Privacy Policy

Introduction

CTSD PARTICIPAÇÕES LTDA ("we," "our," or "us") is committed to protecting your privacy and maintaining the strictest confidentiality standards expected of an investment holding company. This Privacy Policy explains how we collect, use, disclose, and safeguard your information.

By engaging with our company, you agree to the collection and use of information in accordance with this policy.

Information We Collect

As a non-financial holding company, we may collect the following types of information:

• Business Partner Information: Company details, ownership structures, and corporate documentation.
• Contact Information: Names, titles, phone numbers, and email addresses of executives and representatives.
• Investment Information: Financial statements, business plans, and due diligence materials.
• Shareholder Information: Equity ownership records and partnership agreements.
• Governance Information: Board compositions and corporate governance documents.
• Transaction Records: Investment agreements and partnership documentation.

How We Use Your Information

We use the collected information for the following purposes:

• To evaluate potential investment opportunities
• To manage equity participations
• To exercise governance responsibilities
• To monitor portfolio company performance
• To communicate with business partners
• To prepare corporate and financial reports
• To comply with legal and regulatory requirements

Investment & Business Confidentiality

We treat all investment-related information with the highest level of confidentiality. Business plans, financial projections, valuation materials, and strategic information shared with us are protected and not disclosed to competing interests. Due diligence materials are handled with strict discretion.

Portfolio Company Information

As a holding company, we receive detailed information from our portfolio companies for oversight and governance purposes. This information is used solely for investment management and is not shared with other portfolio companies or external parties without authorization.

Shareholder & Partner Records

We maintain records of ownership structures, shareholder agreements, and partnership arrangements. These records are confidential and shared only as required for corporate governance, regulatory compliance, or with explicit consent of the parties involved.

Governance & Board Activities

Through our equity participations, we may participate in corporate governance of portfolio companies. Board meeting materials, strategic discussions, and governance documents are treated as confidential. We maintain appropriate information barriers where required.

Data Security

We implement robust security measures appropriate for sensitive business and investment information. Access to confidential materials is strictly controlled. Digital and physical records are secured with appropriate protections. Our systems comply with industry security standards.

Data Retention

Corporate and investment records are retained for the periods required by Brazilian corporate and tax law. Shareholder records are maintained for the duration of ownership relationships. Due diligence materials may be retained for reasonable periods following investment decisions.

Information Sharing

We do not sell, trade, or rent your information to third parties. We maintain strict confidentiality of business partner information. We may share information only in the following circumstances:

• With professional advisors under confidentiality agreements
• With regulatory authorities as required by law
• With tax authorities for fiscal compliance
• With co-investors when explicitly authorized
• When required by law or legal process
• To protect our legal rights

Your Rights

In accordance with Brazilian data protection laws (LGPD - Lei Geral de Proteção de Dados), you have the right to:

• Access your personal data held by us
• Request copies of relevant documentation
• Request correction of inaccurate information
• Request deletion of data (subject to legal requirements)
• Request information about how your data is processed
• Withdraw consent for non-essential processing
• File a complaint with the National Data Protection Authority (ANPD)

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or regulatory requirements. Significant changes will be communicated to business partners. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have concerns about how we handle your information, please contact us: