Privacy Policy and Personal Data Protection

In the course of our daily activities, it is necessary to collect personal data from our clients and potential clients. This enables us to provide products and services that are in line with the values, interests, and individual characteristics of each investor.

At Tailor Partners, we place utmost importance on the privacy and security of your information. Our main commitment here is to ensure transparency in the treatment of your personal data, whether when accessing our website or other associated platforms.

In this regard, our Privacy Policy and Data Protection (“Privacy Policy”) precisely outline the process of collection, use, and treatment of personal data carried out by Tailor Partners, always in strict compliance with the laws and regulations in force. Through this document, you can clarify which categories of data are collected, the reasons for collection, and the procedures that allow you to update and manage your personal data.

Therefore, our commitment lies in the protection and prioritization of the most valuable asset of all: you.

In compliance with data protection regulations, this Privacy Policy has been drafted in accordance with the following legislations:
a) Federal Law No. 12.965 of April 23, 2014 (Brazilian Civil Rights Framework for the Internet); and
b) Federal Law No. 13.709, of August 14, 2018 (Brazilian General Data Protection Law – LGPD).

This Privacy Policy is automatically effective for all those who use the services, access the website, or relate to Tailor Partners and constitutes acceptance of this Privacy Policy.

Tailor Partners reserves the right to modify the content of this Privacy Policy at any time, making its updated version available on its website www.tailorpartners.com.br.

I. Personal Data Collected

“Personal data” refers to any information related to you that identifies you or allows you to be identified. Tailor Partners processes personal data necessary to fulfill its corporate purpose, complying with the provisions of the contracts it enters into, and fulfilling the obligations imposed by the legislation in force. In the scope of its activities, Tailor Partners may process personal data in the following forms:

a) Identification data (such as name, gender, marital status, date of birth, nationality, place of birth, CPF (Brazilian tax ID), identity, professional credentials, social profiles; photographs, images, videos; signatures; and telephone call voice recordings);
b) Family data (such as names and details of relatives or dependents);
c) Financial data (such as bank account number, billing address, transaction records);
d) Contact data (such as address, telephone, email);
e) Professional activity data (such as profession, employer’s name, position, professional address, professional contact data);
f) Statements and opinions (such as records of complaints, criticisms, comments, or statements; and public communications on Tailor Partners’ websites or social profiles);
g) Contractual data (such as qualification, contract number); and
h) Electronic identification data (such as IP address, cookies, activity logs, online identifiers, location data).

The use of our services and website is subject to reading and agreeing to this Privacy Policy, and if you do not agree with any provision, you must immediately interrupt the contracting of services and/or access to the website; otherwise, it will be considered as full acceptance of the Privacy Policy.

To interested parties, upon receiving your personal data, such as identification data, contact data, and professional activity data, your data will remain stored and processed by Tailor Partners.

II. Purposes of Data Processing

Tailor Partners undertakes to protect your personal data, in accordance with applicable law, making the best efforts not to allow — within its possibilities and responsibilities — third parties to make undue use of the data. We may use your personal data if we have your consent or for another legally permitted or required purpose, including:

a) Compliance with legal or regulatory obligations;
b) Execution of contracts or preliminary procedures related to contracts of which the data subject is a party, at the request of the data subject;
c) Regular exercise of rights in judicial, administrative, or arbitral proceedings;
d) Protection of the life or physical integrity of the data subject or third parties; or
e) Necessity to meet Tailor Partners’ or third parties’ legitimate interests.

III. Data Processing Agents

According to the provisions established by the LGPD (Brazilian General Data Protection Law), both the Controller and the Processor are considered “Data Processing Agents.” The Processor can be defined as any entity, whether a natural or legal person, of public or private nature, that processes personal data following the guidelines established by the Controller. On the other hand, the Controller can be any person, whether a natural or legal person, of public or private nature, who determines and decides on the processing of data.

In this context, whenever Tailor Partners makes decisions about how your personal data will be processed, it will be classified as the “Controller” according to the parameters of the LGPD. In these situations, if it is necessary and permitted by law to share your personal data with third parties, these third parties will be identified as “Processors.” This sharing will always be conducted strictly in accordance with current legal requirements.

If you have any questions regarding the processing of your personal data, you can contact Tailor Partners through our Data Protection Officer via the following email address: [email protected].

IV. Deadlines

Personal data is kept by Tailor Partners according to the purpose that justifies its processing. Generally, Tailor Partners will not retain personal data after the reasons justifying its processing have ceased, and if retention is not imposed by law or necessary to preserve the legitimate interest of the client, as the case may be. We emphasize that, even after the termination of a service contract or a contractual relationship, some records must remain accessible by legal requirement or may be necessary to demonstrate the terms of the relationship, being used only for these purposes.

V. Data Subjects’ Rights

Every natural person is assured the ownership of their personal data and the guaranteed fundamental rights of freedom, intimacy, and privacy, according to applicable law.

Subject to the terms of the law and circumstances, the data subject may request from us:

a) Confirmation of the existence of processing;
b) Access to the data;
c) Correction of incomplete, inaccurate, or outdated data;
d) Anonymization, blocking, or deletion of unnecessary, excessive, or data processed in violation of applicable law;
e) Data portability, as provided by law;
f) Deletion of personal data processed with the previous consent of the data subject, except for data retention cases allowed by law;
g) Information on public and private entities with which data sharing has been carried out;
h) Information about the possibility of not providing consent and the consequences of refusal; or
i) Revocation of consent, according to applicable law.

These rights may be exercised by sending an email to [email protected]. Requests will be handled with special care to ensure their effectiveness.

Every data subject also has the right to petition and/or file complaints regarding their data with the National Data Protection Authority, the Judiciary, and other competent authorities.

For the resolution of any disputes arising from the application of this Privacy Policy, Brazilian law will be strictly observed in its entirety. In case of disputes that may arise, they must be submitted to the court of São Paulo, in the state of São Paulo, with waiver of any other, no matter how privileged it may be.

Last updated: September/2023.

TAILOR PARTNERS • COPYRIGHT © 2023. ALL RIGHTS RESERVED.

Tailor Partners Investment Advisor Ltd., registered under CNPJ No. 25.284.909/0001-40, is an investment advisory firm duly registered with the Brazilian Securities and Exchange Commission in accordance with CVM Resolution 178/23 (“the Company”). The Company has a distribution agreement for financial products with XP Investimentos Corretora de Câmbio, Títulos e Valores Mobiliários S.A. (“XP”), and may, on behalf of its clients, operate in the capital markets in accordance with current legislation. In compliance with CVM regulations, the Investment Advisor cannot administer or manage investors’ assets. Investing in shares carries risks, and past profitability does not guarantee future returns. When engaging in derivative transactions, there is a risk of losses exceeding the invested amounts, potentially leading to significant asset losses. The Company may undertake complementary activities related to the financial, insurance, pension, and capitalization markets, provided they do not conflict with its investment advisory activity. These activities may be conducted through the aforementioned legal entity or through a third-party legal entity. All services are provided with due segregation and in compliance with CVM regulations or other regulatory and self-regulatory bodies. For information and inquiries about our products, please contact your investment advisor. To file a complaint, please contact the XP Ombudsman’s Office at 0800 722 3730 or [email protected].