1. Introduction

Fernandes Capital ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share personal information when you use our website, products, and services. It applies to all clients, prospective clients, website visitors, and third parties who interact with us.

We process personal data in accordance with the Lei Geral de Proteção de Dados Pessoais (LGPD – Law No. 13,709/2018), and other applicable data protection laws. Fernandes Capital is registered as a Data Controller with the Brazilian Autoridade Nacional de Proteção de Dados (ANPD).

2. Information We Collect

We may collect and process the following categories of personal data:

• Identity Data: Full name, date of birth, gender, nationality, passport or national ID number.
• Contact Data: Home address, email address, telephone number.
• Financial Data: Bank account details, payment card information, credit history, income details, tax identification numbers, investment portfolio information.
• Transaction Data: Details of loan applications, repayments, investments, and account activity.
• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types, operating system and platform, and other technology data from devices used to access our website.
• Usage Data: Information about how you use our website, products, and services.
• Marketing & Communications Data: Your preferences in receiving marketing from us and your communication preferences.

3. How We Use Your Information

We use your personal data for the following purposes:

• To assess and process loan and investment applications.
• To manage your account and provide ongoing financial services.
• To comply with legal and regulatory obligations, including anti-money laundering (AML) and Know Your Customer (KYC) requirements.
• To communicate with you about your account, products, and services.
• To send you marketing communications (where you have consented or we have a legitimate interest).
• To improve our website and services through analytics and feedback.
• To detect and prevent fraud, money laundering, and other financial crime.
• To conduct credit checks and affordability assessments.

4. Legal Basis for Processing

We process your personal data under the following legal bases:

• Contract: Processing is necessary to enter into or perform a contract with you.
• Legal Obligation: Processing is required to comply with applicable laws and regulations.
• Legitimate Interests: Processing is in our legitimate interests (e.g., fraud prevention, improving our services), provided these are not overridden by your rights.
• Consent: Where you have given explicit consent, for example, for marketing communications. You may withdraw consent at any time.

5. Data Sharing & Third Parties

We do not sell your personal data. We may share your information with:

• Credit reference agencies, fraud prevention agencies, and identity verification services.
• Regulatory bodies including the FCA, ACPR, HMRC, and other authorities as required by law.
• Service providers and technology partners who process data on our behalf under strict data processing agreements.
• Financial counterparties necessary for the completion of transactions (e.g., banks, insurers).
• Professional advisers including lawyers, auditors, and consultants under confidentiality obligations.

Where data is transferred outside Brazil, we ensure appropriate safeguards are in place, including Standard Contractual Clauses and ANPD-approved mechanisms.

6. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. In general:

• Client records are retained for a minimum of 7 years following the end of the client relationship, in accordance with AML regulations.
• Marketing data is retained until you withdraw consent or opt out.
• Website analytics data is typically retained for 26 months.

7. Your Rights

Under the LGPD, you have the following rights:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your data where there is no compelling reason for its continued processing.
• Right to Restrict Processing: Request restriction of processing in certain circumstances.
• Right to Data Portability: Request transfer of your data to another controller.
• Right to Object: Object to processing based on legitimate interests or for direct marketing.
• Rights related to Automated Decision-Making: Not be subject to decisions made solely by automated means that significantly affect you.

To exercise any of these rights, please contact our Data Protection Officer at dpo@fernandescapital.com.

8. Cookies

Our website uses cookies to improve user experience and analyse website traffic. You can control cookies through your browser settings. For full details, please refer to our Cookie Policy. We use strictly necessary cookies (which cannot be disabled), performance cookies, and optional marketing cookies (which require your consent).

9. Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or damage. These include encryption (TLS/SSL), access controls, regular security audits, and staff training. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and inform affected individuals without undue delay.

10. Contact & Complaints

For questions about this Privacy Policy or to exercise your rights, contact our Data Protection Officer:

You also have the right to lodge a complaint with the supervisory authority in your country — the ANPD (Brazil) at gov.br/anpd.

1. Acceptance of Terms

By accessing the Fernandes Capital website, using our online tools, or engaging with our products and services, you agree to be bound by these Terms and Conditions ("Terms"), our Privacy Policy, and any applicable regulatory requirements. If you do not agree with any part of these Terms, please do not use our services.

These Terms apply to all users of our website, including applicants, clients, registered users, and visitors. Fernandes Capital reserves the right to update these Terms at any time. Continued use of our website or services after changes are published constitutes acceptance of the revised Terms.

2. About Fernandes Capital

Fernandes Capital é registrada no Brasil sob o Número de Empresa 05440489. Nossa sede está localizada na Avenida Paulista, 1374, Bela Vista, São Paulo, SP 01310-100, Brasil.

Fernandes Capital is authorised and regulated by the Banco Central do Brasil – BACEN (Reference: BR-2005-4489) and the Comissão de Valores Mobiliários – CVM (Reference: CVM-8872). Regulation may vary for specific products and services.

3. Our Services

Fernandes Capital provides financial services including, but not limited to, personal loans, business loans, home mortgages, vehicle finance, student loans, corporate finance, and investment portfolio management and tracking tools. All products and services are subject to eligibility assessment, credit checks, and applicable regulatory approvals.

The information provided on our website is for general informational purposes only and does not constitute financial advice. You should seek independent financial advice before making any significant financial decision.

4. Loan Products — Key Terms

• All loan products are subject to status and affordability assessment. Eligibility is not guaranteed.
• Annual Percentage Rates (APR) shown on our website are representative. Your actual rate may differ based on your credit profile and the product applied for.
• Loan calculators are provided for illustrative purposes only. They do not constitute a loan offer or quotation.
• Missing repayments can result in late payment charges, an adverse impact on your credit file, and legal action in extreme circumstances.
• For secured loans (including mortgages), your property or asset may be repossessed if you do not maintain repayments.
• You have the right to repay any loan early. Please refer to your individual loan agreement for early repayment terms.

5. Investment Services — Key Terms

• The value of investments can go down as well as up. You may get back less than you invest.
• Past performance is not a reliable indicator of future results.
• Our investment tracking tools are provided for informational purposes and do not constitute regulated investment advice under MiFID II unless explicitly stated.
• Fernandes Capital does not guarantee returns on any investment product. Investment decisions are made at the client's own risk.
• Tax treatment of investments depends on individual circumstances and may be subject to change.

6. Website Use

You agree to use our website only for lawful purposes and in a way that does not infringe the rights of others. You must not:

• Use the website in any way that breaches applicable local, national, or international law or regulation.
• Transmit unsolicited commercial communications (spam).
• Attempt to gain unauthorised access to any part of our website, systems, or networks.
• Reproduce, duplicate, copy, or resell any part of our website in contravention of these Terms.
• Submit false, misleading, or fraudulent information in any application or enquiry form.

7. Intellectual Property

All content on this website — including text, images, graphics, logos, icons, data, and software — is the property of Fernandes Capital or its content suppliers and is protected by Brazilian and international copyright and intellectual property laws. You may not reproduce, distribute, or commercially exploit any content without our prior written consent.

8. Limitation of Liability

To the fullest extent permitted by law, Fernandes Capital shall not be liable for any direct, indirect, incidental, special, or consequential damages arising from your use of our website or services, including but not limited to financial losses, loss of data, or loss of business opportunity. This does not exclude liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation.

9. Anti-Money Laundering & Fraud Prevention

Fernandes Capital is legally required to carry out identity verification (Know Your Customer) and anti-money laundering checks on all clients. We may share your data with fraud prevention agencies and law enforcement bodies where required by law. Any attempt to use our services for money laundering, fraud, or other financial crime will be reported to the relevant authorities and may result in criminal prosecution.

10. Complaints Procedure

If you are dissatisfied with any aspect of our service, you should first contact us directly:

We will acknowledge your complaint within 2 business days and provide a final response within 8 weeks. If you remain dissatisfied with our response, Clients may refer complaints to the Brazilian PROCON or the CVM Ombudsman at cvm.gov.br.

11. Governing Law

These Terms and any dispute or claim arising out of or in connection with them or their subject matter shall be governed by and construed in accordance with the laws of the Federative Republic of Brazil. However, Brazilian consumers are also protected under the Consumer Defence Code (CDC – Law No. 8,078/1990).

12. Contact Us

If you have any questions about these Terms and Conditions, please contact us: