Privacy Policy

1. Information We Collect

We only collect information that you voluntarily provide to us or that is collected automatically through your interaction with the Site.

• Personal Information: We collect information you provide via our contact form or newsletter sign-up fields, such as your name and email address.
• Usage Data: Our servers automatically collect information when you access the Site, such as your IP address, browser type, operating system, and the specific pages you view.
• Cookies and Analytics Technologies: We use cookies and analytics technologies (Google Analytics and Google Tag Manager) to analyze site traffic and improve your experience. See Section 6 for full details on these technologies and how to opt out.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Communication: To respond to your comments, questions, or requests for information.
• Marketing and Newsletters: We will only send you newsletters and promotional materials if you have provided explicit, affirmative opt-in consent at the time of sign-up, in compliance with CASL. You can opt-out at any time by clicking the "unsubscribe" link in any email we send you.
• Site Optimization: To analyze how visitors use the Site so we can improve our content and functionality.
• Legal Compliance: To comply with applicable Canadian federal and provincial laws, regulations, or legal requests.

3. Third-Party Disclosure & Service Providers

We do not sell, trade, or rent your personal information to third parties for their own marketing purposes. We may share your information with trusted Service Providers who help us operate our business, such as email marketing platforms and hosting and analytics providers. These parties are contractually obligated to keep your information confidential and secure.

Please note that your data may be processed or stored on servers located outside of your province or country, including in the United States. As our operating entity is located in Brazil, all data processed through our systems crosses international borders.

3A. Cross-Border Data Transfers (Quebec Law 25)

In accordance with Quebec Law 25, before communicating personal information outside Quebec, we conduct a Privacy Impact Assessment (PIA) to confirm that the information will receive adequate protection in the destination jurisdiction. All third-party service providers who handle Quebec residents' personal information outside of Quebec are bound by contractual clauses that meet Law 25 requirements.

If you are a Quebec resident and wish to know which third parties receive your personal information, please contact our Privacy Officer at the address listed in Section 10.

4. Your Privacy Rights

In accordance with PIPEDA and Quebec Law 25, you have the right to:

• Access, update, or correct your personal information.
• Withdraw consent for data processing at any time.
• Request data portability — receiving your data in a structured, commonly used technological format.
• Request deletion or anonymization of your personal information, subject to legal retention requirements.
• Opt-out of promotional communications at any time.

4A. Right to De-indexation and Cessation of Dissemination (Quebec Law 25)

Quebec residents have the right to request that we cease disseminating their personal information or de-index any hyperlink associated with their name that provides access to such information, where dissemination causes injury or violates the law or a court order. To exercise this right, please contact our Privacy Officer.

4B. How to Submit a Request

To exercise any of the rights above, please contact our Privacy Officer (see Section 10). We will acknowledge your request and respond within 30 days of receipt, as required by Law 25. In certain complex cases, we may extend this period and will notify you accordingly.

5. Children's Privacy

FinanceNap does not knowingly collect personal information from individuals under the age of 14. In compliance with Quebec Law 25, if a user appears to be under 14, we will seek consent from a parent or legal guardian before collecting any personal information. If you believe a child has provided us with personal information without proper consent, please contact us and we will delete it promptly.

6. Cookie Policy

When you visit financenap.com, certain technologies automatically collect information about your device and browsing activity. This section explains what technologies we use and how you can manage them.

6A. What Is a Cookie?

A cookie is a small data file placed on your device when you visit a website. Cookies can be session-based (deleted when you close your browser) or persistent (remaining on your device for a set period). They may collect information such as your IP address, browser type, device identifiers, pages visited, and time spent on the Site.

6B. Technologies We Use

• Essential Cookies: Required for basic site functionality such as navigation and page loading. These are necessary to deliver the service and cannot be disabled without affecting site performance.
• Analytics Cookies — Google Analytics: We use Google Analytics to understand how visitors interact with the Site, including pages viewed, time spent, and general geographic area. Google Analytics collects data such as your IP address (anonymized), browser type, device type, and browsing behavior on the Site. This data is processed by Google and is subject to Google's Privacy Policy. We use this data solely to improve our content and user experience, and we do not use it to identify individual visitors personally.
• Tag Management — Google Tag Manager: We use Google Tag Manager to manage and deploy the analytics scripts described above. Google Tag Manager itself does not collect personal information; it is a technical tool that controls when and how other tags (such as Google Analytics) are loaded on the Site.

6C. How to Manage or Disable Cookies

You have several options to control or limit how cookies are used when you visit our Site:

• Browser Settings: Most web browsers allow you to control cookies through their settings. You can instruct your browser to refuse all cookies or to alert you when a cookie is being sent. For guidance, visit www.allaboutcookies.org. Please note that disabling cookies may affect the functionality of certain parts of financenap.com.
• Google Analytics Opt-Out: You can prevent Google Analytics from collecting your data by installing the Google Analytics Opt-out Browser Add-on. This add-on instructs the Google Analytics JavaScript to prevent your visit information from being sent to Google Analytics.
• Do Not Track: Some browsers include a "Do Not Track" (DNT) feature. Our Site does not currently alter its data collection practices in response to DNT signals, as no uniform standard for DNT has been established.

7. Data Retention & Destruction

In accordance with Quebec Law 25, we retain personal information only for as long as necessary to fulfill the purposes for which it was collected, and no longer than permitted or required by law. Our retention practices are as follows:

• Contact Form Submissions: Retained for up to 12 months following the resolution of your inquiry, then deleted or anonymized.
• Newsletter Subscriber Data: Retained for as long as you remain subscribed. Upon unsubscribing, your data will be deleted or anonymized within 30 days.
• Usage and Analytics Data: Retained for up to 26 months in aggregated or anonymized form.

Once the retention period ends, personal information is securely deleted or anonymized so that it can no longer identify an individual.

8. Data Security

We implement administrative and technical safeguards, including encryption and secure servers, to protect your data. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

8A. Data Breach Notification

In the event of a confidentiality incident (data breach) involving personal information that poses a risk of serious injury to individuals, we will, in accordance with Quebec Law 25 and PIPEDA:

• Notify the affected individuals as soon as reasonably possible.
• Notify the Commission d'accès à l'information du Québec (CAI) using the prescribed form.
• Maintain a register of all confidentiality incidents, which may be provided to the CAI upon request.
• Take immediate steps to reduce the risk of harm and prevent further incidents.

9. Changes to This Privacy Policy

We reserve the right to update this policy at any time. Changes are effective upon posting. We encourage you to review this policy periodically.

For material changes that affect how we collect, use, or disclose your personal information, we will provide advance notice by email to subscribers and by a prominent notice on the Site. Continued use of the Site after notification of a material change constitutes your acceptance, unless re-consent is required by law.

10. Privacy Officer & Company Information

In compliance with PIPEDA and Quebec Law 25, we have appointed a Privacy Officer responsible for overseeing our data protection practices and handling privacy-related requests and complaints.

For any questions about this Privacy Policy or to exercise your rights, please contact us:

• Web Form: financenap.com/ca/contact/
• Entity: Producentric LTDA
• Address: Av. Paulista, nº 777, Andar 15, Conjunto 15, Sala 1447 – Bairro Bela Vista, São Paulo – SP – Brasil, CEP: 01311-914

Regulatory Contacts

If you are dissatisfied with our response to a privacy concern, you may contact the applicable regulator:

• Federal (PIPEDA): Office of the Privacy Commissioner of Canada — www.priv.gc.ca
• Quebec (Law 25): Commission d'accès à l'information du Québec (CAI) — www.cai.gouv.qc.ca