Terms of Use

This document establishes the General Contracting Terms and Conditions between the CUSTOMER and (i) TRIO TECNOLOGIA LTDA., registered under number 40.090.717/0001-96, and, when applicable, (ii) TRIO INTERMEDIAÇÕES LTDA, registered under number 48.915.263/0001-57; both Brazilian-based companies belonging to the same economic group, headquartered at Rua Pasteur, 463, suite 602, Água Verde, Curitiba, Paraná, Brazil, ZIP code 80.250-104, referred to as "TRIO".

Together, Trio and Customer, are referred to as "Parties" and individually as "Party".

WHEREAS, (i) Trio Tecnologia Ltda, is dedicated to providing technological solutions for financial resource management and (ii) Trio Intermediações Ltda, acts as a international payment facilitation, in the receipt and transfer of monetary values, using the technological solution owned by Trio Tecnologia Ltda, and that (iii) the Customer is interested in contracting Trio’s services. It is strongly recommended to carefully read this TERM, as well as all applicable policies, before using the services provided by TRIO. If there is no agreement with any of the conditions, it is recommended to interrupt the use of the services.

1. DEFINITIONS

1.1 The following terms, when used in the scope of this TERM or AGREEMENT, shall have the following meanings: Beneficiary: refers to a legal entity, national or foreign, that is the ultimate beneficiary of the supply chain, that is, the legitimate receiver or user of the benefits arising from the sale of a product or service. The Beneficiary may be the Trio's own Customer or, eventually, the Customer's customer.

Customer: refers to a legal entity, national or foreign, that hires Trio's services, establishing a contractual relationship between the Parties. Partner: refers to one or more financial institutions authorized by the Central Bank of Brazil to perform payment initiation and transactions, acting as intermediaries in the transfer of funds between the User's and the Customer or Beneficiary's bank accounts. eFX Partner: refers to a financial institution authorized by the Central Bank of Brazil to process foreign exchange transactions and that maintains a supply commercial relationship with Trio. User: refers to a natural or legal person who acquires products or services from the Beneficiary.

2. ACCEPTANCE

2.1 By using TRIO's services, the CUSTOMER agrees to all provisions of this TERM, which shall be binding between the Parties. In this sense, the CUSTOMER is aware of all its obligations and rights, irrefutably agreeing to them.

3. INFRASTRUCTURE SERVICE FOR INSTANT PAYMENTS (“services”)

3.1 To deliver the services to the CUSTOMER in a complete, quick and efficient way, TRIO uses the services of partner financial institutions, duly authorized by the Central Bank of Brazil, for the initiation of payment and settlement of transactions services (“PARTNER”).

3.2 TRIO, through its technological solution, offers infrastructure for instant payments, enabling the CUSTOMER to optimize processes and better manage transactions.

3.2.1 At the discretion of TRIO or the PARTNER, the relationship with the CUSTOMER may be refused or, when accepted, in the cases provided for in clause 6.3, it may be interrupted.

3.3 The CUSTOMER accepts and understands that it must know and respect the policies of TRIO and the PARTNER, especially with regard to combating and preventing money laundering and financing of terrorism. 3.3.1 In compliance with current legislation, the KYC (Know Your Customer) process is an integral and mandatory part of establishing and maintaining the relationship. The CUSTOMER expressly declares that it is aware and accepts that all the information provided is true and complete.

3.4 At any time during the term of the relationship between the Parties, TRIO may request additional documents from the CUSTOMER to verify or update data. The documents must be delivered by the CUSTOMER within 5 (five) business days, under penalty of suspension of services or termination of the contractual relationship, subject to the imposition of a fine under the terms of the Agreement.

3.5 The CUSTOMER expressly authorizes and acknowledges that TRIO may provide information about the Customer, the Beneficiary, the User or the transaction to the PARTNER, provided that such information sharing is strictly necessary for carrying out the operation.

3.6 TRIO undertakes to make available to the CUSTOMER, during agreement term, access and support for the use of TRIO's software.

3.7 Without prejudice to other obligations, TRIO undertakes to: 3.7.1 Provide the CUSTOMER with personal and non-transferable access to the platform duly integrated with the PARTNER's systems. 3.7.2 Collaborate with the CUSTOMER, whenever possible and necessary, to enable integration with the platforms.

4. FACILITATION SERVICES FOR INTERNATIONAL PAYMENTS (“eFX services”) (if contracted)

4.1 Using the eFX (Electronic Foreign Exchange) services, the CUSTOMER must obtain authorization from the USER so that TRIO can act on its behalf for the exercise of exchange operations for remittance of funds.

4.2 The CUSTOMER expressly authorizes TRIO to receive amounts on its behalf, in national currency, which are justified by the sale of products or services by the CUSTOMER, or a Beneficiary, to the User banked in Brazil.

4.3 The eFX services, in accordance with ACAM 220, are restricted to: 4.3.1 Acquisition of goods and services - Other digital payment solutions - Virtual Assets, under code 34038. 4.3.2 Acquisition of goods and services - Other digital payment solutions - Games and Betting, under code 34045. 4.3.3 Acquisition of goods and services - Others, under code 34052.

4.4 Under the terms of exchange legislation, the compensation of amounts is prohibited. Despite, concurrent operations may be performed.

4.5 TRIO will provide the CUSTOMER with access to the balance of amounts in Brazilian Real (BRL).

4.6 TRIO will use a partner supplier, duly authorized by the Central Bank of Brazil, to process all international transfers from the USER to the CUSTOMER (“eFX PARTNER”). 4.6.1 The international transfers will be processed in United States Dollars (USD) or Euros (EUR), as indicated by the CUSTOMER.

4.7 The CUSTOMER authorizes and must obtain consent from the USER so that TRIO and the eFX PARTNER can collect, process and share their registration, financial and personal data with companies of the same economic group, as well as financial institutions, regardless of whether or not they are connected to TRIO, with the purpose of providing the services.

4.8 Under the applicable legislation, it is required for the processing of foreign exchange operations: 4.8.1 Identification of the USER and Beneficiary, including full name or corporate name, CPF or CNPJ, when Brazilian, or equivalent data when foreign, plus information on the corresponding country. 4.8.2 Type, date, foreign currency and transaction value in Brazilian reais and foreign currency of each transaction.

4.9 The CUSTOMER accepts and understands that: 4.9.1 TRIO's eFX services are restricted to the receipt of amounts from USERS and transfer to the CUSTOMER. 4.9.2 TRIO may deduct amounts from the CLIENT, in accordance with the applicable regulations and up to the maximum limit allowed. 4.6.3 The eFX PARTNER, at its discretion or by legal determination, may establish limits for operations and will be responsible for withholding the taxes levied on the transaction, currently the Tax on Financial Operations (“IOF”). 4.9.4 The CUSTOMER must disclose and obtain the awareness and agreement of the USERS on the services contracted herein, their nature and conditions. 4.9.5 The eFX services may be suspended for preventive or corrective maintenance, improvements or for reasons beyond the control of TRIO or eFX PARTNER, without the CUSTOMER being entitled to any compensation. 4.9.6 TRIO or the eFX PARTNER do not guarantee the conversion rate until the transaction is actually carried out. Due to the nature of the operation, the CUSTOMER is subject to exchange rate variations, which may be higher or lower. 4.9.7 Using the services, the CUSTOMER agrees with the exchange rates offered by the eFX PARTNER, as well as acknowledges that TRIO acts in the intermediation between the USER, the CUSTOMER and the eFX PARTNER, not being responsible for the exchange rates practiced.

4.10 The services offered by TRIO under no circumstances may be confused with the products or services offered by the CUSTOMER or the Beneficiary. Therefore, it cannot be held responsible for defects in the relationship with the USER. 4.10.1 If TRIO incurs losses, even after the termination of the Agreement, as a result of the products or services offered by the CUSTOMER or Beneficiary, the CUSTOMER undertakes to indemnify TRIO for the entire amount spent, including, without limitation, costs and attorney fees. 4.10.2 TRIO is hereby authorized to deduct any amount due as a result of clause 4.10.1 from the amounts to be sent to the CUSTOMER. If there is not enough money to deduce, the CUSTOMER undertakes to reimburse TRIO within 20 (twenty) calendar days, counting from the communication.

4.11 According to the CUSTOMER's policy and guidelines, TRIO may operate payments, returns or refunds to the USER. 4.11.1 In case of returns or refunds, the price of the TRIO will be due in all events of the operation. 4.11.2 The CUSTOMER is responsible for managing the balance for return and refund operations. These operations will occur upon the availability of financial resources. If there are not enough balances, the CUSTOMER must provide the amount to TRIO for subsequent payment, reimbursement or return to the User.

4.12 The CUSTOMER is fully responsible for any and all claims arising from or related to the products or services offered, exempting TRIO from any and all liens, obligations or liabilities.

4.13 If the CUSTOMER is not the Beneficiary, that is, it is a Payment Service Provider (“PSP”), the CUSTOMER must provide and keep the list of Beneficiary(ies) updated, as well as, at each transaction, identify and correctly qualify the Beneficiary corresponding amount, under the terms required by current legislation. 4.13.1 The CUSTOMER agrees and is aware that, in order to comply with current legislation, it must expressly communicate to TRIO, at each establishment of a new relationship or termination with the Beneficiary(ies), under penalty of the amounts not being able to be received by TRIO and/or transferred to the CUSTOMER. In the case of a new Beneficiary, both TRIO and the eFX PARTNER must be informed and can decide whether or not to accept processing the related transactions.

4.14. All other provisions of this TERM, insofar as they do not conflict with this section, apply to eFX services.

5. AGREEMENT

5.1 For the effective contracting of TRIO's services by the CUSTOMER, in addition to knowing and accepting this TERM, the Parties must enter into additional instruments with the other contracting details, such as the Agreement for the Supply of Financial Technological Solutions and/or the International Payments Facilitation Service Agreement (eFX) (jointly or separately referred to as the “Agreement”).

5.2 All commercial conditions, price and other provisions will be included in the Agreement. 5.2.1 The CUSTOMER authorizes the transfer of the amount corresponding to the price, for each transaction or according to the best convenience for TRIO.

5.3 The relationship between the Parties is established without any character of exclusivity, both parties being able to contract and be contracted by any other party, without segment reservation, even if competing with the other party, without prejudice to the confidentiality obligations signed.

6. TERM

6.1 This TERM will enter into force on the date the CUSTOMER starts using TRIO's services and will remain in force for the entire term of the relationship between the Parties (“duration”).

6.2 The clauses that have a specific period of validity will have their validity as determined in their wording.

6.3 TRIO may terminate the relationship with the CUSTOMER at any time and with immediate effect, regardless of notification, without prejudice to other rights, in the following cases: 6.3.1 Failure by the CUSTOMER to comply with any of the provisions of this TERM or AGREEMENT. If capable of being remedied, that has not been corrected within 10 (ten) calendar days of notification. 6.3.2 Default of payment by the CUSTOMER. 6.3.3 Attempt or practice by the CUSTOMER in illegitimate, illegal, fraudulent transactions or that violate this TERM or operational or market security rules. 6.3.4 Maintaining the relationship with the CUSTOMER negatively compromises TRIO's image and reputation. 6.3.5 The CUSTOMER provides false or outdated information or fails to present the required documentation. 6.3.6 The TRIO or PARTNER classifies, or reclassifies, at any time, the CUSTOMER's transactions as a high-risk service or product or operation. 6.3.7 Failure by the CUSTOMER to fulfill the obligations assumed in the Money Laundering Prevention and Terrorism Financing and Personal Data Protection clauses.

6.4 Termination of the agreement does not exempt either party from fulfilling its obligations until the effective termination date.

7. CUSTOMER OBLIGATIONS

7.1 The CUSTOMER undertakes to comply with this TERM, as well as any additional conditions, policies, operational and security rules, informed by TRIO.

7.2 It is the CUSTOMER obligation to keep all its registration data, as well as the list of authorized persons, updated. In case of changes, you must inform TRIO, within a maximum period of 10 (ten) days of their occurrence. 7.2.1 Without prejudice to the provisions above, at least annually, the CUSTOMER must revalidate the informed registration data.

7.3 Ensure the veracity, certainty, sufficiency and consistency of the data provided, taking full responsibility for any discrepancies that may arise between the information provided and the actual and/or official data.

7.4 Use the services exclusively for the purposes for which they are intended, in accordance with applicable legal rules and regulations.

7.5 The CUSTOMER is prohibited from using the services to: 7.5.1 Acting in segments or branches of activity different from those listed in the registration. 7.5.2 In which the product or service is prohibited by current legislation or violates morals and good customs or that are or are included in a restrictive list of products and services issued by TRIO. 7.5.3 Involving User under 18 (eighteen) years old.

7.6 Dedicate its best efforts to the implementation of the integration of the platforms necessary for the provision of services, including providing the technological infrastructure in the indicated standards and norms.

7.7 The CUSTOMER must comply with all applicable laws, rules or regulations and is solely and exclusively responsible for the payment of all taxes due and for the fulfillment of all obligations imposed by the competent authorities, including those of a labor, social security, fiscal and consumerist.

7.8 The CUSTOMER undertakes to fully observe all rules relating to the prevention and combat of crimes related to money laundering, concealment of assets and financing of terrorism and other relevant legislation, as well as cooperating with the authorities and regulatory agencies, providing legally admissible information and data and adopting all measures within its power to curb such illicit practices.

7.9 The CUSTOMER is responsible for any claims, demands and indemnities of any nature arising from its activity, as well as for any problems of acceptance, quantity, quality, guarantee, price or inadequacy of the goods and/or services offered, including in the event of repentance on the part of the User, having to resolve directly with the User any and all disputes. The CUSTOMER is also responsible for the correct and timely delivery of the good or service. The CUSTOMER exempts TRIO and/or PARTNER from any liability in relation to the goods and services purchased by Users, including in terms of Brazilian Consumer Protection and Defense Code and other applicable laws. 7.9.1 Indemnify TRIO and/or PARTNER for any liabilities, losses, damages or expenses incurred as a result of actions or omissions by the CUSTOMER or BENEFICIARY, including fraud and claims by third parties.

7.10 The CUSTOMER undertakes to exempt and defend TRIO and/or PARTNER from any lawsuits, labor claims and out-of-court proceedings that may be initiated against TRIO or other companies of the economic group, related to the activity carried out by the CUSTOMER, and to fully indemnify to TRIO and/or PARTNER in the event of conviction for an act or fact attributed to the CUSTOMER's responsibility.

7.11 The CUSTOMER declares to be aware that TRIO has no responsibility for the veracity of the information provided by the User.

7.12 Reimburse TRIO and/or PARTNER for any and all amounts incurred from the items in this clause within 15 (fifteen) business days, counted from the communication and presentation of supporting documents, under penalty of a fine of 10% (ten percent) on the value and default interest of 1% (one percent) per month.

7.13 The CUSTOMER is responsible for obtaining and maintaining, as well as guaranteeing the suitability of the license, all computer hardware, software and communication equipment, as well as practicing all necessary security measures in accordance with bests practices for the operation of the device used, such as, but not limited to, the use of antivirus software and reasonable physical, logical and administrative measures for secure access.

8. LICENSE FOR SOFTWARE USE AND INTELLECTUAL PROPERTY

8.1 - The relationship established between TRIO and the CLIENT, governed by this AGREEMENT and the CONTRACT, is characterized by the revocable, non-exclusive, and non-transferable granting of a software use license during the contracted period.

8.2 - The use of the software does not entail the total or partial transfer of intellectual property rights. The brand, logo, business name, or domain uniquely and exclusively belong to TRIO. The use of the platform does not grant the right to use the brand in connection with any commercial brand without prior express consent.

8.3 - In these terms, the CLIENT acknowledges that all intellectual property rights related to the platform are the exclusive property of TRIO, which owns them entirely, as well as any learning, improvement, change, modification, correction, solution, or any other addition incorporated.

8.4 - The CLIENT and its employees, representatives, proxies, and third parties are expressly prohibited, directly or indirectly, from (i) copying, modifying, creating a derivative work, reverse engineering, decompiling, disassembling, or in any way attempting to extract the source code or underlying ideas and algorithms of the software; (ii) renting, distributing, selling, assigning, or transferring the right to use relevant elements of the platform; (iii) using the platform differently from its intended purpose; (iv) removing or altering any proprietary notices on the platform or any reference to the brand or name of TRIO; (v) publishing or disclosing any evaluation of the platform to third parties without prior written consent; and/or (vi) attempting to replicate the functionality or appearance of the platform.

8.5 - The CLIENT understands that, to integrate with the TRIO platform, it is only necessary to access the APIs and information exchange manuals for customization, without the need to access codes, protocols, hardware, software, or other computer materials whose intellectual property belongs to TRIO. However, in exceptional cases and only for the operationalization of the contracted service, the CLIENT may have access to the codes developed by TRIO, provided that the restrictions of the previous item are observed and that reverse engineering or attempts to develop tools or functionalities from TRIO's intellectual property rights are not practiced.

8.6 - Any intellectual property rights not expressly granted in this document are reserved to TRIO and expressly excluded from this AGREEMENT and CONTRACT.

9. SOFTWARE USAGE AND SERVICE AVAILABILITY

9.1 - TRIO commits to exert its best efforts to ensure that the software serves the CLIENT's purposes. Nevertheless, the platform is provided without any type of warranty, express or implied, including, but not limited to, that the software is free from defects and capable of integrating into the CLIENT's system.

9.2 - The CLIENT understands and accepts that the platform is software in constant development, resulting in changes, updates, and improvements at any time. TRIO does not have any responsibility or obligation to maintain a specific operational structure or design, and it does not have any obligation to comply with customizations, although it may do so at its sole discretion.

9.3 - TRIO will make its best efforts to keep the platform running properly, aiming for an annual availability of 99.5% of the time. However, it will not be held responsible for events beyond its sphere of interference or predictability that go beyond its efforts or preventive routines.

9.4 - In emergency cases related to the regular operation of the platform or security, TRIO will not be obligated to inform the CLIENT in advance of the service interruption. The interruption will be maintained for the necessary time for repairs.

9.5 - TRIO's support services are provided upon requests made through the website https://support.trio.com.br. The response time for each request will vary according to the complexity of the inquiry.

9.6 - The CLIENT acknowledges that there may be interruptions in the provision of services by the PARTNER for technical reasons, preventive or corrective maintenance, without any right to compensation. 9.6.1 - Under no circumstances will TRIO be held responsible for the unavailability of the PARTNER's or related third-party systems, such as the Central Bank of Brazil.

10. TRANSACTION SECURITY

10.1 - The CLIENT acknowledges and agrees that TRIO will implement transaction blocking criteria based on best market practices and internal learning to enhance transaction security.

10.2 - TRIO or the PARTNER reserve the right, at their discretion, not to process transactions deemed suspicious or irregular, without entailing any right to compensation for the CLIENT.

11. RESPONSIBILITIES

11.1 - The CLIENT shall be entirely responsible for any act, deed, or omission of their partners, employees, representatives, or subcontractors, which causes or may cause losses and/or damages to TRIO and/or third parties.

11.2 - The CLIENT is solely responsible for the products or services marketed as a result of their business activities. Therefore, at any time, even after the termination of the Contract, the CLIENT undertakes to indemnify TRIO for all and any disputes. In case TRIO incurs losses due to products or services marketed by the CLIENT or Beneficiary, the CLIENT commits to compensate TRIO for the entire amount expended, including, but not limited to, costs and attorney's fees.

11.3 - TRIO shall not be held responsible for (i) products or services for which the CLIENT or third parties related to the CLIENT are responsible; (ii) services the execution of which is the responsibility of third parties, provided that this is known by the Customer, excluding any fault or intention of TRIO; (iii) total or partial unavailability of the Services due to reasons or failures arising from factors external to the TRIO system (including, but not limited to, fortuitous events and force majeure, electrical grid failures, internal and external network connection failures, third-party software, bugs, and malware attacks, scheduled interruptions, or actions by third parties preventing their availability); (iv) damages caused by integration and/or connection problems with the CLIENT's system resulting from non-compliance with specifications provided by TRIO; (v) misuse of the platform provided by TRIO due to the sharing of login and password by the CLIENT's representatives; (vi) any damages resulting from the CLIENT's failure to meet their obligations; and (vii) indirect or intangible losses, including, but not limited to, loss of profits. 11.3.1 - TRIO's cumulative total liability shall not exceed the consideration actually received from the CLIENT in the last three months of the relationship.

12. COMPLIANCE

12.1 - The CLIENT and its representatives affirm that: (i) they will not undertake any actions harmful to the national or foreign public administration, as defined by the current legislation; (ii) they have not benefited from the breach of any legal provision, whether in their own name or on behalf of third parties; (iii) they commit to inform TRIO within 2 (two) business days if they become aware of any violation of the mentioned law, providing all additional information requested. This duty of communication shall remain valid even after the termination of the contract, provided that it is related to the contracting period; (iv) they are solely responsible for the breach of any anti-corruption laws and other obligations that may affect the national or foreign public administration, as well as any other related regulations, committed by themselves, in their name, or by related third parties; and (v) they undertake to comply with the laws and regulations governing money laundering and terrorism financing crimes, and other related rules issued by the competent authorities, whenever applicable.

12.2 - All and any sanctions imposed as a consequence of non-compliance with the provisions in the previous section are the exclusive responsibility of the CLIENT.

13. CONFIDENTIALITY

13.1 - The Parties undertake to maintain the confidentiality of each other's confidential information, whether acquired or known during and after the contractual relationship.

13.2 - For the purpose of this AGREEMENT, "Confidential Information" means: (i) all techniques used in the conduct of the business of one Party and its controlled, affiliated, parent, and commonly controlled companies; (ii) reports, inventions, designs, trade secrets, secret formulas, new products, trademarks, "know-how," methods and processes, whether patented or not, as well as any Intellectual Property; (iii) contracts and registration, tax, and banking information of customers, suppliers, service providers, and customer and supplier lists and registries; (iv) all work, methods, processes, technologies, and market secrets, business and administrative practices, corporate plans, finances, new business opportunities, accounting methods, management methods, business plans, price and cost structures, management techniques, personal or non-public information, particularly the knowledge of competing companies; and/or (v) any information, material, or document provided by one Party to the other, related to that Party, its controlled, parent, affiliated, and commonly controlled companies, whether expressly identified as confidential or not, whether recorded in documentary form or in digital or physical format; (vi) any information passed from one Party to the other, in written, oral, physical, electronic, or any other form of information acquisition aimed at enabling the contracted service. The term Confidential Information shall also include: (i) the existence and content of the AGREEMENT; and (ii) all notes, analyses, compilations, studies, and other documents containing, reflecting, or relating to the subject matter of the services.

13.3 - The following shall not be considered Confidential Information: (i) TRIO's publicly disclosed APIs, which may be replicated with other TRIO clients without infringing the duty of confidentiality; (ii) Confidential Information that is in the public domain or made available to the public through any other means not in violation of this AGREEMENT by the receiving Party; (iii) the terms and conditions of the AGREEMENT when they have to be made available to the Central Bank or other government authority, as required by applicable regulations; and (iv) Confidential Information that was legally in the possession of the receiving Party before the execution of this instrument, without an obligation of secrecy.

13.4 - In the event of a request from a competent authority and/or a court decision that determines the disclosure of Confidential Information of the other Party, the receiving Party must, as soon as possible, notify the other Party in writing to enable the latter to judicially obtain the right not to have its Confidential Information disclosed, provided that such a decision is not confidential. In any case, disclosure, when necessary, must be made only in relation to the content of the respective request and/or decision.

13.5 - Confidential Information shall remain the property of the disclosing Party, which may demand its return at any time by written notice to the receiving Party. Within 5 (five) business days of receiving the notice, the receiving Party must return all original copies of the Confidential Information and destroy all respective copies in its possession and in the possession of its representatives.

13.6 - Neither of the Parties: (i) will use the Confidential Information of the other Party except as necessary for the performance of the contracted activities, and (ii) will disclose such Confidential Information to any third party, except to its representatives, directors, and employees ("Representatives") who need to be aware of such Confidential Information for the performance of the contracted activities.

13.7 - The Parties shall be responsible for any breach of the confidentiality obligation by their Representatives who have received Confidential Information.

14. DATA PROTECTION

14.1 - All capitalized terms in this clause shall have the respective meanings attributed by Law No. 13,709 of August 14, 2018 ("LGPD"), which the Parties hereby declare to be aware of.

14.2 - The CUSTOMER declares to TRIO, for all legal purposes, that it collects, uses, stores, and transmits (together, the "Processing") Personal Data in compliance with all applicable laws and regulations, and that it has obtained all necessary authorizations and relies on the necessary legal bases for Processing Personal Data, in accordance with the current legislation, releasing TRIO from any liability to Data Subjects due to inadequate Processing of Personal Data, as well as any defect in obtaining Consent, including the impossibility of proving it. 14.2.1 - For the purposes of this AGREEMENT, "Personal Data," as defined in Article 5, I, of LGPD, means any information that allows the direct or indirect identification of a living person, such as: name, ID, CPF, gender, date and place of birth, phone number, residential address, GPS location, photograph, medical records, bank card, income, payment history, consumption habits, leisure preferences; IP (Internet Protocol) address, and cookies.

14.3 - The CUSTOMER agrees that in order to perform the services, TRIO and the PARTNER must have access to Personal Data, which is owned by the respective CUSTOMER's clients and will be Processed by TRIO and the PARTNER. The CUSTOMER is responsible for obtaining the necessary Consent in accordance with applicable law.

14.4 - The CUSTOMER must ensure that any Personal Data provided to TRIO for the purpose of the contracted object originates from a database that is lawfully constituted and can be shared for service purposes in accordance with applicable law.

14.5 - The CUSTOMER must take the necessary measures, including providing adequate information to data subjects and ensuring the existence of a valid legal basis, so that TRIO and the PARTNER have the right to receive and Process such Personal Data for the purpose of performing the services.

14.6 - The Parties declare that they adopt security measures, technical and administrative, capable of protecting Personal Data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, disclosure, or any form of inadequate or unlawful Processing.

14.7 - If the CUSTOMER does not ensure the adequate Processing of Personal Data for the purposes of the services and compromises the security, confidentiality, and integrity of the shared Personal Data, the CUSTOMER: 14.7.1 - Will be solely responsible for its actions or omissions, as well as those of its respective employees, representatives, legal agents, contractors, or third parties related or anyone who has had access to Personal Data. 14.7.2 - Will be responsible for paying (i) any court, administrative, and arbitration procedural expenses, in any instance or court, arising from actions or proceedings that may be initiated against TRIO or third parties; and (ii) fines, including but not limited to those applied by the Public Prosecutor's Office, the National Data Protection Authority, the Central Bank, or consumer protection and defense agencies, without prejudice to damages.

14.8 - The Party receiving the Personal Data provided by the other Party must Process Personal Data only to the extent necessary to achieve the purpose for which the Personal Data was provided and to comply with its obligations, which is the correct provision of the contracted services. The Parties acknowledge that Personal Data may also be Processed if necessary to comply with a legal or regulatory obligation to which the Party is subject in Brazil or to exercise rights in legal, administrative, and arbitration proceedings.

14.9 - If one of the Parties receives a request, inquiry, or complaint from a data subject or a regulatory authority or other competent body regarding the Processing of Personal Data (including, without limitation, any request for access, rectification, deletion, portability, or restriction of the Processing of Personal Data) in accordance with rights provided by applicable law, the Party must, whenever possible, immediately and in any case within 5 (five) business days, notify the other Party in writing of such request, unless the complaint, inquiry, or request requires a shorter deadline, ensuring the exercise of data subject's rights.

14.10 - The Parties acknowledge and agree that, with regard to the Processing of Personal Data, each Party acts as a controller with respect to such Processing, and no Party is intended to act as a processor for the other Party with respect to any Processing of such data, since each Party will Process Personal Data individually and autonomously.

15. MODIFICATIONS TO THE AGREEMENT

15.1 - TRIO may change this AGREEMENT at any time, without prior notice and at its sole discretion. The current AGREEMENT will always be available on the website and can be accessed at any time.

15.2 - In the event of modifications during the contract period, TRIO will notify the CUSTOMER in advance, and the new conditions will come into effect 15 (fifteen) business days after the communication or publication. Failure to respond or the continuation of the relationship within 10 (ten) business days from the date of communication or publication will constitute tacit acceptance of the new terms.

16. GENERAL PROVISIONS

16.1 - TRIO and the CUSTOMER shall be individually responsible, within the scope of their commercial activities, for the collection of taxes and charges applicable in accordance with the current legislation, and any increases or changes shall be borne by the respective taxpayer. If during the contract period, new taxes or fiscal contributions or changes in tax rates arise, the Parties agree to review and negotiate the values of any differences resulting from these changes in order to rebalance the relationship established herein.

16.2 - The CUSTOMER may not assign or transfer any rights or obligations under this Agreement, in whole or in part, without the prior written consent of TRIO.

16.3 - If any provision is declared invalid, illegal, or unenforceable, the validity, legality, and enforceability of the remaining provisions will not be affected by such declaration.

16.4 - Any tolerance by the parties regarding the breach of this AGREEMENT will constitute mere indulgence and will not constitute waiver or novation of the contract or its clauses.

16.5 - Nothing in this AGREEMENT shall be interpreted as creating or constituting any form of partnership, association, representation, or agency relationship between the Parties.

16.6 - In the event of a conflict between the Portuguese and English versions, the English version will prevail and will be considered the definitive version.

16.7 - This AGREEMENT shall be governed and interpreted in accordance with the laws of Brazil. Any disputes arising from or related to this AGREEMENT shall be settled exclusively by the court of Curitiba/PR, Brazil, to the exclusion of any other forum.