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Legal

Terms of Use

1. Acceptance of Terms

By accessing or using this website, platform, services, applications, communications, or related materials operated by PWM Investimentos Brasil Ltda (“we”, “us”, “our”), you agree to be bound by these Terms of Use. If you do not agree with these Terms, you should not access or use this website or any associated services.

2. Purpose of Website

This website is provided for general informational, commercial, and onboarding purposes. It is intended to describe our business activities, service capabilities, membership offerings, digital infrastructure, financial services access, and related support functions. Content on this website does not constitute legal, financial, tax, regulatory, or investment advice unless expressly stated otherwise.

3. Eligibility

You may only use this website and our services if you are legally capable of entering into binding agreements under applicable law. Where our offerings relate to regulated financial services, investment access, or onboarding to third-party providers, additional eligibility, verification, jurisdictional, and suitability requirements may apply.

4. Accuracy of Information

We aim to ensure that information on this website is accurate and current. However, we do not guarantee that all content is complete, error-free, or up to date at all times. Information may be changed, suspended, withdrawn, or updated without notice.

5. No Offer or Solicitation

Unless expressly stated otherwise, nothing on this website constitutes:

  • an offer to issue or sell any financial product;

  • a solicitation to acquire any financial product or service;

  • investment advice or a recommendation;

  • legal, tax, or accounting advice; or

  • a representation that any product or service is available in every jurisdiction.

Any financial services, digital banking functionality, credit, investment access, treasury services, or payment functionality described on this website may be subject to separate agreements, regulatory restrictions, third-party approvals, and jurisdictional limitations.

6. User Conduct

You agree not to:

  • use the website unlawfully or fraudulently;

  • interfere with the website’s operation or security;

  • upload or transmit malicious code;

  • attempt unauthorized access to systems, data, accounts, or networks;

  • provide false, misleading, or incomplete onboarding or KYC information; or

  • use the website in a manner that may damage our reputation, regulatory standing, or commercial relationships.

7. Intellectual Property

All content on this website, including text, branding, graphics, layout, visual assets, software interfaces, and other materials, is owned by or licensed to us unless otherwise stated. You may not copy, reproduce, modify, republish, distribute, or commercially exploit website content without prior written consent.

8. Third-Party Services

Our platform may involve third-party providers, including custodians, regulated financial institutions, payment partners, credit providers, technology vendors, service operators, and investment or compliance partners. Access to certain services may require direct or indirect contractual arrangements with those providers. We are not responsible for the independent acts, omissions, outages, decisions, or policies of third-party service providers except to the extent required by law.

9. Limitation of Liability

To the maximum extent permitted by law, we exclude liability for any direct, indirect, incidental, consequential, or special loss arising from use of, or reliance on, this website or its content. This includes loss arising from delay, interruption, cyber incidents, data errors, third-party failures, regulatory restrictions, or inability to access a service described on the website.

10. Indemnity

You agree to indemnify and hold us harmless against claims, liabilities, losses, damages, and expenses arising from your misuse of the website, breach of these Terms, violation of applicable law, or provision of false or misleading information.

11. Privacy and Data Handling

Your use of this website is also governed by our Privacy Policy, Cookie Policy, AML/KYC Policy, and Data Protection notice.

12. Amendments

We may amend these Terms of Use at any time by updating this page. Continued use of the website after publication of updated Terms constitutes acceptance of those amendments.

13. Governing Law

These Terms shall be governed by the laws of Brazil, unless another jurisdiction is expressly required by the relevant service agreement, regulated offering, or mandatory law.

14. Contact

For questions about these Terms, please contact: compliance@platinumwealthmarkets.com

Financial Services Platform Statement

1. General Statement

PWM Investimentos Brasil Ltda operates a financial services platform that may include access to account infrastructure, payment services, treasury functionality, onboarding systems, digital transaction tools, credit-related solutions, investment access, and related support services.

2. Platform Model

Our platform may operate through a combination of:

  • our own commercial services;

  • licensed and authorized third-party financial institutions;

  • custodian, banking, payment, compliance, and service partners; and

  • white-label or embedded service arrangements.

Accordingly, not all services described on this website are necessarily provided directly by PWM Investimentos Brasil Ltda in its own name or under its own regulatory permissions.

3. Regulated Activities

Where a service constitutes a regulated financial service, product issuance activity, payment activity, investment activity, or another regulated function, that service may be performed by an appropriately licensed, authorized, contracted, or regulated third-party entity. Availability will depend on jurisdiction, client classification, onboarding status, risk review, and legal eligibility.

4. No Universal Availability

The mention of any banking, treasury, account, payment, investment, or credit capability does not mean that the service is available to all clients, in all countries, or under all circumstances. Access may be conditional on due diligence, contractual approval, regulatory permissions, and service-provider acceptance.

5. No Representation of Direct Licensing

Unless explicitly stated, nothing on this website should be interpreted as a representation that PWM Investimentos Brasil Ltda itself is a bank, licensed deposit-taking institution, securities dealer, investment manager, credit institution, or regulated entity in every jurisdiction in which this website may be viewed.

6. Request for Further Information

Detailed information regarding service structure, provider roles, applicable documentation, and regulatory status can be made available upon request and subject to suitability, confidentiality, and onboarding requirements.

Financial Services Specific

Regulatory and Jurisdictional Position

Our services may involve activities conducted directly by us, through affiliates, through licensed or regulated counterparties, through approved service providers, or through institutional, banking, custody, payment, exchange, investment, escrow, or advisory partners.

Certain products or services referred to on this website may only be available:

  • in specific jurisdictions

  • to approved or eligible clients

  • subject to enhanced due diligence

  • through authorised financial institution partners

  • subject to local legal and regulatory requirements

  • after completion of know your customer, anti-money laundering, sanctions, and risk assessment procedures

Not all services described on this website are available to every person, entity, or jurisdiction. Users are responsible for ensuring that their access to this website and any use of our services is lawful in their own country or place of residence.

No Offer, Solicitation, or Personal Advice

The content on this website is provided for general informational purposes only. It does not constitute:

  • an offer to issue or sell financial products

  • an invitation to invest

  • a public securities offering

  • personal banking advice

  • personal financial product advice

  • legal or tax advice

  • a guarantee of outcomes, approvals, returns, or access

Any references to banking, payments, investments, digital assets, trade opportunities, private placements, capital solutions, treasury services, or related financial activity are general in nature and must not be relied upon as a recommendation or promise.

Clients should obtain their own independent legal, financial, tax, and regulatory advice before entering into any transaction or arrangement.

Banking, Payments, and Financial Services

Our business may facilitate access to financial and commercial services in Brazil through approved institutional frameworks, technology platforms, banking relationships, custodial arrangements, payments infrastructure, and third-party providers.

Where financial services, payment services, escrow arrangements, digital asset services, investment opportunities, treasury functions, or trade-related services are made available, these may be subject to:

  • Brazilian regulatory requirements

  • contractual restrictions

  • compliance approvals

  • institutional onboarding rules

  • product-specific disclosures

  • partner terms and conditions

  • credit or risk approval processes

Access to any financial service is not automatic and may be refused, limited, suspended, or withdrawn where required by law, regulation, internal policy, partner requirements, risk assessment, sanctions screening, fraud prevention, or operational constraints.

Brazilian Compliance and Regulatory Standards

As a business connected to financial and commercial activity in Brazil, we take compliance seriously and structure our operations with regard to applicable Brazilian laws, regulations, and market practices.

Depending on the nature of the service, this may include compliance considerations connected to:

  • anti-money laundering and counter-terrorism financing obligations

  • customer identification and verification

  • fraud prevention and transaction monitoring

  • sanctions and restricted-party screening

  • corporate registration and beneficial ownership verification

  • foreign exchange and cross-border transaction rules

  • consumer protection obligations

  • contractual disclosure obligations

  • data protection and privacy compliance

  • record keeping and audit requirements

Users acknowledge that Brazilian regulatory treatment may differ depending on the service type, transaction structure, counterparty profile, and the legal status of the provider involved.

KYC, AML, and Source of Funds

To protect our platform, our clients, and our institutional relationships, we may require individuals and businesses to complete know your customer, anti-money laundering, counter-terrorism financing, sanctions, and source of funds checks before accessing some or all services.

This may include requests for:

  • identification documents

  • proof of address

  • company registration documents

  • constitutional documents

  • tax information

  • beneficial ownership details

  • source of wealth information

  • source of funds evidence

  • transaction purpose and commercial background

  • supporting invoices, contracts, or trade documentation

We reserve the right to delay, decline, restrict, suspend, or terminate onboarding, transactions, or access where information is incomplete, inconsistent, unsatisfactory, or where a compliance concern exists.

Investment Risk Disclosure

Where the business presents investment-related services, private market opportunities, trade-linked opportunities, structured transactions, direct investments, private placements, or alternative asset exposure, these activities carry risk.

Investment and transaction risks may include:

  • loss of capital

  • illiquidity

  • counterparty failure

  • borrower default

  • market volatility

  • legal and regulatory change

  • foreign exchange risk

  • enforcement risk

  • operational risk

  • technology risk

  • settlement risk

  • jurisdictional risk

  • documentation risk

Past performance is not a reliable indicator of future performance. Indicative returns, target returns, scenarios, or market commentary are illustrative only unless expressly stated otherwise in formal transaction documents.

No representation is made that any investment, structure, or transaction will achieve its intended result.

Digital Assets and Digital Transactions

Where digital payment rails, token-based settlement, stablecoin transactions, digital escrow, or digital asset-linked services are used, additional risks and legal considerations may apply.

These may include:

  • blockchain settlement risk

  • wallet access risk

  • smart contract or technology failure

  • regulatory uncertainty

  • pricing or liquidity dislocation

  • counterparty and custody risks

  • cyber incidents

  • irreversible transaction risk

Digital asset-related services may be limited by jurisdiction, partner policy, legal changes, or evolving market standards. Users must ensure they understand the operational and legal risks before participating in any digital transaction.

Trade, Escrow, and Commercial Transactions

Where we support trade, escrow, receivables, private commercial transactions, or cross-border structuring, our role may vary depending on the arrangement.

In some cases we may act as:

  • platform provider

  • introducer

  • arranger

  • commercial facilitator

  • operational coordinator

  • service integrator

  • financial intermediary through approved partners

Unless expressly agreed in writing, we do not assume responsibility for the underlying commercial performance of third parties, shipment outcomes, supplier performance, buyer performance, legal title disputes, tax outcomes, or enforcement recoveries.

Each transaction remains subject to its own governing documents, commercial terms, and risk allocation.

Privacy Policy

1. Introduction

We are committed to protecting your privacy and handling personal data responsibly, lawfully, and securely. This Privacy Policy explains how we collect, use, store, share, and protect personal information obtained through our website, platform, onboarding systems, communications, and related services.

2. Information We Collect

We may collect:

  • identification information, including name, nationality, date of birth, and identification documents;

  • contact details, including email address, phone number, and address;

  • account, onboarding, and profile information;

  • transaction and usage data;

  • communications and support history;

  • technical data such as device, IP address, browser type, and website usage;

  • compliance and due diligence information;

  • any other information voluntarily provided by you or lawfully obtained from third parties.

3. How We Use Personal Data

We may process personal data to:

  • provide and administer our website and services;

  • respond to enquiries and onboarding requests;

  • carry out identity verification, due diligence, and compliance checks;

  • manage client relationships;

  • facilitate access to third-party providers and services;

  • improve platform functionality and user experience;

  • meet legal, regulatory, reporting, risk management, and security obligations; and

  • protect legitimate business interests where lawful.

4. Legal Bases

Where applicable law requires, we process personal data based on one or more lawful grounds, including consent, performance of a contract, compliance with legal or regulatory obligations, protection of rights, fraud prevention, and legitimate interests consistent with applicable law.

5. Data Sharing

We may share information with:

  • regulated financial institutions;

  • payment, banking, custody, and technology partners;

  • identity verification and compliance service providers;

  • professional advisers, auditors, legal counsel, and insurers;

  • regulators, law enforcement, courts, and governmental authorities where required; and

  • entities involved in a merger, restructuring, sale, or transfer of business or assets.

6. International Transfers

Given the cross-border nature of our operations, your personal data may be transferred internationally where necessary for service delivery, administration, support, verification, storage, or compliance. Where required, we will adopt appropriate safeguards and contractual measures for such transfers. LGPD includes specific rules for international transfers, and ANPD has issued regulation governing transfer mechanisms and adequacy analysis.

7. Data Retention

We retain personal information only for as long as reasonably necessary for lawful business purposes, regulatory compliance, dispute handling, recordkeeping, security, fraud prevention, and enforcement of rights.

8. Security

We use administrative, technical, and organizational measures designed to protect personal data against unauthorized access, misuse, alteration, disclosure, or loss. However, no electronic transmission or storage system is completely secure, and we cannot guarantee absolute security.

9. Your Rights

Subject to applicable law, you may have rights to request access, correction, portability, deletion, anonymization, information about sharing, or review of certain data processing activities. In Brazil, these rights are framed under LGPD and supervised by ANPD.

10. Contact

Privacy-related requests may be sent to: [insert privacy email / DPO email]

Cookie Policy

1. Use of Cookies

Our website uses cookies and similar technologies to support website functionality, security, performance, analytics, and user experience.

2. Types of Cookies We May Use

We may use:

  • strictly necessary cookies;

  • functionality cookies;

  • analytics and performance cookies;

  • security cookies; and

  • marketing or preference cookies, where applicable.

3. Purpose

Cookies may be used to:

  • maintain website sessions;

  • remember preferences;

  • measure traffic and usage trends;

  • improve content, navigation, and performance;

  • support fraud prevention and platform security; and

  • assist with communications and campaign performance.

4. Consent and Controls

Where required by applicable law, non-essential cookies will only be used with your consent. You may also adjust browser settings to reject or delete cookies, but doing so may affect website functionality.

5. Third-Party Cookies

Some cookies may be placed by third-party service providers such as analytics, communications, or embedded content providers. Their use is subject to their own privacy practices.

6. Updates

We may update this Cookie Policy periodically to reflect operational, legal, or technical changes.

AML / KYC Policy

1. Commitment

We are committed to maintaining robust anti-money laundering, counter-terrorism financing, sanctions, fraud prevention, and client due diligence standards.

2. Verification Requirements

Before providing access to certain services, accounts, products, payment capabilities, investment pathways, or platform features, we may require:

  • proof of identity;

  • proof of address;

  • corporate registration documents;

  • beneficial ownership information;

  • source of funds and source of wealth information;

  • tax and jurisdictional information;

  • transaction purpose details; and

  • any additional information reasonably required for compliance.

3. Ongoing Monitoring

We reserve the right to monitor account activity, onboarding information, transaction patterns, jurisdictional exposure, and client behavior for compliance, fraud prevention, risk management, and legal obligations.

4. Enhanced Due Diligence

Higher-risk clients, transactions, structures, jurisdictions, or activity types may be subject to enhanced due diligence, additional documentary requests, delayed onboarding, or refusal of service.

5. Refusal, Suspension, or Reporting

We may delay, decline, suspend, restrict, or terminate access to services where:

  • required KYC information is not provided;

  • information cannot be verified;

  • suspicious activity concerns arise;

  • sanctions or legal restrictions apply; or

  • we are required to act by law, regulation, court order, or competent authority.

6. No Obligation to Disclose Internal Controls

For security and legal reasons, we are not obliged to disclose the full nature of our internal monitoring, screening, reporting thresholds, or control systems.

7. Regulatory Context

Brazil’s AML/CFT framework is centered on the Brazilian authorities including Coaf, with prudential and compliance obligations for institutions authorized by the Central Bank of Brazil, including the internal policy and control framework addressed in Circular No. 3,978/2020.

Risk Disclosure

1. General Warning

Financial, commercial, digital asset, payment, trade, credit, treasury, and investment-related services involve risk. You should not rely solely on website content when deciding whether to use a service, enter a transaction, or pursue an investment opportunity.

2. Types of Risk

Depending on the relevant service, risks may include:

  • regulatory and legal risk;

  • market risk;

  • currency and foreign exchange risk;

  • credit and counterparty risk;

  • operational risk;

  • liquidity risk;

  • technology and cybersecurity risk;

  • settlement risk;

  • fraud risk;

  • jurisdictional and enforcement risk; and

  • loss of capital, delay, or restricted access to funds or assets.

3. No Guarantee

Past performance, indicative returns, case studies, strategic commentary, or transaction examples do not guarantee future performance or outcomes. Any forward-looking statements are illustrative only and may not materialize.

4. Suitability

Not all services or opportunities are suitable for all users. You are responsible for obtaining your own legal, tax, accounting, investment, and regulatory advice before making decisions.

5. Third-Party Dependence

Certain outcomes may depend on third-party institutions, market infrastructure, external approvals, and counterparties. Delays, restrictions, losses, or failures may arise from those parties.

Regulatory Notice

1. General Notice

This website may describe activities, services, structures, or opportunities that are subject to financial services, payments, privacy, AML/KYC, consumer, or other laws and regulations in one or more jurisdictions.

2. Jurisdictional Limitation

Nothing on this website should be taken as a statement that every service is legally available in every jurisdiction or to every category of person.

3. Third-Party Regulated Providers

Where regulated activity is carried out through a licensed, authorized, regulated, or supervised third-party institution, provider, or partner, the relevant service may be subject to that entity’s own terms, onboarding requirements, regulatory obligations, and acceptance criteria.

4. No Misleading Characterization

References to “platform”, “digital banking”, “financial services”, “investment access”, “treasury”, “payments”, or similar terms are descriptive of service functionality and ecosystem structure and should be read together with the applicable contractual, provider, and regulatory disclosures.

5. Further Information

More detailed regulatory, licensing, and service-structure information may be provided upon request and where appropriate.

Complaints Handling

1. Our Commitment

We are committed to handling complaints fairly, promptly, and professionally.

2. How to Lodge a Complaint

If you have a complaint about our website, conduct, onboarding, communications, or services, please contact us at:

  • Email: [insert complaints email]

  • Phone: [insert phone]

  • Address: [insert address]

Please include your name, contact details, a clear description of the issue, and any relevant supporting documents.

3. Internal Review

We will acknowledge receipt of your complaint and aim to review it within a reasonable timeframe. We may request further information where required to investigate the matter properly.

4. Escalation

If you are dissatisfied with the outcome or handling of your complaint, you may have rights to escalate the matter to a relevant external body, regulator, ombudsman, dispute-resolution entity, consumer channel, or supervisory authority depending on the nature of the service and the jurisdiction involved.

5. Brazil Consumer Channels

In Brazil, complaint pathways may include direct provider handling and public complaint channels such as consumidor.gov.br, alongside other relevant consumer protection channels depending on the matter. The Central Bank also indicates public complaint pathways in its consumer guidance.

Data Protection (LGPD)

1. Commitment to LGPD

Where Brazilian data protection law applies, we process personal data in accordance with the principles and requirements of the Lei Geral de Proteção de Dados Pessoais (LGPD).

2. Scope

This includes data collected through our website, onboarding, account interactions, customer support, service delivery, analytics, compliance procedures, and commercial relationships.

3. Principles

We seek to process personal data consistently with applicable principles including lawful purpose, adequacy, necessity, transparency, security, prevention, non-discrimination, and accountability.

4. Data Subject Rights

Where applicable, data subjects may request confirmation of processing, access, correction, anonymization, blocking, deletion, portability, information on sharing, and review of certain processing decisions, subject to legal and regulatory limitations.

5. Data Protection Contact

Questions or requests relating to personal data and LGPD rights may be directed to:
compliance@platinumwealthmarkets.com

6. Supervisory Authority

The Brazilian National Data Protection Authority (ANPD) is the authority responsible for overseeing and enforcing the LGPD framework in Brazil.

Disclaimer

1. General Disclaimer

The content on this website is provided for general information only. It is not intended to constitute legal, tax, accounting, regulatory, financial, or investment advice, and should not be relied upon as such.

2. No Client Relationship

Accessing this website, submitting an enquiry, or receiving general information from us does not by itself create a client, advisory, fiduciary, banking, financial, legal, or professional relationship.

3. No Reliance

Users should undertake their own due diligence and seek their own independent professional advice before making any commercial, financial, legal, or investment decision.

4. Forward-Looking Statements

This website may contain statements regarding future opportunities, platform development, service capabilities, market positioning, or strategic direction. Such statements are indicative only and subject to change, uncertainty, dependency on partners, regulatory conditions, and commercial feasibility.

5. Third-Party Content

We may reference third-party institutions, capabilities, market practices, service providers, or opportunity types. Such references do not necessarily constitute endorsement, guarantee, or representation of availability.

6. Regulatory and Jurisdictional Limits

Certain services described on this website may be restricted, unavailable, or unsuitable in certain jurisdictions or for certain persons. Users are responsible for ensuring that access to, or use of, any service is lawful in their own jurisdiction.

General 

Intellectual Property

Unless otherwise stated, all content on this website, including text, branding, graphics, concepts, layouts, service descriptions, documents, and platform materials, is owned by us or used under licence.

Users may not copy, reproduce, distribute, republish, modify, frame, scrape, or commercially exploit website content without prior written consent.

Use of our website does not grant any right, title, or interest in our intellectual property or in the intellectual property of our partners or service providers.

Limitation of Liability

To the maximum extent permitted by law, we exclude liability for any loss, damage, cost, delay, interruption, inaccuracy, or consequence arising from:

  • use of this website

  • reliance on website content

  • service unavailability

  • delays in onboarding or approvals

  • compliance-based restrictions

  • third-party errors or failures

  • cyber events

  • digital transaction incidents

  • market losses

  • commercial disputes between counterparties

Nothing on this page excludes any liability that cannot lawfully be excluded under applicable law.

Changes to Legal Information

We may update this Legal page from time to time to reflect changes in our business, our services, our contractual framework, market practice, or legal and regulatory requirements.

Users should review this page periodically to remain informed of the current legal position applying to the website and related services.

Contact and Legal Notices

For legal notices, compliance queries, privacy matters, or requests relating to this website or our services, please contact us through the official contact channels listed on the website.

Formal legal or compliance communications should include sufficient detail to allow us to identify the relevant person, entity, transaction, or issue.

If you have any additional inquiries then please contact us. complaints@platinumwealthmarkets.com

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