1. INTRODUCTION

1.1 Sinai Alliance Trade, registered under CNPJ nº 51.048.948/0001-58, respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we use and protect your personal data and about your privacy rights in accordance with the General Data Protection Law (Law No. 13.709/2018).

1.2 By accessing and using the website and/or application of Sinai Alliance Trade (hereinafter “we,” “us,” “our,” “bank,” or “Sinai Alliance Trade”), you (“user”) agree and accept, without reservation, the provisions of these terms of use.

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 number, email;

2.1.2 Financial information: such as bank account details, information about transactions 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 settings, 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 on your browser or device by websites, applications, online media, and ads.

4. HOW WE USE YOUR DATA

4.1 We use your data to:

4.1.1 Provide financial services to you;

4.1.2 Comply with 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, comply with legal obligations, or with your consent.

6. DATA SECURITY

6.1 We implement security measures to protect your personal data. However, the transmission of information over the internet is not completely secure, and while 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 Under 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 file.

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 oppose the processing of your personal data under certain circumstances.

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

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

8. CHANGES TO THE 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 published on our website. We recommend that you review regularly to stay 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 rights of 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, the visitation of which is limited to the contents expressly offered. The User is prohibited from:

10.1.1 Accessing programming areas;

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

11. PROHIBITIONS

11.1 The User may not engage in the following actions as a result of or through the use of our website and/or application:

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

11.1.2 Acts contrary to morals and good customs;

11.1.3 Violating the rights of third parties;

11.1.4 Violating the rights of confidentiality and privacy of others;

11.1.5 Acts that cause or promote contamination or harm any equipment of Sinai Alliance Trade and/or third parties, including through viruses, trojans, malware, worms, bots, backdoors, spyware, rootkits, ransomware, or any other malicious codes;

11.1.6 Committing any acts that directly or indirectly, in whole or in part, may cause harm to Sinai Alliance Trade, any User, and/or any third parties.

12. BREACH OF TERMS OF USE

12.1 If the User breaches any provision of these Terms of Use or legal provisions, without prejudice to other measures, Sinai Alliance Trade may, at any time, at its sole discretion, take appropriate legal measures, suspend or limit access to the website and/or application, terminate the account of any User and/or take other actions it deems necessary to ensure compliance with these Terms and the proper functioning of the website and/or application.

13. LIMITATION OF LIABILITY

13.1 We are exempt from liability in the event our website and/or application remain offline, temporarily for maintenance, or due to damage, loss, or any nature caused by system performance failures, error, omission, interruption, defect, or delay in operation or transmission, viruses, trojans, malware, worms, bots, backdoors, spyware, rootkits, or any other devices that may be created as a result of the User’s navigation on the Internet or failure of the line or system, server or internet connection, even if we have been advised of the possibility of such damages, losses, or expenses.

13.2 We are not responsible for the misuse of information, instruments, materials provided and/or equipment used by our website and/or application for any purpose, made by any User, being the sole responsibility of that User for any injury to their own rights or those of third parties, caused or not by that improper use.

13.3 We are not responsible for the content of other websites that may be available on our website’s pages, or for which this website’s address is available. It is the User’s duty to read the Terms of Use, the External Privacy Notice, and other legal documents of the websites accessed through external links contained on our website and/or application, as well as to act according to what is stated 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 under confidentiality obligations. For more information, please consult our External Privacy Notice.

14.2 The login and password may only be used by the registered User, and sharing login and/or password with any third parties is expressly prohibited. The User assumes full responsibility for safeguarding, confidentiality, and proper use of the registered login and password, releasing Sinai Alliance Trade from any responsibility. Furthermore, if any abnormal access or transaction pattern is identified from this User, the information security team or related areas of Sinai Alliance Trade will take appropriate measures to verify the occurrence, which may include temporarily rejecting access without prior notice to the User.

14.3 The User is responsible for the accuracy and truthfulness of the data provided, and acknowledges that inconsistencies 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, instruments, page organization, graphics, images, videos, and designs, belongs to Sinai Alliance Trade or third parties who have lawfully granted their usage rights, 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 business name, trademark, domain name, slogan, or advertising expression, or any distinctive sign or intellectual property owned by Sinai Alliance Trade.

16. GENERAL PROVISIONS

16.1 The tolerance of Sinai Alliance Trade regarding any eventual non-compliance with any provisions of this Agreement by any Client will not constitute a waiver of the right to demand compliance with the obligation, nor forgiveness, nor alteration of what is stated herein.

16.2 This Agreement is governed by Brazilian legislation. Any disputes or controversies arising from any acts performed in the context of the use of Sinai Alliance Trade’s services by Clients, including regarding the breach of this Agreement or the violation of the rights of Sinai Alliance Trade, other Clients, and/or third parties, including intellectual property rights, confidentiality, and personality rights, will be processed in the Capital District of the State of Paraná.

16.3 Transactions conducted electronically by the Client will be accepted and valid as an effective means of proving authorship, authenticity, integrity, and confidentiality, and if conducted by phone, may be recorded. The use of tokens, with the indication of a numerical code, the option of Alerts (PUSH), for your mobile phone, security phrases, cellular mobility services geolocation, and the biometric identification of your mobile phone may be used as methods for validating and authenticating transactions made by the Client.

16.4 To resolve any doubts and/or issues related to the use of Sinai Alliance Trade’s services, contact your Account Manager and, if you are not yet our client, use the customer service number provided. If the issue persists, contact our Ombudsman using the provided service number. For questions related to the Privacy Policy, please consult the contact channel available in that document.