Privacy Policy

1.1) The purpose of the Privacy and Personal Data Usage Policy is to demonstrate WM TRADING’s commitment to transparency in protecting the data provided by data subjects. 1.2) We do not share personal information with third parties without proper authorization and do not disclose any data that can identify users, except in the case of court orders or legal requirements. 1.3) This Policy covers how WM TRADING handles personally identifiable information collected directly through our website, client portal, registration forms, commercial negotiations, data automation and integrations. This data is stored in electronic databases via submitted forms or information received from emails, system integrations, and platform usage. 1.4) Acceptance of this Policy occurs when you access or use WM TRADING’s website, applications, or services. This indicates that you are aware of and fully agree with the way we use and process your information, in compliance with Brazil’s General Data Protection Law (LGPD), Law No. 13.709/2018.

2.1 Right to Revoke 2.1.1) Data subjects may request revocation of data use permissions once the legal data processing period has expired. 2.2 Right to Disclosure 2.2.1) WM TRADING does not disclose personal data, except by legal requirement or at the data subject’s request. 2.2.2) The data subject has the right to know, at any time, what data is being processed, how it is being used, and, when applicable, with whom it is shared, via prior request. 2.3 Right to Rectification 2.3.1) The data subject may request corrections to personal data, except for information included in Digital Certificates, which cannot be changed after issuance. 2.4 Right to Deletion 2.4.1) The data subject may request the complete deletion of personal data at any time, except for data that must be retained by legal obligation. 2.5 Right to Data Portability 2.5.1) Data portability requests will be evaluated individually by contacting: dpo@wmtrading.com.br

3. RESPONSIBILITIES OF DATA SUBJECTS

3.1) Data subjects must ensure that any personal information provided to WM TRADING is accurate, complete, and up to date.

5.1.1) In compliance with the LGPD, we provide the following information about the data controller:

6. HOW WE HANDLE YOUR PERSONAL DATA Our personal data is collected and used to provide you with a complete experience when you use our products and/or services through our website, platforms, or applications.

6.1 What data do we collect? 6.1.1) We may collect the following personal data during your registration or use of WM TRADING products and/or services:

6.2 For what purpose do we use your data? 6.2.1) The information requested from data subjects is necessary to acquire services and/or products, receive information, quotes and proposals, and access the platforms of WM TRADING. Its purpose is to provide the requested services to the data subject, in compliance with legal and regulatory obligations, including:

6.3 Do we collect data from children and adolescents? 6.3.1) WM TRADING does not intentionally collect data from children or adolescents under the age of 16. 6.3.2) Children under 16 must obtain parental or guardian consent before sharing data with WM TRADING. 6.3.3) We advise parents and guardians to monitor children or adolescents under the age of 16 to ensure they do not share data with WM TRADING without prior authorization.

6.4 How do we keep your personal data secure? 6.4.1) Personal information collected is stored with strict confidentiality and security standards, and no document, information, or record under WM TRADING’s custody is shared with third parties, except when:

6.4.2) WM TRADING does not sell personal data of the data subjects under its custody.

6.5 For how long do we store your data? 6.5.1) We store your data for the period necessary to fulfill the purposes for which it was collected.

6.5.2) For data related to holders of digital certification, data is stored for a minimum of 7 (seven) years from the expiration or revocation of the Digital Certificate.

6.5.3) Other information, including audit records, must be retained for at least 5 (five) years or as long as required by law to preserve rights, prevent fraud, and ensure legal security.

6.6 Third-Party Relationships This Privacy and Personal Data Usage Policy applies to WM TRADING in addition to the Information Security Policy and other institutional policies.

6.6.1) To fulfill the purposes listed in item 6.2 of this Policy, data may be shared with companies within the WM TRADING Group, as well as with service providers and suppliers, to meet the needs of the contracted products and/or services. These parties will be considered data processors.

7.1) WM TRADING reserves the right to change this Policy whenever necessary in order to provide data subjects with greater security and transparency. Whenever there are changes that require new authorizations, a new version will be published, subject to new consent.

8.1) This document shall be governed by and construed in accordance with Brazilian law. The Court of the District of Vitória, State of Espírito Santo, is hereby elected as competent to settle any questions arising from this document, expressly waiving any other, however privileged.

9.1) WM TRADING reserves the right to notify its clients of any information that affects the safety of the products or services provided. If you have any questions about this Privacy Policy or the practices of this website, please contact us at dpo@wmtrading.com.br.

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