NOTICE ON PERSONAL DATA PROTECTION

Casa de Investimentos is a financial intermediary dedicated to carrying out financial intermediation activities, within the scope of which it is required to process a number of clients' personal data.

Casa de Investimentos only processes the personal data necessary to provide its services in the best possible way, complying with the terms of the contracts it enters into, as well as the obligations imposed on it by law or regulation and sharing exclusive information content with its clients and potential clients.

Customer information may be collected through documents drawn up for this purpose or by visiting our website, using our services or viewing our online advertisements. The information collected by the online means indicated is anonymous and does not allow the customer to be identified, as described in the Cookies Policy.

As part of its professional activity, Casa de Investimentos processes the following personal data:

a)     Identification data (such as name, date of birth, gender, nationality, place of birth, identification document number, tax number, passport number);

b)     Contact details (such as address, telephone number, email address);

c)      Data on professional activity (such as profession, employer, past professional experience, level of training, remuneration, etc.);

d)     Family data (such as marital status, number of children, etc.);

e)     Data on financial situation (such as approximate amount of assets, regular income, source of regular income);

f)       Data on the investment objectives (such as the period over which it is intended to invest, the type of results sought);

g)     Contractual data (such as customer number, contract number).

Casa de Investimentos does not process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, nor genetic data, biometric data, health data or data relating to a person's sex life or sexual orientation.

Casa de Investimentos does not process personal data related to criminal convictions and offences, unless such processing is required and, to that extent, authorized by the applicable legislation and/or regulations.

Casa de Investimentos processes the personal data of its clients when it is necessary for the following purposes:

a)     Execution of contracts or pre-contractual steps;

b)     The fulfilment of legal obligations to which Casa de Investimentos is bound.

The processing of personal data is also justified if:

a)     It is necessary for the defence of the vital interests of the clients or the vital interests of another natural person;

b)     It is necessary for the protection of the legitimate interests pursued by Casa de Investimentos or by third parties, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of the personal data in question, prevail over them.

Casa de Investimentos only processes personal data based on the client’s consent for specific purposes, namely to send opinion articles, newsletters, interviews and invitations to initiatives promoted by Casa de Investimentos.

Casa de Investimentos undertakes to always keep clients updated on the collection of their personal data, informing them specifically of the purpose(s) of the processing.

The owner of personal data processed by Casa de Investimentos has the rights described in the following points.

All your rights can be exercised through:

a)     E-mail to info@casadeinvestimentos.com;

b)     Letter to the address Rua Beato Miguel de Carvalho, 242, 4710-356 Braga, Portugal.

Whenever Casa de Investimentos collects your personal data, it informs you specifically about the rights related to the processing of the personal data collected.

You can ask Casa de Investimentos to confirm whether your personal data is being processed. If so, Casa de Investimentos guarantees you the right to access your personal data, and you can also access information about:

a)     The purposes of the data processing;

b)     The categories of personal data in question;

c)      The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or belonging to international organizations;

d)     When possible, the period envisaged for the retention of personal data or, if this is not possible, the criteria used to set this period;

e)     The right to request Casa de Investimentos to rectify, erase or limit the processing of your personal data, or the right to object to such processing;

f)       The right to lodge acomplaint with the National Data Protection Commission;

g)     If the data has not been collected from the data subject, the information available on the origin of such data;

h)     The existence ofautomated decisions, including the definition of profiles – should Casa deInvestimentos admit its use – and the relevant information regarding the underlying logic of this use, as well as the importance and expected consequences of such processing for the data subject.

The owner of personal data may request Casa de Investimentos to delete it whenever:

a)     The personal data is no longer necessary for the purpose for which it was collected or processed;

b)     Withdraws the consent on which the processing of the data is based, and there is no other legal basis for said processing;

c)      They exercise their right to object to the processing and there are no overriding legitimate interests justifying it;

d)     The personal data have been unlawfully processed; or

e)     The personal data must be erased in order to comply with a legal or regulatory obligation to which Casa de Investimentos is subject.

The right to erasure does not apply when the processing of personal data is necessary:

a)     To the exercise of freedom of expression and information;

b)     To comply with a legal obligation of Casa de Investimentos that requires processing, provided for in an applicable legal or regulatory rule; or

c)      or the purposes of declaring, exercising, or defending a right in legal proceedings.

The owner of the personal data may request the restriction of the processing oftheir data, the processing in question being dependent on their consent,whenever:

a)     They have contested the accuracy of the personal data, for a period that allows Casa de Investimentos to verify its accuracy;

b)     The processing of the data is unlawful and the data subject has objected to the erasure of the data, requesting instead that its use be restricted;

c)      Casa de Investimentos no longer needs the personal data for processing purposes, but the data has been requested by Casa de Investimentos for the purposes of declaring, exercising or defending a right in legal proceedings;

d)     The data subject objects to the processing of personal data, and the restriction of the processing of personal data is put into effect until it is proven that Casa de Investimentos' legitimate reasons prevail over theirs.

The processing of personal data subject to limitation under the exercise of this right is not subject to the consent of the data owner when it is concerned with its maintenance, the declaration, exercise, or defence of a right in legal proceedings, the defence of the rights of another natural or legal person, or weighty reasons of public interest.

The owner of the personal data may ask Casa de Investimentos to make the data provided available to them or directly to a new data controller, in a structured, commonly used and machine-readable format. To this end, this portability must be technically possible, and it is also required that:

a) The processing is based on the consent of the data owner or on a contract whose execution or the carrying out of pre-contractual procedures has given reason to the provision of their personal data; and

b) The processing is carried out by automated means.

In general, Casa de Investimentos does not process personal data using exclusively automated processes.

Notwithstanding, Casa de Investimentos informs you that you have the right not to be subject to any decision taken exclusively by automated means, including profiling, which is likely to have an effect on your legal sphere or affect you in a similar way.

The right not to be subject to exclusively automated individual decisions may have exceptions, if the decision in question:

a) Is necessary for the conclusion or execution of a contract between the respective owner and Casa de Investimentos;

b) Is authorized by applicable laws and regulations, in which appropriate measures are also provided for to safeguard the rights, freedoms and legitimate interests of the owner; or

c) Is based on their explicit consent.

In the cases provided for in points a) and c), Casa de Investimentos guarantees that the rights, freedoms and legitimate interests of the data owners are safeguarded, applying appropriate complementary measures, such as guaranteeing human intervention in the processing process, the right to express their point of view and to contest the decision taken.

The personal data provided to Casa de Investimentos by the respective data owner is shared by Casa de Investimentos, for the purposes set out in point 4, with entities that provide services to Casa de Investimentos, such as financial institutions or other institutions related to the capital market, or with public authorities, such as the portuguese Comissão de Mercado de Valores Mobiliários, the Bank of Portugal or the Judicial or Administrative Courts, or other public authorities in relation to which the obligation to communicate is provided for in applicable legislation or regulations.

In cases of transfer of personal data to countries or organizations located outside the European Union, whenever the European Commission has declared, by means of an adequacy decision, that that country guarantees a level of protection of personal data equivalent to that resulting from European Union legislation, the transfer of data will be based on that adequacy decision.

In cases where the transfer is made to countries or organizations located outside the European Union, for which there is no adequacy decision by the Commission, Casa de Investimentos implements appropriate safeguards to ensure the protection of your personal data, guaranteeing that you enjoy enforceable rights and effective legal remedies.

In the absence of an adequacy decision or adequate guarantees under the above terms, Casa de Investimentos may only transmit personal data to third countries or international organizations under the terms of the applicable laws and regulations, when one of the following conditions is met:

a) The data owner has explicitly given their consent to the planned transfer, after having been informed of the possible risks that may result for them from such transfers, due to the lack of an adequacy decision and adequate guarantees;

b) The transfer is necessary for the execution of a contract between the owner and Casa de Investimentos or of steps taken at the owner's request prior to the formation of the contract;

c) The transfer is necessary for the conclusion or execution of a contract, concluded in their interest, between Casa de Investimentos and another natural or legal person;

d) The transfer is necessary for important reasons of public interest, recognized in accordance with the applicable laws and regulations;

e) The transfer is necessary for the establishment, exercise or defence of a right in legal proceedings;

f) The transfer is necessary to protect vital interests of the data owner;

g) The transfer is carried out from a register which, as required by applicable laws and regulations, is accessible to the general public or to any person who can demonstrate a legitimate interest in it, but only to the extent that the conditions of access stipulated in these same applicable laws and regulations are met in the specific case.

Any doubts or questions regarding the processing or protection of your personal data should be reported to Casa de Investimentos using the following contact methods:

• Email: info@casadeinvestimentos.com

• Address: Rua Beato Miguel de Carvalho, 242, 4710-356 Braga, Portugal

• Telephone: +351 253 617 607