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Structure Financial Privacy Policy

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Last Modified: April 27, 2022

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Introduction

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This policy applies to information Structure Financial (\"Structure\" or \"We\") collects from you, the user and data subject (\"You\") in our Application, our Website and in email, text, and other electronic communications sent through or in connection with this Application (collectively \"Services\").

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The term \"Personal Data\" as used in this policy, describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified.

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This document contains a section dedicated to Brazilian Users and their privacy rights.

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Personal Data Controller

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A Personal Data controller is a person or organization who controls the collection, holding, processing or use of Personal Data, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.

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For purposes relevant data protection legislation, Structure is the personal data controller.

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Structure Financial Inc.\nCraigmuir Chambers,\nRoad Town Tortola VG 1110,\nBritish Virgin Islands

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Structure contact email : legal@structure.fi

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Types of Data Collected

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The types of Data that this Application collects, by itself or through third parties includes:

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We collect this information from you when you freely provide it on the Application, or in case of Usage Data, collected automatically when using this Application.

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Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

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Users who are uncertain about which Personal Data is mandatory may contact us for clarification.

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Use of Tracking Tools

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Any use of Cookies or of other tracking tools by this Application or by the owners of third-party services used by this Application serve the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

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Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to us.

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Method and Basis of Processing Data

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Methods of processing

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We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

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The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. Data may be accessible to you and in some cases, to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. You may request a list of these parties at any time.

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Please note, however, that no method of transmission of the Internet or method of electronic storage is 100% secure and we therefore cannot promise, ensure, or warrant the security of any Personal Data that you provide to us.

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Legal basis of processing

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We may process Personal Data relating to you if one of the following applies:

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Sharing and Transfer of Data

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Structure shares Personal Data in the following ways:

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Structure is a global company, with offices and Suppliers located throughout the world. As a result, Personal Data may be transferred outside the country in which you reside for the purposes identified. Any such transfer of Personal Data shall take place under applicable law and will be protected through international data transfer agreements where necessary that have been recognized by relevant data protection authorities as providing an adequate level of protection to the Personal Data we process.

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Retention of Data

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We will retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. We determine data retention based on the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from an unauthorized user, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

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Personal Data collected for purposes related to the performance of a contract between you and us will be retained until such contract has been fully performed.

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Personal Data collected for the purposes of Structure's legitimate interests will be retained as long as needed to fulfill such purposes.

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We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

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Once the retention period expires, Personal Data will be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

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The Purposes of Processing

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The Data we collect about you is collected to:

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Device Permissions for Personal Data Access

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Depending on your specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

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By default, these permissions must be granted by you before the respective information can be accessed. You may still revoke the permission at any time after it has been given. To revoke permissions please refer to your device settings or contact us for support. Revoking of such permissions might impact the proper functioning of the Application.\nWhen you grant us permission to use your data, the respective Personal Data may be processed, accessed, modified or removed by the Application.

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Our Services are Intended For Adults

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Our Application is not intended for children. If you use our Services, you declare yourself to be an adult according to your region's applicable legislation. Minors may use this Application only with assistance of a parent or guardian. Nobody under the age of 13 may use this Application. If you believe we might have any information from or about a child under 13, please contact use at legal@structure.fi or:

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Structure Financial Inc.\nCraigmuir Chambers\nRoad Town Tortola VG 1110\nBritish Virgin Islands

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Your Privacy Rights

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If you reside in certain jurisdictions, you may be permitted to exercise certain rights regarding your Data that we process. In particular, you may have the right to do the following:

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If you would like to exercise any of the rights listed above, or if you would like to contact us about any questions you may have regarding your Personal Information, please contact us at legal@structure.fi and provide (a) enough information to identify you and (b) a description of what right you want to exercise and the information to which your request relates. Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

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How \"Do Not Track\" Requests Are Handled

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Our Application does not support \"Do Not Track\" requests.

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Changes to this Privacy Policy

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We reserve the right to make changes to this privacy policy at any time by notifying you on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to you via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed above.\nShould the changes affect processing activities performed on the basis of your consent, we will collect new consent from you, where required.

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Information for Users Residing in Brazil

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This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as \"we\", \"us\", \"our\").\nThe provisions contained in this section apply to all Users who reside in Brazil, according to the \"Lei Geral de Proteção de Dados\" (Users are referred to below, simply as \"you\", \"your\", \"yours\"). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.\nThis part of the document uses the term \"personal information\" as it is defined in the Lei Geral de Proteção de Dados ( LGPD ).

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The grounds on which we process your personal information

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We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

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To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

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Categories of personal information processed

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To find out what categories of your personal information are processed, please see \"Types of Data Collected\" above.

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Why we process your personal information

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To find out why we process your personal information, please see \"Legal Basis of Processing\" above.

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Your Brazilian privacy rights, how to file a request and our response to your requests

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You have the right to:

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You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

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How to file your request

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You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

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How and when we will respond to your request

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We will strive to promptly respond to your requests.\nShould it be impossible for us to do so, we'll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

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In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you'd like your personal information to be delivered in electronic or printed form.\nYou will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

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In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

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Transfer of personal information outside of Brazil permitted by the law

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We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

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Additional information for Users residing in Brazil

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We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.\nThe ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:

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