Privacy Policy & Terms of Use

1. Introduction and Scope

This Privacy Policy explains how Zenite Ventures S/A ("Kigar", "we", "us", or "our"), the controller of your personal data, collects, uses, shares, stores, and protects personal data in connection with the Kigar payments ecosystem, including our mobile application, website, and related services (together, the "Services").

Kigar is a global, app-first payments ecosystem built primarily for companies moving money domestically and internationally, and available to individuals as well. Kigar is not a bank. Regulated banking, custody, foreign-exchange, and settlement activities are performed by licensed financial partners; Kigar operates the software layer that connects you to those capabilities.

This Policy applies to every person and business that accesses or uses the Services, including account holders, their authorized representatives and beneficial owners, and visitors to our website. It is designed to comply with the Brazilian General Data Protection Law (Lei nº 13.709/2018 – "LGPD") and, where applicable to businesses and users located outside Brazil, to give effect to equivalent rights under the EU General Data Protection Regulation ("GDPR") and comparable regimes.

This Policy should be read together with our Terms of Use, of which it forms an integral part.

2. Data Controller and Contact

The controller responsible for processing your personal data is Zenite Ventures S/A, a company incorporated in Brazil, operating the Kigar ecosystem.

For any matter relating to this Policy or to the processing of your personal data, you may contact us through the in-app support channel or by writing to our Data Protection Officer (Encarregado de Proteção de Dados) using the contact details in the "Data Protection Officer and Contact" section below.

Where licensed financial partners act as independent controllers of certain data (for example, to satisfy their own regulatory obligations), their own privacy notices govern that processing and are made available to you when you enable the relevant partner services. In respect of processing they carry out on our behalf and under our instructions, such partners and providers act as operators (operadores/processors).

3. Personal Data We Collect

We collect the following categories of personal data, depending on how you use the Services:

Identification and registration data: full name, business (legal) name and trade name, date of birth, nationality, taxpayer identification numbers (such as CPF or CNPJ) and equivalent foreign identifiers, government-issued identity documents, photographs and selfies used for identity verification, and, for businesses, corporate registration data.

Contact data: email address, telephone number, postal and registered addresses.

Corporate and relationship data: for business accounts, information about the company's ownership structure, directors, authorized representatives, beneficial owners, and the roles of individuals connected to the account.

Verification and compliance data (KYC/KYB): documents and information required to verify identity, ownership, source of funds, and eligibility, and to meet anti-money-laundering, counter-terrorism-financing, sanctions-screening, and fraud-prevention obligations.

Financial and transactional data: account balances, transaction history, payment instructions, counterparties, invoice and payment references, and other records generated when you move money domestically or internationally through the Services.

Device, technical, and usage data: IP address, device identifiers, operating system and app version, language and time-zone settings, log data, in-app activity, and diagnostic information.

Security and authentication data: credentials, transaction passwords/PINs, and, where you choose to enable it, indicators that biometric authentication (such as fingerprint or face recognition) was successfully performed by your device. Biometric matching is carried out on your device by the operating system; we do not receive or store your raw biometric templates.

Communications data: the content of messages, support requests, and other communications you send to us, including records of interactions for quality and compliance purposes.

Website and cookie data: information collected via cookies and similar technologies when you visit our website, as described in the "Cookies and Similar Technologies" section.

Some of this data is provided directly by you; some is generated automatically as you use the Services; and some is received from third parties such as licensed financial partners, identity-verification and anti-fraud providers, sanctions and politically-exposed-person data sources, and public registries, in each case to operate the Services and meet legal obligations. Some verification, sanctions, and politically-exposed-person data may constitute sensitive personal data under the LGPD, and where required we process it only on a lawful basis provided by law or, where applicable, with your specific and highlighted consent.

4. Purposes of Processing

We process personal data for the following purposes:

- To create, operate, and maintain your account and provide the Services, including enabling you to move money domestically and internationally and to manage payments to suppliers, invoices, and counterparties.

- To verify your identity and, for businesses, the identity of representatives and beneficial owners (KYC/KYB), and to assess eligibility.

- To process, execute, and reconcile transactions through licensed financial partners.

- To detect, prevent, and investigate fraud, unauthorized access, and other unlawful or prohibited activity, including through automated screening and risk scoring.

- To comply with legal and regulatory obligations, including anti-money-laundering, counter-terrorism-financing, sanctions, tax, record-keeping, and reporting requirements, and to respond to lawful requests from competent authorities.

- To secure the Services, authenticate users, and authorize sensitive actions.

- To provide customer support and respond to your requests.

- To improve, personalize, and develop the Services, including analytics, diagnostics, and quality assurance.

- To communicate with you about the Services, including operational, security, and administrative messages, and, where permitted, about products and features.

- To exercise or defend legal rights and to enforce our agreements.

5. Legal Bases for Processing

We rely on the following legal bases under the LGPD (and, where applicable, the corresponding bases under the GDPR):

- Performance of a contract / execution of preliminary procedures at your request (LGPD Art. 7, V; GDPR Art. 6(1)(b)): to create and operate your account and provide the Services you request.

- Compliance with a legal or regulatory obligation (LGPD Art. 7, II; GDPR Art. 6(1)(c)): to meet KYC/KYB, anti-money-laundering, sanctions, tax, and reporting requirements.

- Legitimate interests / regular exercise of rights (LGPD Art. 7, IX; GDPR Art. 6(1)(f)): to secure the Services, prevent fraud, ensure network and information security, improve the Services, and defend legal rights, provided such interests do not override your fundamental rights and freedoms.

- Consent (LGPD Art. 7, I; GDPR Art. 6(1)(a)): for certain optional processing, such as specific marketing communications or non-essential cookies, where required. Where processing relies on consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.

- Credit protection and fraud prevention (LGPD Art. 7, X): where applicable to protect the integrity of the ecosystem.

Where sensitive personal data is processed, we rely on the specific legal bases of LGPD Art. 11, including compliance with a legal or regulatory obligation, fraud prevention and security of the data subject, regular exercise of rights, or your specific consent.

Where we process data to fulfil legal obligations or to perform our contract with you, providing that data is necessary to use the Services; without it, we may be unable to open or maintain your account. Where we rely on legitimate interests, you may request further information about the balancing assessment performed.

6. Sharing of Personal Data

We share personal data only as necessary and in accordance with applicable law, with the following categories of recipients:

- Licensed financial partners who provide regulated banking, custody, foreign-exchange, payment, and settlement services, so that your transactions can be executed and the applicable regulatory obligations met.

- Our infrastructure and technology providers who host and support the Services, including cloud, storage, security, communications, and analytics providers, acting as our operators (processors) under contractual data-protection obligations.

- Identity-verification, anti-fraud, sanctions-screening, and compliance providers engaged to verify users and protect the ecosystem.

- Competent authorities, regulators, and courts, where disclosure is required by law, regulation, or valid legal process, or to protect our rights, users, and the integrity of the Services.

- Professional advisers (such as legal, audit, and accounting advisers) under confidentiality obligations.

- Parties to a corporate transaction (such as a merger, acquisition, or reorganization), subject to appropriate safeguards and continuity of this Policy.

We do not sell your personal data, and we do not share it with third parties for their own independent marketing purposes. We require recipients acting on our behalf to process personal data only under our instructions and to maintain appropriate confidentiality and security. You may request information about the categories of recipients with whom your data has been shared, as described in the "Your Rights" section.

7. International Data Transfers

Because Kigar operates a global ecosystem, personal data may be processed and stored in countries other than your own, including outside Brazil and the European Economic Area.

When we transfer personal data internationally, we implement safeguards required by applicable law. Under the LGPD, transfers are made to countries with an adequate level of protection or, where such adequacy is not established, on the basis of appropriate guarantees such as standard contractual clauses, specific contractual commitments, binding corporate rules, or another lawful basis under Art. 33 of the LGPD. For data subject to the GDPR, we rely on adequacy decisions or, where applicable, Standard Contractual Clauses approved by the European Commission, together with supplementary measures where needed.

You may contact our Data Protection Officer to obtain more information about, and where available a copy of, the safeguards applied to international transfers of your personal data.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to provide the Services, and for as long as required to comply with our legal, regulatory, accounting, and reporting obligations, to resolve disputes, and to enforce our agreements.

Because the Services involve regulated financial activity, certain categories of data — in particular identity-verification (KYC/KYB) records and transaction records — must be retained for periods mandated by applicable anti-money-laundering, financial, and tax legislation, which typically require retention for several years after the account relationship ends.

When personal data is no longer required for these purposes, we will delete, anonymize, or irreversibly de-identify it in accordance with applicable law. Anonymized data that can no longer be associated with an individual may be retained and used for statistical and analytical purposes.

9. Automated Decision-Making and Profiling

To protect the ecosystem and comply with our regulatory obligations, some processing — such as fraud detection, transaction monitoring, sanctions and politically-exposed-person screening, and eligibility and risk assessment — may involve automated processing, including profiling. These processes may, in certain cases, influence decisions such as whether a transaction is allowed, delayed, or referred for manual review, or whether an account is opened, limited, or suspended.

Where a decision is taken solely on the basis of automated processing that affects your interests, you have the right, under LGPD Art. 20, to request a review of that decision and to receive clear information about the criteria and procedures used, subject to trade and commercial secrets and to legal limits where disclosure would compromise fraud prevention, security, or regulatory obligations. Where the GDPR applies, you may also have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, except as permitted by law, and to obtain human intervention, express your point of view, and contest the decision.

To exercise these rights, contact our Data Protection Officer using the details below.

10. Your Rights as a Data Subject

Subject to applicable law, you have the following rights in relation to your personal data:

- Confirmation and access: to confirm whether we process your personal data and to obtain access to it.

- Correction: to request the correction of incomplete, inaccurate, or outdated data.

- Anonymization, blocking, or deletion: to request anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in non-compliance with the law.

- Deletion of data processed based on consent: to request deletion of personal data processed on the basis of your consent, subject to legal retention requirements.

- Portability: to request portability of your data to another service or product provider, subject to applicable rules and trade/commercial secrets.

- Information about sharing: to obtain information about the public and private entities with which we have shared your data.

- Information about consent: to be informed about the possibility of not providing consent and the consequences of refusal.

- Withdrawal of consent: to withdraw consent at any time, where processing is based on consent.

- Objection and restriction: to object to or request restriction of processing carried out on the basis of legitimate interests, and, under the GDPR where applicable, additional rights including the right to object to automated decision-making and to lodge a complaint.

- Review of automated decisions: to request review of decisions taken solely on the basis of automated processing that affect your interests, as described in the "Automated Decision-Making and Profiling" section.

To exercise any of these rights, contact our Data Protection Officer using the details below. We may need to verify your identity before responding and will reply within the timeframes established by applicable law (under the LGPD, generally in a simplified format immediately and in full within fifteen (15) days of your request). We do not charge a fee for exercising your rights except where permitted by law for manifestly unfounded or excessive requests. Certain rights are subject to legal limits — for example, where retention is required by law or where a request would compromise fraud prevention, compliance obligations, or the rights of others.

You also have the right to lodge a complaint with the competent supervisory authority. In Brazil, this is the National Data Protection Authority (Autoridade Nacional de Proteção de Dados – ANPD); in the European Economic Area, your local data protection authority.

11. Security

We adopt technical, administrative, and organizational measures designed to protect personal data against unauthorized access, loss, alteration, destruction, and any form of inappropriate or unlawful processing.

These measures include encryption of data in transit and at rest, strong authentication and transaction-authorization controls, strict internal controls and least-privilege access governance, network and application security monitoring, logging and auditing, and secure development practices. Regulated data handled by licensed financial partners is subject to institutional-grade custody and security controls maintained by those partners.

No method of transmission or storage is completely secure. You play an important role in protecting your account: keep your credentials, transaction password, and device secure, enable available security features, and notify us promptly of any suspected unauthorized access.

12. Data Breach and Incident Notification

We maintain procedures to detect, respond to, contain, and remediate personal-data security incidents.

In the event of a security incident that may create relevant risk or harm to you, we will notify the competent authority (the ANPD in Brazil, or the relevant supervisory authority where the GDPR applies) and affected data subjects within the timeframe and in the manner required by applicable law. Our notification will describe, to the extent known, the nature of the affected data, the individuals concerned, the measures taken, and the steps you can take to mitigate potential effects.

Where an incident affects data held or processed by a licensed financial partner or other provider acting on our behalf, we will coordinate with that partner so that the applicable notification obligations are met.

13. Cookies and Similar Technologies (Website)

Our website uses cookies and similar technologies to operate correctly, remember your preferences, ensure security, and understand how the site is used.

We use: strictly necessary cookies, which are essential for the site to function and cannot be switched off; functional cookies, which remember your choices and preferences; and analytics cookies, which help us understand aggregate usage and improve the site. Where required by law, non-essential cookies are used only with your consent.

You can manage cookies through your browser settings and, where available, through our cookie-preferences tool. Disabling certain cookies may affect the functionality of the website. Our mobile application does not use advertising cookies; it uses standard device and diagnostic technologies as described in this Policy.

14. Children and Minors

The Services are intended for businesses and for individuals who are of legal age and have full legal capacity in their jurisdiction. The Services are not directed to children, and we do not knowingly collect personal data from children.

If we become aware that we have collected personal data from a child without appropriate legal authorization, we will take steps to delete that data. If you believe a minor has provided us with personal data, please contact our Data Protection Officer.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in the Services, in our practices, or in legal and regulatory requirements.

When we make material changes, we will notify you through the app, our website, or other appropriate means before the changes take effect, and we will update the "last updated" date. Your continued use of the Services after the effective date constitutes acknowledgment of the updated Policy, except where additional consent is required by law. Prior versions will be made available on request.

16. Data Protection Officer and Contact

Zenite Ventures S/A has appointed a Data Protection Officer (Encarregado de Proteção de Dados) responsible for handling questions and requests relating to the processing of personal data and for liaising with data subjects and the competent authorities.

To exercise your rights, ask questions about this Policy, or raise any privacy concern, contact us through the in-app support channel or by writing to our Data Protection Officer at the privacy contact address published by Zenite Ventures S/A (for example, the privacy contact channel indicated within the app and on our website). We will respond within the timeframes required by applicable law.

Last updated: July 2026.

1. Introduction and Acceptance

These Terms of Use (the "Terms") govern your access to and use of the Kigar application, together with all associated software, interfaces, features, and services (collectively, the "Platform"). The Platform is a global payments ecosystem built to help businesses and individuals move money domestically and across borders, manage payables and receivables, settle invoices with suppliers and partners worldwide, and operate multi-currency workflows from a single mobile-first experience.

Kigar is the intellectual property and software product of Zenite Ventures S/A ("Zenite," "we," "us," or "our"), which owns and licenses the Platform. By downloading, accessing, registering for, or using the Platform, you ("you," "User," or "Account Holder") acknowledge that you have read, understood, and agree to be bound by these Terms and by any additional policies referenced herein, including our Privacy Policy. If you are entering into these Terms on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that entity, and "you" refers to that entity.

If you do not agree with these Terms, you must not access or use the Platform. Your continued use of the Platform constitutes ongoing acceptance of these Terms as they may be updated from time to time.

2. Definitions

For the purposes of these Terms, the following capitalized terms have the meanings set out below:

"Account" means the registered profile through which you access and use the Platform.

"Business Day" means a day on which banks are generally open for business in Brazil, excluding Saturdays, Sundays, and national holidays.

"Licensed Partners" means the duly authorized and regulated financial institutions, payment institutions, custodians, exchange service providers, and other licensed third parties that provide the underlying regulated banking, custody, settlement, foreign exchange, and related services made accessible through the Platform.

"KYC" means Know Your Customer identity verification procedures applicable to individual Users.

"KYB" means Know Your Business verification procedures applicable to corporate Users, including verification of legal existence, ownership, control structure, and beneficial owners.

"PF" means an individual natural person (pessoa física).

"PJ" means a legal entity or company (pessoa jurídica).

"Platform" means the Kigar application and all associated software, features, content, and services as described in these Terms.

"Transfer Password" means the dedicated security credential required to authorize outbound movements of funds and other sensitive operations.

"User Content" means any data, documents, information, or materials that you submit, upload, or transmit through the Platform.

Defined terms used in the singular include the plural and vice versa, and headings are for convenience only and do not affect interpretation.

3. Description of the Platform

The Platform is a comprehensive, technology-driven payments ecosystem designed primarily for businesses (PJ) and equally available to individuals (PF). Through a single application, the Platform enables Users to hold and organize balances in more than one currency, initiate and receive domestic transfers, settle invoices and supplier obligations, send and receive funds internationally, convert between currencies at applicable rates, and manage day-to-day treasury and payment operations that would otherwise require multiple providers, accounts, and intermediaries.

The Platform is engineered to solve real operational problems for organizations that move money at home and abroad: reducing the friction, delay, and cost of cross-border payments; consolidating multi-currency operations; streamlining supplier and invoice settlement; and giving finance teams and business owners a clear, unified view and control of their money in real time. Individuals benefit from the same speed, transparency, and multi-currency capabilities.

Kigar acts as the software and technology layer of this ecosystem. The regulated financial services accessed through the Platform — including deposit-taking, custody, settlement, foreign exchange, and cross-border payment execution — are provided by Licensed Partners, as described in Section 6. The specific features available to you may depend on your verification status, your Account type (PJ or PF), your jurisdiction, and applicable legal and regulatory requirements. We may add, modify, or discontinue features at any time in accordance with these Terms.

4. Eligibility, Registration, and Verification (KYC/KYB)

To open an Account and use the Platform, you must meet applicable eligibility requirements. Individual Users (PF) must be at least eighteen (18) years old and have full legal capacity to enter into binding contracts. Corporate Users (PJ) must be validly constituted, in good standing, and duly represented by a person authorized to bind the entity.

By registering, you agree to provide true, accurate, current, and complete information and to keep such information updated at all times. As a condition of access, you must complete identity and eligibility verification. This includes KYC procedures for individuals and KYB procedures for companies, which may require submission of identification documents, corporate and registration records, proof of address, information regarding beneficial owners and controlling persons, tax identifiers, source-of-funds information, and any additional documentation required to comply with applicable anti-money-laundering, counter-terrorism-financing, sanctions, and regulatory obligations.

Verification is performed by us and/or by Licensed Partners. We and our Licensed Partners reserve the right, at our sole discretion, to accept or refuse any application, to request additional information at any time, to re-verify your identity or your business periodically, and to limit, suspend, or close an Account where verification cannot be completed or where information is found to be false, incomplete, or outdated.

You may not open or maintain an Account if you are subject to applicable sanctions, are located in or acting on behalf of a restricted jurisdiction or restricted party, or if providing services to you would violate applicable law. Each User may hold Accounts only as permitted by these Terms and applicable policies.

5. Account, Access, and Security

You are responsible for maintaining the confidentiality and security of your Account credentials and for all activity that occurs under your Account. The Platform provides layered security controls designed to protect your Account and your funds, including device-based biometric authentication (such as Face ID or fingerprint recognition, where supported by your device) and a dedicated Transfer Password that is required to authorize outbound movements of funds and other sensitive operations.

The Transfer Password is distinct from your device unlock and login credentials and constitutes an additional authorization layer. You agree to keep your Transfer Password, biometric enrolments, device, and any other authentication factors secure and confidential, and never to share them with any third party. Any operation authorized through your valid credentials, biometric authentication, or Transfer Password will be deemed to have been authorized by you.

You agree to notify us immediately if you suspect any unauthorized access to or use of your Account, loss or theft of your device, or compromise of your credentials. We may suspend access, require re-authentication, or apply additional security measures where we detect unusual, suspicious, or potentially unauthorized activity, in order to protect you, other Users, and the integrity of the Platform.

You are responsible for ensuring that your device, operating system, and network are secure and up to date. To the extent permitted by applicable law, we are not responsible for losses arising from your failure to safeguard your credentials or device, or from your use of compromised or unsupported hardware or software.

6. Nature of Services — Kigar Is Not a Bank

Kigar is a technology platform and payments ecosystem. Kigar is not a bank, and Zenite Ventures S/A does not operate as a financial institution. The Platform itself does not take deposits, does not custody or hold your funds, and does not carry out regulated banking, custody, settlement, or foreign exchange activities on its own account.

All regulated financial services accessible through the Platform — including the holding and safekeeping of balances, deposit and withdrawal processing, payment settlement, currency conversion, and cross-border transfers — are provided by duly authorized and regulated Licensed Partners under their own terms, licenses, and regulatory supervision. Custody of funds, where applicable, is provided on an institutional basis by such Licensed Partners. Your use of those regulated services may be subject to the separate terms, verification requirements, and policies of the relevant Licensed Partner, which you agree to comply with.

Kigar's role is to provide the software, user experience, orchestration, and technology that make these services accessible in a unified and efficient manner. References in the Platform or these Terms to holding, sending, converting, or receiving money describe the functionality made available to you through Licensed Partners and do not represent that Zenite itself performs regulated financial activities. Nothing in these Terms shall be construed as an offer by Zenite to provide banking or other regulated financial services.

7. Acceptable Use

You agree to use the Platform only for lawful purposes and in accordance with these Terms. You must comply with all applicable laws, regulations, and Licensed Partner requirements, including those relating to anti-money laundering, counter-terrorism financing, sanctions, tax, foreign exchange, and consumer protection.

You agree that you will not, and will not permit any third party to: (a) use the Platform to facilitate or conduct any illegal, fraudulent, deceptive, or unauthorized activity, including money laundering, terrorism financing, sanctions evasion, tax evasion, or the financing of prohibited goods or services; (b) provide false, misleading, or inaccurate information, or impersonate any person or entity, or misrepresent your affiliation with any person or entity; (c) use the Platform on behalf of an undisclosed third party or otherwise circumvent verification requirements; (d) access or attempt to access another User's Account, or interfere with the security, integrity, or availability of the Platform; (e) reverse engineer, decompile, disassemble, copy, modify, or create derivative works of the Platform or any part of it, except to the extent expressly permitted by applicable law; (f) use robots, scrapers, or other automated means to access the Platform, or introduce viruses, malware, or other harmful code; (g) resell, sublicense, or commercially exploit the Platform without our prior written authorization; or (h) use the Platform in any manner that could damage, disable, overburden, or impair it or interfere with any other party's use.

We and our Licensed Partners may monitor, review, delay, block, reverse, or refuse transactions and may report activity to competent authorities where required or where we reasonably suspect a violation of these Terms, applicable law, or applicable risk and compliance policies. You are solely responsible for the accuracy of the payment details, beneficiary information, and instructions you submit.

8. Fees

Your use of certain features of the Platform may be subject to fees, which may include, without limitation, transaction fees, currency conversion spreads or margins, cross-border transfer fees, and service or maintenance charges. Applicable fees, and the manner in which they are calculated, will be disclosed to you within the Platform before you confirm a relevant operation or otherwise made available to you in accordance with applicable law.

Wherever practicable, the Platform is designed to present the applicable fee, the estimated total, and your resulting balance before you authorize an outbound operation, so that you can review the full cost before confirming. By confirming an operation, you agree to the fees disclosed for that operation.

Fees may vary depending on the type of operation, the currencies involved, the Account type (PJ or PF), the destination, the amount, prevailing market conditions, and the requirements of Licensed Partners. We may introduce new fees or modify existing fees prospectively in accordance with Section 18. Fees charged for completed operations are generally non-refundable except as required by applicable law. Taxes, levies, and charges imposed by third parties or by law may apply in addition to our fees and are your responsibility.

9. Currency Conversion, Rates, and Cross-Border Payments

The Platform enables you to hold balances in more than one currency and to convert between currencies. Currency conversion and cross-border payment execution are performed through Licensed Partners at rates that reflect prevailing market conditions and that may include a spread or margin. Exchange rates fluctuate continuously, and the rate applicable to a given conversion or transfer is the rate presented to you at the time of the operation, or as otherwise determined in accordance with the applicable Licensed Partner's rate methodology.

Where the Platform displays an indicative or quoted rate, that rate is provided for your convenience and may change until the operation is confirmed and executed. Certain conversions or transfers may complete promptly, while others — particularly cross-border operations and certain currency conversions — may require additional processing time, may be subject to settlement windows, cut-off times, intermediary processing, and verification or compliance checks, and may therefore be completed asynchronously rather than instantaneously. You acknowledge and accept that timing of completion is not guaranteed and may depend on factors outside our control.

Cross-border payments may be subject to additional requirements, including foreign exchange regulations, reporting obligations, beneficiary and correspondent verification, and the rules of the receiving jurisdiction and receiving institution. You are responsible for ensuring that the beneficiary details and purpose information you provide are accurate and complete, and for complying with any applicable tax and regulatory obligations arising from your cross-border activity. We and our Licensed Partners are not responsible for delays, rejections, or additional charges imposed by intermediary or beneficiary institutions.

10. Transactions, Authorization, and Irrevocability

You are responsible for reviewing and confirming the details of each operation before authorizing it. Once an outbound operation has been authorized using your credentials, biometric authentication, and/or Transfer Password and submitted for processing, it may not be possible to cancel, reverse, or recover the funds, particularly where the operation has already been executed or settled by a Licensed Partner or credited to a beneficiary.

We employ measures designed to prevent duplicate or unintended operations, including confirmation and review steps prior to authorization. Nonetheless, you bear responsibility for the accuracy of the information you submit, including amounts, beneficiary identifiers, and payment references. We and our Licensed Partners are not obligated to reverse an operation that was correctly executed in accordance with your instructions.

Credits to your Account, including deposits, may be reflected after processing and confirmation, and the timing of such reflection may depend on the processing method and on Licensed Partner confirmation. We may place holds, limits, or additional review on operations for security, compliance, risk, or legal reasons, and may decline to process operations that would breach applicable law, sanctions, or risk policies.

11. Intellectual Property

The Platform, including the Kigar name, brand, logos, visual identity, user interfaces, designs, text, graphics, software, source and object code, architecture, features, and all related intellectual property, is owned by Zenite Ventures S/A and/or its licensors and is protected by copyright, trademark, trade secret, and other intellectual property laws. Kigar is the exclusive intellectual property and software product of Zenite Ventures S/A.

Subject to your compliance with these Terms, Zenite grants you a limited, personal, non-exclusive, non-transferable, non-sublicensable, and revocable license to access and use the Platform solely for its intended purposes and in accordance with these Terms. This license does not transfer to you any ownership rights in the Platform or any part of it.

You may not copy, reproduce, distribute, modify, adapt, translate, publicly display, create derivative works from, reverse engineer, decompile, or disassemble the Platform or any of its components, except to the extent expressly permitted by applicable mandatory law. All rights not expressly granted to you are reserved by Zenite. Any feedback, suggestions, or ideas you provide regarding the Platform may be used by Zenite without restriction or obligation to you.

You retain ownership of your User Content. You represent that you have the rights necessary to submit your User Content and grant Zenite and, where applicable, its Licensed Partners a license to use, host, store, process, and transmit your User Content solely as necessary to provide, operate, secure, and improve the Platform and to comply with legal and regulatory obligations.

12. Third-Party Services and Licensed Partners

The Platform integrates with and relies upon services provided by Licensed Partners and other third parties to deliver its functionality. Your access to certain services may require you to accept the terms and policies of the relevant Licensed Partner, and your use of those services is subject to such terms in addition to these Terms.

While we select Licensed Partners with care, we do not control and are not responsible for the acts, omissions, availability, performance, or decisions of third parties, including any decision by a Licensed Partner to delay, hold, decline, or reverse an operation, or to request additional information. Where a Licensed Partner suspends, limits, or terminates the underlying regulated service, the corresponding functionality on the Platform may be affected.

The Platform may also contain links to or integrations with third-party websites, applications, or services that are not operated by us. We are not responsible for the content, security, or practices of such third parties, and your interactions with them are solely between you and the relevant third party.

13. Data Protection and Privacy

Zenite processes personal data in accordance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais — Law No. 13.709/2018, "LGPD") and other applicable data protection laws. In connection with your use of the Platform, we and our Licensed Partners collect and process personal and business data for purposes including account creation, identity and business verification (KYC/KYB), provision and operation of the Platform, transaction processing, security and fraud prevention, compliance with legal, regulatory, and anti-money-laundering obligations, and communication with you.

The legal bases for such processing may include the performance of a contract, compliance with legal and regulatory obligations, the legitimate interests of Zenite and its Licensed Partners, and, where applicable, your consent. Personal data may be shared with Licensed Partners, service providers, and competent authorities to the extent necessary for these purposes and as permitted or required by law, including in the context of cross-border transactions.

As a data subject, you have the rights afforded to you under the LGPD, including rights of access, correction, portability, information about sharing, review of automated decisions, and, subject to legal and regulatory retention requirements, deletion. We retain personal and transaction data for as long as necessary to fulfil the purposes described above and to comply with applicable legal, regulatory, accounting, and audit obligations. Full details regarding the processing of personal data are set out in our Privacy Policy, which forms an integral part of these Terms and of your relationship with us.

14. Electronic Communications and Notices

You consent to receive communications from us in electronic form, including through the Platform, by email, by push notification, or by other electronic means, and you agree that all agreements, notices, disclosures, and other communications we provide to you electronically satisfy any legal requirement that such communications be in writing.

We may send you operational, security, compliance, and administrative communications relating to your Account and the Platform; these are part of the Services and you cannot opt out of them while you maintain an Account. Marketing communications, where sent, are subject to your preferences and applicable law.

Notices to us must be sent through the support and contact channels made available within the Platform or as otherwise specified by Zenite. It is your responsibility to keep your contact details current so that you receive our communications; communications are deemed received when sent to the details associated with your Account.

15. Disclaimers

To the maximum extent permitted by applicable law, the Platform is provided on an "as is" and "as available" basis, without warranties of any kind, whether express, implied, statutory, or otherwise, including any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, or availability.

We do not warrant that the Platform will be uninterrupted, timely, secure, or error-free, that defects will be corrected, or that the Platform will be free of viruses or other harmful components. We do not guarantee any particular processing time, exchange rate, or outcome for any operation, and estimated times and quoted rates are indicative only and subject to change until execution.

The Platform does not provide financial, investment, tax, accounting, or legal advice, and nothing on the Platform should be construed as such. You are solely responsible for evaluating the suitability of any operation for your circumstances and for obtaining independent professional advice where appropriate. Access to and availability of features may vary by jurisdiction, Account type, and verification status, and may change over time.

Nothing in this Section limits any rights or protections you may have as a consumer under applicable mandatory law, including the Brazilian Consumer Protection Code (Código de Defesa do Consumidor) where it applies to you. Some jurisdictions do not allow the exclusion of certain warranties; in such cases, the exclusions in this Section apply only to the extent permitted by applicable law.

16. Limitation of Liability

To the maximum extent permitted by applicable law, in no event shall Zenite Ventures S/A, its affiliates, directors, officers, employees, agents, or licensors be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, business, goodwill, data, or anticipated savings, arising out of or in connection with your use of, or inability to use, the Platform, whether based in contract, tort, strict liability, or any other legal theory, even if advised of the possibility of such damages.

Without limiting the foregoing and to the extent permitted by law, Zenite shall not be liable for losses arising from: the acts, omissions, delays, holds, or decisions of Licensed Partners or other third parties; fluctuations in exchange rates or market conditions; delays or failures in cross-border processing, settlement, or beneficiary crediting; inaccurate, incomplete, or fraudulent instructions or information submitted by you; unauthorized access resulting from your failure to safeguard your credentials, device, or Transfer Password; or events beyond our reasonable control, including force majeure events, network or telecommunications failures, and interruptions of third-party services.

To the extent that liability cannot lawfully be excluded, the aggregate liability of Zenite arising out of or relating to these Terms and the Platform shall be limited to the amount of fees actually paid by you to Zenite for the specific operation or service giving rise to the claim during the three (3) months immediately preceding the event giving rise to the liability. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable mandatory law, including liability for fraud, willful misconduct, or rights afforded to consumers under applicable consumer protection law.

17. Indemnification

You agree to defend, indemnify, and hold harmless Zenite Ventures S/A, its affiliates, and their respective directors, officers, employees, agents, and licensors from and against any and all claims, demands, actions, proceedings, losses, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or in connection with: (a) your use or misuse of the Platform; (b) your violation of these Terms or of any applicable law or regulation; (c) your violation of the rights of any third party, including any Licensed Partner; (d) the inaccuracy or incompleteness of any information, instruction, or documentation you provide; or (e) any operation you authorize through the Platform.

This indemnification obligation survives the termination or expiration of these Terms and your use of the Platform. We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which case you agree to cooperate with our defense of such claim. This Section applies to the extent permitted by applicable law and does not require you to indemnify us for losses caused by our own fraud or willful misconduct.

18. Changes to the Terms and the Platform

We may modify these Terms from time to time to reflect changes in the Platform, in our services, in applicable law or regulation, in the requirements of Licensed Partners, or in our business practices. When we make material changes, we will provide notice through the Platform or by other reasonable means, and, where required by applicable law, we will obtain your consent or provide advance notice.

The updated Terms will indicate their effective date. Your continued access to or use of the Platform after the updated Terms take effect constitutes your acceptance of the changes. If you do not agree with the updated Terms, you must stop using the Platform and may close your Account in accordance with Section 19.

We may also add, modify, suspend, or discontinue any feature or functionality of the Platform, in whole or in part, at any time, including as required by Licensed Partners or applicable law. We will endeavor to provide reasonable notice of material changes that adversely affect your use, where practicable.

19. Suspension, Termination, and Inactive Accounts

You may stop using the Platform and request closure of your Account at any time, subject to the settlement of any pending operations and obligations and to applicable legal and regulatory retention requirements.

We may, at our discretion and to the extent permitted by applicable law, suspend, restrict, limit, or terminate your access to the Platform or your Account, in whole or in part, with or without prior notice, where: (a) we reasonably believe you have violated these Terms or applicable law; (b) verification (KYC/KYB) cannot be completed or your information is found to be false, incomplete, or outdated; (c) we detect or reasonably suspect fraud, unauthorized access, money laundering, sanctions exposure, or other unlawful or high-risk activity; (d) required by a Licensed Partner, competent authority, or applicable law; (e) necessary to protect the security or integrity of the Platform, other Users, or Zenite; or (f) the underlying regulated service provided by a Licensed Partner is suspended or withdrawn.

Upon suspension or termination, your right to use the Platform ceases immediately. Where funds are held through Licensed Partners, the handling and return of any remaining balance will be subject to applicable law, compliance requirements, and the policies of the relevant Licensed Partner. We may treat an Account as inactive or dormant after a prolonged period without activity, and may apply additional verification, limits, or closure procedures to such Accounts in accordance with applicable law and Licensed Partner requirements. Provisions of these Terms that by their nature should survive termination — including those relating to intellectual property, disclaimers, limitation of liability, indemnification, data retention, and governing law — shall survive.

20. Complaints and Consumer Support

If you have a complaint or concern relating to the Platform, you may contact us through the support and contact channels made available within the Platform. We maintain procedures to receive, register, and respond to complaints within the timeframes required by applicable law, and we will endeavor to resolve them fairly and promptly.

Where a complaint relates to a regulated service provided by a Licensed Partner, we will, where appropriate, direct or coordinate your complaint with the relevant Licensed Partner so that it can be addressed by the responsible party. Nothing in these Terms affects your right, where you qualify as a consumer, to seek redress through the competent consumer-protection bodies or courts under applicable mandatory law.

21. Force Majeure

Zenite shall not be liable for any failure or delay in the performance of its obligations under these Terms to the extent such failure or delay results from causes beyond its reasonable control, including but not limited to acts of God, natural disasters, epidemics or pandemics, war, terrorism, civil unrest, governmental or regulatory actions, changes in law, failures or interruptions of telecommunications, internet, or power infrastructure, cyberattacks, and failures or interruptions of third-party or Licensed Partner services. During the continuance of such an event, the affected obligations shall be suspended, and we will use reasonable efforts to resume performance as soon as practicable.

22. Assignment

You may not assign, transfer, or delegate these Terms or any of your rights or obligations under them, in whole or in part, without our prior written consent. Any attempted assignment in violation of this Section is void. Zenite may freely assign or transfer these Terms and its rights and obligations hereunder, in whole or in part, including to an affiliate or in connection with a merger, acquisition, corporate reorganization, or sale of assets, upon reasonable notice where required by law.

23. Governing Law and Jurisdiction

These Terms are governed by and construed in accordance with the laws of the Federative Republic of Brazil, without regard to conflict-of-law principles. The Platform serves businesses and individuals globally; however, the contractual relationship between you and Zenite Ventures S/A is governed by Brazilian law.

Subject to any mandatory provisions of applicable consumer protection or other law that may grant you the right to bring proceedings in another forum (including, for consumers in Brazil, the courts of their own domicile), the courts of the domicile of Zenite Ventures S/A in Brazil shall have jurisdiction to resolve any dispute arising out of or in connection with these Terms or the Platform. You and Zenite agree to attempt in good faith to resolve any dispute amicably before initiating formal proceedings.

24. General Provisions

These Terms, together with the Privacy Policy and any policies and additional terms expressly incorporated by reference, constitute the entire agreement between you and Zenite Ventures S/A regarding the Platform and supersede any prior agreements or understandings on the subject matter.

If any provision of these Terms is held to be invalid, illegal, or unenforceable, that provision shall be modified to the minimum extent necessary to make it enforceable, or, if it cannot be so modified, severed, and the remaining provisions shall continue in full force and effect. Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that or any other right or provision, and any waiver must be in writing to be effective.

These Terms may be provided to you in more than one language for convenience; in the event of any conflict, and to the extent permitted by applicable law, the version designated by Zenite as controlling shall prevail. The relationship between you and Zenite is that of independent parties, and nothing in these Terms creates any partnership, agency, joint venture, or employment relationship.

25. Contact

If you have any questions, requests, or complaints regarding these Terms or the Platform, or if you wish to exercise your rights, including your rights under the LGPD, you may contact Zenite Ventures S/A, the owner and licensor of Kigar, through the support and contact channels made available within the Platform. We will endeavor to respond to your inquiries within a reasonable time and in accordance with applicable law.

Zenite Ventures S/A is the entity responsible for the Kigar Platform. Requests relating to the underlying regulated services may, where appropriate, be directed to or coordinated with the relevant Licensed Partner in accordance with applicable procedures.