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Privacy Policy

TERMS OF USE AND PRIVACY POLICY

Last updated: October 2025

Corporate name: MUEVY INSTITUIÇÃO DE PAGAMENTO S.A.

CNPJ [Corporate Taxpayer ID]: 46.297.307/0001-05

Address: Alameda Rio Negro, 585 Bloco A, 2º andar, Conj. 22, Alphaville, Barueri/SP – CEP [ZIP code] 06454-000

Contact email: atendimento@muevy.com

Table of Contents

1. Object and Scope

These Terms of Use and Privacy Policy (“Terms”) govern the use, by the User, of the payment initiation services provided by Muevy in its own environment or integrated third-party environments (“Platform”), including the Pix payment journey via Open Finance and related functionalities, such as consent, authentication, sending the payment order, status return, and provision of proof of payment.

Muevy acts as a Payment Institution authorized and regulated by the Central Bank of Brazil, in the Payment Transaction Initiator (ITP) modality, responsible for initiating and sending the payment order to the User’s financial institution (Account Holding Institution – IDC). Muevy does not hold, manage, or keep User funds.

2. Glossary

Authentication: Process of verifying the User’s identity with their IDC.

Consent: Free, informed, and unequivocal authorization granted by the User to share data and/or execute the initiation via Open Finance, which can be revoked at any time.

Personal Data: Information related to an identified or identifiable natural person, according to Law No. 13.709/2018 (LGPD).

IDC – Account Holding Institution: Institution where the User maintains their payment or bank account.

ITP: Payment Transaction Initiator – participant in Open Finance that sends the payment order to the IDC indicated by the User.

LGPD: General Personal Data Protection Law (Law No. 13.709/2018).

Open Finance: Regulatory ecosystem that allows standardized sharing of data and financial services, subject to the User’s consent.

Platform: Muevy’s own technological environment and/or integrated third-party environments where the payment journey occurs.

User: Natural person or legal entity that uses the initiation services.

3. Acceptance of Terms

By using the Platform, the User declares that they have read, understood, and accepted these Terms.

In certain flows, additional acceptance may be requested (e.g., acceptance of Open Finance consent and acceptance of the transaction summary).

When applicable, contracting by a legal entity must observe its articles of association, with the operator (representative with powers) being responsible for the use of the services and the veracity of the information provided.

4. Payment Journey (Standard Flow)

The standard journey comprises:

  1. Button context and label: Display of the payment method and link to these Terms.
  2. Bank selection (IDC): List of institutions.
  3. Confirmation and redirect: Payment summary (amount, recipient, fees, date, method) and notice of redirection to the bank’s app/website.
  4. Authorization at the bank: Authentication and authorization at the IDC.
  5. Processing messages and proof of payment: Display of status (success, error, pending) and provision of proof of payment with minimum information required by regulation (identification of parties, amount, date/time, transaction ID, method, institution).

Mandatory information for the User: Payment method, transaction amount, fee (if any), recipient, payment date, and identification of Muevy as the responsible ITP.

5. Responsibilities of the Parties

Of the User: a) Provide true and updated data; b) Maintain the security of their devices and banking credentials; c) Check balance and Pix limits; d) Review the transaction summary; e) Comply with applicable legislation.

Of Muevy: a) Provide the initiation service according to Bacen regulation and Open Finance rules; b) Send the payment order to the indicated IDC; c) Display clear information; d) Provide status and proof of payment; e) Adopt security, compliance, and AML/CFT controls; f) Process Personal Data according to the LGPD.

Of the IDC: Responsible for User authentication, balance verification, anti-fraud analysis, and authorization/denial of the transaction, as well as for the settlement of the Pix.

Muevy does not guarantee the authorization or settlement of the transaction; completion depends on the IDC and the compliance of credentials, limits, and security rules.

6. Limitations of Use and Prohibited Conduct

The User is prohibited from: i) Using the Platform for illicit purposes; ii) Violating third-party rights; iii) Bypassing authentication; iv) Interfering with the Platform’s operation; v) Providing false information.

Muevy may suspend or terminate the User’s access in case of violation of these Terms, signs of fraud, or legal/regulatory determination.

7. Privacy and Data Protection (LGPD)

7.1 Controller and Contacts

Muevy is the Controller of the Personal Data processed within the scope of these Terms and may rely on Processors (technological providers and partners) under its contractual instructions.

Contact channels:

7.2 Categories of Data Processed

Registration data: name, CPF/CNPJ [Taxpayer ID], contact; Transactional data: amount, recipient, date, method, identifiers; Technical data: device, IP, logs, cookies.

Performance of a contract, legal/regulatory obligation, regular exercise of rights, legitimate interest, and consent (when required by Open Finance).

7.4 Purposes

Provision and improvement of initiation services; regulatory compliance (Bacen, COAF); fraud prevention; security and auditing; responding to User requests.

7.5 Sharing

With IDCs, recipients, technological providers, and regulatory/judicial authorities, observing necessity and confidentiality.

7.6 Data Subject’s Rights

The User may request access, correction, deletion, portability, information about sharing, and revocation of consent.

Inquiries: compliance@muevy.com.br

7.7 Retention and Deletion

Data is kept for the time necessary to comply with legal obligations and defend rights.

7.8 International Transfers

May occur to cloud providers; Muevy adopts guarantees provided by the LGPD (standard clauses and appropriate technical measures).

8. Information Security

Muevy adopts technical and organizational controls proportional to the risks, including encryption, environment segregation, vulnerability management, logs, access control, strong authentication, PCI DSS compliance, and incident communication.

9. Fraud and Money Laundering Prevention

Muevy maintains a structure and procedures for PLD/FT [AML/CFT], such as due diligence (KYC/KYP/KYE), monitoring, restricted lists (PEP, OFAC, UN, EU, SDN), communications to COAF, and internal training.

The User may revoke consent at any time with their IDC or Muevy.

11. Processing Messages and Errors

The Platform will display the transaction status and, in case of rejection, standardized reasons and an option to retry.

12. Customer Service, Complaints, and Communications

General channel: atendimento@muevy.com

Privacy and data protection matters: compliance@muevy.com.br

13. Intellectual Property

All rights related to the Platform, trademarks, and content belong to Muevy or its licensors.

14. Changes to these Terms

Muevy may change these Terms; relevant changes will be communicated through the Platform.

15. General Provisions

Partial invalidity does not invalidate the remainder. Forbearance regarding non-compliance does not imply waiver.

16. Applicable Law and Jurisdiction

Brazilian law applies. Chosen jurisdiction: São Paulo/SP, notwithstanding the consumer’s domicile.

ANNEX A – Information for the User

  • Payment method (Pix via Open Finance / Selected bank)
  • Amount and fees
  • Recipient identification
  • Payment date
  • Identification of Muevy (CNPJ 46.297.307/0001-05)
  • Redirect notice

ANNEX B – Proof of Payment (Minimum Fields)

  • Date/time of initiation
  • IDC and recipient
  • Amount and method (Pix)
  • Transaction ID
  • Indication: “performed via Muevy (ITP)”

ANNEX C – Data Subject’s Rights (LGPD)

Summary of rights (access, correction, deletion, portability, objection, revocation of consent). Contact: compliance@muevy.com.br

Internal References (Muevy Policies)

  • Compliance Policy
  • Know Your Partner Policy (KYS/KYP)
  • PLD/FT [AML/CFT] Policy
  • Information Security Policy

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