Privacy Policy

A AVOID INVESTMENTS you know how important it is to know and be sure about the use of the personal data in your possession. Therefore, we take care to clarify and explain our Privacy Policy. We recognize the need for protection and appropriate management of personal information collected on our site, as well as that provided by our customers. This Privacy Policy will help you understand what types of information we can collect, how that information may be used, with whom the information may be shared, and what are the rights of the owners with regard to the protection of their personal data.

The personal information we obtain may be collected in the following ways:

Website: Personal information is collected when the user interacts on our site through the contact form. The personal data collected are name, email and telephone number. The user may also choose to send newsletters, by registering the e-mail. You can unsubscribe from the newsletter mailing list at any time by clicking on the unsubscribe link contained in the body of the emails themselves. The user of our portal is under no obligation to provide any personal data to browse the pages of the site, so any information is provided of free and spontaneous will. It is only necessary for the collection of basic data when the user wishes to return their contact. All personal information is collected in a fair and non-invasive manner, with your voluntary consent. Personal information is not accessible to anyone outside the specific function for which it was collected.

Data related to the provision of our services: To make our services feasible, we collect personal data from our clients, such as full name, ID, social security number, date of birth, marital status, profession, address and nationality. We also collect financial information, such as bank, account type, branch, checking account, monthly income, financial investments, other income, in addition to movable and immovable property. Data related to the provision of our services: To make our services feasible, we collect personal data from our clients, such as full name, ID, social security number, date of birth, marital status, profession, address and nationality. We also collect financial information, such as bank, account type, branch, checking account, monthly income, financial investments, other income, in addition to movable and immovable property. This data is necessary for identifying the best investment alternatives and drafting a contract.

Sharing: Personal data, such as email and financial information, may be shared with the portfolio consolidation app for the purpose of assisting clients in tracking their investments.

Fraud Prevention (KYC Procedure - Know Your Customer): For the purpose of analysis related to the prevention of the use of the financial system, the clients' full names and social security numbers are collected. Such data is shared with a company specialized in the preparation of research for this purpose, in compliance with specific regulatory standards on the subject.

Service channels: The user may contact us by phone call or email. Personal data is collected for the purpose of identifying the user, as well as to fulfill your request. These may include, but are not limited to, name, email, and telephone number. In addition to these, we collect any personal data that is spontaneously provided by the user.

Cookies: personal data may be collected through cookies. For more information, see our Cookie Policy.

Employees: As for the personal data collected from our employees, these are necessary for the employee to register, in compliance with labor laws and the execution of the employment contract.

VITA INVESTIMENTOS Social Media is also used to communicate and interact with its customers and consumers through third-party websites, such as Facebook, Instagram, Twitter or LinkedIn. These third-party websites are an Internet-based technology that is not operated or controlled by AVOID INVESTMENTS. When interacting, sharing, or “Like” the page of AVOID INVESTMENTS on Facebook, Instagram, Twitter, or LinkedIn, or other social media, you may disclose certain personal information to AVOID INVESTMENTS or to third parties.

We use “social buttons” to allow our users to share or bookmark web pages. These are buttons from third-party social media sites that can record information about your activities on the internet, including this site. Please review the respective terms of use and privacy policies of those platforms to understand exactly how they use your information, such as how to opt out of receiving or deleting such information.

The amount of visible personal information will depend on your own privacy settings on Facebook, Twitter, and other social media.

Below are the purposes and legal bases of VITA INVESTIMENTOS data processing:

We only rely on our legitimate interest for specific purposes. These personal data treatments do not in any way override the interests, rights and freedoms of the personal data subjects.

VITA INVESTIMENTOS It is not a practice to disclose information that can identify the user and never shares information or sells and rents that personal data to third parties. This data is for the exclusive internal use of the company to achieve the purposes expressed in the previous item. Data may be shared with third parties only under the following conditions:

Upon a court decision or request by regulatory bodies, government oversight bodies, administrative and judicial authorities;

Data transferred to public agencies to comply with current legislation, for example personal data contained in electronic invoices and respective XMLs, or data of our employees necessary for the payment of the INSS or FGTS; Data transferred to accounting or human resources service providers, to meet tax and labor obligations;

Data transferred to financial institutions to provide payment options to our clients, or to pay salaries to our employees and providers;

Data shared with partners, operators, and service providers that participate, directly or indirectly, in the development of the business activities of AVOID INVESTMENTS, such as fraud prevention research (KYC Procedure — Know Your Customer), wallet consolidation application, payment processes, sending emails, advertising and marketing, security and performance monitoring, processing and fulfillment of orders and transactions, research, data storage, auditing, and data processing;

Data transferred for the purpose of executing the contract, as well as for the protection of the interests of AVOID INVESTMENTS in any type of conflict, including legal actions.

Some of the service providers mentioned above may be located abroad and, in this case, AVOID INVESTMENTS adopts additional safeguards to guarantee an adequate level of protection of personal data, in accordance with the relevant Brazilian legislation.

To ensure that your personal information is secure, we communicate our privacy and security guidelines to the employees and business partners of AVOID INVESTMENTS and we strictly follow the precautionary measures regarding privacy within the company.

We strive to protect your Personal Information, and those entrusted to us by our clients, through physical, technical, and organizational measures aimed at reducing the risks of loss, misuse, unauthorized access, disclosure, and undue alteration of this data.

Personal Data Subjects have certain rights with regard to their personal data and can exercise them by contacting us via email: dpo@vitainvestimentos.com.

The rights of the owners are:

Confirmation of the existence of personal data processing;

Access to personal data, in accordance with applicable legislation;

Correction of incomplete, inaccurate, or outdated personal data;

Portability of personal data;

Deletion of personal data, when it is processed based on the consent of the owner or when the data is unnecessary, excessive or treated in non-compliance with applicable legislation;

Request for information about the shared use of personal data;

Revocation of consent, where applicable.

A AVOID INVESTMENTS will always evaluate the best way to comply with the request to exercise any of your rights. However, the AVOID INVESTMENTS you may fail to comply with your request, in whole or in part, in specific situations protected by law, such as for the fulfillment of a legal obligation or a contract that you have with you.

We stress the importance of keeping your personal data accurate and up to date. Therefore, keep VITA INVESTIMENTOS always informed if your personal details change or are incorrect.

For security reasons, for requests made through the email dpo@vitainvestimentos.com, the request will be answered when we are certain of the user's identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the owner. These data and information will be protected for a period of storage and deleted, as soon as the purpose of confirming the owner's identity has expired.

This Privacy Policy applies to the above-mentioned circumstances for the entire period in which AVOID INVESTMENTS store personal data. We store and keep your information: (a) for the time required by law; (b) until the end of the processing of personal data, as mentioned below; or (c) for the time necessary to protect the rights of AVOID INVESTMENTS. Thus, we will process your data, for example, during the applicable statute of limitations or as long as necessary to comply with a legal or regulatory obligation.

The termination of the processing of personal data will occur in the following cases: (a) when the purpose for which the personal data was collected is achieved, and/or the personal data collected are no longer necessary or relevant to the achievement of that purpose; (b) when the Data Controller requests the deletion of their data; and (c) when there is a legal determination in this regard.

In the event of termination of the processing of personal data, subject to the hypotheses established by the applicable legislation or by this Privacy Policy, the personal data will be deleted.

AVOID INVESTMENTS reserves the right to update or modify this Policy, at any time and without prior notice. However, we will always publish the new revised version on our website. If there are changes in the way in which we treat personal data, you will be informed to verify that you intend to continue using our services.