Privacy Policy

We collect information necessary to provide our escrow and title services effectively and securely: PERSONAL IDENTIFICATION INFORMATION: • Full legal name and any aliases • Date of birth • Government-issued ID numbers (CPF, RG, passport, SSN, driver's license) • Nationality and country of residence • Photographs for identity verification CONTACT INFORMATION: • Email addresses • Phone numbers (mobile and landline) • Mailing addresses • WhatsApp and other messaging app identifiers FINANCIAL INFORMATION: • Bank account details • Tax identification numbers • Payment information • Transaction amounts and currency preferences • Source of funds documentation • Financial statements (when required) PROPERTY AND TRANSACTION INFORMATION: • Property addresses and descriptions • Title documentation and property records • Purchase and sale agreements • Contract terms and conditions • Transaction parties and their representatives PROFESSIONAL INFORMATION: • Employer information • Business registration details • Professional licenses • Attorney or agent authorization TECHNICAL INFORMATION: • IP address and device identifiers • Browser type and version • Operating system • Access times and dates • Pages visited and actions taken • Cookies and similar tracking technologies COMMUNICATIONS: • Email correspondence • Text messages and SMS communications • Phone call records (with consent) • Chat and messaging platform interactions • Document submissions and uploads We collect this information: • Directly from you when you provide it • From third parties such as government registries, title companies, and financial institutions • Automatically through our website and technology systems

We use your personal information for the following purposes: SERVICE DELIVERY: • Processing and managing escrow transactions • Conducting title searches and examinations • Verifying identities and authenticating parties • Coordinating with government agencies and registries • Facilitating document signing and notarization • Managing fund transfers and disbursements LEGAL AND REGULATORY COMPLIANCE: • Know Your Customer (KYC) verification • Anti-Money Laundering (AML) checks • Compliance with BACEN regulations • Tax reporting requirements (when applicable) • Court orders and legal obligations • Government agency requests • Record retention requirements COMMUNICATION: • Transaction status updates and notifications • Document requests and reminders • Appointment scheduling • Customer support and assistance • Service announcements • Marketing communications (with consent) BUSINESS OPERATIONS: • Quality assurance and training • Risk management and fraud prevention • Analytics and service improvement • Internal auditing and compliance monitoring • Dispute resolution • Business development and planning SECURITY: • Protecting against unauthorized access • Detecting and preventing fraud • Maintaining system security • Investigating suspicious activity • Ensuring transaction integrity

Under Brazilian LGPD, we process your personal data based on the following legal bases: • CONSENT: When you explicitly agree to processing for specific purposes (e.g., marketing communications) • CONTRACT PERFORMANCE: Processing necessary to fulfill our service agreement with you • LEGAL OBLIGATION: Compliance with Brazilian and international laws (KYC/AML, tax reporting, etc.) • LEGITIMATE INTERESTS: Our legitimate business interests, such as fraud prevention and service improvement, balanced against your rights • PROTECTION OF LIFE: In situations requiring immediate action to protect health or safety • CREDIT PROTECTION: For financial risk assessment when applicable You have the right to withdraw consent at any time where consent is the legal basis for processing. This will not affect the lawfulness of processing based on consent before withdrawal.

We may share your personal information with: SERVICE PROVIDERS AND PARTNERS: • Title insurance companies • Notaries and registry offices (cartórios) • Banks and financial institutions • Legal professionals and attorneys • Appraisers and inspectors • Document translation services • Technology service providers • Payment processors GOVERNMENT AND REGULATORY AUTHORITIES: • Brazilian Federal Revenue Service (Receita Federal) • Central Bank of Brazil (BACEN) • COAF (Conselho de Controle de Atividades Financeiras) • Real estate registries • U.S. regulatory authorities (when applicable) • Court orders and legal processes TRANSACTION PARTIES: • Other parties to your transaction (buyers, sellers, lenders) • Real estate agents and brokers • Legal representatives • Authorized agents and attorneys BUSINESS TRANSFERS: • In connection with mergers, acquisitions, or asset sales • To successors or assignees of our business We share information only: • With your consent • As necessary to provide our services • To comply with legal obligations • With appropriate confidentiality and security measures We do NOT sell your personal information to third parties for their marketing purposes.

Our services may involve transferring your personal information internationally, including: • Between Brazil and the United States • To other countries where transaction parties are located • To service providers in various jurisdictions When we transfer data internationally: • We ensure appropriate safeguards are in place • We comply with LGPD requirements for international transfers • We use standard contractual clauses or other approved mechanisms • We obtain consent when required For data transferred from Brazil, we ensure the destination country provides adequate data protection or implement additional safeguards.

We implement comprehensive security measures to protect your personal information: TECHNICAL SAFEGUARDS: • Encryption of data in transit and at rest • Secure servers and databases • Multi-factor authentication • Regular security assessments and penetration testing • Intrusion detection and prevention systems • Secure backup and disaster recovery procedures ORGANIZATIONAL MEASURES: • Access controls and role-based permissions • Employee training on data protection • Confidentiality agreements with staff and contractors • Data minimization practices • Regular security audits • Incident response procedures PHYSICAL SECURITY: • Secure office facilities with access controls • Protected document storage • Secure disposal of physical records Despite our security measures, no system is completely secure. We cannot guarantee absolute security, and you acknowledge the inherent risks of transmitting data electronically. In the event of a data breach affecting your personal information, we will: • Notify you promptly as required by law • Report to relevant authorities (ANPD in Brazil) • Take immediate steps to mitigate harm • Implement corrective measures

Under LGPD and applicable U.S. laws, you have the following rights: RIGHT TO ACCESS: • Request confirmation of whether we process your personal data • Access your personal data we hold • Receive copies of your data RIGHT TO CORRECTION: • Request correction of incomplete, inaccurate, or outdated data • Provide updated information RIGHT TO DELETION: • Request deletion of your personal data in certain circumstances • Subject to legal retention requirements RIGHT TO PORTABILITY: • Receive your data in a structured, commonly used format • Request transfer to another service provider RIGHT TO RESTRICT PROCESSING: • Object to certain processing activities • Limit how we use your data RIGHT TO WITHDRAW CONSENT: • Withdraw previously given consent at any time • Without affecting prior lawful processing RIGHT TO INFORMATION: • Know the entities with which we share your data • Understand the consequences of not providing consent RIGHT TO LODGE COMPLAINTS: • File complaints with the Brazilian ANPD (Autoridade Nacional de Proteção de Dados) • Contact relevant U.S. regulatory authorities To exercise your rights, contact us using the information in Section 14. We will respond within the timeframes required by law (typically 15 days under LGPD). LIMITATIONS ON RIGHTS: Your rights may be limited by: • Legal obligations requiring data retention • Legitimate interests that override your rights • Defense of legal claims • Protection of third-party rights

We retain your personal information for as long as necessary to: • Fulfill the purposes for which it was collected • Comply with legal and regulatory obligations • Resolve disputes and enforce agreements • Maintain business records RETENTION PERIODS: • Transaction records: Minimum 5 years from transaction completion (Brazilian law requirement) • KYC/AML documentation: 5-10 years as required by regulation • Tax-related information: As required by Brazilian and U.S. tax law • Financial records: Minimum period required by financial regulations • Marketing communications: Until you opt-out or withdraw consent • Website analytics: Typically 26 months After retention periods expire, we will: • Securely delete or destroy personal information • Anonymize data for statistical purposes • Maintain only what is legally required You may request deletion of your data before retention periods expire, subject to legal requirements.

Our website uses cookies and similar technologies to: • Enable essential website functionality • Remember your preferences and settings • Analyze website traffic and usage patterns • Improve user experience • Provide targeted content TYPES OF COOKIES WE USE: ESSENTIAL COOKIES: • Required for website operation • Cannot be disabled • Enable navigation and access to secure areas FUNCTIONAL COOKIES: • Remember your preferences (language, region) • Enhance functionality • Provide personalized experiences ANALYTICS COOKIES: • Measure website traffic and performance • Understand user behavior • Improve our services You can control cookies through your browser settings. Note that disabling cookies may affect website functionality. We do not use third-party advertising cookies or sell your browsing data.

When you provide your phone number, you consent to receive text messages from us regarding your transactions and services. MESSAGE TYPES: • Transaction updates and alerts • Document requests and reminders • Appointment confirmations • Security notifications • Service announcements • Marketing messages (with separate opt-in) COMPLIANCE: We comply with: • U.S. Telephone Consumer Protection Act (TCPA) • A2P 10DLC regulations • Brazilian telecommunications regulations YOUR RIGHTS: • Standard message and data rates apply • Message frequency varies based on transaction activity • Text "STOP" to any message to opt-out • Text "HELP" for assistance • Carriers are not liable for delayed or undelivered messages Opting out of text messages does not affect essential transaction communications via other channels.

We send emails for: TRANSACTIONAL EMAILS: • Transaction status updates • Document delivery • Payment confirmations • Account notifications • Security alerts MARKETING EMAILS: • Service announcements • Educational content • Special offers (with consent) COMPLIANCE: • We comply with CAN-SPAM Act and Brazilian regulations • All marketing emails include opt-out options • We honor opt-out requests promptly • Transactional emails cannot be opted out of To unsubscribe from marketing emails, click the "unsubscribe" link in any marketing email or contact us directly.

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child without proper parental consent, we will: • Delete the information promptly • Terminate any associated account • Notify appropriate parties If you believe we have collected information from a child, please contact us immediately.

We may update this Privacy Policy periodically to reflect: • Changes in our practices • New legal requirements • Service enhancements • Technological developments When we make material changes: • We will post the updated policy on our website • We will update the "Last Updated" date • We will notify you by email or other means • We will obtain new consent if required by law Your continued use of our services after changes constitutes acceptance of the updated Privacy Policy. If you do not agree with changes, you should discontinue use of our services.

For questions, concerns, or requests regarding this Privacy Policy or your personal information: DATA PROTECTION OFFICER: Email: privacy@banctitle.com Phone: [Contact Number] GENERAL INQUIRIES: Email: info@banctitle.com Address: [Business Address] REGULATORY CONTACTS: Brazil - ANPD: https://www.gov.br/anpd/ U.S. - FTC: https://www.ftc.gov/ We will respond to your inquiries within 15 days as required by LGPD, or within timeframes required by other applicable laws.

If you are in Brazil, you have the right to lodge a complaint with: ANPD - Autoridade Nacional de Proteção de Dados Website: https://www.gov.br/anpd/ Email: [ANPD Contact] For U.S.-based concerns, you may contact relevant federal or state authorities depending on the nature of your concern.

This Privacy Policy is provided in both English and Portuguese. In the event of any conflict between versions, the Portuguese version shall prevail for Brazilian residents and transactions, and the English version shall prevail for U.S. residents and transactions, except where law requires otherwise.