This policy explains which personal data is collected on this website, what it is used for, who it may be shared with, and how you can exercise your rights, under Lei nº 13.709/2018 (LGPD, Brazil's General Data Protection Law).

1. Who the controller is

Carlos Filho, an investment advisor affiliated with GWM Investments, an independent investment agents' firm (agentes autônomos) accredited with BTG Pactual, under CVM Resolution nº 178/2023 (CVM is Brazil's securities regulator).

Contact for privacy matters: [email protected].

2. What data is collected

Only what you type into the contact form, on your own initiative:

Through the site's automated assistant: the messages exchanged (with phone number, email, CPF (Brazilian taxpayer ID) and postal code masked), the page, the date and a code derived from the IP address — see Site assistant.

Sensitive data

The wealth range is optional and deliberately collected in broad ranges, never as an exact amount. Do not ask for or send through this site: CPF, RG (Brazilian ID card number), passwords, account numbers, card details, statements or health information. None of this is needed to schedule a diagnostic.

3. What this site does NOT do

• It does not use the data for anything other than replying to your contact.
• It does not keep the form content beyond what is needed to reply: a copy is stored in a server area outside the website, accessible only to Carlos, and is deleted on request.
• It does not use tracking cookies, advertising pixels or analytics tools.
• It does not sell, rent or transfer data to third parties.
• It does not build behavioral profiles or make automated decisions about you.

Calculators

The compound interest simulator and the exchange spread calculator run entirely in your browser. The values you type are not sent anywhere. The spread calculator queries only the public PTAX rate (the Central Bank's reference exchange rate) through the Central Bank of Brazil API; that query sends the currency and the date, never your values.

4. How the data is handled

When you submit the form, the site records a copy of the data in a server area outside the website, accessible only to Carlos, even if you do not confirm sending through WhatsApp — this is what allows a reply when WhatsApp fails. The message also opens ready-made in your WhatsApp, and whether to send it is your decision. From the moment it is sent, the conversation is handled within WhatsApp, subject to the WhatsApp (Meta) privacy policy, and is stored on Carlos's device like any other work conversation.

5. Legal basis and purpose

• Consent (art. 7, I): by filling in and submitting the form, for the initial contact you requested.
• Preliminary procedures related to a contract (art. 7, V): if the conversation evolves into an advisory proposal.

The data is not used for any purpose other than the one that prompted the contact.

6. Sharing

The initial contact is handled only by Carlos. If you decide to become a client, account opening and custody take place within the BTG Pactual structure, under the institution's own privacy policy and regulatory obligations, including the legal requirements for identification (KYC) and anti-money-laundering. At that point, the necessary data is provided by you directly to the bank.

Hosting is provided by Vercel, which, like any web server, records technical access logs (IP address, browser, date/time) for operation and security. These logs are not accessed or cross-referenced with the form data.

7. Retention

Form leads are kept for as long as the interest in the contact lasts and are deleted on request; assistant conversations are deleted after 90 days (see the Site assistant section). WhatsApp messages are kept for as long as the relationship or the interest in the contact lasts, and deleted on request, except where there is a legal or regulatory obligation to retain them (for example, records required for advisory activity).

Site assistant

The site has an automated assistant with pre-written answers; it does not use artificial intelligence to generate text and does not make investment recommendations. When you use it, the following are recorded: the messages exchanged (phone number, email, CPF and postal code are masked before being stored), the page where the conversation started, the date and a code derived from the IP address (hash), used only to limit abuse. If you provide your name and WhatsApp through the assistant, that data follows the same policy as the contact form above. Conversations are deleted after 90 days; only daily totals remain, without content.

8. Your rights (art. 18 of the LGPD)

You may, at any time and free of charge, request:

• confirmation that processing exists and access to the data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of unnecessary or excessive data;
• portability to another provider;
• deletion of data processed on the basis of consent;
• information about whom the data has been shared with;
• withdrawal of consent.

Just ask by email or directly on WhatsApp. The reply is given as soon as possible and, at the latest, within the legal deadline.

9. Security

The site is served exclusively over HTTPS. The server area where the leads and assistant conversations are kept is outside the website, with no public access, and the exposure surface is minimal: only what Carlos needs in order to reply.

10. Minors

The site is not intended for people under 18 and does not knowingly collect data from children and adolescents.

11. Changes

If this policy changes, the “last updated” date at the top is changed. Relevant changes will be communicated to anyone in active contact.

12. Investment notice

The information on this site is for informational and educational purposes only and does not constitute an individualized investment recommendation, an offer or a promise of returns. Investments involve risk and may result in losses. Past performance is no guarantee of future performance.

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