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<div id="termo-tradersclub">
    <p>How and why we treat users' personal data</p>
    <h3>Privacy Notice</h3>
    <p>Updated on September 30, 2020.</p>
    <p>This Privacy Notice is intended for users of the website, mobile app, and other electronic properties (“Platform”), made available by TC Traders Club S.A. and its affiliated companies (“TC”).</p>
    <p>For the purposes of this Privacy Notice, users of the Platform are defined as “Customers”</p>
    <p>Through this Privacy Notice, Customers are informed:</p>
    <blockquote>
        <p>
            a) About what personal data is handled by TC;<br/>
            b) For what purposes and for how long personal data are handled by TC;<br/>
            c) With whom personal data may be shared;<br/>
            d) What the Customers’ rights are in relation to the handling of their personal data; and<br/>
            e) About the channel to be used by Customers for the exercise of their rights as personal data subjects.
        </p>
    </blockquote>
    <p>In general, TC is the controller of personal data and makes decisions regarding the handling of personal data under the terms of this Privacy Notice.</p>
    <br/>
    <h3>1. Document control and storage</h3>
    <p>TC may collect the following personal data from its Customers:</p>
    <blockquote>
        <ul>
            <li>Full name;</li>
            <li>Signature;</li>
            <li>Date of birth;</li>
            <li>Nationality;</li>
            <li>Landline and cell phone number;</li>
            <li>Marital status;</li>
            <li>Full address and proof of address;</li>
            <li>Email address;</li>
            <li>Identity card (RG) data and images;</li>
            <li>Data and images from the registration of individual taxpayers;</li>
            <li>Social Security Number (CPF);</li>
            <li>Data and images of the National Driver’s License (CNH);</li>
            <li>Carrier’s vehicle data, including</li>
            <li>owner’s information;</li>
            <li>Copy or numbers of other government identification documents;</li>
            <li>Personal data contained in articles of incorporation and powers of attorney;</li>
            <li>Organization or company to which they belong or are registered with and related information;</li>
            <li>Position or job title;</li>
            <li>Contract information;</li>
            <li>Geolocation data when using the App;</li>
            <li>Photographs collected for the security systems of TC;</li>
            <li>Information on personal and professional history and, as permitted by law, criminal records;</li>
            <li>Banking and financial information, including credit card data;</li>
            <li>Credit information;</li>
            <li>Technical information, such as the IP address,</li>
            <li>Device identification, location data (based on the IP), information about cookies, when the Customer accesses the website or other electronic properties of TC; and</li>
            <li>Communication, verbal or written, maintained between the Customer and TC.</li>
        </ul>
    </blockquote>
    <p>Please note that in certain situations, such as prospecting Customers or in compliance with the best practices and anti-corruption regulations, TC may also obtain your personal data from other sources, such as on public websites or through background check providers, in strict compliance with applicable data protection laws and regulations.</p>
    <br/>
    <h3>2. Purpose and duration of data handling</h3>
    <p>TC performs customer data handling activities in a transparent manner and for lawful and specific purposes, as listed below:</p>
    <blockquote>
        <ul>
            <li>To allow you to navigate the Platform, including aggregated or non-aggregated analysis of Customer behavior, identifying issues and making improvements to the Platform, personalizing resources and monitoring security;</li>
            <li>To allow the provision of the services offered by TC, registration, feasibility of transactions, permission and feasibility of contract signing;</li>
            <li>To respond to requests and contacts, receive complaints, investigate reports or respond to requests from Customers and other subjects involved in the operation;</li>
            <li>To establish contacts between TC and Customers, including to guarantee the fulfillment of obligations;</li>
            <li>To allow the provision of assistance and ancillary services possibly related to the contracts established with Customers;</li>
            <li>To manage the relationship with Customers, including through communication using available means, direct marketing, advertising and promotional actions;</li>
            <li>For marketing and advertising purposes of TC services, including targeted advertising based on behavior, consumption and/or location profile;</li>
            <li>To conduct satisfaction surveys or other polls;</li>
            <li>To verify the Customer’s identity;</li>
            <li>For the legal exercise of TC rights, including in contracts and legal, administrative or arbitration proceedings, as well as for compliance with legal obligations;</li>
            <li>To prepare responses to authorities in the context of judicial or administrative proceedings, in compliance with legal, regulatory or any other lawfully required matters by TC, or in defense of its legitimate rights and interests;</li>
            <li>To carry out activities to prevent fraud and illegal activities, including measures to protect TC, Customers and/or third parties; and </li>
            <li>For credit protection.</li>
        </ul>
    </blockquote>

    <p>TC undertakes to maintain personal data as necessary to meet the aforementioned purposes and to delete personal data when possible and as reasonably required, in compliance with the Brazilian data protection law.</p>
    <p>If the Customer has any questions about TC’s personal data retention and deletion practices, he or she may contact the communications channel with personal data subjects by sending an email to <a href="mailto:infosec@tradersclub.com.br">infosec@tradersclub.com.br</a>.</p>
    <br/>
    <h3>3. Personal data sharing</h3>
    <p>TC may share your personal data with third parties only to the extent strictly necessary to meet the purposes listed in this Privacy Notice and according to one or more of the following situations:</p>
    <blockquote>
    <ul>
        <li>If the third party in question is one of TC’s parent companies, subsidiaries or affiliates;</li>
        <li>If the third party in question is a service provider or business partner, handling personal data on behalf and in the interests of TC, as personal data operator or controller, upon strict compliance with applicable law;</li>
        <li>If the third party in question is an official public body or entity, regulatory agency, law enforcement agency or governmental authority, requesting information legitimately in the context of regular legal inspections, audits, processes or procedures that constitute binding legal obligations with TC, or when it is reasonably necessary to protect the rights of TC, Customers and/or third parties;</li>
        <li>When TC has obtained the Customers’ unrestrained, unambiguous and express consent for data sharing.</li>
    </ul>
    </blockquote>
    <br/>
    <h3>4. Security and place of data handling</h3>
    <p>TC undertakes to adopt and maintain reasonable security, technical and administrative measures to prevent irregular or unlawful processing of Customers’ personal data, including unauthorized data access, destruction, loss, change or communication.</p>
    <p>All TC employees are subject to confidentiality obligations. Furthermore, TC updates and tests its security systems to protect personal data, according to the best practices.</p>
    <p>Customers’ data handling activities may be performed outside Brazil. Although other countries may have data protection levels different than those adopted in Brazil, TC will adopt safeguards, including contractual safeguards, to maintain customer rights, confidentiality, integrity and information security.</p>

    <h3>5. Rights of Personal Data Subjects</h3>
    <p>The following rights of the personal data subject may be exercised at any time, in accordance with applicable law, by Customers upon request:</p>
    </p>
    <blockquote>
        <ul>
            <li>Confirmation of the existence of personal data handling;</li>
            <li>Access to personal data;</li>
            <li>Correction of incomplete, inaccurate or outdated personal data;</li>
            <li>Anonymization, blocking or deletion of unnecessary and excessive data, or data handled in non-compliance with Brazil’s General Data Protection Law (LGPD);</li>
            <li>Portability of personal data to another provider of services or products, subject to regulation of the Brazilian authority;</li>
            <li>Deletion or anonymization of the personal data processed based on the Customer’s consent, except when the law authorizes the maintenance of this data on another basis;</li>
            <li>Information on publicly and privately held entities with which TC has shared Customers’ personal data;</li>
            <li>Information about the possibility of not authorizing the handling of personal data and the consequences of this action; and</li>
            <li>Revocation of consent, when processing has been made based on the data subject’s consent.</li>
        </ul>
    </blockquote>
    <br/>
    <h3>6. Exercise of data subject’s rights</h3>
    <p>TC will facilitate the exercise of rights by data subjects, whenever possible and in accordance with the law.</p>
    <p>TC has a specific communication channel to manage communications with data subjects and enable the exercise of their rights.</p>
    <p>Os Clientes poderão fazer qualquer reclamação, solicitação ou pedido de informação relacionado ao tratamento de seus dados pessoais, inclusive para o exercício dos direitos de titular de dados indicados no presente Aviso de Privacidade e garantidos pela legislação nacional, através do e-mail infosec@tradersclub.com,br, aos cuidados do encarregado de dados da empresa (DPO).</p>
    <p>Customers may make any complaint, demand or request for information related to the handling of personal data, including for exercising the data subject rights indicated in this Privacy Notice and guaranteed by Brazilian law, by sending an email to <a href="mailto:infosec@tradersclub.com.br">infosec@tradersclub.com.br</a>, to the attention of the Company’s Chief Data Officer (CDO).</p>
    <p>When Customers contact TC to exercise their data subject rights, TC may collect information for the purposes of confirming the data subject identity, to the extent of its interest and for security purposes.</p>
    <br/>
    <h3>7. Updates to the privacy notice</h3>
    <p>This Privacy Notice may be updated from time to time.</p>
    <p>All changes shall be considered immediately effective, except in the case of a communication to the contrary sent by the TC to the data subjects. TC will take reasonable steps to notify its Customers about updates in the Privacy Notice terms.</p>
</div>

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