Privacy Policy

AtivoLabs ("we," "us," or "our") is a technology company that provides various products and services, including AssetLink, Linka AI, and Sócia. This Privacy Policy applies to all of our Services and describes:

• The types of information we collect about you
• How we use and process that information
• How we share your information with third parties
• Your rights regarding your personal information
• How we protect your information

We are committed to compliance with applicable privacy laws, including the European Union's General Data Protection Regulation (GDPR) and other privacy regulations worldwide.

To help you better understand this Privacy Policy, here are some key terms and their definitions:

• Personal Data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation performed on personal data, such as collection, recording, organization, storage, use, or disclosure.
• Data Controller: The entity that determines the purposes and means of processing personal data. AtivoLabs is the data controller for the personal data we collect through our Services.
• Data Subject: The individual to whom the personal data relates (you, our user).
• Cookies: Small text files stored on your device that allow websites to remember information about your visit.

We collect several types of information from and about users of our Services:

3.1 Information You Provide to Us

You may provide us with personal information when you:

• Create an account or register for our Services
• Complete forms on our websites or applications
• Subscribe to newsletters or marketing communications
• Contact our customer support team
• Participate in surveys, promotions, or other activities
• Make transactions or investments through our platforms

The types of information you may provide include:

• Contact information (name, email address, phone number, postal address)
• Account credentials (username, password)
• Financial information (payment card details, bank account information)
• Identity verification information (date of birth, identification documents)
• Profile information (profile picture, professional background, preferences)
• Communications and correspondence with us

3.2 Information We Collect Automatically

When you interact with our Services, we may automatically collect certain information, including:

• Device information (IP address, device type, operating system, browser type)
• Usage data (pages visited, time spent on pages, links clicked)
• Location information (approximate location based on IP address)
• Log data (access times, error reports)
• Cookies and similar tracking technologies

3.3 Information From Third Parties

We may receive information about you from third parties, such as:

• Identity verification services
• Financial partners and payment processors
• Business partners and service providers
• Publicly available sources
• Social media platforms (if you connect your social media accounts to our Services)

We use the information we collect for various purposes, including:

4.1 Providing and Improving Our Services

• Create and manage your account
• Process your transactions and investments
• Provide customer support and respond to your inquiries
• Maintain and improve our Services
• Develop new features, products, and services
• Monitor and analyze usage patterns and trends

4.2 Personalization and Communication

• Personalize your experience with our Services
• Recommend features or content that may interest you
• Send you service-related notifications and updates
• Communicate with you about products, services, promotions, and events
• Respond to your comments and questions

4.3 Legal and Security Purposes

• Verify your identity and prevent fraud
• Comply with legal obligations and regulatory requirements
• Enforce our Terms of Service and other agreements
• Protect our rights, property, and safety, as well as the rights, property, and safety of our users and others
• Detect, investigate, and prevent fraudulent transactions and other illegal activities

We process your personal information based on one or more of the following legal grounds:

• Your consent
• Performance of a contract with you
• Compliance with legal obligations
• Our legitimate interests, provided they do not override your fundamental rights and freedoms

We may share your information with the following categories of recipients:

5.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

• Payment processors and financial institutions
• Cloud hosting and data storage providers
• Customer support services
• Analytics providers
• Marketing and advertising partners
• Identity verification services

These service providers are required to protect your information and may only use it to provide services to us.

5.2 Business Partners

We may share your information with business partners with whom we jointly offer products or services. These partners are required to maintain the confidentiality of your information and are not permitted to use it for any purpose other than providing the specific products or services.

5.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court order, government request). We may also disclose your information to:

• Comply with legal obligations
• Protect and defend our rights or property
• Prevent or investigate potential wrongdoing in connection with our Services
• Protect the personal safety of users of our Services or the public

5.4 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information, as well as any choices you may have regarding your information.

5.5 With Your Consent

We may share your information with third parties when you have given us your consent to do so.

We do not sell your personal information to third parties.

We take the security of your personal information seriously and employ appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage.

Our security measures include:

• Encryption of sensitive data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and penetration testing
• Employee training on data protection and security
• Monitoring for suspicious activities and unauthorized access
• Secure data backup procedures

While we implement safeguards designed to protect your information, no security system is impenetrable, and we cannot guarantee the security of your information. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account.

Depending on your location, you may have certain rights regarding your personal information. These may include:

7.1 Access and Information

You have the right to request access to the personal information we hold about you and to receive information about how we process it.

7.2 Correction and Completion

You have the right to request that we correct inaccurate or incomplete personal information about you.

7.3 Deletion

You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

7.4 Restriction of Processing

You have the right to request that we restrict the processing of your personal information in certain circumstances, such as when you contest the accuracy of the information.

7.5 Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that information to another controller in certain circumstances.

7.6 Objection

You have the right to object to the processing of your personal information in certain circumstances, such as when we process your information for direct marketing purposes.

7.7 Withdrawal of Consent

If we process your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal.

7.8 Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

To exercise your rights, please contact us using the information provided in the "Contact Information" section below. We will respond to your request within the timeframe required by applicable law. In certain circumstances, we may need to verify your identity before processing your request.

Please note that some of these rights may be limited where we have compelling legitimate grounds or legal obligations to continue processing your personal information.

We retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In determining the appropriate retention period for personal information, we consider:

• The amount, nature, and sensitivity of the personal information
• The potential risk of harm from unauthorized use or disclosure of your personal information
• The purposes for which we process your personal information
• Whether we can achieve those purposes through other means
• Applicable legal, regulatory, tax, accounting, or other requirements

In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We are based in Portugal and operate internationally. Your personal information may be transferred to, stored, and processed in countries other than the country in which you reside. These countries may have data protection laws that are different from the laws of your country.

When we transfer your personal information to other countries, we take appropriate safeguards to ensure that your personal information receives an adequate level of protection, such as:

• Transferring to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission
• Implementing appropriate data transfer mechanisms, such as Standard Contractual Clauses approved by the European Commission
• Obtaining your explicit consent to the proposed transfer after informing you of the possible risks

By using our Services, you consent to the transfer of your personal information to countries outside your country of residence, subject to appropriate safeguards.

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to remove that information from our servers.

We and our third-party service providers use cookies, web beacons, and other tracking technologies to collect information about your browsing activities on our websites and applications. These technologies help us analyze trends, administer the website, track users' movements around the website, and gather demographic information about our user base as a whole.

11.1 Types of Cookies We Use

• Essential Cookies: These cookies are necessary for our websites and applications to function properly and cannot be switched off in our systems. They are usually only set in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms.
• Analytics Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our websites and applications. They help us know which pages are the most and least popular and see how visitors move around the site.
• Functionality Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
• Targeting Cookies: These cookies may be set through our website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

11.2 Managing Cookies

You can control and manage cookies in various ways. Most web browsers allow you to manage your cookie preferences. You can:

• Delete cookies from your device
• Block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies
• Set your browser to notify you when you receive a cookie

If you disable or refuse cookies, please note that some parts of our websites and applications may become inaccessible or not function properly.

For more information about cookies and how to manage them, visit www.aboutcookies.org or www.allaboutcookies.org.

Our websites and applications may contain links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Examples of third-party services we may integrate with include:

• Social media platforms (e.g., Facebook, Twitter, LinkedIn)
• Payment processors
• Analytics providers
• Marketing and advertising partners
• Customer support tools

These third parties may have their own privacy policies and terms that govern their use of your information.

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of any material changes by posting the updated Privacy Policy on our websites and applications, and we will update the "Last Updated" date at the top of this Privacy Policy.

If we make material changes to this Privacy Policy, we will provide additional notice, such as a prominent notice on our websites or applications, or by sending you an email notification, if appropriate.

We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

For users in the European Economic Area (EEA), we have appointed a Data Protection Officer who can be contacted at [email protected].

You also have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable law. For users in the EEA, you can find contact details for your local supervisory authority on the European Data Protection Board website.