PRIVACY NOTICE | ECHOES CAPITAL
Last updated on: 05/13/2025
1. INTRODUCTION
Echoes Capital is committed to the privacy of its clients, complying with applicable legislation, especially the General Data Protection Law – LGPD (Law 13.709/2018 or “LGPD”) and its updates and/or regulations. For the purposes of the LGPD, ECHOES CAPITAL SECURITIZADORA S.A., registered under CNPJ/MF No. 48.845.217/0001-29, headquartered in São Paulo, SP, at Avenida Presidente Juscelino Kubitschek, No. 1,327, 4th floor, International Plaza II, Vila Olímpia, ZIP 04543-011 (“Echoes Capital” or “We”), is the controller of your personal data.
This Privacy Notice describes the personal data processing activities we may carry out in relation to clients who contract, use or access our products, services, website and/or app, and third parties who have carried out any transaction with Echoes Capital and/or with one of our clients.
2. HOW WE COLLECT YOUR PERSONAL DATA
We may collect your personal data when you:
● Contract our products and/or services;
● Use our websites and/or apps;
● Contact us;
● Carry out a transaction with our clients.
3. PERSONAL DATA PROCESSED
According to the LGPD, personal data is information related to an identified or identifiable natural person. We may process the following personal data:
● Registration data: full name, ID number (RG), CPF (taxpayer number), phone number, email, address, and date of birth.
● Financial data: account number, bank branch, bank name, bank statements, PIX keys, income tax returns, and other financial data.
● Browsing data: IP address, device ID, and other user identifiers while browsing (e.g., cookies – see section 4 of this Privacy Notice).
4. USE OF COOKIES
Cookies are files or information that may be stored on your devices when you visit our websites and/or apps. Generally, a cookie contains the name of the website that created it, its lifespan, and a value generated randomly.
Echoes Capital uses cookies to facilitate use and improve our websites and/or apps, including tailoring them to your interests and needs. Cookies may also be used to speed up your future activities and experiences on our websites and/or apps.
Types of Cookies and What They Do:
Necessary: These cookies are essential for our websites and/or apps to load correctly and function properly.
Performance: These cookies collect information about your interactions with our websites and/or apps, indicating the areas visited, time spent on the site, and any issues encountered.
Functional: These cookies allow our websites and/or apps to remember your preferences, providing you with a more personalized experience. They also enable the use of certain tools such as videos and interactive fields on our websites and/or apps.
Marketing: These cookies are used to deliver advertising content that is relevant to you, as well as to measure the effectiveness of advertising campaigns on our websites and/or apps. They also track the pages you visit.
You can delete cookies at any time using your browser settings. Each browser has its own guidelines for managing cookies. If you do not accept certain cookies, some services offered on our websites and/or apps may not function properly.
5. PURPOSES OF DATA PROCESSING
We may process your personal data for the following purposes:
● To carry out our activities and provide the products and/or services you contracted;
● To create and update your profile on our websites and/or apps;
● To provide support related to our products and/or services;
● To identify, authenticate, and verify requirements for contracting our products and/or services;
● To create and analyze your credit profile;
● To carry out credit assignment and other financial operations;
● To investigate, prevent, and combat fraud, financial crimes, and other unlawful acts;
● To perform marketing, prospecting, research, and promotion of our products and/or services;
● To comply with legal, regulatory, and/or self-regulatory obligations;
● To comply with court, administrative, and arbitration orders and decisions.
6. SHARING PERSONAL DATA
Your personal data may be shared with third parties in the following cases. Sharing will occur to the extent necessary to achieve the purposes described in this Notice:
Authorities and regulatory bodies
To investigate, prevent, and combat fraud, financial crimes, and other unlawful acts;
To comply with legal, regulatory, and/or self-regulatory obligations;
To comply with court, administrative, and arbitration orders and decisions.
Business partners, service providers, and other third parties
To comply with legal, regulatory, and/or self-regulatory obligations;
To comply with court, administrative, and arbitration orders and decisions;
To carry out credit assignment and other financial operations.
7. YOUR RIGHTS AS A DATA SUBJECT
According to the LGPD, you have the following rights:
● Confirmation and access – You may request confirmation of whether Echoes Capital processes your personal data and, if so, request access, including copies of records.
● Correction of incomplete, inaccurate, or outdated data – If you notice your data is incomplete, incorrect, or outdated, you can request correction or update.
● Anonymization, blocking or deletion of data – You may request the anonymization, blocking, or deletion of data deemed excessive for its purpose.
● Data portability – You can request your data be transferred to another service provider.
● Information about sharing – You may ask for detailed information on public and private entities with which your data has been shared.
● Information about the option to deny consent – If your consent is required for a specific activity, you can request clarification on the consequences of denying it.
● Revocation of consent – You can withdraw your consent at any time, which will not affect previous lawful processing.
● Deletion of data processed based on consent – You may request the deletion of data processed with your consent, as long as it is not required for other legal purposes.
● Objection to data processing – If you disagree with any data processing purpose, you may object and request it be stopped.
● Review of automated decisions – You may request a review of automated decisions that affect your interests. Echoes Capital ensures its technologies follow legal and ethical standards.
To exercise your rights, contact our Data Protection Officer through the channel mentioned in section 11 of this Notice.
For your security, Echoes Capital may request additional information and/or documents to verify your identity before fulfilling requests. In some cases, Echoes Capital may have legitimate grounds to deny a request, including the protection of trade secrets or compliance with legal obligations.
Echoes Capital will respond to requests within a reasonable time, in accordance with applicable law.
8. STORAGE AND DELETION OF PERSONAL DATA
Your personal data will be retained for as long as necessary to fulfill the purposes for which it was collected. Since these purposes include audits, legal or regulatory obligations, and exercising rights, some data may be retained even after your relationship with us ends. Once there is no further need to keep your data, it will be anonymized or deleted.
9. SECURITY
As the data controller, Echoes Capital adopts technical and administrative security measures to protect your personal data against unauthorized access, and accidental or unlawful situations of destruction, loss, alteration, disclosure, or any improper or illegal processing.
While we strive to safeguard your data, we cannot guarantee complete security. Unauthorized access, hardware or software failures beyond Echoes Capital’s control, and other external factors may compromise data security. Your role is essential in maintaining a secure environment. If you become aware of any security issues, please contact us
10. CHANGES TO THIS NOTICE
Echoes Capital continuously improves this Notice, which may result in updates to its terms. Any changes will become valid, effective, and binding upon being published on Echoes Capital’s websites and/or apps.
If a change materially affects the terms and conditions, Echoes Capital will provide a notice on its website and/or apps inviting you to review the updated version.
11. CONTACT THE DATA PROTECTION OFFICER
If you have any questions and/or need to contact us, please reach out to our Data Protection Officer, Jose Luis Camargo de Oliveira Junior, via the following email: