PRIVACY POLICY

The ASA is committed to ensuring that its data processing operations are in line with best market practices and legal requirements.

Thus, in order to signal this institutional commitment to the fundamental right to privacy and its materialization in the right to the protection of personal data, considering the entry into force of Law No. 13,709 / 18 (General Data Protection Law - “LGPD”) , we present our “Privacy Policy”.

THIS POLICY SEEKS TO DEMONSTRATE:

• • the types of personal data we collect about you;

• • how we collect and use this data;

• • with whom your data may be shared;

• • your rights as a data subject.

WHAT ARE THE PRINCIPLES WE FOLLOW TO PROCESS DATA?

The ASA processes your personal data in accordance with the principles of good faith, purpose, adequacy, need, free access, data quality, security, prevention, non-discrimination and, most importantly, transparency.

WHAT ARE THE GROUNDS FOR THE TREATMENT OF YOUR PERSONAL DATA?

Any treatment of data carried out by the ASA will be based on at least one legal basis and will be carried out in an appropriate manner for the purpose of its collection.

The processing of your personal data will take place especially:

• (i) to comply with legal or regulatory obligations;

• (ii) to serve the legitimate interests of the ASA, its partners or third parties;

• (iii) in other cases, the processing of personal data will be conditioned to your consent.

DATA WE RECEIVE FROM YOU:

• • contact details: full name, e-mail, telephone number;

• • data for marketing actions and research - information and opinions gathered in research by the ASA.

HOW DO WE USE YOUR DATA?

he processing of your personal data may serve the following purposes:

• • confirm your identity and address;

• • guarantee your safety;

• • send marketing actions;

• • meet your requests through our service channels;

• • ensuring their proper identification and qualification, in accordance with current legislation.

WITH WHOM CAN WE SHARE YOUR DATA?

The ASA only shares your information when it is necessary or relevant for the purposes set out in this Privacy Policy, within strict security standards, always aiming at the confidentiality of your information and following data protection and privacy rules.

Examples of Sharing:

• • with strategic partners, including for offering, contracting and using their products and services, or jointly developed or that may have a benefit for you;

• • with distributors, brokers, for the development of our activities;

• • with regulatory bodies, other public entities, institutions of the financial system, including for the fulfillment and execution of legal, regulatory and contractual obligations and for the protection and regular exercise of rights;

• • sharing anonymized, grouped information, cookies or other information or forms that do not allow your personal identification;

• • situations in which your consent may be necessary and, if so, we will request your consent in due course.

HOW LONG DO WE KEEP YOUR DATA?

We will keep your data, at least, for as long as you have a relationship with us. After the end of this initial retention period, we will keep your data for as long as necessary to comply with regulatory obligations and current legislation.

WHAT PRECAUTIONS WERE IMPLEMENTED TO PROTECT YOUR DATA?

We adopt security measures for the treatment of all personal data collected, especially sensitive personal data. These measures, technical and organizational, have been implemented to prevent unauthorized access, accidental or intentional manipulation, loss or destruction of your personal data.

We periodically evaluate the security procedures adopted in order to guarantee the privacy of information. The information collected via the ASA Corporate Website is stored in the ASA Information System, having its integrity and availability guaranteed, and is handled only by authorized persons and for purposes pre-established by the ASA, in accordance with strict security and confidentiality standards.

It is important to note that the ASA does not send e-mails without your authorization. On the ASA Corporate Website, the user can learn about the institution's history, products and services and obtain information, without having to provide any personal data.

WHAT ARE YOUR RIGHTS AS A HOLDER OF THIS DATA?

The ASA will guarantee you, the holder of personal data, the exercise of the rights provided for in the applicable law, among them:

• • confirmation of the existence of the processing of your personal data;

• • access to this data;

• • correction of incomplete, inaccurate or outdated data;

• • anonymization, blocking or elimination of unnecessary, excessive or treated data in non-compliance with the LGPD;

• • portability of your personal data, upon express request;

• • obtaining information on public and private entities with which the ASA shares its data;

• • revocation of consent, when applicable.

Some of these rights still need to be detailed and regulated by the National Data Protection Authority - ANPD so that they can be adequately served by the ASA.

POLICY CHANGES

As privacy and data protection is a dynamic issue, we may modify this Policy at any time.

As we are always looking to improve our products and services, this Privacy Policy may undergo updates to reflect the improvements made. Therefore, we recommend that you visit this page periodically so that you are aware of the changes made.

Contact of the person in charge of processing personal data for the ASA

For more information about the processing of your personal data or the terms of this Policy, send an e-mail to our Personal Data Processing Officer (DPO): encarregado-dados@asainvestments.com.br.