Privacy Policy and Terms of Use

This Privacy Policy will inform you about how we use and safeguard your personal data and about your privacy rights in accordance with the brazilian General Data Protection Law (Law No. 13,709/2018).

1. INTRODUCTION

1.1 Sinai Asset Bank, registered under CNPJ nº50.981.512/0001-54, respects your privacy and is committed to protecting your personal data.

2. DATA WE COLLECT

2.1 We collect, process, and store the following types of personal data:

2.1.1 Contact information: such as name, address, phone, email;

2.1.2 Financial information: such as bank account details, transaction information, and structured operations;

2.1.3 Identification information: such as CPF or CNPJ number;

2.1.4 Technical data: such as IP address, login data, browser type and version, time zone setting, browser plug-in types, operating system and platform, and other technologies on the devices you use to access our website.

3. COOKIES

3.1 We use cookies and similar technologies to collect and store information when you visit our website. Cookies are small text files that are stored in your browser or device by websites, apps, online media, and advertisements.

4. HOW WE USE YOUR DATA

4.1 We use your data to:

4.1.1 Provide financial services to you;

4.1.2 Fulfill legal or regulatory obligations;

4.1.3 Improve and personalize our services and communications;

4.1.4 Send marketing communications, if you agree.

5. DATA SHARING

5.1 We do not share your personal data with third parties, except as necessary to provide our services, fulfill legal obligations, or with your consent.

6. DATA SECURITY

6.1 We have implemented security measures to protect your personal data. However, the transmission of information over the internet is not entirely secure, and although we do our best to protect your personal data, we cannot guarantee the security of data transmitted to our website.

7. YOUR RIGHTS

7.1 In accordance with the LGPD, you have rights related to your personal data:

7.1.1 Access: You have the right to request access to your personal data that we have on our records.

7.1.2 Correction: If the data we have about you is incorrect or incomplete, you have the right to request correction.

7.1.3 Deletion: In certain cases, you have the right to request the deletion of your personal data from our records.

7.1.4 Opposition to processing: You have the right to object to the processing of your personal data under certain circumstances.

7.1.5 Limitation of processing: Under certain circumstances, you have the right to request the limitation of the processing of your personal data.

7.1.6 Data portability: You have the right to request the transfer of your data to you or to a third party.

8. CHANGES TO PRIVACY POLICY AND TERMS OF USE

8.1 We may update our Privacy Policy and Terms of Use from time to time. Changes will take effect when posted on our website. We recommend that you review regularly to be informed about our privacy practices and terms of use.

9. CONTACT

9.1 If you have any questions about this Privacy Policy and Terms of Use, please contact us. You can exercise your access, rectification, deletion, and other rights by contacting us at the indicated address.

10. ACCESS AND USE

10.1 The User is responsible for having their own resources to access the internet and use our website and/or application, whose visitation is limited to the expressly offered content. The User is prohibited from:

10.1.1 Accessing programming areas;

10.1.2 Performing reverse engineering, translating, or decompiling the source codes used that are not open, for any purpose.

11. PROHIBITIONS

11.1 The User may not perform the following actions due to or through the use of our website and/or application:

11.1.1 Commit any illegal acts and/or violate current legislation, including the provisions of Law 9.613/98 (and subsequent amendments) and Law 12.846/13;

11.1.2 Acts contrary to morality and good customs;

11.1.3 Violate the rights of third parties;

11.1.4 Violate the rights of confidentiality and privacy of others;

11.1.5 Acts that cause or provide contamination or harm any equipment of Sinai Asset Bank and/or third parties, including through viruses, trojans, malware, worm, bot, backdoor, spyware, rootkit, ransomware, or any other malicious codes;

11.1.6 Commit any acts that directly or indirectly, in whole or in part, may cause harm to Sinai Asset Bank, any User, and/or any third parties.

12. NON-COMPLIANCE WITH TERMS OF USE

12.1 If the User breaches any provision of these Terms of Use or legal provision, without prejudice to other measures, Sinai Asset Bank may, by itself or through third parties, at any time, at its sole discretion, initiate appropriate legal measures, suspend or limit access to the website and/or application, terminate any User’s account, and/or take other measures it deems necessary for compliance with these Terms and for the proper functioning of the website and/or application.

13. LIMITATION OF LIABILITY

13.1 We are exempt from liability in the event that our website and/or application remains offline, temporarily for maintenance, or in the event of damage, loss, or harm of any nature caused by performance failures in the system, error, omission, interruption, defect, or delay in operation or transmission, viruses, trojans, malware, worm, bot, backdoor, spyware, rootkit, or any other devices that may be created, due to the User’s internet browsing or failure of the line or system, on the server or internet connection, even if we have been warned of the possibility of such damages, losses, or expenses.

13.2 We are not responsible for the misuse of the information, tools, materials provided, and/or equipment used by our website and/or application, for whatever purposes, made by any User, being entirely responsible for any injuries to their own right or third parties, caused or not by this improper use.

13.3 We are not responsible for the content of other websites that may be available on the pages of our website, or whose address of this site is available on them. It is the duty of Users to read the Terms of Use, the External Privacy Notice, and other legal documents of the sites accessed through the external links contained on our website and/or application, just as to act according to what is determined in those texts.

14. REGISTRATION

14.1 To access restricted information and services, it may be necessary to register on our website and/or application, by creating a profile with login and password, and/or providing all or some personal registration data. Other registration data for User identification may be obtained through public information sources and/or through service providers contracted for this purpose and under the duty of confidentiality of the same. For more information, see our External Privacy Notice.

14.2 The login and password can only be used by the registered User, and it is expressly forbidden to share the login and/or password with any third parties. The User assumes full responsibility for the safekeeping, confidentiality, and proper use of the registered login and passwords, exempting Sinai Asset Bank from any responsibility. Furthermore, if any anomalous access or transaction pattern is identified from this User, the information security team or related areas of Sinai Asset Bank will take the appropriate measures to verify the incident and may even reject access temporarily without prior communication to the User.

14.3 The User is responsible for the accuracy and truthfulness of the data provided and acknowledges that the inconsistency of these may result in the inability to access our website and/or use the application.

15. INTELLECTUAL PROPERTY

15.1 Unless otherwise stated, all content on our website and/or application, such as information, materials, tools, page organization, graphics, images, videos, and designs, belong to Sinai Asset Bank or third parties who have lawfully granted their right of use, and the User is prohibited from using them.

15.2 The User may not, through the use of our website and/or application, use any company name, trademark, domain name, slogan or advertising expression, or any distinctive sign or intellectual property owned by Sinai Asset Bank.

16. GENERAL PROVISIONS

16.1 Sinai Asset Bank’s tolerance regarding any breach of any provision of this Agreement by any Client shall not constitute a waiver of the right to demand compliance with the obligation, nor forgiveness, nor alteration of what is hereby provided.

16.2 This Agreement is governed in accordance with Brazilian law. Any disputes or controversies arising from any acts performed within the scope of using Sinai Asset Bank services by Clients, including with respect to the breach of this Agreement or the violation of the rights of Sinai Asset Bank, other Clients, and/or third parties, including intellectual property rights, confidentiality, and personality, will be processed in the District of the Capital of the State of Paraná, Brazil.

16.3 Transactions that are to be carried out electronically by the Client will be accepted and valid as an effective means to prove the authorship, authenticity, integrity, and confidentiality, and if carried out by phone, may be recorded. The use of a token, with the indication of a numerical code, the option of Alerts (PUSH), for your cell phone, security phrases, mobile mobility services, geolocation, and your cell phone’s biometrics may be used as ways to validate and authenticate the transactions carried out by the Client.

16.4 To resolve any doubts and/or problems related to the use of Sinai Asset Bank services, contact your Account Manager, and if you are not yet our client, by the customer service number provided. If the problem persists, contact our Ombudsman at the provided service number. For questions related to the Privacy Policy, please refer to the contact channel provided in that document.