Privacy Policy and Terms of Use

1. Introduction

Finner Soluções em Serviços Financeiros Ltda. ("Finner") values the privacy and security of its users' data. This document sets out the rules for the collection, use, storage, processing and protection of data, as well as the conditions for using our platform available at https://platform.finner.com.br.

2. Acceptance

By using the platform, the user declares that they have read and agreed to all the terms of this Privacy Policy and Terms of Use. If you do not agree, you must not access or use the platform.

3. Services Offered

Finner offers the following services:

• Registration of financial assets;
• Underlying asset validation;
• Portfolio management;
• Reconciliation of financial data.

4. Registration and Access to the Platform

Use of the platform is restricted to users affiliated with companies that have an active contract with Finner. Creating an account is required to access the services. Only previously authorized users may use the system.

5. Data Collected

During use of the platform, the following are collected:

• User identification data (e.g., name, work e-mail);
• Data related to financial assets, such as Cédulas de Crédito Bancário (CCBs — Bank Credit Notes) and equivalent documents;
• Access and browsing data through cookies and tracking tools.

6. Use of Data

The data is used to:

• Enable the operation of the platform;
• Validate and register financial assets;
• Ensure the security, integrity and traceability of operations;
• Comply with legal and contractual obligations.

7. Cookies and Tracking Technologies

We use cookies and tools such as Google Analytics to improve the user experience, analyze platform traffic and ensure its performance.

8. Data Sharing

Finner does not share personal data with third parties for commercial purposes. However, we engage third-party services for activities such as hosting, processing and information security, always respecting the principles of the LGPD (Brazil's General Data Protection Law).

9. Storage and Security

The data is stored on secure servers, using encryption, authentication and access control technologies. We employ information security best practices to protect data against unauthorized access.

10. Rights of Data Subjects

In compliance with the Lei Geral de Proteção de Dados (LGPD — Brazil's General Data Protection Law), users have the right to:

• Confirmation that processing exists;
• Access to the data;
• Correction of incomplete or outdated data;
• Deletion of data (within legal limits);
• Withdrawal of consent.

Requests must be sent to: admin@finner.com.br.

11. Usage Restrictions

The following is expressly prohibited:

• Using the platform for unlawful or fraudulent purposes;
• Accessing or attempting to access third-party data without authorization;
• Using the platform without a contractual relationship with Finner;
• Violating the internal rules of the contracting companies.

Non-compliance may result in the suspension or cancellation of access, without prejudice to any applicable legal measures.

12. Modifications

Finner may modify this document at any time. The new version will be published at https://www.finner.com.br and/or within the platform. We recommend reading it periodically.

13. Jurisdiction and Applicable Law

This document is governed by Brazilian law, in particular Lei nº 13.709/2018 (Law No. 13,709/2018 — the LGPD) and the Marco Civil da Internet (Brazilian Civil Rights Framework for the Internet). Any dispute will be settled in the courts of the district where Finner is domiciled, unless otherwise provided by contract.