties in the following situations and within the limits required and authorized by the Law:

I. With companies and individuals contracted to carry out certain activities and services on behalf of CESTAROLLI CÂMBIO;

II. With group companies;

III. With suppliers and partners to perform the services contracted with CESTAROLLI CÂMBIO (such as information technology, accounting, financial and currency exchange operations, among others);

IV. With regulatory bodies, other public entities, institutions of the financial system and third parties, including for the fulfillment and execution of legal, regulatory and contractual obligations and to protect and exercise of rights;

V. With other financial institutions, including when necessary, for the processing of any transaction or other activities for the execution of a contract;

VI. For administrative purposes such as: research, planning, service development, security and risk management;

VII. When necessary as a result of legal obligation, determination authority, or court decision.

VIII. In the event of Personal Data being shared with third parties, all the subjects mentioned in items I to V must use the Personal Data shared in a consistent manner and in accordance with the purposes for which they were collected (or to which the Data Subject/User previously consented) and in to) and in accordance with the provisions of this Data Protection Policy, other privacy Protection Policy, other website or country privacy statements, and all applicable privacy and data protection laws.

There may be situations in which your specific consent is required and, if so, we will ask for your consent before any sharing.

5. LEGAL GROUNDS FOR DISCLOSING YOUR DATA

In certain circumstances, CESTAROLLI CÂMBIO may disclose Personal Data Personal Data, to the extent necessary or appropriate, to government agencies, consultants and other third parties for the purpose of complying with legislation or a court order or subpoena, or if CESTAROLLI CÂMBIO believes in good faith that such action is necessary to:

I. Comply with legislation requiring such disclosure;

II. To investigate, prevent or take action in relation to suspected or actual suspected or actual illegal activities or to cooperate with public bodies or to protect national security;

III. Execution of its contracts;

IV. Investigate and defend itself against any claims or allegations;

V. In the event of the sale, merger, incorporation or reorganization of CESTAROLLI CÂMBIO.

CESTAROLLI CÂMBIO will inform the respective Users of any legal claims resulting in the disclosure of personal information, in accordance with the terms of item 4, unless such notification is prohibited by law or by court order, or if the request is an emergency. emergency. CESTAROLLI CÂMBIO may contest these requests if it considers that the requests are excessive, vague or made by incompetent authorities.

6. INTERNATIONAL DATA TRANSFER

Your Personal Data may be transferred to and processed in other countries, in accordance with the provisions of the LGPD and applicable legislation, for the purposes set out in this Data Protection Policy.

For example, data can be transferred abroad if it is necessary for the performance of a contract (such as prepaid card transactions or credit card transactions carried out abroad or foreign card transactions transactions carried out in Brazil, foreign exchange and payment orders to or from other financial institutions); to comply with CESTAROLLI's legal and regulatory obligations regulatory obligations of CESTAROLLI CÂMBIO; for the regular exercise of rights in administrative, judicial or arbitration proceedings or for the investigation of crimes and other illicit acts.

7. ABOUT COOKIES

Cookies allow the collection of data related to browsing depending on the type of device used, the authorizations granted by you through your device settings and the functionalities used in each application. in each application. We may use our own or third-party cookies on our Sites and Applications.

Cookies are small text files that may or may not be added to the in the device's browser. These files store and recognize data that guarantee the correct functioning of the Sites and Applications and help us to identify your preferences and improve your experience.

7.1 Types of cookies and their purposes

Cookies can collect data for different purposes related to to the functionalities of our Sites and Applications.

Here are the types we use for operation and to ensure the correct access and operation of applications:

7.1.1 Essential to the functioning of the website

CDN / CloudFlare

Referring to the functionality of the global system. They guarantee the operation of the system and are related to the routing to the datacenter selected by CloudFlare to serve the user.

CloudFlare's Privacy Policy applies.

7.1.2 Storing preferences and other features

i18n / Internationalization

Referring to the internationalization system. Stores the preferences and the language identified by the browser.

No personal information.

They are part of the internal workings of the site and are only stored in the in the domain cestarollitravel.com.br/cambio.

Jivochat

These are cookies used by the Jivochat chat system and are described in its in its Cookies and Privacy Policies.

7.1.3 Metrics and Analytical Data

Anonymous data is collected to analyze the use of the site, allowing improvements to be made according to the usage information collected.

Google Analytics

For anonymous collection of data and metrics related to website use. E.g.: Pages accessed, time spent on each page, origin of access, city/country of origin, etc.

Google's Privacy Policy and terms of use apply.

MouseFlow Cookies

Used as a simple "mark" or "flag" to identify whether the user is accessing the site for the first time or not.

None of the cookies contain personally identifiable information.

Google Firebase Performance Module

Collection of anonymous performance metrics such as the speed of loading speed of pages and their component items.

This information helps to identify elements that may slow down the site, so that corrections and improvements can be made whenever necessary. improvements can be made whenever necessary.

Google maps

Dynamic maps incorporated into the site to make it easier to locate location of CESTAROLLI CÂMBIO and its exchange offices.

Google's Privacy Policy and Terms of Use apply.

The User can deactivate or delete cookies, as well as the technologies technologies, in their browser settings and in the operating system settings of their device. operating system settings, with the exception of functional cookies which, if deactivated, will not allow the use of the Sites and Applications.

Just a reminder that if certain cookies are disabled, the Sites or Applications or some of their features or functionalities may not function properly.

8. SECURITY OF PERSONAL INFORMATION

All Personal Data will be stored in the CESTAROLLI CÂMBIO's database or in a database maintained "in the cloud" by the providers of service providers contracted by CESTAROLLI CÂMBIO, which are duly in accordance with current data legislation.

CESTAROLLI CÂMBIO and its suppliers use various security procedures to protect the confidentiality procedures to protect the confidentiality, security and integrity of your Personal Data, preventing the occurrence of any damage resulting from the processing of this data.

Although CESTAROLLI CÂMBIO uses security measures and monitors its system to check for vulnerabilities and attacks to protect your Personal Data from Personal Data against unauthorized disclosure, misuse or alteration, the Holder/User understands and agrees that there is no guarantee that the information may not be accessed, disclosed, altered or destroyed by breach of any of the physical, technical or administrative safeguards.

9. DATA RETENTION

CESTAROLLI CÂMBIO retains all the data provided, including the Personal Data Personal Data, for as long as the Data Subject's/User's registration is active and as is necessary for the performance of its services.

CESTAROLLI CÂMBIO will retain your Personal Data and will keep your data stored until you request its deletion, or for 5 (five) years from the last from the last foreign exchange transaction closed with CESTAROLLI CÂMBIO. (own CESTAROLLI CÂMBIO. (own position) or intermediated by CESTAROLLI CÂMBIO. Financial Institution authorized by the Central Bank of Brazil.

CESTAROLLI CÂMBIO may keep your Personal Data after receiving your request for deletion if this is necessary to comply with legal obligations, resolve disputes, maintain security, prevent fraud and abuse and ensure the fulfillment of contracts.

10. LEGAL BASES FOR PROCESSING

CESTAROLLI CÂMBIO only processes Personal Data in situations where it is authorized by law or with the express and unequivocal consent of the User.

As described in this Privacy Policy, CESTAROLLI CÂMBIO has legal bases for collecting, producing, receiving, classifying, use, access, reproduce, transmit, distribute, process, archive, store, delete, evaluate or control information, modify, communicate, transfer, disseminate or extract data about the Holder/User.

The legal bases include your consent (collected expressly and unequivocally in the unequivocally in the Consent Form), contracts and preliminary procedures (where processing is necessary in order to enter into a contract with the with the Data Subject/User or with the company of which he/she is a partner, director, manager, or employee) and legitimate interests, provided that such processing does not does not infringe your rights and freedoms, in accordance with the purpose of the legal relationship established with CESTAROLLI CÂMBIO.

Such interests include protecting the Holder/User and CESTAROLLI CÂMBIO from threats, complying with applicable legislation, the regular exercise of rights in judicial, administrative or arbitration proceedings, enabling the conducting or administering business, including quality control, reports and services offered, managing business transactions, understanding and improve business and customer relationships and enable users to find economic opportunities. users to find economic opportunities.

The User has the right to refuse or withdraw the consent given to CESTAROLLI CÂMBIO, and CESTAROLLI CÂMBIO may terminate the provision of its services to this User in the event of such a request.

If you have any doubts about the legal bases for collecting, processing and storage of your personal data, please contact CESTAROLLI CÂMBIO and its Data Protection Officer at cestarolli@tappartner.com.br.

11. RIGHT TO ACCESS AND CONTROL YOUR PERSONAL DATA

CESTAROLLI CÂMBIO offers the Data Subject/User various options as to what to do with his/her Personal Data. Personal Data collected, processed and stored, including its deletion and/or correction. deletion and/or correction. The Owner/User may:

Deleting data: the Data Subject/User may request the deletion of some of of their Personal Data (for example, if they are no longer necessary to services).

Changing or correcting data: the Data Subject/User can edit or request the edit some of their Personal Data. The Owner/User may also request updates, changes or corrections to their data in certain cases, especially if they are incorrect.

Place objections, limits or restrictions on the use of data: the Holder/User may request that we stop using all or some of their Personal Data (for example, if we do not have the right to continue using it), or limit our use of such data (for example, if your Personal Data is incorrect or Personal Data is incorrect or stored illegally), it being noted that CESTAROLLI CÂMBIO may process Personal Data in accordance with the legal bases listed in in Item 3 - Purposes of this Policy.

The Owner/User has the right to access or take his/her data: the Holder/User may request a copy of their Personal Data and the data you have provided in a legible format in printed or electronic form.

The Data Controller/User can make the requests listed above by contacting contacting our Data Protection Officer at cestarolli@tappartner.com.br and these requests will be considered in accordance with applicable laws.

12. REVOCATION OF CONSENT

You accepted our privacy policy and the use of Cookies on this device on July 15, 2024 at 22h 42m and 31 seconds via the our Cookies banner at the bottom of the page.

13. REVISIONS TO THE POLICY

Should CESTAROLLI CÂMBIO modify this Privacy Policy, such changes will be changes will be published visibly on the CESTAROLLI CÂMBIO website. This Policy is valid from July/24. Should the Holder/User have any questions about this Data Protection Policy, please contact CESTAROLLI CÂMBIO, please contact CESTAROLLI CÂMBIO at the addresses below/call center of the Data Protection Officer. of the Data Protection Officer.

14. CONTACT

CESTAROLLI CÂMBIO has appointed Mr. ANTONIO ALEXANDRE SAD KYK as its Data Protection Officer ("DPO"). Data Protection Officer ("DPO"), pursuant to article 41 of Law 13.70/2018 - LGPD. - pursuant to article 41 of Law 13.709/2018 - LGPD.

The Card Holder/User can contact the DPO at the following address physical:

Rua Uruguaiana, 1326 - Bosque, Campinas - SP - CEP 13026-002

By phone: +55 (19) 98128-3489 or by e-mail: alexandrekyk@alexandrekyk.com.br.

15. MEDIATION AND FORUM SELECTION

This policy is subject to the Law of the Federative Federative Republic of Brazil, Law 13.709/2018 and its amendments, and the Court of the District of São Paulo, State of São Paulo is competent to settle any dispute in relation to it.