Privacy Policy

Updated November 16, 2021.

1. PRIVACY STATEMENT

VITA INVESTIMENTOS knows how important it is to know and be sure about the use of personal data in its possession. Therefore, we care to clarify and explain our Privacy Policy. We recognize the need to protect and properly manage the personal information collected on our website, as well as that provided by our customers. This Privacy Policy will help you understand what types of information we may collect, how this information may be used, with whom the information may be shared and what rights holders have with regard to the protection of their personal data..

2. WHAT PERSONAL INFORMATION WE COLLECT

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

Site: Personal information is collected when the user interacts with our website through the contact form. The personal data collected are name, email and telephone. The user may also choose to send newsletters by registering the e-mail. It is possible to unsubscribe from the newsletter sending list at any time by clicking on the unsubscribe link contained in the body of the emails. The user of our portal is not obliged under any circumstances to provide any personal data to browse the pages of the site, so any information is provided of their own free will. It is only necessary to collect basic data when the user wants the return of his contact. All personal information is collected in a fair and non-invasive manner, with your voluntary consent. Personal information is not accessible to any person outside the specific role for which it was collected..

Data related to the provision of our services: To make our services viable, we collect personal data from our customers, such as full name, RG, CPF, date of birth, marital status, profession, address and nationality. We also collect financial information, such as bank, type of account, branch, checking account, monthly income, financial investments, other income, in addition to movable and immovable assets. Data related to the provision of our services: To make our services viable, we collect personal data from our customers, such as full name, RG, CPF, date of birth, marital status, profession, address and nationality. We also collect financial information, such as bank, type of account, branch, checking account, monthly income, financial investments, other income, in addition to movable and immovable assets. This data is necessary to identify the best investment alternatives and to prepare a contract..

Sharing: Personal data such as email and financial information can 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 full name and CPF of the customers are collected. Such data are 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 can get in touch by telephone or e-mail. Personal data is collected in order to identify the user, as well as to fulfill his/her request. These may include, among others, name, email and phone number. In addition to these, we collect any personal data that is spontaneously informed by the user..

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

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

3. SOCIAL MEDIA

VITA INVESTIMENTOS also uses Social Media 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 Internet-based technology that is not operated or controlled by VITA INVESTIMENTOS. By interacting with, sharing or “Liking” the VITA INVESTIMENTOS page on Facebook, Instagram, Twitter or Linkedin, or other social media, you may disclose certain personal information to VITA INVESTIMENTOS or third parties..

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

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

4. PURPOSES AND LEGAL BASIS

We list below the purposes and legal bases of VITA INVESTIMENTOS data processing:

We only rely on our legitimate interest for specific purposes. These processing of personal data in no way override the interests, rights and freedoms of the holders of personal data..

5. ABOUT THE SHARING AND ASSIGNMENT OF INFORMATION

VITA INVESTIMENTOS does not have the practice of disclosing information that can identify the user and never shares information or sells and rents this personal data to third parties. These data are 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 judicial decision or request by regulatory bodies, government inspection, administrative and judicial authorities;

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

Data transferred to financial institutions to provide payment options to our customers, 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 VITA INVESTIMENTOS commercial activities, such as research for fraud prevention (KYC – Know Your Customer Procedure), portfolio consolidation application, processes payment, emailing, advertising and marketing, security and performance monitoring, processing and fulfillment of orders and transactions, research, data retention, auditing and data processing;

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

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

6. INFORMATION SECURITY

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

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

7. RIGHTS OF HOLDERS

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

These are the rights of the holders:

Confirmation of the existence of processing of personal data;

Access to personal data, pursuant to applicable legislation;

Correction of incomplete, inaccurate or outdated personal data;

Personal data portability;

Deletion of personal data, when it is processed based on the consent of the holder or when the data is unnecessary, excessive or treated in violation of applicable legislation;

Request for information on shared use of personal data;

Withdrawal of consent, when applicable.

VITA INVESTIMENTOS will always evaluate the best way to fulfill the request to exercise any of its rights. However, VITA INVESTIMENTOS may fail to comply with your request, in whole or in part, in specific situations protected by legislation, such as, for example, to comply with a legal obligation or a contract it has with you..

We emphasize the importance of keeping your personal data accurate and up to date. Therefore, keep VITA INVESTIMENTOS always informed if your personal data changes or is incorrect..

For security reasons, for requests made through the email dpo@vitainvestimentos.com, the request will be answered when we are sure of the user’s identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the holder. These data and information will be protected during the storage period and deleted as soon as the purpose of confirming the identity of the holder is exhausted..

8. TERMINATION OF TREATMENT

This Privacy Policy applies to the aforementioned circumstances throughout the period in which VITA INVESTIMENTOS stores personal data. We store and maintain your information: (a) for as long as 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 VITA INVESTIMENTOS. 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 is no longer necessary or relevant to the scope of that purpose; (b) when the Holder requests the deletion of their data; and (c) when there is a legal determination to this effect.

In cases of termination of processing of personal data, except in the cases established by applicable legislation or by this Privacy Policy, personal data will be deleted.

9. PERSONAL DATA CHARGER (DPO)

VITA INVESTIMENTOS makes available below the contact details of the Personal Data Officer (DPO), who is responsible for meeting any and all requests from the data subjects or the National Authority, which are related to personal data.

For any questions, requests or complaints regarding the processing of personal data, please contact our Personal Data Officer:

DPO EXPERT® (www.dpoexpert.com.br) – contact: dpo@vitainvestimentos.com

If, despite our commitment and efforts to protect your data, you feel that your data protection rights have not been met, please contact our DPO. In addition, you have the right, at any time, to file a complaint directly with the National Data Protection Authority, if you believe that the rights to your personal data have been infringed.

10. CHANGES IN THE PRIVACY POLICY

VITA INVESTIMENTOS 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 we treat personal data, you will be informed to verify if you intend to continue using our services..