Privacy and Data Security Policy

Last updated on February 27, 2024

FZF CAPITAL LTDA. (“FZF Capital”), a legal entity governed by private law, registered with the CNPJ under No. 37.029.647/0001-56, headquartered at Rua Casa do Ator, n. 1117, conjunto 161, Vila Olímpia, São Paulo, SP - CEP 04546-004, collects personal data with the purpose of providing its services. 

We are committed to preserving the privacy and security of our users, with such data processing being done in strict compliance with applicable laws and regulations, particularly with the European Union's General Data Protection Regulation (GDPR) and the General Data Protection Law (LGPD). 

It is strongly recommended that users read this Privacy Policy carefully.

Users' registration data is not disclosed to third parties, except when necessary for user service, provision of benefits, promotions, and satisfaction surveys.  Your personal data is essential for your order to arrive safely.

1. Introduction

The Privacy and Data Security Policy (“Policy”) defines the guidelines for the treatment and protection of personal information collected during access to and use of the services offered by FZF Capital.

Through the Terms of Use, FZF Capital establishes the rules and conditions for the use of the Platforms by Users. By accessing, registering and/or using the services offered on the Platform, the user declares that they are over 18 (eighteen) years of age and expressly declares that they have read, understood and accept all the conditions stipulated herein and in the Terms of Use.

This Policy is complementary to the Terms of Use that regulate the access and use of the service by the corresponding user (“User”) when digitally subscribing and/or accessing and/or using the FZF Capital website (“Terms of Use”), as well as establishing the treatment that FZF Capital grants to the information of Users and third parties involved in the registration of users (“Signatories”) that is captured and/or stored by FZF Capital.

This policy applies to all users of the FZF Capital website or application who have their personal data processed by us in any way.

2. Changes to the Privacy Policy

FZF Capital reserves the right, at its sole discretion, to modify this Policy, including new rules, conditions and/or restrictions, and shall communicate this to the User through the platforms for use of the Service. Continued access and/or use of the Service by the User will imply automatic acceptance of any updates to this Policy.

3. Data Collected and its Purpose

FZF Capital respects your privacy. Any information you provide us with will be treated with the highest level of care and security and will only be used in accordance with the limits set out in this document.

When accessing the site, regardless of registration, certain information (data on the browser used, type of device, time spent, IP address, operating system, browser, browser language, time zone, local time and geolocation) will be stored on servers used by FZF Capital.

This and other personal information captured from Users and Signatories is necessary for their identification in the context of accessing and using the Services.

FZF Capital collects the information you provide when you use our platform, including when you create a registration. This may include your full name, e-mail address, and other personal data. FZF Capital may collect additional information when you communicate with us, through our employees and agents, or when you respond to a survey.

To receive the FZF Capital Newsletter, which is sent free of charge by e-mail, the user must access the “sign up” option on the site and provide the following mandatory data: e-mail address. The data provided will not be sold or passed on.

FZF Capital reserves the right to use the registered e-mail address to send advertising campaigns. The request to unsubscribe can be made directly on the website, at the following link: https://l1nq.com/AOi3x.

In addition, FZF Capital also uses data for marketing and communication purposes, including the dissemination of products, services, activities, promotions, campaigns and events in which FZF Capital takes part, as well as user support information, by e-mail and/or SMS.

The data is required for:

• sending you the FZF Capital Newsletter by e-mail;

• optimize your interaction with us;

• guarantee the security of the site, platform and the data it processes;

• inform you about offers and advertise our services;

• to comply with legal obligations;

• administrative and management purposes;

• to keep you informed about the products and services we offer;

• to carry out targeted online advertising;

• preventing, detecting and investigating activities that are in breach of our Code of Conduct or that are prohibited or illegal; 

• improvements to the platform.

FZF Capital uses legal bases, which may vary according to the purpose of collection, to process users' personal data. The storage period may change depending on the legal basis applicable to each situation and purpose.

4. Data Storage

FZF Capital adopts technical and administrative security measures to protect personal data from unauthorized access and from accidental or unlawful destruction, loss, alteration, communication or any form of inappropriate or unlawful processing.

The information captured will be stored in accordance with strict confidentiality and security standards, such as encryption. However, it is important that the user is aware that due to the very nature and technical characteristics of the Internet, this protection is not infallible and is subject to violation by the most diverse malicious practices.

In such cases, data is processed in accordance with the LGPD (General Data Protection Act) and other protection legislation. We take security measures in accordance with our policies and adopt standard clauses in contracts with suppliers and service providers.

By using your account and/or communicating with us, you agree to the processing of your information, including the international transfer of data where necessary. We take measures to ensure that any information collected is treated securely, in accordance with data protection standards and in accordance with this Privacy Policy.

FZF Capital will not store or archive any contract and/or other document uploaded for signature purposes. For this reason, the User and/or the Signatories of the contracts and/or other documents must take all necessary measures for the safekeeping and archiving of the contracts and/or other documents signed through the communication.

5. Data Storage Period

Regarding the service of collecting evidence about online content via the website, FZF Capital will cryptographically store the data referred to in topic 3 on its own server, securely and protected against loss, misuse and unauthorized access. 

This data will only be used for the specific purpose for which it was collected and authorized by the user. All other data collected will be stored for as long as it is necessary for the user's activity.

6. User Rights and Responsibilities​

The User guarantees and is responsible for the veracity, accuracy, validity and authenticity of the personal data and other information that they provide for use of the Service and commit to keeping it updated. FZF Capital shall not be held liable in the event of false or inaccurate data being entered and may, at its sole discretion, suspend and/or cancel the User's registration at any time if any inaccuracy is detected.

In compliance with the General Data Protection Regulation, FZF Capital users are guaranteed the right to: - Transparency, information, access and notification, so that they are aware of the processing of their data; - Rectification of incorrect data and incomplete data; - Deletion of data, which can be requested by the user, as well as carried out automatically in the cases provided for by law, such as in the event that they are no longer necessary for the purpose for which they were collected; - Objection to the possibility of receiving direct communications via e-mail and/or SMS; - Withdrawal of consent for the collection and use of data, at any time; - Non-subjection to automated decisions, so as to request human intervention whenever deemed necessary; - Portability, by requesting the transfer of your data to third parties.

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7. With Whom We Share Data

We may share personal data with operators or controllers, always respecting the LGPD and the minimum amount of personal data necessary to achieve the purposes listed below:

• Companies in the same economic group or affiliates of FZF Capital;

• Companies that develop and maintain the website;

• Judicial, administrative, regulatory or governmental authorities provided there is an express order.

8. Use of COOKIES

Cookies are small text files stored on the electronic device that memorize preferences, map opportunities for improvement and provide targeted content.

FZF Capital uses cookies and anonymous identifiers for audience control, navigation, security and advertising. Cookies can be accepted or disabled by accessing the tools provided by the browser or mobile device.

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9. Law and Jurisdiction

This policy will be governed, interpreted and executed in accordance with the Laws of the Federative Republic of Brazil, especially Law No. 13,709/2018, regardless of the Laws of other states or countries, with the jurisdiction of São Paulo/SP to settle any doubts arising from this document.

10. Registration and Acceptance of Terms and Conditions

Registration as a user to use the Service (“User”) implies full and irrevocable acceptance of all the terms and conditions in force and published by FZF Capital on the electronic channels for purchase, including acceptance of this Policy, as may be amended.

Once registered, Users may, at any time, review and change their registration information using the tool provided.

For further information, queries or requests regarding the processing of your personal data, you can contact our Data Protection Officer (DPO), Privacy Guaranteed, at contato@fzfcapital.com.