Lubanco Advisory sets forth in its Terms of Use the conditions of use of its Site through which the User may access the content made available by Lubanco Advisory.

‍

1. DEFINITIONS

For the purposes of these Terms of Use, the following definitions apply:

1.1. Internet Protocol Address (IP Address): the code assigned to a terminal on a network to enable its identification, defined according to international parameters.

1.2. Internet: the system consisting of a set of logical protocols, structured worldwide for public and unrestricted use, in order to enable data communication between computers, notebooks, netbooks, smartphones, tablets and any other devices that connect to the internet through different networks.

1.3. Privacy Policy: the privacy policy of Viera Rezende, which governs the processing of data and personal information of Users and is available on the Site.

1.4. Site: Lubanco Advisory's website through which the User accesses the contents made available by Lubanco Advisory.

1.5. User(s): all persons who in any way interact with Lubanco Advisory, receive information from Lubanco Advisory, access or use the Site or use, directly or indirectly, the services of Lubanco Advisory.

‍

2. ACCEPTANCE OF TERMS OF USE

By accessing the Site, the User fully agrees and accepts the provisions of these Terms of Use. If you do not agree with any of the provisions contained in these Terms of Use, we recommend that you do not use and/or access the Site. The Privacy Policy is an integral part of these Terms of Use.

3. PRIVACY

3.1. Personal Information: Personal Information is information that Lubanco Advisory collects about you that enables us to identify you. Types of Personal Data include:
i. user's name;
ii. your e-mail address;
iii. user's telephone number;
iv. information about Users' use of our Site (some information may be collected automatically, such as IP Address, unique mobile device identifier, browser type, browser language and access times); and
v. it is also possible to automatically collect the User's location, provided that this permission is enabled on the User's mobile device.

3.2. Lubanco Advisory's Commitment When Collecting Personal Data: Lubanco Advisory is committed to complying with the regulations applicable to all of the personal data processing it performs. More specifically, Lubanco Advisory undertakes to observe the following principles:
i. your Personal Data are processed lawfully, fairly and transparently (principles of lawfulness, fairness and transparency);
ii. your Personal Data are collected for specified, explicit and legitimate purposes as set out in the Privacy Policy and will not be further processed in a way incompatible with those purposes (purpose limitation principle);
iii. your Personal Data are kept in a proper and relevant manner and are limited to what is necessary to fulfill the purposes for which they are processed (principle of data minimization); and
iv. your Personal Data are correct, up to date and all reasonable steps are taken so that data that are incorrect in light of the purposes for which they are processed are erased or rectified without delay (principle of inaccuracy).

3.3. Ways of Collecting Personal Data on the Site: Lubanco Advisory may collect the information of Users of the Site in the following ways:
i. through the User's own registration on the Site; and
ii. through the use of cookies or other technology to store information about User browsing on the Site.

3.4. Use of Collected Information: User information is collected, stored, handled, processed and used by Lubanco Advisory for the following purposes:
i. to develop, maintain and improve the features and functionality of the Site;
ii. analyzing Site performance, measuring Site audience, tracking Users' Site browsing habits, how they arrived at the Site (for example, through links from other sites, search engines or directly from the address), evaluating statistics related to the number of visits to and use of the Site, its features and functionality; and
iii. improve Users' browsing experiences with the Site.

3.5. Non-sharing of Personal Data: Lubanco Advisory preserves the privacy of Users and does not share the Users' Personal Data with third parties, except upon consent of the User himself/herself, court order and obligation provided for in the legislation in force.

3.6. Responsible for the collected data: In order to ensure the proper application of the rules about data privacy and, in accordance with the provisions of the relevant data protection legislation - Law 13,709 of 2018, called the General Data Protection Law -, Lubanco Advisory has designated the chief operating officer of Lubanco Advisory as the data protection officer. Lubanco Advisory carries out appropriate internal procedures aimed at safeguarding compliance with these rules within its organization.

3.7. Period of Use of Collected Information: Lubanco Advisory undertakes to keep Personal Data for a period no longer than required to fulfill the purposes for which they are processed. In addition, Lubanco Advisory stores Personal Data in accordance with the storage periods required by applicable law.

3.8. Image: In the event that the User considers that there are facts or circumstances that constitute illegal activity in the use of any content accessible through this Site and, in particular, that represent the violation of intellectual property rights, personality rights or other rights, he/she must send a communication to Lubanco Advisory via e-mail to contato@lubancoadvisory.com containing the following data:
i. personal information: name, address, telephone number and e-mail address of the complainant;
ii. specification of the alleged unlawful activity that has occurred on the Site and, in particular, in the case of alleged copyright infringement, precise and complete indication of the protected and allegedly infringed content;
iii. facts and/or circumstances that would indicate that the use constitutes an infringement of the alleged rights; and
iv. Lubanco Advisory reserves the right to remove, in its sole discretion and at any time, all content from the Site, regardless of prior notice.

‍

4. VIOLATIONS

You may not engage in the following actions because of or through your use of the Site:
i. practice of any unlawful acts and/or violation of current legislation;
ii. threat, coercion, physical or moral embarrassment to other Users;
iii. infringement of third parties' rights;
iv. violation of the rights of secrecy and privacy of others;
v. acts that cause or favor the contamination or damage of any Lubanco Advisory and/or third party equipment, including by means of viruses, trojans, malware, worms, bot, backdoor, spyware, rootk it, or any other devices that may be created;
vi. perform any acts that directly or indirectly, in whole or in part, may cause damage to Lubanco Advisory, any User and/or any third party; and
vii. use any corporate name, trademark, domain name, slogan or trade dress or any other distinctive sign or intellectual property owned by Lubanco Advisory.

‍

5. RESPONSIBILITIES

5.1. The User is solely responsible:
i. for any and all acts or omissions performed by him/her from his/her access to the Internet and/or Site; and
ii. for making good any and all damages, direct or indirect, that are caused to Lubanco Advisory, any other User, or any third party as a result of your failure to comply with these Terms of Use or any act performed from your access to the Internet and/or Web Site.

5.2. In no event will Lubanco Advisory be liable:
i. for any act or omission performed and/or damage caused by the User arising from their access to the Site;
ii. for the misuse of the Site by any User;
iii. system failures, technical impossibilities or unavailability; and
iv. the installation of viruses, trojans, malware, worms, bot, backdoor, spyware, rootkit, or any other devices that may be created as a result of User's internet browsing on the Site.

5.3. If you breach any provision of these Terms of Use or the law, without prejudice to other remedies, Lubanco Advisory may, by itself or by a third party, at any time take such action as it deems necessary to enforce these Terms of Use and for the proper functioning of the Site. Such action may be taken in Lubanco Advisory's sole discretion, without any notice or prior or subsequent notification to any User or any third party, by any means or in any manner, without prejudice to initiating appropriate legal action, or suspending or limiting access to the Site.

‍

6. RIGHTS OF THE DATA SUBJECT

6.1. In accordance with applicable legislation concerning the protection of personal data, the data subject may at any time exercise their rights to rectification and deletion of data concerning them, as well as their rights to limitation and opposition to the processing and portability of their personal data.

6.2. All these rights are exercised by means of an e-mail to be sent to contato@lubancoadvisory.com. In this context, we request that the data subject attach to his/her request the elements necessary for his/her identification (last name, first name, e-mail address) as well as any other information necessary to confirm his/her identity.

6.3. Lubanco Advisory will cooperate as necessary to ensure the exercise of its clients' rights or to assist them with any questions or complaints.

‍

7. DATA SECURITY

Ensuring the security and confidentiality of User Personal Data is a priority for Lubanco Advisory. Accordingly, all appropriate technical and organizational measures have been implemented, taking into account the nature, scope and context of the personal data that are extracted from our Site and/or by means of other technologies and the risks involved in processing them, in order to preserve the security of your personal data and, more particularly, to prevent any accidental or unlawful destruction, loss, alteration, disclosure, intrusion or unauthorized access to such data.

‍

8. CHANGES TO ACCESS AND TERMS OF USE

Lubanco Advisory reserves the right to adapt the Personal Data protection policy and undertakes to communicate on its Site any changes or additions.

‍

9. INTELLECTUAL PROPERTY

9.1. Lubanco Advisory is the copyright owner of all content made available on the Site, as well as of all intellectual property rights and related rights, including but not limited to database rights, trademarks, applications for registration, etc.

9.2. Unless the User has the express written permission of Lubanco Advisory, the User shall not use the name, trademark or logo belonging to Lubanco Advisory.

9.3. You are not permitted to download, print, temporarily store, retrieve and display information from the Site on your computer screen or mobile device, print pages (but not copy) and store such pages in electronic form on your computer or mobile device for your personal use or for internal use within your organization.

9.4. You are not permitted (unless you are given express permission) to adapt or modify the information contained on this Site or any part of it and the information or any part of it may not be copied, reproduced, republished, downloaded, posted or otherwise transmitted to any third party for commercial gain.

‍

10. LAW AND JURISDICTION

These Terms of Use are governed in accordance with Brazilian law. Any disputes or controversies arising from any acts performed in connection with the use of the sites and/or applications by Users, including in relation to the breach of the Terms of Use or the violation of the rights of Lubanco Advisory, other Users and/or third parties, intellectual property rights, confidentiality and personality, will be processed in the Courts of the Capital of the State of Rio de Janeiro.