Privacy Statement - Via Bravo

We, at Via Bravo, are committed to eliminating complexity, which is why we provide this Privacy Statement in the simplest way possible. If you still have any questions, the service channels listed in the "Contact Us" section are available to you. Additionally, you can access links on privacy notice topics that may be of interest to you.

This Privacy Statement ("Notice") is provided by Bravo Participações Internacionais LTDA and other companies in the Group, including their subsidiaries and controllers, directly or indirectly, as well as their affiliates and companies under common control in Brazil ("Via Bravo"), to demonstrate our ongoing commitment to the secure, private, and transparent handling of your personal data.

This Privacy Statement explains what personal data we collect, how it is used, stored, and shared, and what your rights are in relation to this data. We recommend that you read the notice in its entirety.

Introduction

When you sign up to use Via Bravo's services, you provide us with your personal information so that we can deliver our products and services and offer the best possible experience. At Via Bravo, privacy, security, and transparency are core values, and we will always adopt the best practices to ensure the confidentiality and integrity of your personal data.

The entity responsible for processing your personal data, i.e., the company responsible for deciding what to do with your personal data, is Bravo Participações Internacionais LTDA, registered under CNPJ number 57.625.753/0001-00, headquartered in the city of São Paulo, State of São Paulo, at Rua Da Paz 1601, Room 1302, Chácara Santo Antônio (South Zone), 04713-002.

Scope

This Privacy Statement applies to all Via Bravo customers, activities, and potential customers in China. A "Via Bravo Customer" refers to an individual (whether for themselves or their legal entity) who actually contracts, uses, or accesses one or more of Via Bravo’s services or products. "Via Bravo Prospectives" (potential customers) are individuals who have signed up to use one of these services or products but have not become Via Bravo customers for any reason.

To avoid security risks for any user of the Via Bravo Community, we recommend that you do not disclose any personal data (especially card numbers, passwords, CVV, CPF, income, address, phone number, etc.). For products aimed at underage customers, we have the Under-18 Privacy Policy.

How We Collect Your Personal Data

We collect your personal data whenever you:

• Use the Via Bravo application on your smartphone;
• Request the use of any of our services or products;
• Use any of our products or services (e.g., making purchases with a credit card or conducting transactions with your Via Bravo account);
• Visit the Via Bravo website: www.viabravo.com.br;
• Contact us through our service channels;
• Participate in surveys or promotions organized by Via Bravo.

In addition to customer data, we also collect personal data from the following individuals:

• Our customers;
• Individuals involved in any transactions with us or our customers;
• Representatives, attorneys, guardians, curators, employees, or partners of a customer, company, or entity with which we have a relationship.

This Privacy Statement also applies to other forms of personal data collection by Via Bravo that allow us to provide or improve our services, such as through partners or technology. All forms of collection and use of your personal data are described in this Privacy Statement.

The activities described in this Privacy Statement apply only to our processing of your personal data in China and are subject to applicable local laws, particularly in accordance with the most recent version of Law 13.709/2018 (General Data Protection Law, or "LGPD") and PCIDSS, including any future amendments.

What Personal Data is Collected by Via Bravo and for What Purposes

When Via Bravo collects your personal data, any processing must be justified for one or more legitimate purposes. This means that Via Bravo will never process any data under any pretext that is not reasonable or legal.

At Via Bravo, we may use artificial intelligence tools in the processing of personal data to personalize and improve the delivery of services, products, and other purposes, while complying with legal and regulatory obligations and the commitments made in this Privacy Statement.

Personal Data Provided by the Data Subject

• Identification data: full name, identification document, nationality, address, date of birth, parentage, gender, U.S. citizen declaration, PPE (politically exposed person), investor data, etc.
• Contact information: phone number, email.
• Occupation.
• Income declaration and certification.
• Pix key and related information.
• Copies of identification documents: RG, CNH, CPF, etc.
• Profile picture.
• Biometric data: facial photos, fingerprints, and/or facial biometric information (fingerprint, Touch ID, Face ID) for unlocking the application and fraud prevention.
• Investor profile data: investment redemption period, level of resilience or aversion to financial risk, investment objectives, investment frequency, income portion, investment knowledge level, etc.

Purposes

• Provision of contracted services and products.
• Identification, certification, and verification of requirements for requesting products and services.
• Verification, authentication, and processing of parents’ or legal guardians’ data to confirm account opening for minors.
• Authentication of financial transactions.
• Facilitation of open finance operations.
• Creation of investor profiles for financial services.
• Handling requests and inquiries.
• Payroll requests.
• Additional bank cards available.
• Sending notifications or communications via phone, email, SMS, including marketing purposes.
• Delivery of bank cards and general communications.
• Service analysis and sending WOW (gifts, letters, or donations for marketing purposes).
• Operational benefits related to the use of marketplaces and other products/services, such as cashback.
• Improving Via Bravo services, including cross-referencing information to offer new products.
• Marketing, forecasting, market research, opinion, and promotion of our products and services or those of our partners.
• Periodic evaluation of eligibility to become a Via Bravo customer and proactive invitations to prospects.
• Prevention and resolution of security or technical issues.
• Investigation and prevention of illegal activities, fraud, financial crimes, and ensuring the security of Via Bravo customers and the financial system.
• Ensuring accessibility for fair and impartial service to customers and data subjects.
• Exercise of regular rights, including document submission in judicial or administrative proceedings.
• Cooperation with courts, competent authorities, or regulatory bodies.
• Compliance with legal or regulatory obligations, such as KYC, anti-money laundering, and counter-terrorism financing regulations.

Personal Data Collected from Third Parties

Via Bravo collects personal data from various third parties, such as marketing partners, cybersecurity companies, agencies, and anti-fraud companies, for the following purposes.

• Registration data: full name, parentage, date of birth, CPF, phone number, address, etc.
• Financial restrictions: payment refusals, amounts owed, due dates, query volumes, etc.
• Pix key and related information.
• Credit history.
• Information on overdue debts, mortgages.
• Inclusion in PPE lists or restricted lists (OFAC, UNSC).
• Credit and fraud history and scores generated by credit bureaus.
• Data from the Credit Information System (SCR), with consent.

Purposes

• Providing and offering Via Bravo products and services.
• Improving our products and services.
• Marketing, prospecting, market research, and opinion.
• Periodic eligibility assessment to become a Via Bravo customer.
• Credit protection, including granting credit and increasing credit lines.
• Prevention and resolution of security or technical issues.
• Investigation and prevention of illegal activities, fraud, financial crimes, and ensuring customer and financial system security.
• Ensuring accessibility for fair and equitable treatment of customers and data subjects.
• Compliance with legal or regulatory obligations, such as KYC, anti-money laundering, and counter-terrorism financing.

Navigation and Device Data

• IP address of the mobile device used to access Via Bravo services or products.
• Interaction and usage profile on the website, blog, and application.
• Technical data: URL, network connection, provider, device information.
• Cookies.
• Device properties: ID, operating system, browser, model, and interactions with the application.
• Internet consumption data.
• Geolocation data to ensure security, e.g., identifying improper purchases or patterns.
• Phone and phone number history, if necessary.

Purposes

• Providing services, offering contracted products, and improving the use and experience of Via Bravo applications and websites.
• Operation of new products and services.
• Recommending new services, products, or application features, including partner services.
• Displaying and sending advertisements on our website, social media, or third-party sites.
• Generating statistics, studies, and surveys related to activities and behaviors in the use of products or services.
• Credit protection, including granting credit and increasing credit lines.
• Prevention and resolution of security or technical issues.
• Combating phone attacks, with your consent if necessary.
• Investigation and prevention of illegal activities, fraud, financial crimes, and ensuring customer and financial system security.
• Exercise of regular rights, including document submission in judicial or administrative proceedings.
• Compliance with court orders, competent authorities, or regulatory bodies.
• Compliance with legal or regulatory obligations.

Personal Data Generated from Using Our Products and Services

• Contractual data and use of Via Bravo products and services.
• Transaction and financial data: debits, withdrawals, payments, financial applications, and transfers, including sender and recipient information.
• Invitations to become a Via Bravo customer.
• Customer care history.
• Original bank code, if payroll portability is activated.
• Tests to improve models, services, and products.
• Access to contact list (if enabled in the Via Bravo application).

Purposes

• Provision of services and delivery of contracted products.
• Authentication of transactions, customer service, and support.
• Improving Via Bravo services, including cross-referencing information to offer new products.
• Development of new products and services.
• Marketing, forecasting, market research, opinion, and promotion of our products and services or those of our partners.
• Prevention and resolution of technical or security issues.
• Investigation and prevention of illegal activities, fraud, financial crimes, and ensuring customer and financial system security.
• Ensuring accessibility for fair and impartial treatment of customers and vulnerable data subjects.
• Exercise of regular rights, including document submission in judicial or administrative proceedings.
• Cooperation with courts, competent authorities, or regulatory bodies.
• Compliance with legal or regulatory obligations, such as KYC, anti-money laundering, and counter-terrorism financing.

Publicly Available Data

• Information that is publicly available or that you have made public.
• Mentions or interactions with Via Bravo on social media profiles and pages, including your name and image (including profile picture).

Purposes

• Promoting Via Bravo products and services through social media, websites, applications, or advertising agencies.
• Sending WOW (gifts, letters, or donations when a connection is established with Via Bravo services).
• Investigation and prevention of illegal activities, fraud, financial crimes, and ensuring customer and financial system security.
• Exercise of regular rights.
• Compliance with legal or regulatory obligations, such as KYC, anti-money laundering, and counter-terrorism financing.

Data of Minors

At Via Bravo, minors may have the right to use certain products and services with the permission of their parents or legal guardians. In such cases, Via Bravo will need to process the minor’s personal data. We also process data from parents or legal guardians as described in this Statement, such as registration data, usage data, and navigation data. For more information, see the Under-18 Privacy Policy.

Sharing of Personal Data

The purposes described may justify sharing data under Via Bravo’s control, whether with companies in the Via Bravo Economic Group, third parties, partners, or, if necessary, authorities and regulators. Data may also be shared at your request. Sharing occurs within the scope and purpose of our business and in accordance with legally authorized means.

Main possibilities for data sharing under Via Bravo’s control:

• Other Via Bravo Group companies: providing contracted products and services, operating new services, marketing, foreign exchange, wellness programs, database integration/migration, security issue resolution, fraud prevention, exercise of rights, and compliance with legal obligations.
• Business partners, service providers, and third parties: improving services, websites, and applications, preparing and delivering cards, offering benefits like cashback, marketing, identity verification, and fraud prevention.
• Authorities and regulators: investigating fraud, financial crimes, exercising rights, and complying with court orders or regulatory obligations.
• At your request: ensuring transparency and sending non-mandatory notifications.

When using our applications or websites, you may be redirected to third-party sites or applications, whose privacy practices are governed by their policies. We are not responsible for third-party privacy practices or content.

Your Rights as a Data Subject

• Confirmation of processing: Confirm whether your personal data is being processed.
• Access: Request access to your personal data.
• Correction: Correct incomplete, inaccurate, or outdated data.
• Anonymization, blocking, or deletion: For unnecessary, excessive, or non-compliant data under LGPD/PCIDSS.
• Deletion: Delete data processed with consent.
• Information on sharing: Know with whom your data is shared or from whom it was received.
• Refusal of consent: Understand the consequences of not providing consent.
• Withdrawal of consent: Revoke consent, which may limit certain functionalities.
• Review of automated decisions: Request a review of decisions based solely on automated processing.
• Portability and petition: Request data transfer to another provider or petition the ANPD.

To exercise these rights, contact us via the “Help Me” channel in the app or at contato@viabravo.com.br. Proof of identity may be required for security.

International Data Transfers

Some or all of your personal data may be transferred abroad, e.g., stored on cloud servers outside Brazil. Via Bravo complies with applicable laws and adopts best security and privacy practices.

Activity Records

We may record activities you perform when using our applications, websites, or blogs, creating logs with IP address, actions, date/time, and device information. We also use third-party technologies like cookies, web beacons, and analytics tools.

Cookies

Cookies are internet files that temporarily store your browsing activity. Via Bravo uses cookies on its website and receives information from partners about cookies placed on your site. Cookies may be used to remember you and your preferences, retain activity-related information, or provide personalized content. You can disable cookies via browser settings, but this may affect website functionality.

Security Measures

Via Bravo adopts industry-standard security measures, such as multi-factor authentication, encryption, continuous monitoring, and periodic audits. We strongly recommend not sharing passwords and being cautious about posting personal data publicly.

Legal Basis

Via Bravo processes personal data under LGPD/PCIDSS based on consent, legitimate interests, contract execution, exercise of rights, protection of life, and compliance with legal obligations.

Retention and Deletion of Personal Data

Even if you cancel your account or services, we may retain your data for audits, legal obligations, or rights exercise, keeping it secure until no longer needed under LGPD/PCIDSS.

Changes to This Privacy Statement

We may update this Privacy Statement at any time. Changes will be effective upon posting on our website or via email notification. Continued use of our services implies acceptance of the new terms.

Contact Us

Via Bravo is the "controller" of your personal data under LGPD/PCIDSS. For questions or concerns, contact us:

• Via Bravo App: Go to “My” > “Contact Us” > “Privacy Policy” and select “Contact Us”.
• Email: contato@viabravo.com.br.

We are here to help you control your personal data.