Privacy & Data Treatment Policy

Purpose

This Privacy and Data Treatment Policy aims to demonstrate how São Pedro Capital (“São Pedro Capital” or “we”) collects, uses and, when applicable, shares your information, always with the commitment to protect your privacy and your Personal Data, establishing the rules on Data Processing, as well as explaining what your rights are and how to exercise them, pursuant to Law 13.709/18 – General Data Protection Law (“LGPD”).

It is important that you read this information about privacy along with any other notice of privacy or processing that eventually we provide on specific occasions when collecting or processing your personal data so that you can be fully aware of how and why we use your data. This privacy notice complements other notices and does not replace them.

We can change this Privacy Policy periodically. If we make changes, you will be informed through the new date indicated at the end of this document, and in some cases, we can provide you with an additional notice (for example, adding a statement to the home page of this website or sending a notice e-mail).

This Policy applies to all investors, employees, partners, or persons who have a relationship with São Pedro Capital, as well as all visitors to this website.

Definitions

(i) Cookies: This website uses various technologies such as cookies, as described below, in order to collect information that helps São Pedro Capital to understand how the website is used. Specifically, when a visitor uses the website, São Pedro Capital may automatically collect multiple statistical data for use of the website, which can be analyzed to improve web design and functionality, increase São Pedro Capital ability to serve investors and their accounts and customize its communications to investors regarding products and services.

A “cookie” is a small file of letters and numbers stored on the computer, tablet, mobile phone or other device of a user when visiting a website. Cookies contain information that is transferred to a device or read on it, allowing websites to recognize such devices and store certain information such as user preferences.

If you do not feel comfortable with the idea that your data are being used in this way, most computer systems and browsers offer settings and privacy options such as disabling cookies or option for the “Do not Track” feature. This website does not cancel the operation of these settings or options. However, if you do not want to provide such information through the website or if you choose to use the above-mentioned privacy features in your computer system or browser, you may not get certain content, features, services, products or benefits of this website.

The use of Cookies by SÃO PEDRO CAPITAL does not identify individual website visitors for third parties or allows third parties to collect personal identification information about their online activity during the time you visit non-affiliate websites.

(ii) Personal Data:  is the information related to the natural person that makes it possible to identify him directly or indirectly. Personal data are considered: name, ID, CPF, gender, date and place of birth, telephone, home address, location via GPS, photo portrait, health record, bank card, income, payment history, consumption habits, leisure preferences; IP address (Internet Protocol) and cookies, among others.

(iii) Sensitive Personal Data: is any data on racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical, or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person and are subject to specific treatment conditions.

(iv) Data Protection Officer: natural or legal person appointed to act as a communication channel between the company São Pedro Capital, the holders of personal data and the National Data Protection Authority (ANPD).

(v) Data Owner: is the natural person to whom the Personal Data that are the object of processing refer.

(vi) User: People who access the website and/or interact with the activities offered on it.

Information Security

São Pedro Capital restricts access to data collected about you from this website to employees, agents, contractors and third parties who have a commercial need to become aware of such information. To protect your personal data, we have deployed security measures compatible with industry practices and standards for an investment company like ours to prevent your personal data from being accidentally lost or used or accessed without authorization, changed or disclosed.

To protect your privacy and protect your personal data, São Pedro Capital has a governance program that contains rules of good practices, internal policies, and procedures, which establish organizational conditions, training and mechanisms for supervision and risk mitigation related to the Processing of Personal Data. São Pedro Capital Policies are available on this website.

Information Collection

a) Personal data collected automatically

We collect certain information about you automatically when you access or use this website, including data about your use, such as the type of browser, access times, pages viewed and your IP address.

We may use this information collected about users for a variety of purposes, such as improving our website and your online experience, understanding which areas and features of our website are popular, counting visits, customizing our communications to suit visitors, as well as for other internal business purposes.

b) Personal data provided by the holder

The information eventually collected and shared with São Pedro Capital by users will be used exclusively for: (i) identification of potential investor contact; (ii) sensitive data will not be collected on this website; (iii) the data will not be used for commercial purposes and will not be shared with third parties for commercial purposes; (iv) the data may be accessed by third parties hired by São Pedro Capital to meet legal and regulatory requirements.

São Pedro Capital handles personal data of those who have or had any relationship with the company, were or are a partner, director, or employee, and may even share this data with service providers hired for accounting services, with the sole purpose of complying with legal labor and tax obligations. The managing partners may have their personal data shared with companies that São Pedro Capital intends to relate to in compliance with money laundering prevention rules.

c) Investment opportunities

The use of your personal data provided to us about a particular investment opportunity shall be governed by the privacy policy contained in the subscription agreement and related documents.

Sharing of Information

São Pedro Capital may share data about you collected from this website:

(a) within São Pedro Capital, as permitted by law, to promote and develop our services,

(b) with non-affiliates that provide services for São Pedro Capital, such as fund administration, risk analysis and logical analysis of data for use to the provision of such services,

(c) when the disclosure is necessary or recommended according to some law, rule, regulation, decree or international, federal, regional, state or local policy, and this disclosure is not prohibited by law, rule, regulation, decree or policy or,

(d) for fraud prevention and analysis considering the Laws for the Prevention of Money Laundering and Terrorism and Anti-Corruption Financing,

(e) if you authorize or give us instructions to disclose such information.

(f)  São Pedro Capital may transfer data about you collected from this website in relation to, or during negotiation of, any merger, funding, acquisition, bankruptcy, dissolution process, or any other operation or process involving the sale, transfer or divestiture of all or part of São Pedro Capital business or assets.

Notwithstanding the above, São Pedro Capital may freely share aggregated or unidentified information, which cannot be used to identify you with third parties.

Rights of Owners

In compliance with applicable regulations with regard to the processing of personal data, São Pedro Capital respects and ensures you the possibility to submit requests based on the following rights:

i) Confirmation of the existence of processing;

ii) Access to data;

iii) Correction of incomplete, inaccurate or outdated data;

iv) Anonymization, blocking or deletion of unnecessary, excessive or processed data in disagreement with the law;

v) Portability of data to another service provider or product, at the express request of a User;

vi) Deletion of processed data with User consent;

vii) Obtaining information on public or private entities with which São Pedro Capital has shared personal data;

viii) Information on the possibility of non-consent of a User and to be informed about the consequences in case of denial;

ix) Withdrawal of consent.

The above rights may be exercised through a formal request to contato@saopedrocapital.com.

If you request the deletion of your Personal Data, it is possible that they will not be deleted promptly, in compliance with article 16 of the General Law on Personal Data Protection, which allows the processing of data for an additional period, including to comply with a legal obligation or regulatory.

Retention of Collected Information

The Personal Data collected and activity records are stored in a secure and controlled environment, and may be on our servers located in Brazil, as well as in an environment of use of resources or cloud servers, which may require transfer and/or processing of your Data outside Brazil.

These transfers only involve companies that demonstrate compliance with applicable laws, maintaining a similar or stricter Compliance level than that provided for in Brazilian law.

We store Personal Data only for as long as is necessary to fulfill the purposes for which it was collected or to comply with any legal, regulatory or rights preservation obligations.

After the maintenance period and the legal requirement, the Personal Data will be deleted using safe disposal methods or used anonymously for statistical purposes.

Consent

It is with your consent that we process your personal data. Consent is the free, informed, and unambiguous expression by which you authorize São Pedro Capital to process your data.

Thus, in accordance with the General Data Protection Law, your data will only be collected, processed and stored with prior and express consent.

Your consent will be specifically obtained for each purpose described above, evidencing São Pedro Capital’s commitment to transparency and good faith towards its users/clients, following the relevant legislative regulations.

By using the services of São Pedro Capital and providing your personal data, you are aware of and consent to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

At any time and at no cost, you may revoke your consent.

End of Data Processing

São Pedro Capital may keep and process personal data registered throughout the period in which they are relevant to regulatory compliance, in compliance with the rules established by the regulators and within the scope of the purposes listed in this term.

Questions

In case of questions about this privacy policy, including to exercise your rights, contact the Data Protect Officer at São Pedro Capital, Luciane Gomes, by e-mail: contato@saopedrocapital.com.br

 

São Paulo, July 2021.