Last Updated: July 14th, 2026

This document outlines the privacy and data processing policy of NAWKA CYBERSECURITY (NAWKA SOLUÇÕES E SERVIÇOS LTDA.), in compliance with Brazilian Laws No. 13,709/2018 and No. 13,853/2019, known as the Brazilian General Data Protection Law (LGPD), as well as the General Data Protection Regulation (GDPR) applicable to personal data of European Union residents.

This Privacy Policy describes how NAWKA handles information in connection with the Portfolio Ledger application and the NAWKA website.

Portfolio Ledger is designed to operate primarily as a local application. Investment records, transactions, portfolio information, imported databases, backups, and other financial data entered by the user are stored on the user’s own device and are not uploaded to or stored on NAWKA’s servers.

1. Information Processed by the Portfolio Ledger Application

Portfolio Ledger does not independently collect analytics, advertising data, telemetry, contact information, financial account credentials, or the investment data entered by the user.

The application may access or transmit limited technical information only for the purposes described below.

1.1 Locally Stored Portfolio Data

Information entered or imported into Portfolio Ledger, including:

Investment assets;
Purchase and sale transactions;
Quantities, prices, fees, dates, and currencies;
Portfolio performance information;
Locally created or imported database files;
Application settings and preferences;

is stored locally on the user’s device.

NAWKA does not receive, access, store, sell, or share this information.

The user is responsible for protecting the device, database files, and any backups created or exported through the application.

1.2 Marketplace Licensing and Purchase Validation

When Portfolio Ledger is installed or acquired through Google Play or the Microsoft Store, Google or Microsoft may process certain information required to:

Confirm that the application was legitimately acquired;
Validate licenses, subscriptions, or purchase status;
Prevent fraud or unauthorized use;
Meet marketplace, tax, legal, security, and regional requirements.

Depending on the marketplace and device, this information may include account, transaction, device, technical, license, and approximate regional information.

This processing is performed by Google or Microsoft under their own terms and privacy policies. NAWKA receives only the information made available by the applicable marketplace and necessary to determine the licensing status of the application.

Portfolio Ledger does not use marketplace licensing information for advertising or user profiling.

1.3 Alternative Evaluation or Business Licensing

Portfolio Ledger may support an alternative licensing channel for evaluation, testing, demonstration, corporate, or volume-licensing purposes.

When such a license is requested or activated, NAWKA may process limited information necessary to:

Issue the license;
Associate it with the authorized installation or customer;
Validate its authenticity and validity period;
Prevent license duplication, alteration, replay, or unauthorized use;
Provide licensing support.

Depending on the licensing process, this information may include:

Customer or organization name;
Contact information supplied by the requester;
License identifier;
Installation or device identifier generated for licensing purposes;
License type, issue date, expiration date, and validation status;
Technical information necessary to diagnose licensing problems.

This licensing information is not used for advertising and is not combined with the user’s locally stored portfolio or transaction data.

License-related records are protected using appropriate technical and organizational security controls, including encryption where applicable.

1.4 Banco Central do Brasil PTAX Service

Portfolio Ledger connects to the public data services provided by the Banco Central do Brasil — BCB to retrieve PTAX foreign-exchange rates.

The request may include information such as:

The requested currency;
The relevant date or date range;
Standard network information automatically transmitted during an internet request, such as the device’s public IP address and technical request headers.

Portfolio Ledger does not send the user’s portfolio, transactions, name, email address, account credentials, or other locally stored financial information to Banco Central do Brasil.

The PTAX service is an external public-data service operated independently by Banco Central do Brasil. Its availability, operation, logging, and data-handling practices are governed by Banco Central do Brasil. The BCB provides PTAX and exchange-rate information through its public API and OData services.

2. Information Collected Through Our Website

The NAWKA website and the Portfolio Ledger application are separate environments.

Visiting our website does not give NAWKA access to the investment or transaction data stored in Portfolio Ledger.

When you access our website, certain technical and usage information may be automatically processed by our hosting infrastructure, security services, or analytics providers, including Google Analytics.

This information may include:

Device category;
Operating system;
Browser and browser version;
Internet Protocol address;
Date and time of access;
Approximate geographic region derived from the IP address;
Referring website, search engine, social network, advertisement, or direct link;
Pages viewed and interactions with the website;
Cookie identifiers or similar online identifiers.

We use this information to:

Operate and secure the website;
Understand website traffic and usage;
Identify technical problems;
Improve website performance and content;
Measure the effectiveness of communications or advertising campaigns;
Produce aggregated audience statistics.

Google Analytics may use cookies and similar identifiers to distinguish users and sessions and measure website interactions. Google also provides controls that may limit analytics storage and collection.

Where required by applicable law, non-essential analytics or advertising cookies will be used only after the user has provided the appropriate consent.

Users may manage or disable cookies through their browser settings or through any cookie-consent controls provided on the website. Disabling cookies may affect certain website features.

3. How We Use Information

NAWKA uses information covered by this Privacy Policy only when reasonably necessary to:

Provide and maintain Portfolio Ledger;
Validate marketplace or alternative licenses;
Provide customer and technical support;
Retrieve requested PTAX exchange-rate information;
Operate, protect, analyze, and improve our website;
Prevent fraud, misuse, and unauthorized licensing;
Comply with legal, tax, regulatory, or contractual obligations;
Protect the rights, property, and security of users, NAWKA, and third parties.

NAWKA does not sell the personal information of Portfolio Ledger users.

NAWKA does not use investment or transaction information stored in Portfolio Ledger for advertising, profiling, analytics, or marketing because that information is not transmitted to NAWKA.

4. Information Sharing

We may disclose limited information only in the following circumstances:

4.1 Service Providers

Information may be processed by service providers that support specific functions, such as:

Google Play licensing and distribution;
Microsoft Store licensing and distribution;
Website hosting and security;
Google Analytics or other website analytics services;
Email, support, or business-license administration services.

These providers process information according to their own privacy terms and, where applicable, contractual obligations.

4.2 Legal and Security Requirements

We may disclose information when reasonably necessary to:

Comply with applicable laws or regulations;
Respond to a valid court order, subpoena, or lawful government request;
Establish, exercise, or defend legal rights;
Investigate fraud, security incidents, or unauthorized use;
Protect the safety, rights, and property of NAWKA, users, or third parties.

4.3 Business Transfers

If NAWKA undergoes a merger, acquisition, restructuring, or transfer of assets, relevant records may be transferred as part of that transaction, subject to applicable privacy and confidentiality requirements.

5. Data Retention

5.1 Data Stored in the Application

Portfolio and transaction information remains on the user’s device until the user edits it, deletes it, clears the application’s data, uninstalls the application, or deletes the relevant database or backup files.

NAWKA cannot remotely access or delete locally stored Portfolio Ledger data.

5.2 Licensing Records

Information used for alternative evaluation or business licensing may be retained for as long as necessary to:

Maintain and validate the license;
Provide support;
Prevent fraud or unauthorized activation;
Document the business relationship;
Comply with legal, accounting, tax, or contractual obligations.

When the information is no longer required, it will be deleted, anonymized, or securely archived as permitted or required by law.

5.3 Website and Analytics Data

Cookie duration depends on the type of cookie and the configuration of the website and analytics services.

Some cookies may expire when the browser session ends, while others may remain for a defined period unless deleted earlier by the user.

Analytics information may be retained according to the retention settings configured by NAWKA and the policies of the applicable analytics provider. Therefore, the previous fixed statement that all cookies expire after 30 days should only be used if your website is technically configured to enforce that exact period.

8. User Rights and Choices

Subject to applicable law, users may have the right to:

Request confirmation of whether NAWKA processes their personal information;
Request access to information held by NAWKA;
Request correction of inaccurate or incomplete information;
Request deletion of information when legally permitted;
Object to or restrict certain processing;
Withdraw consent when processing is based on consent;
Request information about parties with whom data has been shared;
File a complaint with the competent data-protection authority.

These rights apply only to information held or controlled by NAWKA.

Because portfolio and transaction data is stored locally, users manage that information directly through the application, the operating system, or the relevant database and backup files.

Marketplace-related information may need to be managed directly through the user’s Google or Microsoft account.