Privacy Policy

1. Who we are

Atlas Resources LTDA, registered under CNPJ 47.725.538/0001-27, with registered office at Praça Genuino Napoleão Magalhães, 330, Lt 1 C, Centro, Ipanema – MG, ZIP 36950-000, Brazil, is a non-financial holding company that participates in other companies as a shareholder, controls the operations of a business group and manages investments and equity stakes.

This Privacy Policy describes how we collect, use, store and protect personal data in full compliance with the Brazilian General Data Protection Law (LGPD – Law No. 13,709/2018).

2. Data we collect

We may collect the following types of personal data:

• Identification data: full name, company name, CPF/CNPJ.
• Contact data: email address, phone number, physical address.
• Browsing data: IP address, browser type, pages visited, traffic source.
• Communication data: messages sent via contact form or email.
• Contractual and financial data: information required for investment agreements, shareholder relations and corporate transactions.
• Corporate data: business information shared by partners, portfolio companies and counterparts for governance and due diligence purposes.

3. How we use your data

We use collected personal data for:

• Managing holding company operations, investments and portfolio relationships;
• Processing business proposals, shareholder agreements and M&A transactions;
• Communicating with investors, partners and corporate contacts;
• Fulfilling tax, legal, regulatory and corporate governance obligations;
• Improving our website and digital presence;
• Protecting the legitimate interests of Atlas Resources LTDA and its group.

4. Data sharing

We may share personal data with:

• Group companies: subsidiaries and companies in which Atlas Resources holds equity, for governance, compliance and operational coordination purposes;
• Service providers: legal advisors, auditors, accounting firms, IT systems and hosting providers, under confidentiality agreements;
• Financial institutions: banks and regulated entities involved in investment transactions, as required;
• Public authorities: when required by law, court order or regulatory body.

All sharing is based on legal grounds provided by the LGPD (contract performance, legal obligation or legitimate interest).

5. Cookies and tracking technologies

Our website may use cookies for functionality, analytics and marketing. Types include essential, analytics and marketing cookies. You may configure your browser to refuse cookies, though some features may be affected.

6. Data retention

Personal data is retained for the duration of the business relationship, the minimum period required by Brazilian tax and corporate law (generally 5 years), and applicable statute of limitations for legal proceedings. After the retention period, data will be securely deleted or anonymized.

7. Your rights (LGPD)

Under the LGPD (Law No. 13,709/2018), you have the right to confirmation, access, correction, deletion, portability, withdrawal of consent, objection, and information about data sharing.

8. Information security

We implement appropriate technical and organizational measures, including encrypted connections (HTTPS/SSL), access controls, strong authentication policies and periodic security reviews. In case of a relevant security incident, we will notify the ANPD and affected individuals within legally required timeframes.

9. External links

Our website may link to third-party sites. This Privacy Policy does not apply to external sites. We recommend reviewing the privacy policy of each site you visit.

10. Changes to this policy

This policy may be updated periodically. The last update date is always shown at the top. Continued use of our services after changes constitutes acceptance of the revised version.

11. Contact and Data Protection Officer

To exercise your rights or raise questions about this policy:

• Company: Atlas Resources LTDA
• CNPJ: 47.725.538/0001-27
• Address: Praça Genuino Napoleão Magalhães, 330, Lt 1 C, Centro, Ipanema – MG, ZIP 36950-000, Brazil