Terms & Conditions

Terms of Use

Thank you for accessing the website (“Site”) of Aveno Consultoria Ltda. and its affiliates (collectively, “Aveno”). 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 Aveno, 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 any misappropriation and other claims arising from or relating to your continued use of the Site after such breach.

Use of the Site

Aveno grants a limited right to use the Site, which is subject to your full 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 Aveno’s sole discretion, your right to use all or any 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 Aveno’s systems or networks, or any systems or networks connected to the Site or to Aveno.

This Site is owned by Aveno and is protected by copyrights, patents, database rights, trademarks, service marks and/or other intellectual property and proprietary rights that are owned by Aveno. 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 Aveno in writing.

Updates to the Site

Aveno 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. Aveno 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

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

Site Security

Aveno 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, circumventing, 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 artificial intelligence) to navigate or collect data from the Site in an automated and unauthorized manner; (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 personal information of third parties through 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 their password to any unauthorized person, and the users are solely responsible for maintaining the confidentiality and security of their password.

If you access Content through a password protected area, please note that the written agreements between you and the applicable Aveno 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 Aveno 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, Aveno should be notified immediately. Aveno 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 Aveno’s property and may be used for any lawful purpose. Aveno 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 Aveno’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, Aveno is not using the Site to provide investment or 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.

Aveno 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 Aveno uses reasonable efforts to obtain information from reliable sources, Aveno 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 Aveno’s 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 those 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.

Aveno does not provide any advice on the tax consequences of any investment.

Past Performance

For clarification purposes, past performance is not an indication of future results and Aveno 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

Aveno 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 Aveno 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 user’s 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 Aveno has been advised of or should have knowledge of the possibility of such damages.

Without limiting our general disclaimer, Aveno does 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

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

Aveno may report any activity that it suspects may violate any law or regulation to regulators, law enforcement officials or other persons or entities that it deems appropriate. Aveno may also issue warnings, 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 Aveno’s endorsement, sponsorship, affiliation or recommendation of the third party, its information, materials or services.

Submitting Materials or Confidential Information

Aveno receives a large number of business ideas and materials that we analyze, and we cannot accept the responsibility for protecting against misuse or disclosure of 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

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

Termination of Use

These Terms of Use are effective unless and until terminated by either the user or Aveno. The user may terminate these Terms of Use at any time by discontinuing to use the Site. Aveno 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 Aveno 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 agrees to indemnify and hold harmless Aveno 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 Aveno (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

Aveno may assign these Terms of Use 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 these Terms of Use, as well as any disputes relating to any of them, are governed by and construed in accordance with the laws of the Federative Republic of Brazil, and the courts of the Judicial District of São Paulo, State of São Paulo, are hereby elected to settle any disputes, with waiver of any other, however privileged it may be.

Contact Information

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

Privacy Policy

This Privacy Policy describes how Aveno Consultoria Ltda. and its affiliates (collectively, “Aveno”) collects, uses, discloses, updates, and protects the personal information provided to Aveno through its website at www.usevault.org or its subdomains (“Site”).

This Privacy Policy does not apply to personal information of Aveno’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 Aveno funds. By using or accessing this Site, you agree to comply with the terms and conditions set forth in this Privacy Policy.

The processing of personal data described in this Policy complies with Law No. 13,709/2018 (Brazilian General Data Protection Law – LGPD). The applicable legal bases are, as the case may be, Aveno’s legitimate interest (art. 7, IX) — for network security and aggregate audience measurement — and the adoption of preliminary procedures arising from the user’s voluntary contact (art. 7, V and IX). Mere access to the Site does not constitute consent to the processing of data beyond what is described herein.

Aveno 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 Aveno 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

This Site is institutional and informational. Browsing the Site does not require registration, login or password. The Site does not use tracking or advertising cookies and does not profile visitors. Aveno does not collect personal data (“Personal Information”) through the Site, except when the user voluntarily contacts it — for example, by email —, in which case only the Personal Information that the user provides will be processed, and only to the extent necessary to respond to the request.

As with any internet access, the Site’s hosting provider processes technical access logs — including the visitor’s IP address — exclusively for content delivery, network stability and security, in accordance with standard infrastructure-provider practice.

To measure traffic and performance, the Site uses an analytics tool that does not employ cookies and does not identify the visitor, collecting only aggregate and anonymous data (for example, most-visited pages, country of origin and browser type), without tracking the user across different websites.

Technical access logs are kept for the period necessary for security purposes and, where applicable, for the period set forth in art. 15 of the Brazilian Civil Rights Framework for the Internet (Law No. 12,965/2014), being subsequently deleted or anonymized.

Right to Share Information

Aveno does not sell Personal Information.

Aveno may share technical access logs (such as IP address) and any Personal Information provided by the user with service providers acting on its behalf and order (processors), for purposes of hosting, information security and storage, to the extent necessary for such purposes. Aveno does not share Personal Information with unaffiliated third parties for marketing purposes.

Part of the Site’s technical infrastructure may be located outside Brazil; any international data transfers observe the conditions and safeguards of art. 33 of the LGPD.

Aveno 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, Aveno may disclose Personal Information if it 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 misuse of the Site.

To conclude, Aveno 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 Aveno 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 connection with any acquisition, merger or sale of assets.

Information and Network Security

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

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

Rights of the Data Subject

Aveno 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 Aveno at compliance@usevault.org. Please note that any Personal Information that Aveno has copied may remain in back-up storage for some period of time after the user’s request, and that if the user deletes certain information he may not be able to use Aveno’s services in the future without re-submitting such information.

Pursuant to art. 18 of the LGPD, the data subject has the right, among others, to: confirmation of the existence of processing; access to the data; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the law; portability; information about the sharing of the data; and revocation of consent, where the processing is based thereon. The data subject may also file a complaint with the Brazilian National Data Protection Authority (ANPD). Users located outside Brazil may be subject to additional rights provided under applicable local legislation.

In case the user wishes to exercise any of the rights described above, please contact Aveno at compliance@usevault.org. It is important to note that Aveno will need to verify your identity and to do so, it will request that the user match specific pieces of information provided to Aveno previously, as well as, in some instances, provide a signed declaration 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, Aveno 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, Aveno may require additional proof of identification.

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

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

Third Party Website

The Site may contain links to other websites. Aveno is not and will not be responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urges 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@usevault.org. For the exercise of the rights provided under the LGPD and other matters relating to the protection of personal data, the user may also use this same channel.