DNA

Terms & Conditions

TERMS OF USE

Thank you for accessing the website (“Site”) of DNA Capital Consultoria Ltda. and its affiliates (collectively, “DNA Capital”). By using or accessing this Site, you hereby accept and agree to comply with the following terms and conditions (“Terms of Use”). These Terms of Use are a binding agreement between you and DNA Capital, which will govern your access of this Site, including any information, data, tools, products, services and other content (“Content”) available on or through this Site.

Each time you use the Site you accept and agree to abide by these Terms of Use in its current form and accordingly with the last updated version. Do not use the Site if you do not accept the Terms of Use stated herein. The breach of any provision of these Terms of Use may revoke and terminate your right to access the Site, notwithstanding you may be fully liable for conversion, misappropriation, and all other claims arising from or relating to your continued use of the Site after such breach.

Use of the Site

DNA Capital grants a limited right to use the Site, which is subject to your fully agreement to abide by these Terms of Use, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site. At any time and at DNA Capital sole discretion, your right to use all or portion of the Site may be revoked.

You may not take any action that imposes an unreasonable or disproportionately large load on the infrastructure of the Site or DNA Capital’s systems or networks, or any systems or networks connected to the Site or to DNA Capital.

This Site is owned by DNA Capital and is protected by copyrights, patents, database rights, trademarks, servicemarks and/or other intellectual property and proprietary rights that are owned by DNA Capital. You may not decompose, decompile, reverse engineer, disassemble or otherwise deconstruct all or any portion of the Site. You may not publish, broadcast, retransmit, reproduce, repackage, frame, commercially exploit, create any derivative of or otherwise redistribute all or any portion of the Site, except as explicitly permitted in these Terms of Use or by DNA Capital, by written.

Updates to the Site

DNA Capital reserves the right, at its sole discretion, to change, modify, add or remove any part of the Site, the Content and these Terms of Use at any time and without prior notice. For this reason, each time you use the Site, you should visit and review the then-current Terms of Use that are applicable. Following the posting of changes to the Terms of Use, your continued use of the Site shall be considered as an acceptance and agreement to the changes implemented. DNA Capital undertakes no obligation to update publicly or revise any information on the Site, whether as a result of new information, future developments or otherwise.

Portfolio

DNA Capital is the manager of different investment funds that invest directly in the portfolio companies described through this Site. DNA Capital does not hold any equity interest in the portfolio companies, acting exclusively as a service provider.

Site Security

DNA Capital prohibits any user from violating or attempting to violate the security of the Site, including, without limitation, (a) accessing data not intended for the respective user or logging onto a server or an account which the user is not authorized to access; (b) disabling, removing, defeating, or avoiding any security device or system, including, without limitation, any password and login functionality used to authenticate users; (c) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; (d) attempting to interfere with service to any user, host or network; (e) sending unsolicited email, including promotions and/or advertising of products or services; (f) using or attempting to use any engine, software, tool, agent or other device or mechanism (including, without limitation, browsers, spiders, robots, avatars or intelligent agents) to navigate or search the Site other than the search engine and search agents available on the Site; (g) reverse engineering, decompiling or disassembling the underlying software; (h) removing any notices, warnings, labels, annotations or instructions from any portion of the Site or any related material, including, without limitation, any patent, trademark, copyright, or other proprietary notices or license provisions; or (i) invading the privacy of, obtaining the identity of, or obtaining any personal information about any other user of the Site.

Password Protected Areas

Certain Contents may be made available through a password protected area on the Site, which is intended to be confidential and used only by the individual or entity to whom it was issued. The users are not allowed to disclose your password to any unauthorized person, and the users are solely responsible for maintaining the confidentiality and security of its password.

If you access Content through a password protected area, please note that the written agreements between you and the applicable DNA Capital entities, as well as any provisions set forth in those Contents, govern the parties’ respective rights and obligations with regard to those Contents.

Contents provided through a password protected area generally are confidential and subject to limitations on disclosure and use, and DNA Capital individuals and entities generally have limited liability with respect to the accuracy and completeness of such Contents.

In case of actual or suspected loss, theft or unauthorized use of password, DNA Capital should be notified immediately. DNA Capital is not obligated to inquire as to the authority or propriety of any use of or action taken under your password, and will not be responsible for any loss that arises from such use or action, or from the users failure to comply with these Terms of Use.

Intellectual Property

The users may download or copy Content only to the extent such download is expressly permitted in writing on the Site. No right, title or interest in any downloaded materials or software is transferred to the user as a result of any such downloading or copying. The user may not reproduce (except as noted above), publish, transmit, distribute, display, modify, sell or participate in any sale of or exploit in any way, in whole or in part, any of the Content, the Site or any related software.

Nothing on the Site shall be interpreted as granting any license or right to use any image, trademark, trade dress, logo or service mark on the Site. Anything transmitted to the Site becomes DNA Capital’s property and may be used for any lawful purpose. DNA Capital reserves all rights with respect to copyright and trademark ownership of all material on the Site and will enforce such rights to the full extent of the law. All trademarks and logos displayed on this website are the property of their respective owners, who may or may not be affiliated with DNA Capital’s organization.

No Offers or Reliance

All Content available on the Site is provided for informational purposes only, therefore it shall not be used or considered as an offer to sell or a solicitation of any offer to buy the securities or services. Although the Site may include investment-related information, DNA Capital is not using the Site to provide investment of other advice, and no information or material at the Site is to be deemed a recommendation to purchase, sell or hold any security or other investment, or is to be relied upon for the purpose of making or communicating investment or other decisions.

DNA Capital makes no representations that transactions, products or services discussed on the Site are available or appropriate for sale or use in all jurisdictions or by all investors. Those who access the Site do so at their own initiative and are responsible for compliance with local laws or regulations.

While DNA Capital uses reasonable efforts to obtain information from reliable sources, DNA Capital makes no representations or warranties as to the accuracy, reliability or completeness of any information or document at the Site. Certain information on the Site may contain forward-looking statements, which reflect DNA Capital views with respect to its operations and financial performance. Such forward-looking statements are subject to various risks and uncertainties and speak only as of the date on which they were made. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from this indicated in these statements.

In addition, no information, Content or other materials contained on the Site should be construed or relied upon as investment, legal, accounting, tax or other professional advice or in connection with any offer or sale of securities. Any transactions listed on the Site are included as representative transactions and are not necessarily reflective of overall performance.

DNA Capital does not provide any advisement on the tax consequences of any investment.

Past Performance

For clarifications purposes, past performance is not an indicative of future results and DNA Capital makes no representation that any investment will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.

Limitation of Liability

DNA Capital is not responsible for any damages or injury, including but not limited to special or consequential damages, that result from the use of (or inability to use) this Site, including any damages or injury caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft, destruction or unauthorized access to, or other computer malfunction. You acknowledge that DNA Capital provides the Contents on an “as is” and “as available” basis with no warranties of any kind. Your use of this Site and use or reliance upon any of the materials is made solely at your own risk.

Any Content downloaded or otherwise obtained through the Site is done at the users own discretion and risk and the user is solely responsible for any damage to his computer or other electronic system or loss of data that results from the download of any such Content. The foregoing limitation of liability will apply in any action, whether in contract, tort or any other claim, even if an authorized representative of DNA Capital has been advised of or should have knowledge of the possibility of such damages.

Without limiting our general disclaimer, DNA Capital do not warrant the availability, accuracy, completeness, timeliness, functionality, reliability, sequencing, or speed of delivery of the site or any part of the content.

Right to Monitor

DNA Capital has the right but not the obligation to monitor and record activity on the Site and respond as it deems appropriate. DNA Capital may monitor and record activity on the Site for any reason or for no reason and may investigate any complaint or reported violation of DNA Capital’s policies.

DNA Capital may report any activity that it suspects may violate any law or regulation to regulators, law enforcement officials of other persons or entities that is deems appropriate. DNA Capital may also issue warning, suspend or terminate use of the Site, deny access to all or part of the Site or take any other action that it deems appropriate.

Third Party Content

References on this Site to any names, marks, products or services of third parties, or hypertext links to third party sites or information or Content provided by third parties, are provided solely as a convenience to the users and do not constitute or imply DNA Capital’s endorsement, sponsorship, affiliation or recommendation of the third party, its information, materials or services.

Submitting Materials or Confidential Information

DNA Capital receives a large number of business ideas and materials that we analyze, and we cannot accept the responsibility for protecting those against misuse or disclosure any confidential or proprietary information or other materials in the absence of our express written agreement to do so. Any plans, information and other materials you submit in connection with this Site may be used or disclosed by us for any purpose and in any manner, as we determine in our sole discretion. Please consider this carefully before sending us any information or other materials that you deem confidential or proprietary.

Privacy Policy

DNA Capital’s Privacy Policy applies to use of this Site, and its terms are made a part of these Terms of Use by this reference. DNA Capital’s Privacy Police is available below.

Termination of Use

These Terms of Use are effective unless and until terminated by either the user or DNA Capital. The user may terminate these Terms of Use at any time by discontinuing to use the Site. DNA Capital may terminate these Terms of Use, at its sole discretion and at any time, and may do so immediately without notice by denying the user access to the Site. Upon any termination of these Terms of Use by either DNA Capital or the user, the respective user must promptly destroy all materials downloaded or otherwise obtained from the Site, as well as all copies of such materials, whether made under these Terms of Use or otherwise.

Indemnities

As a condition of the usage of the Site, the user agree to indemnify and hold harmless DNA Capital and its agents, employees and third party sources from and against any and all suits, claims, losses, demands, liabilities, damages, costs and expenses (including attorney’s fees), as incurred, arising from: (i) the use of the Site or related services; (ii) any violation of applicable law, statute, ordinance, regulation or any third party’s rights; (iii) any violation of these Terms of Use; (iv) claims asserted by third parties which, if proven, would place you in breach of representations, warranties, covenants or other provisions contained in these Terms of Use.

Representations and Warranties

You represent and warrant that: (i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these Terms of Use; (ii) you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of these Terms of Use; and (iii) you will not delete any Content.

Effect on Other Agreements

Nothing contained in these Terms of Use is intended to modify or amend any other written agreement you may have with DNA Capital (including, without limitation, any customer agreement, participation agreement or account agreement) (collectively, “Other Agreements”), if any, that may currently be in effect. In the event of any inconsistency between these Terms of Use and any Other Agreement, the Other Agreement will govern.

General Conditions

DNA Capital may assign these Terms of Use a in whole or in part at any time without the users’ consent. The user may not assign these Terms of Use or delegate any of his obligations under these Terms of Use. Any purported assignment of these Terms of Use in violation of its terms is void.

If any provision of these Terms of Use is found invalid or unenforceable, that provision shall be enforced to the maximum extent possible and the remaining provisions of these Terms of Use shall remain in full force and effect.

Governing Law

This Site, this Privacy Policy and this Terms of Use, as well as any disputes relating to any of them, shall be governed to the extent permitted by the applicable law.

Contact Information

Any questions, concerns or complaints regarding these Terms of Use should be sent to compliance@dnacapital.com.

PRIVACY POLICY

This Privacy Policy describes how DNA Capital Consultoria Ltda. and its affiliates (collectively, “DNA Capital”) collects, uses, discloses, updates, and protects personal information provide to DNA Capital through its website at www.dnacapital.com, www.dnacapital.com.br or its subdomains (“Site”).

This Privacy Policy does not apply to personal information of DNA Capital’s employees, job applicants, or contractors, whose data is the subject of a separate privacy policy notice or agreement. This Privacy Policy is provided in addition to any other privacy notices you may receive in connection with your investment in DNA Capital funds. By using or accessing this Site, you hereby consent to such use of your information and agree to comply with the following terms and conditions of this Privacy Policy.

DNA Capital reserves the right, at its sole discretion, to change, modify, revise, and update this Privacy Policy from time to time without prior notice. Any changes DNA Capital makes to this Privacy Policy will be posted on this page. For this reason, each time you use the Site, you should review the most recent version of the Privacy Policy. Following the posting of the updated version of this Privacy Policy, your continued use of the Site shall be considered as an acceptance and agreement to the changes implemented.

Collection of Information

To obtain access to the Site and to receive certain internet services, the user may be required to login and provide certain personal data and information about himself (“Personal Information”). DNA Capital uses Personal Information to fulfill its requests for internet services, as well as other products and services (“Internet Services”), to monitor and improve its Internet Services.

DNA Capital automatically collects certain Personal Information to help understand how the users navigate through the Internet Services. For example, each time the user visits the Site, DNA Capital may automatically collect the user’s IP address, browser and computer type, access time, the webpage from which the user came, and the webpage(s) that the user access during the use of this Site.

This Site uses “cookies”, which may automatically collect certain information and data to enable website performance and formatting. These cookies do not provide DNA Capital with any data analytics or enable behavioral advertising, however DNA Capital may use cookies to keep track of your use of the Internet Services, to validate your identity, to remember your password and preferences, to tailor the Internet Services to your account and to meet your interests by improving the quality of the Internet Services. Also, DNA Capital may log visitor IP addresses, device IDs and similar details for cybersecurity and other website maintenance functions.

Generally, the user can set his browser not to accept cookies or to notify if any cookie is sent, giving the user the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain Internet Services may not function properly.

DNA Capital does not knowingly collect information from minors nor targets the Site to minors.

Right to Share Information

DNA Capital do not sell Personal Information and have not done so for the 12 months prior to the effective date of this Privacy Policy.

DNA Capital may share IP addresses, device IDs, email addresses and similar Personal Information with service providers to perform functions in connection with this Site and DNA Capital’s IT infrastructure, such as operations, cybersecurity and storage. Personal Information shall not be shared with any unaffiliated third-parties for marketing purpose exclusively.

DNA Capital may disclose Personal Information to courts, governmental or non-governmental regulators, and to law enforcement when required by a valid subpoena or court order, or as otherwise permitted or required by law. Also, DNA Capital may disclose Personal Information if believes it is necessary in order to investigate, prevent or take action regarding inappropriate or illegal activities, fraud, or situations involving potential threats to the safety of any person or property, or inappropriate use of the Internet Services.

To conclude, DNA Capital may also disclose Personal Information to its parent company, subsidiaries, joint ventures, or other companies under common control or part of its economic group (in which case DNA Capital will require such entities to honor the terms and conditions of this Privacy Policy), and as part of a corporate transaction with a successor or affiliate or in connected with any acquisition, merger or sale of assets.

Information and Network Security

DNA Capital maintains operational policies to safeguard and provide reasonable security for its data networks. However, no security measures are infallible, therefore DNA Capital suggest all users to use caution when transmitting information over the internet.

Data minimization is a responsibility shared by the user and DNA Capital. Therefore, DNA Capital requests that third parties do not send DNA Capital’s information through the Site or via email or other electronic communications unless DNA Capital specifically requests or requires such information, by written.

Third Party Rights

DNA Capital has controls in place designed to ensure that the information available is relevant, accurate, and appropriate for the purposes used. If users believe that any Personal Information is inaccurate, please contact DNA Capital at compliance@dnacapital.com. Please note that any Personal Information that DNA Capital has copied may remain in back-up storage for some period of time after the user request, and that if the user deletes certain information he may not be able to use DNA Capital’ services in the future without re-submitting such information.

Individuals in certain jurisdictions may have data subject rights, which may include the right to: (i) request access to and rectification or erasure of their Personal Information; (ii) restrict or object to the processing of their Personal Information; and (iii) obtain a copy of their Personal Information in a portable format. Individuals may also have the right to lodge a complaint about the processing of Personal Information with a data protection authority. The rights described herein are not absolute and may not be applicable to all users.

In case the user whishes to exercise any of the rights described above, please contact DNA Capital at compliance@dnacapital.com. It is important to note that DNA Capital will need to verify your identity and to do so, it will request that the user match specific pieces of information provided to DNA Capital previously, as well as, in some instances, provide a signed declaration under penalty of perjury that the user is the individual whose personal information is the subject of the request.

If it is necessary to collect additional information from the user, DNA Capital will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, DNA Capital may require additional proof of identification.

The user may request through an authorized agent; however, DNA Capital will require written proof that the agent is authorized to act on the user behalf. DNA Capital will process the user’s request within the time provided by the applicable law.

Upon request, DNA Capital will delete all the Personal Information it has collected about you, except when the retention is necessary for DNA Capital to (i) comply with federal, state or local laws; (ii) exercise or defend legal claims; (iii) perform a contract between you and DNA Capital; (iv) maintain the functionality or security of DNA Capital systems; and/or (v) comply with or exercise rights provided by law.

Third Party Website

The Site may contain links to other websites. DNA Capital is not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information to such websites.

Contact Information

Any questions, concerns or complaints regarding this Privacy Policy should be sent to compliance@dnacapital.com.