Privacy

The Bank of New York Brazil Privacy Notice

Last updated: July 31, 2025

This privacy notice applies to BNY, BNY Mellon, and Bank of New York Mellon, corporate brands of The Bank of New York Mellon Corporation (collectively, "BNY," "we," "us"). These terms may be used to refer to the corporation as a whole and/or its various subsidiaries generally. This privacy notice explains how we collect, use, and share personal information in the course of our business activities, including:

We may change this notice from time to time to keep you up to date with legal requirements and the way we operate our business. Please check these pages regularly for the latest version of this notice. If we make material changes to this privacy notice, we will seek to inform you by means of a notice on our website or email ("Change Notice").

Important information about BNY:

The BNY entity responsible for your personal information will be the BNY member who originally collects information about you.

You can learn more about BNY at www.bny.com or by contacting us through the information in the Contact Us section.

WHAT PERSONAL INFORMATION WE COLLECT, WHEN AND WHY WE USE IT

In this section, you can learn more about:

The types of personal information we collect;
How we use personal information;
When we collect personal information;
The legal basis for using the personal information.

BNY Data Subjects

BNY collects information about you if you:

you are registered with or use one of our websites or online services;
you are a private customer or have a relationship with us;
represent one of our institutional clients;
work with us as a service provider; or
visit a BNY office or register to attend a BNY event.

Personal Information We Collect

The personal information we collect will fall into one of the following categories:

Your name and how to contact you	Basic contact information about you, including your subscription
Identification data, including unique descriptors	Government-issued identifiers, other unique identifiers such as date of birth, and personal descriptors that may identify you
Finance and transactions	Financial information about you, transaction information and credit information, account authentication data
Contractual data	Information collected as part of the products and services we provide to you
Sociodemographic information	Includes details about your job or profession, nationality, education
Technical Information	Data about devices and technology you use to access our services, including IP address
Behavioral	Information about how you use our products and services
Location	Data we receive about where you are
Communications	Information we capture through your communications with us, for example, telephone conversations, emails, and instant messages
Publicly available data	Details about you that are in public records and information about you that is openly available on the internet
Sensitive data categories	The law and other regulations treat some types of personal information, including health-related personal information, as special, and provide additional protections for it. We will only collect and use these types of data if the law permits us to do so

The personal information we collect will be used for one or more of the following purposes:

	What we use your information for	Base legal	Our legitimate interests
Manage your relationship with BNY	Managing our relationship with you or your company, for example, by figuring out how best to contact you Develop new ways to meet our customers' needs and grow our business, for example by seeking customer feedback or sharing our market research Develop and carry out marketing activities to keep our customers informed about our products and services Develop and manage our brand	Legitimate interests Consent (where required by law)	Find out which of our products and services might interest you and talk about them Communicate with you about BNY and our industry vision and provide thought leadership Seek your consent when we need it to contact you Keep our records up to date and honor your communication preferences
Develop, deliver and support our products and services	Deliver our products and services to individual and institutional clients Provide advice or guidance, for example, to support the use of our products and services Develop, test, and manage new and existing products and services Understanding how our customers use our products and services and those of other organizations, for example, through research and analytics Managing how we work with other companies that provide services to us and our customers, for example, our relationships with suppliers and service providers	Contractual obligation Legal obligation Legitimate interests Consent (where required by law)	Enable the development of our products and services and what we charge for them Define relevant customers for new products and services Ensure that we are able to effectively and efficiently comply with our legal and contractual obligations Comply with regulatory requirements
Administer the products and services we provide	Make and manage customer payments Manage and deliver treasury and investment products and services Manage fees, charges, and interest owed on customer accounts Collect and recover money that is owed to us Exercising our rights set out in agreements or contracts	Consent (where required by law) Contractual obligation Legitimate interests	Ensure that we are able to meet our contractual obligations effectively and efficiently Comply with regulatory requirements
Crime prevention and detection	Detect, investigate, report and seek to prevent fraud, financial crime and money laundering, for example through know-your-customer checks, anti-money laundering and terrorist financing checks and other identity checks Cumprir outras leis e regulamentos que se aplicam a nós, por exemplo, outros serviços financeiros ou legislação específica do país	Contractual obligation Legal obligation Legitimate interests	Ensure that we are able to meet our contractual obligations effectively and efficiently Comply with regulatory requirements
Proteger nossa marca, nossos negócios e os interesses de nossos clientes	Gerenciar o risco para nós e nossos clientes, por exemplo, por meio de pesquisa e análise estatística Responder a reclamações e procurar resolvê-las Cumprir as leis, exigências legais e regulatórias internacionais que possam nos afetar como uma instituição global Proteger nossos sistemas de TI, redes e infraestrutura Running our business efficiently and appropriately, for example, managing our financial position, developing our business capacity or planning, communications, corporate governance or auditing	Interesses legítimos Obrigações legais Obrigações contratuais Exercício de direitos em processos administrativos e judiciais	Garantir que somos capazes de cumprir nossas obrigações contratuais de forma eficaz e eficiente Cumprir os requisitos regulatórios

Additional information on the use of artificial intelligence and machine learning

BNY uses both manual and automated methods of treatment. In particular, we may use automated methods of treatment, such as Artificial Intelligence ("AI") and Machine Learning ("ML"), which are a set of technologies programmed to perform tasks and actions that are commonly associated with humans. We may use AI and/or ML to optimize and increase the efficiency of business processes (e.g., to support customer contact centers that receive inbound inquiries) and/or to support and enhance existing security controls.

Automated treatment methods are subject to regularly tested controls designed to ensure the accuracy and impartiality of the result. When using AI and/or ML, we do not intend to make automated decisions about you, and therefore your request would not produce legal or similarly significant effects on you unless otherwise stated in a specific privacy notice provided directly to you.

Where We Collect Your Personal Information

We will collect the personal information we use for the above purposes from one or more of the sources below:

directly from you, throughout our relationship, including when you use our products, services, and websites;
from other BNY entities
third parties authorized to share your information with us, such as intermediaries, brokers, our institutional clients, and service providers; or
of publicly available sources of information.

The Legal Basis for Using Your Personal Information

We will only collect, use and share your personal information where we are satisfied that we have an adequate legal basis to do so. This is explained in more detail in other sections of this Privacy Notice, where we indicate that we will have one or more of the following reasons for using your personal information:

Our use of your personal information is necessary to perform a contract we have with you or to take steps to enter into a contract with you, for example, when you ask us to provide you with a product or service
Our use of your personal information is necessary to comply with a legal obligation we have, for example, where we are required to report to tax authorities
Our use of your personal information is necessary for regulatory reasons, for example, to prevent and detect financial crime
You have given us your consent for us to use the personal information, for example, if you have agreed to receive marketing communications
Our use of your personal information is in our legitimate interests as a commercial organisation to provide services to our customers, provided that our use is proportionate and respects your privacy rights; Where we rely on our legitimate interest, we will tell you what that interest is.

Processing of personal data of minors

The processing of data of children (considered by the relevant legislation as individuals up to 12 years of age) and/or adolescents (considered by the relevant legislation as individuals between 12 and 18 years of age) may occur as part of the services provided by BNY, even if BNY does not target minors. In the case of data processing of these data subjects, BNY must obtain the specific consent of at least one of the parents or legal guardian before processing the personal data, as well as adopt the necessary measures to process the personal data of minors under the terms of the applicable data protection legislation.

SHARING PERSONAL INFORMATION ON BNY, WITH THIRD PARTIES, WITH OUR REGULATORY BODIES

In this section, you can learn more about how we share personal information:

No BNY
With third parties who help us provide our products and services, and
And with our regulatory bodies

We share your information in the manner and for the purposes described below:

At BNY, when such disclosure is necessary to provide our services or to manage our business.
With third parties who help manage our business and provide services. These third parties have agreed to confidentiality restrictions and use the personal information that we share with them or that they collect on our behalf solely for the purpose of providing the contracted service to us. This includes IT service providers who help manage our IT systems and back office;
with specialized financial market infrastructure providers that support our payment, clearing and settlement businesses;
With agencies, organizations and companies, both in Brazil and abroad, that work with the objective of preventing fraud, financial crimes and money laundering;
With our regulatory bodies,
To comply with all applicable laws, regulations, and rules and requests from law enforcement, regulatory, and other government bodies.
We may share in aggregate, statistical, non-personal information about our website visitors, traffic patterns, and website usage with our business partners, affiliates, or advertisers.

In the future, BNY may sell or transfer some or all of its assets to third parties. Your personal information, technical information about your device or browser, and/or other anonymous information we obtain from you through the Websites may be disclosed to potential or actual third-party purchasers of these assets and/or may be among those transferred assets.

USE OF COOKIES AND OTHER TECHNOLOGIES

In this section, you can learn more about:

types of cookies used on our websites;
third-party advertisers;
third-party websites;
Control of your cookie settings.

Types of cookies used on our websites

We use cookies, web beacons, and similar technologies ("Cookies") to track information provided to us by your browser and our software application when you use our websites. A cookie is a small piece of information that a website stores in the web browser on your device and that can be retrieved later. "Session" cookies are temporary and expire at the end of a browser session, i.e. when you leave a website. Session cookies allow a website to recognize you and load information as you navigate between pages during a single browser session and allow you to use the website more efficiently. "Persistent" cookies, on the other hand, remain in your browser's cookie file even after you leave a website and after your browser is closed. They allow a website to recognize you when you return, remember your preferences, and provide personalized services to you. A cookie will not contain information that allows us to contact you by phone, email, or other means.

We, and third-party service providers acting on our behalf, use persistent and session cookies to:

Remember the preferences you submit, as well as those generated from your usage data and your responses to surveys on our websites;
Measure your use of our websites in an effort to improve the quality of the websites and improve your overall experience, including tracking page views, time and date of access to the website, and other data uses, and identifying your operating system and browser type (but not other information about your computer or the programs contained therein) and your general geographic location; e
Allow you to share certain information on our websites through social media bookmark buttons, email, or on social networking sites.

The third-party service providers mentioned above use the personal information they collect on our behalf solely for the purpose of providing us with the contracted service. They also agreed to confidentiality restrictions.

We may use aggregated usage data to track trends and analyze patterns on our websites. If you register to enter an area of our websites, the website will recognize who you are and collect all information you submit (including subscribing to emails, etc.). The information collected about you on this website may be associated with other identifying information we have about you.

Third-party advertisers

We may use third-party advertising companies to serve advertisements on our behalf on other sites on the Internet. To measure and track the effectiveness of these ads, these companies typically use cookies; Therefore, a cookie may be placed in your browser's cookie file when you click on one of our advertisements or visit a web page associated with our advertising campaigns. These companies may also use and measure information about your visits to our website as part of this same process. The information provided to us by these companies about you will be anonymized.

Third-Party Websites

Our websites contain links to third-party websites (including social media bookmark buttons that allow you to share certain content on our websites). While some of the entities that control these websites are under contract with us, not all are, so we advise you to familiarize yourself with the individual privacy notice and cookies and other terms for each linked website before submitting your personal information. We are not responsible for and have no control over their terms of use or privacy notices, we do not review them, and we accept no responsibility whatsoever with respect to the content of these websites or how they use cookies and handle your personal information. This privacy notice does not apply to your use of third-party websites.

Control your cookie settings

Most browsers are initially set up to accept cookies. However, you can change your browser settings. It may also be possible to configure your browser settings to allow acceptance of specific cookies or to notify you whenever a new cookie is about to be stored on your device, allowing you to decide whether to accept or reject the cookie. You can also disable cookies by setting your browser to reject cookies. Please refer to the help section of your browser for instructions on how to disable cookies. For more information about cookies, how they work, why they are so useful and how to disable them, please visit www.allaboutcookies.org.

If you do not want to accept cookies from our website, please disable them or avoid using our website. If cookies are disabled, it may mean that you have reduced functionality or are unable to use all or part of our website.

Please see our cookie policy to learn more about the information we collect using cookies and tracking technologies.

CONDUCTING DIRECT DIRECT MARKETING

In this section, you can learn more about:

How we use personal information to keep you updated about our products and services;
How you can manage your marketing preferences.

How We Use Personal Information to Keep You Updated on Our Products and Services

We may use personal information to inform you about BNY products and services that we believe may be of interest to you. We may contact you by email, post or telephone or through other communication channels that we believe you may find useful. In all cases, we will respect your preferences about how you would like to manage marketing activities directed to you.

How you can manage your marketing preferences

To protect your privacy rights and ensure that you have control over how we manage marketing directed to you:

We will take steps to limit direct marketing to a reasonable and proportionate level and will only send you communications that we believe may be of interest or relevance to you.

You can ask us to stop direct marketing at any time. You can ask us to stop sending you email marketing by following the "unsubscribe" link you will find in the email marketing messages we send you. Alternatively, you can contact us. Specify whether you would like us to stop all forms of marketing or only a specific type (e.g., email).
And you can change the way your browser manages cookies, which can be used to deliver online advertising, by following the settings on your browser as explained above.

We encourage you to frequently review the privacy notices and preference settings available on social media platforms, as well as your preferences in your BNY account.

TRANSFER OF PERSONAL INFORMATION WORLDWIDE

In this section, you can learn more about:

How we operate as a global company and transfer data internationally.
The agreements we have in place to protect your personal information if we transfer it overseas.

BNY operates globally. As a result, your personal information may be transferred to and stored in countries outside of Brazil, including the United States, the European Union (EU), and India, which are subject to different data protection standards. The purposes of these transfers are available here: The personal information we collect will be used for one or more of the following purposes. We transfer and subsequently process your personal information only for as long as necessary to fulfill the purposes for which it was collected, as described in this privacy notice.

BNY will take the necessary steps to ensure that international transfers of personal information are in accordance with applicable law, to protect your privacy rights. International transfers are made in the following forms:

International transfers of personal information between members of BNY's corporate group will be covered by standard contractual clauses; or
International transfers of personal information to third parties who help manage our business and provide services will require standard contractual clauses and the implementation of security measures appropriate to the nature of the data processed, in line with the provisions of the "Security" section of this privacy notice; or
When we receive requests for information from law enforcement/judicial or regulatory authorities, we carefully validate those requests to conduct them in accordance with the instruments of international law; or
when the transfer is permitted by the National Data Protection Authority (ANPD) of Brazil, based on the destination country, providing adequate data protection for personal information; or
according to the other cases allowed by the ANPD.

We ensure that the processors of your personal information consent to the adoption of security measures to protect your personal information.

If you have any questions, concerns or complaints about the transfer of personal information, or if you would like to exercise your rights, we encourage you to contact our Data Protection Officer first. If you want to file a complaint with the ANPD, visit the agency's website at www.gov.br/anpd/pt-br/canais_atendimento/cidadao-titular-de-dados.

HOW WE PROTECT AND STORE INFORMATION

Security

We have implemented and maintain a comprehensive information security program, with policies and procedures designed to protect the confidentiality and integrity of personal information. The information security program contains administrative, technical, and physical safeguards, appropriate to the type of information in question, designed to: (i) maintain the security and confidentiality of such information; (ii) protect against anticipated threats or dangers to the security or integrity of such information; (iii) protect against unauthorized access to or use of such information that could result in substantial harm, and (iv) ensure proper disposal of such information. The security of your personal information depends, in part, on the security of the devices you use to communicate with us, the security you use to protect user IDs and passwords, and the security provided by your Internet access service provider.

Storage of your personal information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances, we may store your personal information for longer periods, for example, where we are required to do so in accordance with necessary legal, regulatory, tax, accounting or technical requirements.

In specific circumstances, we may store your personal information for longer periods of time in order to have an accurate record of your trades with us in the event of complaints or disputes, or if we reasonably believe that there is a possibility of litigation relating to your personal information or trades.

RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY

Subject to certain exemptions, and in some cases, depending on the processing activity we carry out, you have certain rights in relation to your personal information. Click on the links below to learn more about each entitlement you may have:

Confirm that we are processing your personal information.
Obtain information about the shared use of personal information.
Access personal information.
Correct/delete personal information.
Restrict/block or anonymize the processing of your personal information.
Transfer your personal information.
Withdraw consent to the processing of your personal information.
Review the automated handling of your personal information.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the requested personal information to you.

Subject to legal and other permissible considerations, we will make all reasonable efforts to comply with your request promptly or let you know if we need further information to comply with your request.

We may not always be able to fully comply with your request, for example, if it would affect the duty of confidentiality we have with others or if we are legally permitted to handle the request in a different way.

Right to confirm processing

As part of the right of access, data subjects have the right to confirm whether BNY processes personal information of a specific data subject.

Right to obtain information about the shared use of personal information

As part of the right of access, data subjects have the right to request information about the public and private entities with which BNY has shared personal information.

Right to access personal information

You have the right to request that we provide you with a copy of your personal information that we hold and also to be informed about: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the identity of the data controller; and (d) the entities or categories of entities to which your personal information may be transferred.

Right to correct or erase personal information

You have the right to request correction of inaccurate personal information. We may attempt to verify the accuracy of personal information before rectifying it.

You may also request deletion of your personal information in limited circumstances, where:

They are no longer needed for the purposes for which they were collected.
Or you have withdrawn your consent (where the data processing was based on consent).
Or that the personal information was handled unlawfully.
Or to comply with a legal obligation to which BNY is subject.

We are not obliged to comply with your request to delete personal information if the processing of your personal information is necessary:

For compliance with a legal obligation.
• For the establishment, exercise or defense of legal claims.

Right to restrict/block or anonymize the processing of your personal information

You can ask us to restrict/block or anonymize your personal information, but only when:

The personal information processed is unnecessary or excessive.
Or the personal information is handled unlawfully.

We may continue to use your personal information following a restriction request:

Where we have your consent.
Or to establish, exercise or defend legal claims

Right to transfer your personal information

You may request that we provide your personal information to you in a structured, commonly used and machine-readable format, or you may request that it be transferred directly to another data controller. This right does not apply to personal information that has already been anonymized by the data controller.

Right to withdraw consent to the processing of your personal information

You may withdraw your consent at any time after you have given us consent by contacting our Data Protection Officer, provided that there are no legal or contractual requirements to prevent this and that you have provided us with reasonable notice. If you do not consent to certain uses of the information or if you withdraw your consent, we may not be able to provide you with a particular service. If this is the case, we will explain the situation to help you with your decision.

Right to review automated decision-making about your personal information

Data subjects have the right to review decisions made using automated processing of their personal information, if those decisions are intended to define their personal, professional, consumer or credit profile.

EXERCISING YOUR RIGHTS

You can exercise your rights by submitting a request on our Individual Rights Request Page. Subject to legal and other permissible considerations, we will make all reasonable efforts to comply with your request promptly or let you know if we need further information to comply with your request.

We may not always be able to fully comply with your request, for example, if it would affect the duty of confidentiality we owe to others or if we are legally authorized to handle the request in a different way.

CONTACT US

The main point of contact for all questions arising from this privacy notice is our Data Protection Officer.

You can contact the Data Protection Officer in the following ways:

By email: trmglobalprivacy@bny.com

If you have any questions, concerns, or complaints about our compliance with this notice and data protection laws, or if you would like to exercise your rights, we encourage you to contact the Data Protection Officer first. We will investigate and attempt to resolve complaints and disputes and make all reasonable efforts to honour your wish to exercise your rights as soon as possible and in any event within the timeframes provided by data protection laws.

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