Please read these Website Terms of Use carefully before using the site.

INTRODUCTION

Thank you for visiting transfero.com (“Website” or “Site”).
In these Website Terms of Use (Terms), references to we, us, our means Transfero. References to you and your are to users of our website.

BY USING OUR WEBSITE YOU ACCEPT THESE TERMS

These Terms, together with the documents referred to in it, set out the terms and conditions on which you make use of transfero.com. Please read these Terms carefully before you start to use the Website. By using our Website, you confirm that you accept these Terms and that you agree to comply with them. If you do not agree to these Terms you must not use our Website.

OTHER TERMS THAT MAY APPLY TO YOU
These Terms refer to the following additional terms, which also apply to your use of our website:

• our Privacy Policy transfero.com/privacy;
• our Cookie Notice transfero.com, which sets out information about the cookies on our Site.

WHO WE ARE AND HOW TO CONTACT US

transfero.com is a Website operated by TRANSFERO. If you have any queries or concerns regarding transfero.com or the information contained on it, please contact us at contact@transfero.com.

WEBSITE CONTENT

The content on our website is provided on an “as is” basis and all information, commentary and other materials displayed on our website are intended for general information purposes only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our Website.
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We update our Website regularly and may change the content at any time. Although we make reasonable efforts to update the information on our Website, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up-to-date. Therefore, we disclaim all liability and responsibility arising as a result of any reliance placed on such information, commentary or other materials contained on transfero.com by any visitor to our website or by anyone who may be informed of any of its content.

RESTRICTIONS ON ACCESS AND USE

Website access
Our website is made available free of charge. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. If our website is unavailable for any reason and at any time (including for any period of time), we shall not be liable to you for such an occurrence.

To register on our Website you must be 18 years or older. Only one registration is allowed per person and once registered, you must ensure you keep your registration information up-to-date.

Suspension, withdrawal and restriction of access
⁠We may in our absolute discretion, suspend, withdraw or restrict access to all or some parts of our website to any persons, which shall include, for the avoidance of doubt, users who have registered with us.

Termination of access
⁠We may in our absolute discretion, terminate your access to transfero.com at any time and without notice.

User ID and password
If you establish an account on transfero.com you are responsible for maintaining the confidentiality of your user ID and password, and you are responsible for all activities that occur under that user ID or password. You agree that you will not allow anyone to use your account and that you will not use anyone else’s account.
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We have the right to disable any user ID or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these Terms.
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If you know or suspect that your user ID or password has been unlawfully disclosed or there has been a known or possible breach of security, you must promptly notify us contact@transfero.com.

HOW YOU MAY USE MATERIAL ON OUR SITE

All intellectual property rights contained on the website and all materials published on the website are owned and/or licensed by us with all such rights reserved.
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Except as expressly provided in these Terms, no part of the Website may be copied, reproduced, uploaded, posted, publicly displayed, encoded, translated, transmitted or distributed in any way (including mirroring) to any other computer, server, website or other medium for publication or distribution or for any commercial enterprise, without the express written consent of TRANSFERO.
You may download publicly-available content on transfero.com only for your personal, non-commercial use, provided that:

• you keep intact all copyright and other proprietary notices; and
• if your copying or use of copyrighted materials on transfero.com is other than “fair use” under applicable copyright laws, you must seek permission directly from us.

If you print off, copy or download any part of our website in breach of these Terms, your right to use our website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

LINKING TO AND FROM OUR SITE

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked sites or information you may obtain from them. We have no control over the contents of those sites or resources. We exclude, to the fullest extent permitted by law, all liability that may arise in connection with or as a result of such external site material causing any damage, costs, injury or financial loss of any kind.

WE ARE NOT RESPONSIBLE FOR VIRUSES AND YOU MUST NOT INTRODUCE THEM

We do not guarantee that our site will be secure or free from bugs or viruses.
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You are responsible for configuring your information technology, computer programs and platform to access our site. You should use your own virus protection software.
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You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our website. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

DATA PROTECTION AND PRIVACY

We shall comply with all applicable data protection legislation, including implementing laws, regulations and secondary legislation relating to data protection or privacy, as each of the foregoing may be amended, updated, consolidated, replaced and/or re-enacted from time to time.
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We shall use and process your personal information in accordance with our Cookie Notice and Privacy Policy.

• • To the fullest extent permitted by law, we hereby expressly exclude:
    all conditions, warranties and other terms which might otherwise be implied by statute or the applicable law; and
  • any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our Website or in connection with the access, use, inability to use, or results of the use of our Website, any websites linked to it and any materials posted on it, including liability for:
    • loss of business;
    • loss of income or revenue;
    • loss of profits or contracts;
    • loss of data;
    • wasted management or office time;
    • loss or damage caused to any equipment or software; or
    • any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, malicious code or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the Website or to your downloading of any material posted on it, or on any website linked to it.
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This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraud or fraudulent misrepresentation, or any other liability which cannot be excluded or limited under applicable law.

SEVERABILITY

In the event any provision or part-provision of these Terms is found by any court or other authority of competent jurisdiction to be invalid, unlawful or unenforceable, that provision or part-provision shall, to the extent required, be deemed not to form part of these Terms and the validity and enforceability of the other provisions of these Terms shall not be affected.

VARIATION

TRANSFERO may at its sole discretion amend these Terms at any time. Every time you wish to use our Website, please check these Terms to ensure you understand the terms that apply at that time.

GOVERNING LAW AND JURISDICTION

These Terms shall be governed by, and construed in accordance with, the laws of Brazil. Any dispute arising out of or in connection with these Terms, including any question regarding their existence, validity or termination, or arising from or related to use of our website, shall be subject to the exclusive jurisdiction of the Courts of Brazil.

1. BRAZIL

1.1. VASPs (Virtual Asset Service Providers)

As of today, Law No. 14,478/22 (Crypto Assets Law), enacted in December 2022, has not yet been fully implemented. Although the regulation has been in effect since 2023, certain aspects remain pending further definition by the Central Bank of Brazil, designated as the authority responsible for overseeing and regulating Virtual Asset Service Providers in the country, as per Decree No. 11,563/2023. One of the main unresolved issues is the requirements and processes for companies to obtain licenses to provide Digital Asset Services. Recently, the Central Bank completed the first phase of a public market consultation and is engaging with key market players in Brazil to determine the best way to regulate and oversee this sector. According to the regulator, a second public consultation on the matter is expected in the second half of 2024, alongside plans to structure internal guidelines for stablecoin regulation. The Central Bank aims to finalize normative proposals by the end of 2024.

1.2. PAYMENT INSTITUTION

Transfero Instituição de Pagamento Ltda. operates as the payment institution of the Transfero group under CNPJ No. 47.133.056/0001-88. It is authorized by the Central Bank of Brazil to operate as a payment institution (https://www.bcb.gov.br/meubc/encontreinstituicao).

1.3. ASSET MANAGEMENT COMPANY

Transfero Gestora de Recursos Ltda., registered under CNPJ No. 42.155.153/0001-58, operates in Brazil as an asset management company regulated by the Brazilian Securities and Exchange Commission (CVM). It also adheres to self-regulation rules established by ANBIMA (https://sistemas.cvm.gov.br/?CadGeral).

2. SWITZERLAND

2.1. VIRTUAL ASSET SERVICE PROVIDER (VASP)

Transfero Swiss AG, a company incorporated in Zug, Switzerland, and registered under No. CHE-300.76.450, has been a member of the VQF SRO (Financial Services Quality Assurance Association) since 2021. It is classified as a Virtual Asset Service Provider (VASP), registered under No. 100930.

3. THE BAHAMAS

3.1. VIRTUAL ASSET SERVICE PROVIDER (VASP)

In The Bahamas, Transfero Digital Platform Ltd., incorporated under No. 209214B, recently received authorization in December 2023 from the Securities Commission of The Bahamas (SEC Bahamas) to operate as a Virtual Asset Service Provider and Exchange under the Digital Assets and Registered Exchanges Act, 2020 (DARE Act).

3.2. ASSET MANAGEMENT COMPANY

Transfero Asset Management Ltd., another entity of the group, incorporated in The Bahamas and registered under No. 203877B, is authorized by the Securities Commission of The Bahamas to operate as an asset management company.

4. ARGENTINA

4.1. VIRTUAL ASSET SERVICE PROVIDER (VASP)

Transfero Pagamentos S.A., a company incorporated in Argentina and registered under CUIT No. 30-71704433-5, received authorization in 2024 from the National Securities Commission (CNV) to operate as a Virtual Asset Service Provider in the country.

1. Introduction

TRANSFERO is an innovative company that uses blockchain technology to offer infrastructure to companies that want to offer their customers in Latin America payments services using digital assets. The company also has global operations in countries such as Brazil, Argentina, Switzerland, Chile, Colombia, Bahamas, among others.
Among the company’s values, transparency and trust guide issues related to the protection of personal data. The company constantly adapts to the current regulations related to the treatment of all personal data collected, stored, and shared.

Therefore, the purpose of this Privacy Notice is to convey and assure customers and partners how TRANSFERO relates to the topic of privacy and protection of personal data, its respective treatment and processing by the company.

2. Terms and Definitions

For a better understanding of this document, below are the terms used and their respective definitions:

• National Data Protection Authority (ANPD): Brazilian federal agency for the inspection and implementation of personal data protection measures at the national level.
• Data Encryption: A security method that involves converting data into an unreadable format, called ciphertext, using a specific algorithm. This process is used to protect the confidentiality and integrity of the data, making it incomprehensible to anyone who does not have the appropriate decryption key.
• Personal Data: Any information relating to a natural person, capable of identifying or making him identifiable.
• Sensitive Personal Data: Information that can reveal intimate aspects of a person, generating a possibility of discrimination, according to the exhaustive list of the Brazilian General Data Protection Law (LGPD).
• Data Protection Officer (DPO): A person, individual or legal entity, appointed by the operator or controller of personal data to act as a point of contact between them, the persons to whom the data belongs and the Brazilian National Authority for the Protection of Personal Data (ANPD).
• Brazilian General General Data Protection Law (LGPD): The Brazilian General Data Protection Law (Law No. 13,709/2018) inspired by European legislation, aims to ensure the privacy and security of the personal data of any individual, in observance of the following fundamental rights: privacy, intimacy, freedom of expression and information.
• Processing of Personal Data: Any operation carried out with personal data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
• Personal Data Subject: Individual to whom the personal data refers to.

3. Personal Data Collection

Personal data is collected through the user’s registration to use one of the services offered by the company. Some of the data initially collected, in a non-exhaustive way, to identify the user and their profile are listed below:

• Full name;
• Email Address;
• Telephone;
• Nationality;
• Full residential address;
• Date of birth; and
• Full Name of the Mother.

4. Hypothesis of Personal Data Processing

TRANSFERO processes personal data in order to provide and execute its services, constantly seeking to improve them and ensure the user’s security in its operations. TRANSFERO may also use the data collected to inform users about new products that are launched.
The most frequent purposes for processing personal data are:

• Resolution of doubts and requests from users;
• Contract executions;
• Guarantee of data security, especially against fraud;
• Creation of new products; and
• Advertising.
• For such functionality, TRANSFERO bases its operation on the following
• hypotheses:
• Contract execution, or preliminary procedures related to contract;
• Assent; and
• Legitimate Interest.

5. Processing of Personal Data of Children

TRANSFERO does not collect or process personal data from children and/or teenagers in the provision of its services, except for the legal hypotheses provided for in the LGPD.

6. Storage and Disposal of Personal Data

TRANSFERO stores personal data only for the period necessary to comply with the purposes set out at the time of consent and may keep some data when necessary to comply with a legal or regulatory obligation, as well as for the regular exercise of rights in judicial, administrative or arbitration proceedings.

7. Sharing of Personal Data

In order to conduct its activities, TRANSFERO shares your personal data with third parties, such as:

• Operators: service providers who executes the processing on our behalf, assisting us in the development of the activity, according to our instructions; and
• Public Authorities for the protection of rights.

We emphasize that we carefully evaluate the processing conducted by the operators, observing the principles and purposes, thinking about compliance with the Brazilian General Data Protection Law (LGPD), in addition to the secure sharing of data, ensuring privacy and protection of data.

8. International Transfer of Personal Data

TRANSFERO and some partners are located in several countries, with the possibility of processing data abroad, observing their respective databases.
It should be noted that this transfer only occurs to companies that are in compliance with the local legislation applicable to each respective country, and this should be equivalent or even more rigorously than the Brazilian legislation.

9. Cookies

In order for users to have a valuable experience on our website, “cookies” may be collected by the company. The cookies collected are:

• Strictly Necessary; and
• Analysis.

It should be noted that TRANSFERO is not responsible for the use of cookies added by third parties, so we recommend that you clear your browsing data regularly. For more information, please visit our Cookie Notice.

10. Data Security

TRANSFERO, as it deals with personal data, is responsible for implementing effective technical and administrative measures for the security of information, preventing unauthorized access, disclosure, alteration and/or destruction.
We have developed protection measures capable of ensuring the confidentiality, integrity and availability of the data processed by us, developing internal policies and procedures, as well as training for all our employees, with the aim of implementing the culture of personal data protection, as well as preventing potential incidents. Notwithstanding this and in order to assure users, the company informs you that in the event of suspected incidents or improper access to the user’s account, we may terminate the user’s access at any time and without prior notice, in order to ensure the protection of their data.

Each user of the services can access them through an individualized login and password. We recommend that, when creating your account, you maintain the confidentiality of your user login and unique password, with combinations of characters considered strong. Also, log off as soon as you are done using a shared computer.

11. Rights of Data Subjects

Every individual is assured of their rights regarding the processing of their personal data, preserving freedom, intimacy, and privacy. Therefore, everyone who has established relationships with TRANSFERO may:

• Confirm the existence of the processing of your personal data;
• Access your personal data;
• Correct incomplete, inaccurate, or outdated personal data;
• Request the anonymization, blocking, and deletion of unnecessary or
• excessive data;
• Request information about sharing personal data; and
• Revoke consent.

In cases where TRANSFERO, in the relationship of processing agent, is characterized as a Personal Data Processing Operator, your request will be sent to the Controller, within the deadlines established above.

12. Information Request

To request information or request your rights regarding the personal data we hold, please contact us through our DPO, by e-mail: privacidade@transfero.com.
It should be noted that some documents or information may be required for data security purposes, which can only be accessed by the data subject himself. In addition, the following deadlines of response shall be considered:

• Immediately, after your request, the DPO will contact you, to confirm the existence and access to personal data. In cases where it is not possible execute the analysis immediately or that make it impossible to immediately adopt measures, the confirmation of the opening of the call will be communicated, in a simplified manner; and
• Within fifteen (15) days, counted from the request, the complete statement will be analyzed and sent, confirming the adoption of the measure.

The data information will be provided electronically, in a secure and reputable manner.

13. Amendments

TRANSFERO, aware of the importance of protecting personal data, is constantly improving. Thus, in order to maintain total transparency and security with your personal data processing, this notice is subject to changes and revisions at annual intervals or in view of specific needs.

14. Governing Law and Jurisdiction

This privacy notice is governed and interpreted in accordance with the Brazilian privacy and personal data protection law and also extends to TRANSFERO‘s operation in other countries and must observe the respective local laws of each territory.

Last updated date: November 08, 2024.

1. Introduction

TRANSFERO respects your privacy and promotes the protection of personal data, in accordance with the legal provisions provided for in the General Data Protection Law (LGPD – Law No. 13,709/2018) and with the regulations issued by the National Data Protection Authority (ANPD).
We value the completeness, confidentiality and availability of your personal data. Therefore, all personal data collection is premised on values such as transparency and clarity before the data subjects.

The purpose of this Cookies Policy is to delimit the form of collection of personal data during the use of cookies, which are small files of information and texts generated by websites to improve your internet browsing experience. Through these it is possible to offer more personalized conditions of use of the TRANSFERO website and more interesting forms of navigation for users.

TRANSFERO makes the best efforts in matters related to privacy and protection of personal data to adapt and comply with the current regulations related to the processing of personal data collected, stored and shared by the company.

1. What are Cookies?

Cookies consist of small text files generated by websites, stored on your computer or mobile device through your browser. Although small, cookies have the ability to store various information about the user, such as: email addresses, behavior on the site, among others.

3. Transfero’s Use of Cookies

The TRANSFERO website uses cookies for statistical purposes regarding the website, as well as to keep your browsing safe. Therefore, the cookies used are:

• Strictly necessary: essential for the proper functioning of the website and maintenance of secure user access;
• Analytics & Performance: Improving website performance and analyzing user interaction with our platform. Based on this information, we are able to offer an improved experience to visitors, adapting our services according to their preferences and needs identified during the analysis; and
• Advertising: these are cookies necessary to ensure a personalized experience according to the user’s interests and behaviors, making it possible to offer differentiated commercial conditions, products and services in accordance with the analysis of their preferences.

The types of cookies used by TRANSFERO can be seen in more detail and information in the following table:

It should be noted that TRANSFERO is not responsible for the use of cookies added by third parties. Therefore, we recommend that you clear your browsing data regularly.

4. How to Manage Cookies

Users of the website or app can manage, disable and/or delete cookies through their browser settings. However, it should be noted that choosing to block all types of cookies, including those considered strictly necessary, may result in the impossibility of accessing all the features offered by Transfero for your best browsing.

To disable cookies in your browser, please visit:

• Chrome;
• Safari;
• Edge;
• Opera;
• Firefox.

5. Contact Transfero

To request information and clarification or to request your rights regarding the processing of your personal data, please contact us through our DPO by e-mail: privacidade@transfero.com.

6. Amendments

TRANSFERO, aware of the importance of privacy and the protection of personal data, is constantly improving its governance practices. Thus, this notice is subject to changes and revisions periodically, always by means of communications to users/holders of personal data on our website and/or application.

Last updated date: November 08, 2024.