PRIVACY POLICY

How we take care of your data.

Learn how EFFAP handles personal data used in providing its services and in your browsing experience, clearly and transparently.

Last updated: August 17, 2026

Version: 1.0

01.About this policy

This Privacy Policy explains how EFFAP handles personal data related to website access, account creation and use, purchases of products and services, user support, and other interactions through its channels. Its purpose is to clearly explain how data may be collected, used, stored, and protected.

02.Who is responsible for processing

EFFAP is a brand used by JM Investimentos e Tecnologia LTDA, responsible for processing personal data in situations where it acts as controller. Depending on the service used, certain data may also be processed by providers and partners acting according to their own responsibilities and privacy policies.

03.What data we may collect

Depending on the interaction, we may collect information such as name, email address, contact details, account-related information, data necessary for purchase and payment, support information, website usage records, and other information voluntarily provided by users or generated during service use.

04.Data provided by the user

Some data is provided directly by users when they create an account, request support, make a purchase, complete forms, contact EFFAP, or use certain website features. Users are responsible for providing correct, up-to-date information necessary for the relevant purpose.

05.Automatically collected data

During browsing, certain technical information may be collected automatically, such as IP address, device type, browser, operating system, pages accessed, access date and time, and website usage information. This information may be collected through cookies and similar technologies, as described in the Cookie Policy.

06.How we use data

Personal data may be used to provide and administer products and services, create and manage accounts, process purchases and payments, provide support, respond to requests, maintain system security, prevent misuse, improve the website, and comply with legal and regulatory obligations.

07.Legal bases

Personal data will be processed on the legal bases established in applicable law, including, where relevant, performance of a contract or pre-contractual procedures, compliance with legal obligations, regular exercise of rights, legitimate interest, and the data subject’s consent when necessary.

08.Data sharing

Personal data may be shared with service providers and partners when necessary to provide products and services, process payments, provide support, maintain technological infrastructure, protect systems, comply with legal obligations, or fulfill other legitimate purposes related to EFFAP activities.

09.Payment providers

When users make a purchase, certain data may be sent to the providers responsible for payment processing. These providers may perform checks necessary to process the transaction, prevent fraud, and meet legal and security requirements and their own privacy policies.

10.Third-party services and platforms

Some features used by EFFAP may depend on platforms, technology services, or other external suppliers. When these third parties process data in their own operations, their respective privacy policies and terms may apply.

11.International data transfers

Some suppliers used by EFFAP may be located outside Brazil or use international infrastructure. Where personal data is transferred internationally, the requirements and mechanisms established by applicable law for this purpose will be observed.

12.Information security

EFFAP adopts technical and organizational measures intended to protect personal data against unauthorized access, loss, alteration, disclosure, or misuse. Although security measures appropriate to the risks involved are adopted, no electronic system can be considered completely risk-free.

13.Data retention

Personal data will be retained for the period necessary to fulfill the purposes for which it was collected, meet legal or regulatory obligations, exercise rights, and fulfill other legitimate purposes. After the applicable period ends, data may be deleted or anonymized, subject to the possibilities and obligations established by law.

14.Data subject rights

Under applicable law, data subjects may exercise rights relating to their personal data, including confirmation of processing, access, correction, updating, anonymization, blocking or deletion where applicable, portability, information about sharing, and withdrawal of consent where consent is the basis used.

15.How to exercise your rights

Data subjects may contact EFFAP through the channels provided on the website to request information or exercise rights under applicable law. To protect information security, we may request additional data to confirm the requester’s identity before fulfilling certain requests.

16.Children’s privacy

EFFAP products and services are not directed at people who lack legal capacity to purchase or use the services under applicable law. If personal data improperly provided by minors is identified, EFFAP may take appropriate measures to address the situation according to applicable law.

17.External links and services

The EFFAP website may provide links or integrations with third-party websites, platforms, and services. Use of those environments is subject to their respective privacy policies and terms, and EFFAP is not responsible for third-party data processing practices outside its own environments.

18.Relationship with the cookie policy

Cookie and similar technology use is specifically described in EFFAP’s Cookie Policy. That document supplements this Privacy Policy by explaining the categories of cookies used, their purposes, and the options available to manage these technologies.

19.Policy updates

This Privacy Policy may be updated periodically to reflect changes in services, data processing practices, technologies used, or applicable law. The latest version will be available on this page, together with its update date.

20.Contact

If users have questions about this Privacy Policy, the processing of their personal data, or wish to exercise a right under applicable law, they may contact EFFAP through the support channels provided on the website.