Cognitor Terms of Use

These Terms of Use («Terms») govern access to and use of the public website at mycognitor.com, related marketing and campaign pages, the subscriber web application (portal), editorial content (including without limitation PDF documents, executive summaries, dossiers, daily briefings, podcasts and «special content» materials), communications and services associated with the Cognitor brand (the «Service»).

The Service is provided by ADKZ TECNOLOGIA DA INFORMACAO LTDA, a Brazilian legal entity (trade name: Adkz), CNPJ 46.996.118/0001-12, with its principal place of business at Rua João José Rodrigues de Morais, 270, City Ribeirão, Ribeirão Preto – SP, 14021-340, Brazil (the «Operator», «we»). Personal data processing is governed by the Privacy policy.

By accessing the site, registering contact (e.g. waitlist), creating a portal account or purchasing a paid plan, you state that you have read, understood and accept these Terms. If you do not agree, you must not use the Service.

1. Definitions

• User: natural person who accesses the site, the portal or interacts with the Service.
• Account: authenticated profile on the portal, usually linked to email and optionally sign-in via a third-party identity provider (e.g. Google), as described in the Privacy policy.
• Content: text, audio, PDF files, summaries, podcasts, briefings, data visualisations and any materials made available under the Service, according to your plan.
• Plans: access tiers — typically a free tier with limited features and editorial timing, and a paid plan with additional deliverables and broader access. Exact terms are shown on the portal and/or checkout.
• Free trial: when offered at checkout, a period during which the paid plan may be tried on the terms then displayed (typically up to seven days before the first recurring charge, as configured in Stripe).
• Partner programme: promotion of the Service via links or promotional codes that may apply commercial terms at checkout, subject to the rules then in effect between the Operator, the partner and the payment provider.
• Asset universe: configurable set of financial instruments used as editorial reference; listing in the portal is informational and not personalised investment advice.
• Operator's country: Brazil, with headquarters in Ribeirão Preto, State of São Paulo, relevant for governing law and default venue, without prejudice to mandatory rules of your country as a consumer or habitual resident.

2. Nature of the Service — information and education

Cognitor provides information, structured research and education on markets and investing, with contextual emphasis on US-listed assets and relevant macroeconomics, delivered in Portuguese, Spanish and English, using editorial processes and, where applicable, computational tools, always as non-personalised content. The method uses multiple editorial perspectives and synthesis; it is not «signals», execution chat or a promise of financial return.

We do not provide:

• Personalised investment recommendations for your profile, goals or tax situation;
• investment advisory or investment services requiring a specific licence or registration, unless the Operator is legally authorised and this is clearly stated;
• buy or sell orders for securities in your name;
• portfolio management, administration of third-party wealth or execution of trades on your behalf.

Any investment decision is yours, based on your analysis, risk tolerance and, where appropriate, independent advice from regulated professionals.

The Service does not replace obligations under CVM, the Central Bank of Brazil or other regulators when you invest in products subject to Brazilian or foreign regulation.

The following disclaimer applies to all Content:

Content is strictly informational and educational. It does not constitute personalised investment advice, a solicitation to buy or sell securities, or investment or portfolio management services. Investing involves risk, including loss of capital. Past or simulated performance does not guarantee future results. The user is responsible for their own investment decisions.

3. Account, authentication and security

Portal access may require an Account. You agree to provide accurate data, keep credentials secure and promptly notify us of any unauthorised use. The Operator may refuse, suspend or close Accounts for breach of these Terms, fraud or risk to the Service.

Authentication and session may rely on third-party services (e.g. Google Firebase). You may optionally enable push notifications or install the portal as a progressive web app (PWA); these features are for notices of new content, not trading orders or execution alerts. Personal data processing is governed by the Privacy policy.

4. Subscriptions, payments and plans

Paid plans are processed by a payment provider (typically Stripe). Amount, currency and billing country follow the checkout configuration; the portal may use dedicated local pricing for, among others, Brazil, the United States, Canada, Australia, the Philippines, Mexico, Chile and Colombia, and generally bill in US dollars (USD) for billing countries elsewhere (including the United Kingdom, EU/EEA and other countries), as shown at checkout. Billing cycle, renewal, cancellation, free trial when offered and refund policy are as shown at checkout, in the Stripe Customer Portal (if available) and/or transactional messages. If these Terms conflict with purchase terms for the paid transaction, the purchase terms prevail for that part.

Subscription status used to authorise paid Content is synced with the payment system; the Operator may adjust features and plans with reasonable notice where required by law or good practice. Payment failures may be handled under the provider's and portal's rules (including temporary continued access for an already paid period, when implemented).

5. Content licence and technical restrictions

We grant you a limited, non-exclusive, non-transferable, revocable licence to access Content you are entitled to, for personal non-commercial use, for the duration of the contractual relationship or authorised access.

Without prior written consent from the Operator you must not: reproduce, publicly distribute, resell or share paid Content with third parties; circumvent technical protection (including attempting to access files in private storage without valid authorisation); reverse engineer the application, abusive scraping or behaviour that harms the Service.

Content files may be served via temporary server-validated access mechanisms; you must not share links or copies that allow unauthorised access.

6. Intellectual property

The Cognitor brand, site and portal design, editorial structure, pipeline naming (where disclosed), reports, audio and other distinctive elements are protected by copyright, related rights and/or trade secrets, as applicable in each jurisdiction. No clause transfers those rights to the User.

7. Availability and changes

We aim to keep the Service available but do not guarantee uninterrupted, error-free or delay-free operation. We may modify, discontinue or replace features, provided we do not unjustifiably frustrate rights already acquired for paid subscriptions, under the law applicable in your country.

8. Limitation of liability

Content may contain errors, omissions or become outdated. The Service is provided «as is», without warranties of completeness, fitness for a particular purpose or financial results.

No performance warranties: we do not guarantee profits, capital protection or absence of losses. Financial markets involve risk, including total loss of invested capital.

To the fullest extent permitted by applicable law in your case (including limits under the Brazilian Consumer Defence Code or equivalents elsewhere), we are not liable for indirect damages, lost profits, data loss or consequential damages. If total exclusion is not allowed, the Operator's aggregate liability may alternatively be limited to fees you paid for the Service in the twelve months before the event — or zero if you only use free offers, except for wilful misconduct or gross negligence where the law does not allow limitation.

9. Third-party links and services

The site or Content may reference brokers, data sources or external tools. The Service relies on providers such as Google (authentication, database, push messaging when enabled), Google Cloud Storage (private file storage), Stripe (payments), hosting (e.g. Vercel or equivalent) and others listed in the Privacy policy. We do not control third parties' terms; use is at your own risk.

10. Waitlist and communications

If you join a waitlist or newsletters, data processing and rights to object or withdraw are described in the Privacy policy.

11. Changes to the Terms

We may update these Terms. The current version is the one published on this page with a revision date. For material changes, when we have your contact details, we may notify you by email or in the portal. Continued use after the effective date may constitute acceptance, without prejudice to mandatory consumer rights in your jurisdiction.

Last revised: 4 April 2026.

12. Governing law, venue and international use

The Service is offered online and may be accessed from different countries. The general legal relationship between you and the Operator, including these Terms, is governed primarily by the laws of the Operator's country, except where mandatory laws of another country where you are a consumer or habitual resident provide additional or non-waivable protections.

Brazil: if you are a consumer resident in Brazil, provisions of the Consumer Defence Code (Law 8.078/1990), the LGPD (Law 13.709/2018) and other Brazilian rules may apply. Where applicable, you may rely on venue at your domicile under Art. 101(I) CDC, without prejudice to other procedural rules.

European Union and EEA: if you are a consumer or data subject there, EU/EEA law (including consumer rules and the GDPR where applicable) also applies; choice of the Operator's country does not reduce those guarantees.

Other countries (including the United States): local consumer, privacy or capital-markets laws may impose additional requirements; nothing in these Terms seeks to override mandatory rules of your jurisdiction.

For disputes, the courts of Ribeirão Preto, State of São Paulo, Federative Republic of Brazil, the Operator's seat, are generally competent, unless mandatory law requires another venue (e.g. consumer venue in Brazil). Online dispute resolution platforms or administrative bodies may exist depending on your country.

13. Contact

Questions about these Terms: legal@mycognitor.com.

Personal data: Privacy policy.