Privacy Notice and Terms of use

Privacy Notice MSF Invest.md

Update Date: 01/12/2023

PRIVACY NOTICE

We, at MSF INVESTIMENTOS LTDA, a limited liability company, registered under CNPJ/MF No. 01.583.815/0001-03, headquartered at Rua Waldemar Falcão, No. 1774, Arbus Soft Office rooms 104 to 106, Salvador, Bahia, ZIP Code 40.285-885 (“MSF INVEST”), base our activities on transparency, respect, and ethics, always aiming to provide You (user of our Application) with adequate and necessary information about our services.

For this reason, we have prepared this Privacy Notice (“Notice”). Here, You will learn how we handle your personal data, the security measures we employ, the partners we use, and your rights as a user and client of our Application.

We ask that You take a few minutes to carefully read this Notice, and if you have any questions, do not hesitate to contact us through our Support: development@msfinvest.com.br or +55 (71) 3235-3282.

Glossary

To better understand the content of this Notice, we present below a list with the definition of the terms most commonly used in this document.

Term	Concept
Personal Data	All information that identifies you or makes you identifiable, such as your name, email, IP, among others.
Processing of Personal Data or Processing	Any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.
Data Subject or Data Subject	The natural person to whom the personal data refers. In the context of this Notice, the data subject is You, the user of the Application.
Premium Services	Premium services refer to paid services available in our Application.

Who are we?

MSF Invest is a company committed to providing users of its Application with easy and quick access to information about the Brazilian securities market.

By registering on our Application, You will have access to:

• The list of stocks listed on Brasil, Bolsa e Balcão (“B3”) and their updated market prices;
• Relevant Facts issued on the day;
• Information about investors' participation in B3, public offers made since 2020, information about International Reserves, Foreign Exchange Flow, and Trade Balance;
• Fundamental indicators of stocks listed on B3;
• The history of B3;
• Lessons on metrics to be observed by an investor when participating in the securities market;
• A comparative report on the settlement operations carried out by You in a certain period.

MSF Invest does not provide guidance, recommendation, and advice services, independently and individually, on investments in the securities market.

How do we collect your personal data?

MSF Invest collects your personal data in two ways. First, through the sharing done by You at the time of registration on the Application. Second, through the automatic collection of data about the device and usage of the Application.

What personal data do we process?

During your use of the Application, we may process the following personal data:

• Registration data: full name;
• Contact data: email;
• Data of operations in the securities market: broker used, date of the trading session, nature of the operation (buy or sell), the nomenclature of the stock, total of the operation, quantity of shares involved, average cost of the operation, brokerage value, fees and expenses incurred with the operation, taxes paid, and the net total of the operation;
• Data and attributes associated with the electronic device used: Device identification number, IP of the connection, location, date and time of access to the Application, interactions performed, and the most accessed tabs.

How do we use your personal data?

We at MSF use your personal data for the following purposes:

• Identify and facilitate the registration process in the Application so that You have access to information about the securities market. For this, we use the registration and contact information provided by You when registering on the platform;
• Enable access to premium services;
• Effect the production of reports on operations carried out in the securities market. For this, we will use the data of the operations that You have already carried out in the securities market and that you have manually shared with us;
• Enable our communication with You. We may use your registration and contact data to facilitate our communication with You to inform You about our services or send advertising and/or marketing content;
• Enable technical support for the Application. We may use your device data to facilitate the support process and provide technical assistance in case of bugs or malfunctions of the Application;
• Fulfill legal obligations. We are required by law to retain some basic access record data to the Application such as the IP address of the originating connection, with date and time. Such data are kept for the legally prescribed minimum period of 6 (six) months. Eventually, other data may also be stored for legal compliance, such as those related to formal complaints about service provision;
• Allow the exercise of our rights guaranteed by law. We may process your personal data to exercise our rights guaranteed by law, such as, for example, in our defense in judicial or administrative proceedings, when necessary;
• We may also use the collected data for secondary purposes that are not conflicting or excessive in relation to the purposes listed above, such as in the management and improvement of our services and in the enhancement of the Application.

With whom do we share your personal data?

We may share the data collected through the Application in the following cases:

• With partner companies, when necessary or relevant to the execution of the service provision, including, but not limited to, technical support to maintain the availability of the Application and the systems used by the company;
• To protect our interests in any conflict or dispute, whether judicial, administrative, or arbitral;
• In case of changes or corporate operations involving us, if data sharing is necessary for the regular continuity of the Application services;
• With administrative and/or judicial authorities, upon judicial determination to that effect or request from authorities with legal competence for such.

How do we protect your personal data?

We consider all information collected through the Application confidential, ensuring that it will be treated and stored in accordance with the provisions of this Notice and with the adoption of adequate technical and administrative security measures, according to the degree of sensitivity of the data and the inherent risks of the activity. Among the security measures we adopt are access control to information, the use of firewalls, and the architecture of the software solution with intrusion prevention.

How long do we store your personal data?

We will only retain your personal data for the time necessary to fulfill the purpose for which the data was collected or at your request, as explored in this Notice. Also, the data may be stored for a period:

• Legally possibly linked to the legal relationship with You;
• Necessary for a possible contractual negotiation;
• Necessary for compliance with any legal or regulatory obligation;
• Or if there is another just reason to store it.

When the Personal Data we collect is no longer necessary, we will securely delete it or anonymize it so that it cannot be associated or traced back to You.

What are your rights and how can you exercise them?

We take your rights seriously, and for that reason, we list below your rights as the data subject. They are:

Your Rights	What does this right mean?
Confirmation	You can inquire whether your personal data is being processed by MSF Invest.
Access	You can request access to your personal data stored by the Application, or as a result of one of our services, by contacting us at development@msfinvest.com.br.
Correction	In case of incorrect data, you can request the correction or update of your data by contacting us at development@msfinvest.com.br.
Anonymization, Blocking, or Deletion	If you believe that the data processing we perform is unnecessary, excessive, or non-compliant with LGPD, You can request the anonymization, blocking, or deletion of your personal data through our contact channel development@msfinvest.com.br.
Portability	You may request the portability of the data stored in our systems. This means that, in the event of such a request, MSF Invest will provide a copy of your personal data in a common and interoperable reading format, although compatibility with the technical settings of the receiving company cannot be guaranteed.
Deletion	If we process your personal data based on consent, You may request the deletion of this information by contacting us at development@msfinvest.com.br.
Sharing	Information about public and private entities with whom MSF Invest shares your data is described in this Notice. If you want more details about this sharing, you can contact us through the email development@msfinvest.com.br.
Revocation of Consent	If we process your data based on consent, You may request its revocation by contacting us at development@msfinvest.com.br.

All requests mentioned above will be handled free of charge and will be subject to a prior evaluation of your identity and the feasibility of the request to comply with any legal obligations that may prevent the complete fulfillment of the requests of data subjects.

Updates to this Privacy Notice

We may change or update this Privacy Notice at any time. Whenever this Notice is changed, we will indicate the date of the updated version at the top of this document. We recommend that You periodically consult this Privacy Notice.

Terms of use MSF Invest.md

Update Date: 01/12/2023

TERMS AND CONDITIONS OF USE

We, MSF INVESTIMENTOS LTDA, a limited liability company, registered under CNPJ/MF No. 01.583.815/0001-03, headquartered at Rua Waldemar Falcão, No. 1774, Arbus Soft Office rooms 104 to 106, Salvador, Bahia, ZIP Code 40.285-885 (“MSF INVEST” or “MSF Invest”), base our activities on transparency, respect, and ethics, always seeking to provide you (user of our Application) with appropriate and necessary information about our services. In these Terms and Conditions of Use (“Terms”), you will have access to the set of rules and procedures that govern the use of our Application and the relationship between you and us, MSF Invest. By accessing the Application, you adhere to the rules of use and behavior described in this document and its future changes.

Who we are?

MSF Invest is a company committed to providing users of its Application with easy and fast access to information about the Brazilian securities market.

By registering on our Application, you will have access to:

• The list of stocks listed on the Brazil, Bolsa e Balcão (“B3”) and their updated market prices;
• Relevant facts issued on the day;
• Information about investor participation in B3, public offerings made since 2020, information about International Reserves, Exchange Flow, and Trade Balance;
• Fundamental indicators of stocks listed on B3;
• The history of B3;
• Teaching about the metrics to be observed by an investor when participating in the securities market;
• A comparative report on the settlement operations carried out by you in a certain period.

MSF Invest does not provide guidance, recommendation, and advice services, independently and individually, on investments in the securities market.

User Account

• To use the Application, it is necessary to register, providing your name, last name, and email.
• Once your registration has been completed, you can access information about the securities market and contract our premium services, if you wish.
• You are solely responsible for all activities carried out in your account, including the accuracy and truthfulness of the information shared with us through the Application.
  • You agree to notify MSF Invest immediately of any unauthorized use of your account, as applicable, or any security breach related to access or contracting of services offered in the Application.

General Conditions of Use

• MSF Invest has the right to modify, add, alter, terminate, suspend or discontinue, temporarily or permanently, the Application (in whole or in relation to one or more of its aspects), at its sole discretion, at any time, without the need for prior notice.
• By accepting these Terms, you agree to comply with and respect the set of rules set forth in this document, in the Privacy Notice of MSF Invest, and in national legislation.
• You, as a user of the Application, may not track, collect data, use robots, or extract any information regarding the Application or its contents through the use of your account. Any use of the Application and its content in a manner divergent from that authorized in this document is permanently prohibited.
• You, as a user, undertake not to reproduce, modify, reverse engineer, compile, decompile, transmit, publish, sublicense, allow, authorize, rent, sell and/or distribute, or in any other way not allowed in these Terms, use or transfer, in whole or in part, any content directly or indirectly related to the Application, without prior and express written authorization from MSF Invest.
• You acknowledge and accept that, at any time, MSF Invest may suspend or cancel your account if it violates any clause of these Terms, or if you fail in your duties as a user and/or engage in any fraudulent, intentional, or offensive behavior towards third parties.
• You acknowledge and declare that, at no time, MSF Invest may be held responsible for:
  • Decisions made by you based solely on the information available in the Application, without additional research or requests to securities consultants, including but not limited to any operations carried out by you in the securities market solely and exclusively based on the information available in the Application;
  • Defects and/or technical defects originating from your operating system or your internet access device that may prevent or hinder access to the Application;
  • Any mistakes in the analyses carried out through our premium service, if based on the input of incorrect, incomplete, or outdated information.

In-App Purchase Auto-Renewing Subscription (Pro)

The Pro subscription unlocks exclusive features that enhance your experience. Below, we outline the functionalities enabled by this subscription, in compliance with the Terms and Conditions of Use:

• Virtuosa: Explore advanced features for analysis and insights.
• Settlement Operation: Access the settlement operation for a detailed view of financial transactions.
• Relevant Facts: Stay updated with pertinent information in the financial and business landscape.
• PiVTSB: Utilize PiVTSB for specialized analyses and market projections.
• Financial Turnover: Track financial turnover and stay informed about economic activities.
• International Reserves: Gain access to international reserves to understand global movements.
• Public Offering: Stay informed about public offerings to make informed investment decisions.
• Foreign Exchange Flow and Trade Balance: Analyze foreign exchange flow and trade balance data for a comprehensive understanding of the economic landscape.

Subscription Details:

• Title: Pro
• Length: Annual Renewal
• Price: $229.00

Auto-Renewal Information:

• The Pro subscription auto-renews on an annual basis.
• The subscription fee will be automatically charged to your account within 24 hours before the current subscription period expires.
• You can manage your subscription and turn off auto-renewal by going to your Account Settings after purchase.

Disclosure:

• Please note that the title of the auto-renewing subscription is "Pro Subscription," which is the same as the in-app product name.
• The length of the subscription is one year.
• The price of the subscription is $229.00.

Important Notes:

• The auto-renewal feature is available only in select Territories using the In-App Purchase API.
• The prices for auto-renewing subscriptions are set by us in the App Store Connect tool.
• You may find alternative subscription options, but they will adhere to the specified billing cycles.
• By subscribing to our Pro service, you agree to abide by these terms and conditions. If you have any questions or concerns, please contact our support team.

Duties of MSF Invest

• MSF Invest declares that it employs the necessary and adequate technical and administrative security measures to protect the data you share with us from unauthorized, unauthorized, and/or illegal access. You acknowledge that MSF Invest cannot be held in any way responsible for causes beyond its best efforts, economically reasonable, regarding the integrity, timeliness, and accuracy of such information.
• MSF Invest undertakes to make its best efforts to allow access to the Application 24 (twenty-four) hours a day, 7 (seven) days a week. Without prejudice to the interruption, limitation, or suspension of Application browsing for system updates or adjustments.
  • Despite all efforts by MSF Invest, access to the Application, like any Internet application, is not free of problems, caused by fortuitous events, internal or external, force majeure cases, or other cases not entirely subject to direct control by MSF Invest. In these conditions, you exempt MSF Invest from any claims, yours or third parties, regarding interruptions, interceptions, invasions, virus spread, or other illicit acts.

Intellectual Property

• All intellectual property rights related to the Application belong to MSF Invest, and you, as a user, are only granted the limited right to use the interface to enjoy the information and service provided by it.
• The Application may be temporarily suspended for maintenance reasons. You hereby declare that you agree with modifications, implementation of new features, tools, improvements, or corrections to the Application, and that these will also continue to be the sole and exclusive property of MSF Invest. Improper use of any content or trademarks of MSF Invest is prohibited.

Privacy

Details on how MSF Invest handles your personal data are listed in the Privacy Notice. By using the Application, as well as agreeing to these Terms of Use, you agree to MSF Invest's Privacy Notice and declare and accept that MSF Invest may collect and use data and personal information as outlined in said Notice, in accordance with Law No. 13,709/2018.

General Provisions

• These Terms constitute the complete agreement between You and MSF Invest regarding the use and services provided in the Application, replacing any previous negotiations, contracts, agreements, terms, or conditions regarding its object.
• If any clause of these Terms is deemed invalid, void, or annulable by a competent judicial decision, the parties agree that all other terms and conditions of these Terms of Use will remain valid and effective.
• Tolerance for the breach of any duties outlined in these Terms or in applicable legislation does not imply a waiver by MSF Invest of the exercise of its respective rights.
• The Parties choose the Forum of the Judicial District of Salvador/Bahia as the only competent authority to resolve any disputes and/or claims that may involve the Parties in relation to the Application.