Our confidentiality agreement includes provisions that we, as PixFx Company, stipulate for the information and services we provide to our valued investors. We request that you review this contract in detail.

Your privacy is very important to us. We are committed to protecting and respecting your personal data. This Privacy Policy explains how and when we will use your personal data, how we will keep it safe, and the types of personal data we collect about you when you choose to use our services. It also aims to help you protect your personal data and your rights.

It's important for you to check this page for any updates, as we reserve the right to make changes to our privacy policy periodically. The personal information we obtain is subject to our most current privacy statement. As changes made to this text are important, we would like to inform you that we may forward update notifications to our investors. If you are an employee or third-party service provider operating in the PixFx family, it will be ensured that your personal data, business policy, and contractual relationship are used in accordance with our other policies in the current position by communicating with our company.

In our aforementioned confidentiality agreement, the terms "our," "we," or "PixFx" refer to each group company within Ljubotinjskih junaka br Av. Gastão Sengés, 395 - Barra da Tijuca, Rio de Janeiro - RJ, 22631-280, Brasil, which is the address of our group companies due to the context's potency, unless otherwise stated.

Similarly, the terms "you," "your," or "yours" in this privacy policy refer to the names of our potential investors arising from the content's potency, unless otherwise stated.

When you use any of our communication channels to contact us or when you visit our website, you agree that you have read and understood the terms of this statement and that you understand how we process any personal data you share with us before becoming an investor.

With this policy, you agree that you understand how we obtain, store, process, share, and manage your personal data and rights throughout our business relationship and after the end of the customer relationship, including an update you will make after creating your account at PixFx.

About Us

This privacy policy applies to the data processing activities of data controllers within the PixFx group of companies at the following address: PixFx, Ljubotinjskih junaka br Av. Gastão Sengés, 395 - Barra da Tijuca, Rio de Janeiro - RJ, 22631-280, Brasil.

Collection and Storage of Personal Information

The personal information requested from our investors and potential investors acting in our company includes:

What types of personal information do we collect and store?
As part of our business, we collect personal data from clients and potential clients, including:

- Name, surname, and contact information
- Date of birth and gender information.
- Income and wealth information, including asset and liability details, account balances, transaction submissions, taxes, and financial statements.
- Occupation and employment details.
- Location data.
- Trading risk tolerance data and risk profile.
- Data for IP address, device characteristics, and trading experience.
- Bank account, e-wallet, and credit card information.
- Your visits to the PixFx website or PixFx apps; various details, including traffic data, location data, blogs, and other communication data.


Cookies

We use cookies to collect and store information about your use of the PixFx website. Cookies are small text files stored by the browser on your device's hard drive, and when you visit the PixFx website, they send back data to our web server that needs to be reloaded.

These cookies allow us to adjust your personal settings and load your personal preferences to enhance your experience. You can learn more about our cookies in the "Our Cookie Policy" section on the PixFx website.

Additionally, we keep records of your trading activities, including:

- Products you trade with PixFx Company
- Historical data about your investments
- Choices you make for a particular product or service
If you are an institutional investor, you must share additional information with us, such as company addresses, shareholders, directors, and executives, including additional personal information about shareholders and directors.

We reserve the right to request additional information as necessary to comply with our legal and regulatory requirements.

The aforementioned data: we obtain our services in various ways using our websites, account registration applications, demo registration forms, webinar registration forms, website cookies, and similar tracking technologies integrated into our website and applications.

Changes in news and information provided during our updates: we also have the right to access data about our investors through third-party marketing lists purchased from third parties, public sources, social media platforms, brokers and affiliates, bankers and credit card processors, subscription-based intelligence databases, and other third parties.

In addition to these, we may request personal data at certain intervals at our own request (for example, through market surveys, inquiries, or special offers).

If you do not wish to provide information that allows us to fulfill your request for a particular product or service, we may not be able to provide the requested product or service.

We may record any communication we have, electronically or by phone, about the services we provide to you and our relationship with you.

The above-mentioned records will be the exclusive property of our company and will provide proof of communication between the company and the investor. These phone conversations may be recorded without a tone warning or other notice. Additionally, please note that if you visit any of our offices or facilities, we may have CCTV cameras that will record your image.




With whom can your personal data be shared?
As part of the use of your personal information for the purposes described above, we may disclose your information to:

- Companies that provide financial services and others within the PixFx Group.
- Third-party app providers when using the PixFx apps, communication systems, and trading platforms used by third parties.
- Service providers and specialized consultants hired to provide administrative, IT, analytical, optimization, online marketing, financial, regulatory, compliance, insurance, research, or other services.
- Brokers with whom we have a reciprocal relationship and those who provide promotional services to their affiliates.
- Payment service providers and banks that process your transactions.
- Auditors, consultants, or contractors overseeing any of our business objectives.
- Agreements with law enforcement agencies and government agencies responding to other regulatory requests, as required by law.
- Any third party for whom such disclosures are necessary to enforce our Terms of Service and other related agreements.
- Any person authorized by you.
- We strive to disclose to these third parties only the minimum personal data necessary to fulfill their contractual obligations. Our third-party service providers are not permitted to share or use the personal data we provide them for any purpose other than providing services to us.

Our websites or applications may contain links to third-party external sites. However, please note that third-party sites are not covered by this privacy statement and are not subject to our privacy standards and procedures.

You can check their pages to learn more about the privacy practices and procedures of third parties.

When and how do we obtain your approval?
We may process your personal information on behalf of one or more legal proceedings regarding the reasons and purposes determined by our company. The legal situations referred to as the legal basis are as follows:

- Compliance with contractual responsibilities to the investor
- Complying with legal and regulatory requirements
- To pursue our legitimate interests
- If any of the laws consisting of these three items are neglected when using the personal information of our investors, the approval of the investor is required. This permission will be given by the investor freely and voluntarily.
- The investor has the right to withdraw their consent at any time by contacting the company through the contact information of PixFx specified in this privacy policy.

Management of Personal Data

PixFx is committed to protecting the personal data transmitted, stored, or otherwise processed. We will implement and maintain appropriate technical and organizational measures to protect against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure and to ensure the level of security necessary to protect the personal data provided to us from access.

We have appointed a "Data Protection Officer" to ensure that the management of personal information complies with this privacy statement and applicable legislation. In addition to the Trading regulations, we assume that those who accept the confidentiality of this information, handle personal information, or receive such information will respect the right to privacy and comply with all relevant data protection laws and these privacy statements.

The data protection measures we have implemented include:

Our employees who handle personal information are trained in security measures that require them to implement these security measures. In these security measures, "firewalls" are applied, and our employees can only access the personal data necessary for the task they are performing.
Data encryption technologies are used during data transfer in Internet transactions.
Customer access codes transferred between networks using firewalls, intrusion detection systems, and virus checking tools are used against unauthorized persons and viruses entering our system.
When outsourcing electronic data, a clean desk policy is applied in all facilities providing secure storage for physical records, institutionally maintained by us and all our relevant institutions, using secure private networks or encryption.
Physical and electronic means, such as access cards, cameras, and guards, are used to protect against unauthorized access.



Retention Period of Personal Information

We keep personal data in a combination of secure computer storage facilities, paper files, and other records. When we determine that personal data is no longer needed, we will remove details that would identify the investor or securely destroy records. Additionally, it may be necessary to retain records for a significant period of time. For example, we are subject to investment services and anti-money laundering laws that require us to maintain copies and evidence of actions taken by our company regarding identity verification, income sources, transaction tracking, phone and chat communications, email, requests, and trading history. In addressing your complaints and records, we may demonstrate that we have complied with regulatory codes of conduct throughout the business relationship. These records must be kept for five years after the termination of our relationship with you, or longer if required by our regulators. When you opt out of receiving marketing communications, we will keep your information on our suppression list because we know you do not wish to receive such communications. The data we collect from you may be transferred and stored outside the European Economic Area (EEA). It may also be processed by personnel working outside the EEA who work for us or for one of our suppliers or affiliates. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. When we transfer your data to other third parties outside the EEA, we may, in some cases, rely on applicable standard contractual clauses, binding corporate rules, EU-US Privacy Shield, or other similar regulations. If you want a copy of such regulations, please contact us using the contact details below.

Investor Rights

While not valid in all circumstances, investor rights are as follows:
- Request access to personal data (commonly known as a "data subject access request")
- Request correction of the personal data that we hold about you
- Request deletion of personal data. However, we may not always comply with your request for deletion due to certain legal reasons, which will be communicated to you upon request.
- In the scope of your fundamental rights and freedoms, you may notify us of situations where you feel uncomfortable or believe that your personal data will be processed for reasons upon which we rely for a legitimate interest (or those of third parties).

You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

- Request restriction of processing of your personal data.
- This enables you to request that we suspend the processing of your personal data in the following scenarios:
- When you ask us to determine the accuracy of data that keep them, unless you need them to establish, exercise or defend legal claims.
- When you object to the use of your data. However, we need to verify whether it overrides the legal grounds for using it.
- To request the transfer of your personal data to you or to third parties. We will provide you or the third parties you choose with your personal data in a structured, commonly used, and machine-readable format.
- You should note that this right applies only to automated information (e.g., not printed copies) that you consented to use for you or that we used to enter into a contract with you.
- Withdraw your consent at any time to process your personal information.

Investor Complaints and Requests

We endeavor to respond to all requests within 1 (one) month. If the investor's request is complex or excessive, our response time may take longer than 1 (one) month. In this case, we inform our investor within 1 (one) month of receiving the request and keep them updated. We may charge a reasonable fee when a request is manifestly unfounded, excessive, or repetitive, or when we receive a request to provide more copies of the same data. In this case, we will send the investor a fee request that they must accept before processing their request. Alternatively, we may refuse to comply with the investor's request in these circumstances.