1 - Introduction

ASA is committed to processing the personal data to which it has access in accordance with current applicable legislation on privacy and data protection, in particular the provisions established by Law No. 13,709/2018 ("General Personal Data Protection Law" or "LGPD").

Accordingly, ASA has drawn up this Cookies Policy ("Policy") to explain, in a simple, transparent and objective manner, what cookies are, which cookies are used by ASA on its website and/or application (available at https://asa.com.br/) and what role they play in its activities.

2 - What are cookies?

Cookies are small electronic text files or fragments of information that are downloaded onto the user's computer, smartphone or any other electronic device with internet access. These small text files contain information about users' browsing on the ASA website and retain information related to their preferences, in order to improve the user experience and personalize access to the ASA website.

Cookies can be used for user authentication, monitoring malicious activity, research and analysis of the performance of the website and/or application.

ASA does not use any cookies that record personal data or information, passwords or operations carried out by the user on its platforms.

3 - For what purpose does ASA use cookies?

ASA uses cookies to provide the best user experience for its users, making its applications personalized and easier to navigate, based on user choices and browsing behavior.

This enables ASA to adjust the content of its applications to make it more relevant to the user, as well as remembering the preferences of its users, enabling faster and more efficient browsing.

For the purposes described in this Policy, ASA may collect, store, process and use information about the user's browsing on the website and/or application, which is part of the browsing logs.

4 - What types of cookies does ASA use?

While users are browsing the site, ASA uses the following cookies:

Research, analysis and performance cookies:

These help ASA to understand the performance of its website, its audience, the browsing habits of its users, the length of time they have visited the website, the way in which they have accessed a particular page of the website, as well as any problems encountered, such as error messages;

Preference cookies:

Enable ASA to collect information related to user behavior and preferences, allowing ASA to record information such as the preferred language, the region where the user is located, among other local settings, providing a personalized experience to users;

Advertising cookies:

These allow ASA to present relevant advertising to the user, both on and off its website or on third-party websites, and identify whether users who have viewed its marketing/advertising actions have visited the ASA website after viewing it, to measure the effectiveness of advertising campaigns. In addition, these cookies can be used by ASA to remember any searches carried out by users on the site and, on the basis of such searches, present them with advertisements related to their interests; and

Security cookies:

These enable the activation of the site's security features in order to help monitor and/or detect malicious activity, as well as to protect user information from access by unauthorized third parties.

For reference, these cookies can also be:

Persistent cookies:

Remain on the users' hard disk after the browser is closed and will be used by the browser on subsequent visits to the site. These cookies can be removed by following the user's browser instructions; or

Session cookies:

These are temporary and disappear after the browser is closed, and it is possible to reset the web browser to refuse them. However, some features of the platform may not work properly if the ability to accept cookies is disabled.

The user can disable cookies through the configuration options of their browser. However, by deciding to remove cookies, the user is aware and acknowledges that it is possible that the website and/or application may not properly perform all of its functions, partially or totally affecting navigation.

In addition, since cookies capture personal data about the user, ASA recommends reading the Privacy Policy, available for viewing at any time at <asa.com.br>, which contains more information about how ASA processes personal data to carry out its activities.

5 - Updates

ASA reserves the right to change this Policy at any time, and any changes to this Policy will take effect immediately after its publication on its website. For this reason, the date of its last update is indicated at the end of this policy.

6 - Contact

Any matters relating to this Policy should be addressed to the following e-mail address dpo@asa.com.br.

ASA is committed to protecting the Personal Data to which it has access in accordance with current applicable legislation, in particular the General Personal Data Protection Law (Law No. 13,709/2018, "LGPD"), as well as the best practices on privacy and data protection in the market in which it operates.

For this reason, ASA has drawn up this Privacy Policy ("Policy") to clarify, in a simple, transparent, and objective manner, how it processes Personal Data in the context of its business activities.

This Policy is available to view at any time on the ASA website.

1. Definitions

The following definitions apply to this Policy:

"ASA":	ASA Asset 2 Gestão de Recursos Ltda;
"ASA Digital Channels":	Website, app, and other digital channels used by ASA to interact with its customers
"Controller":	The individual natural or legal person, whether governed by public or private law, responsible for decisions regarding the processing of Personal Data;
"Personal Data":	Any information relating to an identified or identifiable person, including electronic identification;
"Sensitve Personal Data":	Personal Data concerning race or ethnicity, religious beliefs, political opinion, membership of a trade union or religious, philosophical, or political organization, data concerning medical / genetic conditions, gender / sexual orientation, or biometric data, when linked to an individual;
"LGPD":	Law No. 13,709/2018, known as the General Personal Data Protection Law, which provides the legal bases for the processing of Personal Data and the obligations and requirements relating to information security incidents involving Personal Data of Data Subjects;
"Operator":	Individual or legal person, whether governed by public or private law, who processes Personal Data on behalf of the Controller;
"Policy":	This Privacy Policy;
Persoanal Data Holder” or “Holder":	The individual whose Personal Data is being processed;
“Personal Data Processing”:	All operations carried out with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.

2. Who does this Policy apply to?

This Policy applies to all persons who access and otherwise use the ASA Digital Channels and their respective functions, as well as to all persons with whom ASA (and/or the investment vehicles managed by ASA) maintains commercial or legal relations and who therefore have their Personal Data processed by ASA, for example:

• Clients (investors) - current or prospective - of the investment vehicles managed by ASA, as well as their partners, administrators, representatives and/or attorneys;
• Customers - current or prospective - of other products and services that may be made available by ASA and/or its affiliates;
• Assignors, debtors and/or third-party guarantors of assets and credit rights that are or may become part of the portfolios of investment vehicles managed by ASA, as well as their partners, administrators, representatives and/or attorneys-in-fact;
• Representatives and advisors of ASA’s clients (current or prospective), as well as distributors of investment products and financial institutions, and representatives of their partner firms;
• Representatives of suppliers and service providers;
• Natural persons or representatives of legal persons who carry out any other legal business with ASA, its affiliates, and/or with investment vehicles managed by ASA;
• Applicants for jobs at ASA and/or its affiliates;
• Visitors to the physical offices of ASA and/or its affiliates.

3. Guidelines:

The Data Subject must read this Privacy Policy in full, so that he/she is aware of the processing of personal data carried out by ASA.

If you do not agree with this Policy, we ask that you stop browsing the ASA Digital Channels and/or that you do not submit a proposal to contract any of our services or provide your data by any other means available.

4. Which Personal Data are collected?

For ASA to carry out its activities, it is essential that it conducts some Personal Data Processing operations, which may involve, for example, the following Personal Data:

• Identification data, such as name, e-mail, address, nationality, telephone number, identification documents (RG and CPF), among other information that may be requested as applicable to the relationship between ASA, its affiliates, and/or the investment vehicles managed by ASA, and the Accountholder. Such data is provided by the Accountholders themselves or is included in personal documents, corporate documents, tax documents, contracts, and/or available from public sources;
• Client registration data: in addition to the above identification data, additional information may be collected in accordance with the intended relationship, in compliance with applicable regulations, such as: level of education, profession, knowledge and experience in financial investments, declared income, expectation of future income, assets and their composition, bank account number, confirmation of classification as Politically Exposed Persons (PEP), among others; including personal data of the legal representatives of legal entity clients or investment funds, and third party contractors;
• Geographic Location: information that identifies the Holder's location through, for example, latitude and longitude coordinates obtained by GPS, Wi-Fi or cellular location triangulation, which enable the proper and secure operation of certain functionalities made available through the ASA Digital Channels.
• Device Information: data that may be collected automatically from any device used to access the ASA Digital Channels. This information may include, but is not limited to, the type of device, the device's network connections, the device's name, the device's IP address, information about the device's browser and the internet connection used, geo-location information and information about the applications downloaded on the device.
• Technical Usage Data: information that shows how the Data Subject uses the ASA Digital Channels and their functionalities, including the IP address, statistics on how pages are loaded or viewed, the websites that the Data Subject has visited and browsing information collected through cookies or similar technology.
• Complementary data of candidates in selection processes:, in addition to identification data, such as information on educational background and professional experience, languages spoken, certificates obtained, age, date of birth, gender, photograph (as included in CVs by the Data Subjects themselves). This data may also be collected directly from public sources, such as social networks where Data Subjects post their Personal Data;
• Vehicle data:, such as license plate number and car model, among other information that may be necessary to authorize access to the ASA parking lot, provided directly by the Holder.

5. For what purposes Personal Data is processed?

ASA processes the Personal Data indicated in this Policy for the following purposes:

• Contractual obligations: to enter into contracts of various kinds and also to fulfill the obligations assumed in the contract with the Holder or the legal entity it represents or relates to;
• Distribution of fund quotas and/or asset management: to carry out the activities of distributing quotas of investment funds under its management and/or asset management, with regard to collecting registration information, identifying and verifying the requirements for making investments; confirming investment or redemption orders; accepting investment or redemption requests; and other related acts;
• Execute the contract or related preliminary procedures: in order to register clients and maintain the relationship, formalize contracts, communicate with clients and drawees, analyze and pay out credit operations and procedures for receiving and collecting, such as, but not limited to, issuing slips, bank instructions, writing off securities, reconciliation, opening a controlled/guaranteed account, among others;
• Carrying out credit assessment: such as in the case of documentation analysis, periodic credit and risk analysis and updates, collateral registration, real estate transaction assessment, credit limit analysis, profile classification, security checks and others;
• Fraud prevention: to monitor and analyze Card Holder behavior in relation to the use of ASA Digital Channels and their functionalities, and the services and products made available by ASA, in order to manage risks and prevent fraud;
• Compliance with legal and regulatory obligations: to comply with legal and regulatory obligations arising from current legislation applicable to ASA's activities and the services and products involved, including compliance and anti-money laundering obligations and specific rules applicable to contract performance and/or compliance with legal and regulatory requirements, in particular, but not limited to, the rules of the Brazilian Securities and Exchange Commission ("CVM"). ASA may also process Personal Data to fulfill obligations defined in self-regulatory codes to which it has adhered, such as those issued by ANBIMA (Brazilian Association of Financial and Capital Market Entities), as applicable;
• Communication: for communication with Unitholders, such as sending relevant corporate communications about ASA and its products; answering requests and queries; marketing and prospecting for new clients;
• Due Diligence: analysis for starting and maintaining relationships with service providers and partners;
• Recruitment and selection: to recruit and select candidates for job vacancies at ASA;
• Holder service: to respond to any requests from the Holders, via the means of communication made available by ASA on the ASA Digital Channels;
• Internal management: to manage activities related to ASA's accounting, procurement, controllership and compliance, as well as other relevant internal areas;
• Defense of interests: to defend the rights and interests of ASA, its affiliates, and/or investment vehicles under ASA's management, in any legal or extrajudicial claims;
• Other purposes: ASA may also use the Personal Data collected for other purposes that are not conflicting or excessive in relation to the purposes listed above, always in accordance with the applicable Brazilian legislation in force, based on legitimate interests, except in cases where the rights and legal guarantees of the Data Subject prevail.

6. With whom is Personal Data shared?

ASA may share Personal Data in the following circumstances:

• Companies and vehicles of the same economic group, exclusively in accordance with the purposes set out in this Policy;
• Other parties involved: due to ASA's business model and the relationship maintained with the respective client, it may be necessary to share Personal Data with other processing agents, such as service providers, subcontractors, financial institutions, distributors, brokers and trustees and custodians, within the limits of what is necessary and always in accordance with current applicable Brazilian legislation and with the adoption of best information security practices, in order to guarantee the security and confidentiality of Personal Data.
• In addition, ASA may share Personal Data with public authorities as necessary to comply with its legal, regulatory and self-regulatory obligations. Likewise, in the event that any police, administrative or judicial authority requests access to the Data Subject's Personal Data, and this request is supported by the applicable Brazilian legislation in force, ASA may share the Personal Data in order to fulfill this request.
• Finally, ASA may share Personal Data to protect its interests in any type of conflict, including administrative and judicial claims.

7. How long is Personal Data stored?

The Personal Data processed for the purposes described in this Policy will be stored by ASA only for the period established in the terms of the applicable legislation, being retained only in the legal hypotheses and only for the period in which they are necessary for the achievement of lawful, specific and informed purposes, as well as for the protection of the regular exercise of rights, rendering of accounts or request of competent authorities.

In addition to the hypotheses described above, in order to determine the appropriate retention period for Personal Data, the quantity, nature, potential risk of damage arising from unauthorized use or disclosure are also taken into account. unauthorized use or disclosure, the purpose of Processing and whether it is possible to achieve such purposes by other means and in accordance with applicable legal requirements.

8. What are your rights?

In compliance with current applicable legislation, with regard to the Processing of Personal Data, ASA informs you that it respects and guarantees the possibility of submitting requests based on the following rights provided for in the LGPD, as applicable:

• Confirmation of the existence of Personal Data Processing;
• Access to Personal Data;
• Correction of incomplete, inaccurate or outdated Personal Data;
• Anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of applicable legislation;
• Portability of processed data;
• Deletion of any Personal Data processed on the basis of consent, except in the cases provided for in the applicable legislation;
• Information on the public and private entities with which we will share your personal data, if applicable;
• Information on the possibility of not giving consent and the consequences of not giving consent; and
• Revocation of your consent, where applicable.

To find out more about these rights, ASA recommends and encourages you to read the LGPD in full, specifically Chapter III.

If the Personal Data Subject needs to exercise any of the rights described above, or if they believe that their Personal Data has been and/or is being used in a manner incompatible with the purposes described in this Policy, they may submit their request through the contact details provided in Item 13 of this Policy.

In order for the Data Subject to exercise their rights, as mentioned above, ASA may request certain information for the purposes of authenticating their identity and guaranteeing the privacy and security of their Personal Data

9. How is your Personal Data protected?

ASA implements appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing or accidental loss, destruction or damage. For example, ASA processes Personal Data in a secure operating environment, access to which is segmented and restricted by passwords, or in physical archives, access to which is only granted to authorized employees.

Although ASA adopts security measures compatible with the nature of the Personal Data it processes and with the best practices available in the Brazilian market, ASA cannot guarantee against technical failures or possible malicious actions by third parties, given the very nature of current information technologies.

10. Personal data of children and adolescents

ASA's business activities do not involve the Processing of Personal Data of children or adolescents, which is why no Personal Data is intentionally collected from these Data Subjects.

In the event that ASA collects or receives data from children or adolescents, all appropriate measures to protect this data will be adopted, always in the best interests of these Data Subjects, in accordance with the applicable laws in force.

11. Intellectual property

The following are owned by ASA:

• All software, applications or functions used on or linked to the website and/or application;
• The visual identity of the website and/or application;
• The name, brand, domain name, slogan or any advertising expression or distinctive signs owned by ASA appearing on the website and/or application; and
• All content created and produced by ASA or by third parties, which may not be used, in any way or form, by users or third parties.

12. Updating and validity

This Policy has been in force since February 2024.

ASA seeks to improve its activities on a daily basis, so it reserves the right to amend this Policy at any time, primarily with a view to providing the data subject with an increasing level of transparency about the way in which it processes Personal Data.

In addition, should this Policy undergo any significant changes, ASA will publish the amended version of this document in order to inform Data Subjects of the new conditions for the Processing of their Personal Data.

13. Legislation and jurisdiction

This Policy is governed, interpreted, and executed in accordance with the applicable Brazilian legislation in force, in particular the LGPD, regardless of the laws of other countries, and the jurisdiction of the district of São Paulo/SP will settle any doubts or controversies arising from this Policy.

14. Contact

ASA is available to answer any questions arising from this Policy or the way we process Personal Data, as well as to receive requests from Data Subjects, via the following e-mail: [dpo@asainvestments.com.br]