1. Information We Collect

We may collect:

• personal information,
• contact details,
• investor qualification data,
• KYC/AML documentation,
• financial information,
• communication records,
• device and browser information,
• IP addresses, and website usage data.

2. Use of Information

Collected information may be used for:

• investor verification,
• compliance procedures,
• due diligence,
• transaction evaluation,
• operational communications,
• platform administration,
• cybersecurity monitoring,

legal obligations, and risk management.

3. Confidentiality and Security

We implement commercially reasonable administrative, technical, and organizational measures designed to protect confidential and sensitive information.
However, no digital transmission, communication channel, or storage system can be guaranteed to be completely secure.

4. Information Sharing

We do not sell personal information.

Information may be shared with:

• legal advisors,
• compliance providers,
• financial institutions,
• regulators,
• strategic partners,
• service providers,
• auditors, and governmental authorities where required.

5. Compliance Obligations

We may disclose information where required by:

• applicable law,
• court order,
• regulatory inquiry,
• AML/KYC obligations,
• sanctions compliance,
• fraud prevention, or governmental authority.

6. International Data Transfers

Information may be processed, transferred, and stored in multiple jurisdictions, including the Federative Republic of Brazil and other applicable international jurisdictions where operational, compliance, or service-related activities are conducted.
Users acknowledge and consent to cross-border data processing and transfer in accordance with applicable laws and regulations.

7. Cookies and Analytics

This website may use:

• cookies,
• analytics technologies,
• security monitoring tools, and performance tracking systems.

Users may disable cookies through browser settings, although certain website functionality may be affected.

8. Data Retention

Information may be retained for:

• legal obligations,
• compliance purposes,
• dispute resolution,
• transaction records,
• operational requirements,
• cybersecurity monitoring, and internal risk management.

9. No Guarantee of Security

While commercially reasonable security measures are implemented, The Rossa Group LLC does not guarantee absolute protection against:

• cyberattacks,
• unauthorized access,
• data breaches,
• infrastructure failures,
• or third-party security incidents.

Users acknowledge these inherent technological risks.

10. User Rights

Subject to applicable law, users may request:

• access to personal information,
• correction of inaccurate information, or deletion of certain data.

Requests may be subject to legal, regulatory, contractual, or compliance limitations.

11. Third-Party Services

This website may contain links, integrations, or references to third-party services or platforms.
The Company is not responsible for the privacy practices, policies, or security measures of third parties.

12. Governing Jurisdiction

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Federative Republic of Brazil.
Any disputes relating to privacy, data protection, or platform usage shall be subject to the exclusive jurisdiction of the competent courts of the Federative Republic of Brazil.

13. Policy Updates

The Company reserves the right to modify or update this Privacy Policy at any time without prior notice.
Continued use of the website constitutes acceptance of updated policies.