WEBSITE PRIVACY POLICY

Comporta Family Office Ltda. respects the privacy of its users and is committed to protecting the personal data collected through its website. This Privacy Policy explains how the collection, use, storage, and protection of user information is carried out, in accordance with the General Data Protection Law (Law No. 13,709/2018 – LGPD).

1. Definitions Company:

Comporta Family Office Ltda. and its affiliated companies within its economic group. User: A natural person who accesses or uses the Website, aged 18 (eighteen) years or older, emancipated, or duly represented or assisted. The Company's activities do not presume the processing of Personal Data from children or adolescents, and such data are not intentionally collected. If this occurs, the Company will take appropriate measures for their protection, always in compliance with applicable legislation. Personal Data: means any information provided and/or collected by the Company and/or its affiliates on the Website that: (i) identifies, or that, when used in combination with other information processed by the Company, identifies an individual; or (ii) through which the identification or contact information of a natural person can be derived. Website: The Company's institutional website.

2. Collection of Personal

Data The Company collects the following Personal Data from the User through the contact form available on the Website:

• Full name
• Email
• Phone number
• Content of the message voluntarily sent by the user

The User is aware of, understands, and agrees that providing data on the Website is voluntary, with the purpose of enabling direct contact with the Company.

3. Purpose of Processing

The Personal Data collected are used for the following purposes:

I. To enable communication with the User and respond to questions, comments, or requests; II. To provide information about the Company's services and maintain relationships with clients and interested parties; III. To send institutional communications, advertising, emails, marketing campaigns, phone contacts, SMS messages, messaging apps, or social networks; IV. To conduct recruitment and selection processes; V. To comply with legal, regulatory, administrative, or judicial obligations, always observing the principles of the LGPD, the rights of the data subjects, and the legitimate interests of the Company.

4. Data Sharing

Personal Data will not be sold, rented, or shared with third parties, except: (i) when necessary to comply with legal obligations or to protect the Company's interests in any type of conflict, including administrative and judicial demands; (ii) with the User’s express consent; (iii) third parties contracted for operational support (e.g., website hosting), who follow confidentiality and data protection obligations.

5. Storage and Security

Personal Data is stored securely, in a controlled environment, with the adoption of appropriate technical and administrative measures to prevent unauthorized access, loss, alteration, or improper disclosure.

Although the Company adopts security measures compatible with the nature of the Personal Data it processes and with the best practices available in the Brazilian market, the Company cannot guarantee total security of this data, as it is subject to technical failures or malicious actions by third parties, given the nature of current information technologies.

The User understands and exempts the Company and the Website from any liability for exclusive fault of third parties, such as in cases of hacking or cracking attacks, exclusive fault of the User, as well as if the User themselves transfers Personal Data.

6. Your Rights

Under the LGPD, the User has the right to:

• Confirm the existence of data processing;
• Access their own Personal Data;
• Correct incomplete, inaccurate, or outdated data;
• Request the deletion of their data, when applicable;
• Revoke consent at any time.

To exercise these rights, the User must contact: [email protected]

The Company reserves the right to retain data to comply with legal or regulatory obligations, to transfer data to third parties when expressly authorized by law, provided that data processing requirements are respected, as well as for the exercise of rights in judicial and administrative processes.

7. Cookies

The Website uses cookies and similar technologies to improve users’ browsing experience, understand access patterns, and personalize content. The use of these technologies is based on the User’s consent, collected through the preference management platform AdOpt. Data collected by cookies on the Website may be shared with third-party companies for traffic analysis, User behavior, and browsing reports; for remarketing and ad personalization; for campaign analysis, targeting, and ad optimization. These third parties may operate servers outside Brazil, which may involve international data transfer.

Cookies are small files stored on the device when the User visits a website. They may contain information about browsing, preferences, or device. Types of cookies the Website may contain:
 

• Essential: Necessary for the basic operation of the Website;
• Performance: Help understand how visitors interact with the Website;
• Functionality: Allow remembering User preferences;
• Marketing: Used to provide more relevant content.

Data that may be collected by cookies: IP address, browser type and operating system, pages accessed, duration of visit, language preferences, information about clicks, and browsing behavior.

The User can accept or reject the use of cookies at any time via the "My options" button displayed on the cookie banner when accessing the Website.

8. Changes to this Policy

The Company may update this Privacy Policy periodically. It is recommended that the User consult this document whenever using the Website.

9. Contact

For any questions regarding this Privacy Policy or Personal Data, the User can contact: [email protected]