TERMS OF SERVICE

DEFINITIONS:

Mobills refers to the company, software and its own corporate name.

1. COMPANY OVERVIEW

1.1. The present Terms of Service was developed by Mobills Labs Soluções em Tecnologia Ltda., registered under the Corporate Taxpayer Registry (CTR) nº 20.256.063/0001-10, and has as main goal to regulate the conditions for the provision of services of personal financial management for its Users.

1.2. MOBILLS is a personal financial management platform conceived to assist the education and management of money on a daily basis, by which the User can control his incomes and expenses from his phone, tablet or computer.

1.3. User is every natural person that agrees with the conditions for the provision of services mentioned in the present Terms of Service, understanding his rights and duties.

1.4. In order to access all the benefits offered by the financial management platform MOBILLS, the User must read the present Term, accept the following conditions through the option “I accept and agree to the Terms of Service and Privacy Policy” and, finally, complete the registration process.

1.5. By accepting the present Term, the User declares that has civil capacity or, in case of not having, the User was assisted by a civil apt person when agreeing to the following conditions, according to the Brazilian Civil Code, enacted in 2002.

1.5. If you are between 16 years old and under 18 years old, and intend to use our products and services, you should review these Terms of Use with your parent or legal guardian to ensure that you understand all of the conditions set out herein.

1.6. By agreeing to these Terms you declare that you have at least 16 years old. If you are under 16 years old, Mobills may request your parent's or legal guardian's consent for you to use MOBILLS.

2. USING MOBILLS

2.1. To start having access to the platform’s benefits, the User must declare his acceptance of the Terms of Service and Privacy Policy, complete the registration process and enter his data. MOBILLS assumes no responsibility for the veracity of the information inserted.

2.2. The User may register for free with MOBILLS, opting, if he or she wishes, for the Premium Plan, which allows the charging of a monetary value due to the benefits added to this type of account, as indicated below:

PRODUCT PERIOD VALUE
Mobills Premium 1 year $49.99
Mobills Premium 1 month $14.99

2.3. MOBILLS reserves the right to start charging the User due to the services received as a Premium Account, through prior notice that allows the User decides whether to continue using the platform.

2.4. It is suggested that the User use a safe password, including both upper and lowercase letters, numbers and symbols, who is the unique responsible for maintaining the confidentiality of his own account.

2.5. If the User feels that is needing help with some feature of the platform, he can easily find it by accessing the Help Central, sending an e-mail to suporte@mobills.com.br or visiting the following website: https://comunidade.mobills.com.br.

3. MOBILLS’ SERVICES

3.1. MOBILLS offers 02 (two) types of accounts conceived for using the platform, the Basic Account and the Premium Account, according to the benefits that the User wants to have access, which are presented on the website https://www.mobills.com.br/planos/.

3.2. The advantages of each plan can be modified upon advance notice delivered to the User, through publication on the platform itself or by email, explaining the new conditions.

4. BANKING INTEGRATION

4.1. If the User wants to improve his experience, he can contact the company MOBILLS to inform his bank account details (for example, bank name, account number, credit card number etc.), along with the password used for internet banking, giving express authorization to MOBILLS to access your financial data provided by the internet banking linked to the informed bank account .

4.2. In order to have access to your financial data located in banks or institutions, the company uses its own technology, or hire specific partners (feel free to consult our Privacy Policy here).

4.3. By opting for banking integration on MOBILLS, you have to agree and consent to our partners’ Privacy Policy, which can be found in our own platform when agreeing with the banking integration. If you do not want to give your consent, do not worry! MOBILLS will never share any of your personal data, not even proceeds to banking integration.

4.4. The unique MOBILLS actions related to the bank data provided by the User are the integration of this data with its own platform, and the data sharing with partners that can deliver this service to us, in a way that the User can take advantage of the benefits provided by MOBILLS as realistic as possible. MOBILLS does not transfer financial values and the company neither conducts financial operations nor interfere, in any way, with assets and banking accounts informed by the User.

4.5. The User must be aware that the acquisition of banking data by MOBILLS relies on the services delivered by the financial institutions pointed by the User. Thus, our company cannot guarantee punctuality, precision, delivery or absence of failures during the process of obtaining financial data through the platforms that belongs to these institutions, given the fact that the importation of this data may be subject to technical problems or another difficulty related to the connection, what could result in failures during the obtaining process.

4.6. In addition, MOBILLS collects the information given by the financial institutions provided by the User, but does not review the data collected. Because of this, the User has the duty to review the information provided by MOBILLS about his financial data before making decisions based on them.

5. SECURITY MEASURES

5.1 MOBILLS informs that all personal data collected from Users is stored in an encrypted form, in addition to being synchronized, processed and stored in servers of high-level security standards, ensuring similar security level found in banking institutions to the entire database stored by us.

5.2 The security measures taken were elaborated to avoid and prevent problems related to the treatment of the data collected, although there is no 100% (one hundred percent) secure system of protection against hackers or third parties who make use of illegal methods. Because of this, MOBILLS is not responsible for illegal access, as well as acts committed by third parties who succeed in collecting or using, by any means, registration data and informations made available by the User on the platform.

6. DUTIES

6.1. The User is the unique responsible for every data and information that he inserts on his own account and MOBILLS is not in charge of verifying the veracity of the personal data inserted.

6.2. Although MOBILLS makes all possible efforts to improve experience and storage of data, it is not possible to guarantee that the entered information will be available during all the usage time of the company’s platform. It is possible that the entered information be deleted, eventually, without advance notice and, because of that, the User is the solely responsible for maintaining copies of all the data and reports elaborated by MOBILLS that he wishes to keep.

6.3. MOBILLS will not be responsible, no matter what was the type of account chosen by the User, under no circumstances for any damage arising from:

a) Misusing of the platform by the User;

b) Poor connection with internet;

c) Interruption of the transmission, diffusion, availability, reception, acquiring and access to information; and

d) Any other interruptions of access to the platform, no matter what or who is responsible for causing it.

6.4. MOBILLS will not be held responsible, under no circumstances, for the User’s decision based on any report or data provided by the platform, since is not your obligation to deliberate about the User’s choices.

6.5. Users are fully responsible for, during the usage of the platform (web and mobile), always acting in good faith in their civil relations, following the provisions and legislation, regulations, ordinances and other legal rules applicable, being not allowed, for example, to:

a) disseminate content or to commit any act that violates third parties’ rights or the law;

b) disseminate offensive, pornographic, or any content that promotes or makes apology to terrorism, violence or any other kind of discrimination on the basis of race, sexual orientation, religion, or violates human rights; and

c) disseminate documents of identification or financial informations that are confidential to others.

6.6. MOBILLS will not be held responsible for the products and services delivered by third parties, for example financial institutions, which the User might have contractual relationship or bank account, even if integrated with MOBILLS.

7. PAYMENT METHODS AND PERIODICITY

7.1. If the User chooses Premium Account, the price of the service may vary according to the periodicity of the plan, monthly or annual, and can be paid by credit card or barcode. The payment made by barcode will only be available with the total amount of the annual plan.

7.2. The services of the Premium Account will only be available when MOBILLS has verified the payment of the respective amount, which can take 02 (two) business days.

7.3. If the User chooses not to renew his Premium subscription after the end of the plan, all exclusive features will be automatically disabled and, in the same away, every information provided by the platform may be deleted without advance notice.

7.4. In case of any accountability of MOBILLS, the amount to be paid will not be higher than the amount paid by the User for the usage of the platform.

8. INTELLECTUAL PROPERTY

8.1. All of the intellectual property related to the platform MOBILLS, for instance: operations, software, hardware, domain, logos, emblems, design of pages and advertisements, structure, contents and informations, tools, symbols and expressions which characterize the services provided by the company are solely owned by MOBILLS and will not be granted any extension of use to users, only by being previously authorized, expressly and written by the legal representatives of the company.

9. AMENDMENTS TO THE AGREEMENT

9.1. MOBILLS reserves all rights to edit, at any moment, the terms of this agreement, with prior notification to users about amendments through publication on its own platform, presenting the new terms and always granting the reasonable and sufficient time for your commencement.

10. ACCEPTANCE

10.1. MOBILLS understands that by clicking the button “Agree”, the User declares that has read these terms and agrees with them in every aspect and condition, without being forced and free from any malice, coercion, fraud or mental reservation and that his intention to register in MOBILLS is not related to any other manifestation or statement that was not established by this instrument.

11. GENERAL PROVISIONS

11.1. If any clause or provision of this term be considered invalid, it will not affect the validity and the application of the remainder provisions.

11.2. The violation of any provision presented in these terms by the User implies the interruption, with immediate effects, to the access to the platform.

11.3. The present term represents the entire agreement between MOBILLS and Users, replacing all the previous documents, including communications, changes of intentions or any other type of agreement related to the same content.

11.4. Any amendments to this agreement will be written and brought to the attention of the User, assuming the acceptance if, after the awareness, the use of the website was maintained.

11.5. YOU DECLARE THAT YOU ARE 16 (SIXTEEN) YEARS OLD OR OLDER. IF YOU ARE UNDER 16 (sixteen) YEARS OLD, YOU HEREBY DECLARE THAT YOUR PARENTS OR LEGAL GUARDIANS HAVE READ THESE TERMS OF USE WITH YOU, ASSISTING YOU IN UNDERSTANDING THIS DOCUMENT, AND THAT YOU AND YOUR PARENTS OR LEGAL GUARDIAN AGREE TO ALL LEGAL LIABILITIES OF THESE TERMS OF USE.

12. CONTACT DETAILS

12.1. It is established that the entire communication with MOBILLS must take place through the email suporte@mobills.com.br or its website or platform, in the field available for contacting MOBILLS (https://comunidade.mobills.com.br), being the User solely responsible for the entered informations.

13. DISPUTES

13.1. By accepting these terms, the User agrees that the laws of Brazil, without regard to principles of conflict laws, will govern these terms of service, or any dispute of any sort that might come between MOBILLS and the User.

13.2 Any dispute related in any way to the access to this platform or services provided by MOBILLS shall be arbitrated by state or federal courts located in Fortaleza, Ceará, Brazil, and the User consents to exclusive jurisdiction and venue of such courts.

PRIVACY POLICY

MOBILLS is committed to protecting your privacy as well as your privacy data. Through this Privacy Policy, we will describe our practices of privacy and security implemented in the collection, use and other phases of personal data treatment on our platform.

This policy also informs how you can exercise your rights related to these activities of personal data treatment.

MOBILLS reserves the right to change the present privacy policy, through information published on the platform’s website (https://mobills.com.br) to improve, adapt or update it to conform to legislative or jurisprudential changes.

Attention: the registration and subsequent browsing and use of MOBILLS depends on acceptance of these Privacy Policy provisions. Thus, if the User does not agree with any condition set out, it is recommended that the User disable the page without making the registration.

1. WHICH DATA IS COLLECTED FROM USERS AND HOW?

1.1. MOBILLS reserves the right to collect and store the data entered at the time of registration process and, later, during the registration of additional information spontaneously offered by the User, such as, but not limited to:

a) Personal data: data requested for registration on MOBILLS, for example: full name, email address, telephone, SSN, date of birth, gender, education level, occupation, specialty, monthly income range. Some optional data may be collected for the formation of your financial profile, which will help us to customize the features of the platform according to your interests, in addition to indicating partners that deliver financial services, which may be of your interest.

b) Banking data: data requested to connect our platform with your bank accounts (banking integration) and your credit cards, if you wish to, such as: bank code, bank account number, agency and password of internet banking, credit card number, expiration date, security code, and so on. The banking integration will be exclusively used to access your bank statement, or the description of your credit card bill, and to automate posts to your MOBILLS account. The banking integration may be interrupted by you at any time.

c) Financial data: financial data that can be collected from your bank account or credit card connected to your MOBILLS account, or entered manually by you, such as: information related to transactions, expenses, income, nature and category of your expenses, overdraft, credit, loans, investments, and so on.

d) Communication between you and MOBILLS: information related to the communication between you and MOBILLS by email, telephone, chatbot, social media and/or messenger (whatsapp, telegram, and so on).

1.2. Some data may be collected and stored automatically, such as, but not limited to, device characteristics of access and browser, IP number (Internet Protocol, identification number of network device) with information about date and hour, source IP, features accessed, information about clicks and preferences of browsing, geolocation, and so on.

1.3 The data may be stored on servers situated in Brazil and/or in international territory.

2. HOW DATA IS USED?

2.1 Your personal data may be used to:

a) Improve the website and application mobile device experience;

b) Issue reports, graphics and table charts of expenses;

c) Create alerts and events;

d) Send to the User communications about advertising of MOBILLS and its services;

e) Perform commercial activities, operational and statistics;

f) Send content through email, newsletter and other communications related to MOBILLS, making available to the User, at any time, to express his objection by disabling his shipments;

g) Make commercial analyses and construction of experience journey of current and potential Users;

h) Provide assistance when needed;

i) Research and recommendation of financial services relevant to your profile; and

j) Access your bank account, credit card bill and make automate posts of transactions in MOBILLS.

3. WHO HAS ACCESS TO THE DATA?

3.1. If you give your consent, we reserve the right to share your data, through connection with partner platform, for recommendation about offers or products/services and in order to synchronize your bank accounts held by financial institutions (“banking integration”). The sharing will be done only when needed to the offer or contracting the product/service chosen by you.

3.1.1 In order to have access to you financial data in banks and financial institutions, we use our own technology, or we hire specific partners to provide this service for us, such as: Belvo Tecnologias LTDA (https://belvo.com) and Credit Vista Tecnologia Para Finanças Pessoais Eireli (https://credigo.app).

3.1.2 With the partners indicated above, we share your bank data (bank, agency and bank account), and the password used to access the internet banking. We will have access to your financial data only in view mode. MOBILLS and its partners cannot interfere in your assets or make any transaction from your bank account. Furthermore, all of your data is maintained encrypted on our database, and we grant all the necessary security.

3.1.3 By opting for the banking integration on MOBILLS, you need to agree with the privacy policy of our partners BELVO and CredGO, available to you on our platform, during the act of accession. If you do not want to consent, don’t worry! MOBILLS will not share any of your personal data, or proceed to the banking integration.

3.2. Your personal data may be shared to comply with legal, contractual or administrative obligation, to improve products and services offered by MOBILLS or in case of MOBILLS has outside partners that provide services related to hosting WEB or maintenance.

3.3. The User data may be shared with third parties against payment or not, in the form of statistic anonymous data, without individual information, and used for advertising purposes, granting that will not be possible the identification of the User through the advertise.

4. HOW LONG DO WE MAINTAIN YOUR DATA?

4.1 Your data will be kept in our database during all the period that you remain registered in our platform, afterwards, only within the legal period established.

5. HOW DO WE PROTECT YOUR DATA?

5.1 MOBILLS informs that the User’s personal data is maintained encrypted, in addition to being synchronized, processed and stored in servers of high-level security standards, ensuring similar security level found in banking institutions to the entire database stored by us.

5.2 The security measures taken were elaborated to avoid and prevent problems related to the treatment of the data collected, although there is no 100% (one hundred percent) secure system of protection against hackers or third parties who make use of illegal methods. Because of this, MOBILLS is not responsible for illegal access, as well as acts committed by third parties who succeed in collecting or using, by any means, registration data and information made available by the User on the platform.

6. COOKIES

6.1 Cookies are files elaborated by websites frequented that record information about browsing, making possible that the User keeps connected, at the same time it saves your preferences to offer targeted advertising.

6.2 MOBILLS reserves the right to use cookies in order to collect information about the User and to improve the browsing experience. However, if the User wants to reject the installation of these cookies, he may block or eliminate them through the following website http://tools.google.com/dlpage/gaoptout or even changing his browser preferences.

7. EMAIL MARKETING POLICY

7.1 The act of sending email marketing is in accordance with established standards by law, including under the terms of the Brazilian Code of Self-regulation for Email Marketing Practice, which provides for the use of this marketing tool based on ethics and responsibility, without prejudice to the provision of the law in force.

7.2 MOBILLS does not agree with the act of sending emails without previous authorization (Anti-SPAM Policy). Is considered non-existent, by MOBILLS, the usage of data/registration confirmation with executable attachments (such as extension exe, com, scr, bat) and links for download/archiving.

8. HOW TO EXERCISE YOUR RIGHTS?

8.1 In Brazil: The General Data Protection Regulation (Law nº 13.709/2018), provides you certain rights and guarantees related to your personal data. MOBILLS, to ensure clarity and transparency, in addition to detailing in this policy how the platform uses and protect your personal data, it makes available, on this link, an easy and free channel to you exercise your rights of:

• To request information about the treatment of your personal data: You can confirm if we have treated your personal data and request access or correction if existing inaccurate data; to require a list of all agents with whom we have shared your data;

• Portability: You have the right to request the migration of your personal information to other organization;

• To require the exclusion or anonymization of your personal data: You have the right to ask for anonymization or the definitive exclusion of your own data, if they prove unnecessary or excessive regarding the purpose of the treatment, or in case of being treated in disagreement with the GDPR.

• Withdrawal of consent: you have the right to know the consequences of refusing the provision of consent related to the treatment of your personal information and require the withdrawal of it.

8.1.1 If you request the exclusion of all the data entered by you on MOBILLS, through email or website, this will result in losing access to any functionality of MOBILLS, as well as later restoration of it, except those data that the storage is required by law. If the User was using the Premium account, after requiring the exclusion, it will be necessary a new payment in order to restore it.

8.1.2 You may also contact our Data Protection Officer (DPO) through the following email: privacidade@mobills.com.br

8.2 In European Union: The General Data Protection Regulation – GDPR of the European Union applies to the data collection that belongs to a natural person located in European Union, granting her various rights related to personal information. These rights are listed below and they can be exercised through this link or contacting our DPO directly via privacidade@mobills.com.br:

• Right to access: to require information about your personal data;

• Right to rectification: You may also contact our Data Protection Officer (DPO) through the following email: privacidade@mobills.com.br to request the rectification of any personal information that belongs to you;

• Right to exclusion: to request that we delete any personal information that we have in our own database or in our partners’ database;

• Right to restriction: to request the restriction of processing the personal data that we maintain related to you;

• Right to portability: you may request to receive your personal data in a structured, commonly used and machine-readable form. You also have the right to demand that we transmit it to another data controller;

• Right to objection: you may challenge the processing of your personal data;

• Right to withdrawal of consent: you may withdrawal your consent related to the use of your personal data.

9. DATA FROM CHILDREN AND ADOLESCENTS

9.1. MOBILLS is not intended for children, therefore, those under 16 years are not expected to register on our platform. We do not knowingly collect information from anyone under 16 years of age. If parents or legal representatives believe that their children have provided us with personal data, they may contact us by sending us an email to privacidade@mobills.com.br.

9.2. If you are between 16 years and 18 years old and intend to use our products and services, you should review this Privacy Policy with your parent or legal guardian to ensure that you understand all of the conditions set out herein. If you are under 16 years old, Mobills may request your parent or guardian's consent so that you can use our platform.

10. CONTACT DETAILS AND PRIVACY QUESTIONS

If you have any questions or concerns about MOBILLS’ Privacy Police, you should first contact our officer, through the following email:

Lívia Campos

E-MAIL: privacidade@mobills.com.br

ADDRESS: Rua Monsenhor Bruno, 1153 - Sala 11 - Andar 50 - Aldeota, Fortaleza - CE, 60115-191.

Last updated: 2021-07-06