Foreign trade imports of SIRCLAV TABACO SAS

VERITRADE CORP. TERMS OF SERVICE Effective

Date: June 18, 2026.

Last Updated: June 18, 2026.

Veritrade Corp. · 2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA.

IMPORTANT — PLEASE READ THESE TERMS OF SERVICE CAREFULLY BEFORE ACCESSING OR USING THE VERITRADE PLATFORM . BY CREATING AN ACCOUNT, CLICKING "I AGREE", OR OTHERWISE ACCESSING OR USING THE SERVICE, YOU AND THE LEGAL ENTITY YOU REPRESENT AGREE TO BE LEGALLY BOUND BY THESE TERMS.

These Terms of Service ("Agreement" or "Terms") constitute a legally binding contract between Veritrade Corp., a corporation incorporated under the laws of the State of Florida, USA ("Veritrade", "we", "us", or "our") , and the legal entity or natural person ("Customer", "you", or "your") accessing or using the Veritrade platform, data services, and related products available at www.veritradecorp.com (the "Platform"). If you accept these Terms on behalf of a company or other legal entity, you represent and warrant that you have full legal authority to bind such entity. If you lack such authority, or if you do not agree to these Terms, you must not use the Platform.

1. Definitions

For the purposes of this Agreement, the following terms shall have the meanings set forth below:

"Platform": means Veritrade’s web application, databases, application programming interfaces (APIs), dashboards, reports, and all related software and services.

"Data": means commercial transaction records, import/export data, company profiles, statistics, and any other information available through the Platform, whether sourced from public government customs registries or third-party data providers.

"Subscription": means the paid tier or billing plan selected by the Customer that grants access to specific features and volumes of Data, as set forth on the corresponding pricing page.

"Authorized User": means any employee, contractor, or representative of the Customer who is authorized to access the Platform under the Customer's corporate account.

"Confidential Information": means all non-public information disclosed by one party to the other party that is designated as confidential or that reasonably should be understood to be confidential given the nature of the information.

2. Acceptance of Terms and Eligibility Requirements

By accessing or using the Platform, you represent and warrant that:

(a) you are at least 18 years of age;

(b) you possess full legal capacity to enter into binding contracts;

(c) your use of the Platform complies with all applicable laws and regulations; and

(d) if acting on behalf of a company, you possess the necessary corporate authority to do so.

These Terms apply to all visitors, registered users, and Customers. Veritrade reserves the right to refuse service to anyone, at any time and for any reason, in accordance with applicable law.

3. Description of the Platform and Services

Veritrade provides a cloud-based business intelligence platform that aggregates, organizes, and enables structured searches of international trade transaction data (specifically import and export records). The Platform allows Customers to:

Search and filter commercial transaction records by product, company, country, date range, and other available parameters;

Analyze market trends, competitive intelligence, and supply chain logistics data;

Download Data in structured formats (CSV, Excel, or other available formats) subject to the usage limits of the applicable Subscription plan;

Access reports, automated dashboards, and analytics tools included in the Customer's active tier.

The data available on the Platform is compiled from: (i) public government customs records and official trade registries ; and (ii) data packages from third-party data providers that Veritrade deems reliable. Veritrade does not guarantee the raw accuracy of the underlying source data. Veritrade reserves the right to modify, update, discontinue, or enhance any feature or component of the Platform at any time. We will endeavor to provide reasonable prior notice of material changes when commercially practicable.

4. Subscriptions, Accounts, and Access

4.1 Subscription Plans

Access to the Platform requires a paid Subscription. Subscription plans, features, and data download limits are described on Veritrade's public pricing page. Subscriptions are contracted on an annual basis. The Subscription period shall commence on the Activation Date, defined as the date the service is made available to the Customer on the Platform.

4.2 Account Registration

To access the Platform, the Customer must register an account and provide accurate, current, and complete information. The Customer agrees to update such information in a timely manner to maintain its accuracy. Each corporate account is linked to a specific number of Authorized Users based on the applicable Subscription plan. The Customer shall not:

Share individual access credentials with individuals exceeding the total number of authorized users;

Allow multiple concurrent sessions under a single user credential;

Create an account using false or misleading corporate identity information;

Transfer, sell, lease, or assign account access to unauthorized third parties.

4.3 Account Security

The Customer is solely responsible for maintaining the confidentiality of its access credentials and for all activities performed under its account. The Customer shall immediately notify Veritrade at info@veritradecorp.com of any unauthorized use, credential theft, or security breach. Veritrade shall not be liable for any losses or damages arising from unauthorized use of the Customer's account.

5. Service Fees, Billing, and Payment

5.1 Fees

The Customer agrees to pay the applicable service fees ("Fees"). Prices are expressed in United States Dollars (USD) or Euros (EUR) and do not include applicable taxes, unless otherwise specified.

5.2 Billing and Payment Terms

Subscriptions are billed annually in advance, subject to verification of the corresponding payment. Veritrade may issue invoices and process payments through affiliated entities acting on its behalf, without modifying the contractual relationship established under these Terms or the applicable governing law. Payment is due upon the Customer's acceptance of the Order Form, unless different terms are explicitly agreed upon. For online purchases, payment is made at the time the transaction is completed. In the event of a breach of the payment terms set forth in the Order Form, Veritrade may suspend access to the Platform until the outstanding balance is settled.

5.3 Taxes

The Customer is responsible for all sales, use, VAT, GST, withholding, and other tax levies associated with its Subscription, excluding taxes based on Veritrade's net income. If Veritrade is required to collect such taxes, they will be added to the corresponding invoice. The Customer's tax obligations to its local authority do not affect the full gross amount owed to Veritrade as set forth in Section 5.1.

5.4 No Refunds

All Fees are non-refundable, unless expressly required by applicable law or as provided in Section 10 (Termination). If the Customer cancels its Subscription before the expiration of the current annual term, it shall not be entitled to any refund or credit for the unused prepaid portion.

5.5 Fee Modifications

Veritrade may modify its subscription fees at any time. The fees in effect at the time of each new subscription or renewal shall be those set forth in the corresponding Order Form or renewal notice.

6. License Grant and Intellectual Property

6.1 License to Customer

Subject to the Customer's compliance with this Agreement and timely payment of all due fees, Veritrade grants the Customer a limited, non-exclusive, non-transferable, and non-sublicensable license, during the active Subscription term, to access and use the Platform and Data in accordance with these Terms. The Customer may share and publish its own reports and analyses derived from the Data, citing Veritrade as the source, provided that such reports do not reproduce individual transaction records or bulk datasets obtained from the Platform.

6.2 Restrictions

The Customer shall not, directly or indirectly:

Resell, distribute, rent, sublicense, or make the Platform or Data available to unauthorized third parties;

Use the Data to create, train, or feed a database, product, or software service that competes directly or indirectly with Veritrade;

Engage in data scraping, crawling, or use automated tools to extract Data beyond what is reasonably permitted by the download feature built into the Platform;

Remove, alter, or obscure any copyright, trademark, or other proprietary notices appearing on the Platform;

Reverse engineer, decompile, disassemble, or attempt to derive the source code of any software component of the Platform;

Use the Platform for illegal purposes or in violation of any applicable law or regulation;

Export, re-export, or transfer Data in violation of applicable export control laws.

6.3 Veritrade's Intellectual Property

As between the parties, Veritrade owns and retains all right, title, and interest in and to the Platform, underlying technology, source code, trade names, trademarks, service marks, logos, domain names, and all Data (including all corresponding intellectual property rights). Nothing in this Agreement transfers any ownership rights or titles to the Customer.

6.4 Feedback

If the Customer provides Veritrade with comments, suggestions, or ideas regarding the Platform ("Feedback"), the Customer hereby grants Veritrade a perpetual, irrevocable, royalty-free, worldwide license to use and exploit such Feedback for any purpose, without any restriction or obligation to the Customer.

7. Data, Privacy, and Security

7.1 Customer Data

"Customer Data" means any data or information submitted by the Customer to the Platform (e.g., saved searches, customized reports, user preferences). The Customer retains all rights to its Data. The Customer grants Veritrade a limited license to process Customer Data solely for the purpose of providing, maintaining, and protecting the Platform services.

7.2 Commercial Data — Nature and Accuracy

International trade transaction data available on the Platform is compiled from government customs records and third-party sources. While Veritrade uses commercially reasonable efforts to ensure data normalization, it does not warrant that the data is complete, accurate, current, or error-free. The Customer is solely responsible for verifying data accuracy before making business or commercial decisions based thereon.

7.3 Privacy Policy

The collection and processing of personal data by Veritrade are governed by Veritrade's Privacy Policy, incorporated herein by reference and available at www.veritradecorp.com/privacy. By using the Platform, the Customer acknowledges and accepts the terms of the Privacy Policy.

7.4 GDPR Compliance

For Customers located in the European Economic Area (EEA), Switzerland, or the United Kingdom, Veritrade processes personal data as a data processor (or independent data controller, as applicable), in accordance with the General Data Protection Regulation (GDPR) and applicable national legislation. To the extent required by law, the parties will enter into a Data Processing Agreement (DPA). To request a DPA, contact legal@veritradecorp.com.

7.5 CCPA / CPRA Compliance

For California residents, Veritrade complies with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). Veritrade does not sell or share personal information within the meaning of such regulations. California residents may exercise their privacy rights (access, deletion, correction, opt-out) by contacting legal@veritradecorp.com.

7.6 Security

Veritrade implements commercially reasonable administrative, technical, and physical security measures to protect the Platform and Data. However, no method of transmission or electronic storage is completely secure, and Veritrade cannot guarantee absolute security.

8. Cookie Policy

The Platform uses cookies and similar tracking technologies. In accordance with Veritrade's technical guidelines, the following categories of cookies are employed exclusively:

Category I: Strictly Necessary Cookies (Technical and Security): Essential for the proper functioning of the platform, session management, financial fraud prevention, and mitigation of malicious automated bot attacks (utilizing third-party providers such as Stripe and Cloudflare). These cookies are automatically activated in both the public website and the private environment and cannot be deactivated by the user, as they are mandatory for the execution of the contractual service.

Category II: Statistics and Marketing Cookies (Subject to Consent): Correspond to the integrated HubSpot ecosystem and are focused solely on monitoring visits, analytical traffic analysis, and non-invasive lead generation within the public website. They are not deployed for invasive advertising purposes within the private SaaS product environment, and their use requires the prior and explicit consent of the user through the Platform's cookie consent panel or banner.

The user may configure preferences or revoke consent granted at any time through the Platform's cookie consent panel or via the technical settings of their internet browser. For additional legal inquiries regarding the processing of these technologies, contact legal@veritradecorp.com.

9. Confidentiality

Each party ("Receiving Party") agrees to:

(i) maintain the Confidential Information of the other party ("Disclosing Party") in strict confidence;

(ii) not disclose such Confidential Information to any third party without prior written consent; and

(iii) use such Confidential Information solely for the purposes contemplated under this Agreement.

These confidentiality obligations do not apply to information that:

(a) is or becomes part of the public domain through no fault of the Receiving Party;

(b) was lawfully known to the Receiving Party prior to disclosure;

(c) is independently developed without use of or reference to the Confidential Information; or

(d) is required to be disclosed by applicable law, regulation, or court order, provided that the Receiving Party promptly notifies the other party, to the extent permitted.

Each party acknowledges that a breach of this Section may cause irreparable harm, entitling the non-breaching party to seek immediate injunctive relief in addition to any other available remedies.

10. Term and Termination

10.1 Term

This Agreement commences on the date the Customer first accepts these Terms or executes an Order Form, and continues for the active Subscription term specified in such Form.

10.2 Termination for Cause

Either party may terminate this Agreement immediately upon written notice if:

The other party materially breaches this Agreement and fails to cure such breach within ten (10) days following receipt of written notice thereof; or

The other party becomes insolvent, files for bankruptcy, enters liquidation, or ceases its operations as a going concern.

10.3 Termination by Veritrade — Security Breach

Veritrade may immediately suspend or terminate the Customer's access, without liability or refund, if it has reasonable grounds to believe that the Customer : (i) has violated the use restrictions in Section 6.2; (ii) has shared credentials with unauthorized third parties ; or (iii) has used the Platform to misappropriate data for a service competing with Veritrade.

10.4 Effects of Termination

Upon termination or expiration of this Agreement : (i) all licenses granted hereunder terminate immediately; (ii) the Customer must cease all use of the Platform; (iii) any outstanding amounts become immediately due and payable. If Veritrade terminates the agreement for convenience or reasons not attributable to the Customer, Veritrade's sole liability shall be to refund the pro-rata portion of the fees paid corresponding to the unused Subscription period. If termination results from the Customer's material breach, no refund shall be issued.

10.5 Survival

Sections 6.3 (Veritrade's Intellectual Property) , 9 (Confidentiality) , 11 (Disclaimer of Warranties) , 12 (Limitation of Liability) , 13 (Indemnification) , and 15 (Governing Law) shall survive the termination or expiration of this Agreement.

11. Disclaimer of Warranties

THE PLATFORM AND ALL DATA ARE PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VERITRADE EXPRESSLY DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, AND DATA ACCURACY.

Veritrade does not warrant that : (a) the Platform will operate uninterrupted, error-free, or securely; (b) the Data will be accurate, complete, or current; (c) the Platform will meet the Customer's specific business requirements ; or (d) errors or software defects will be corrected within a specific timeframe. The data available on the platform is sourced from government registries and third-party sources that Veritrade does not control, and Veritrade is not responsible for errors or omissions in those sources. The Customer assumes sole responsibility for verifying the data before using it as a basis for any commercial decision.

12. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VERITRADE, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR SUPPLIERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING, WITHOUT LIMITATION, LOSS OF PROFITS, LOSS OF DATA, LOSS OF GOODWILL, BUSINESS INTERRUPTION, OR THE COST OF PROCUREMENT OF SUBSTITUTE SERVICES, ARISING OUT OF OR RELATED TO THIS AGREEMENT OR THE USE OF (OR INABILITY TO USE) THE PLATFORM, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

In any event, Veritrade's total aggregate liability to the Customer for all claims arising out of or related to this Agreement shall not exceed the total amount of fees actually paid by the Customer to Veritrade during the twelve (12) months immediately preceding the event giving rise to the claim. Some jurisdictions do not allow the exclusion or limitation of certain damages; in such jurisdictions, Veritrade's liability shall be limited to the greatest extent permitted by applicable law.

13. Indemnification

The Customer agrees to indemnify, defend, and hold harmless Veritrade and its officers, directors, employees, agents, successors, and assigns against any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to:

The Customer's breach of any provision of this Agreement;

The violation by the Customer or its users of any applicable law or regulation;

The use of the Platform by the Customer in a manner not authorized by this Agreement;

Any unauthorized access to the Platform resulting from the Customer's failure to safeguard access credentials;

Any third-party claim arising from the Customer's use or misuse of the Data.

Veritrade reserves the right to assume the exclusive defense and control of any matter subject to indemnification by the Customer, in which case the Customer shall fully cooperate with Veritrade in asserting all available defenses.

14. Acceptable Use Policy

The Customer agrees not to use the Platform to:

Violate any local, state, national, or international law or regulation;

Transmit illegal, defamatory, harassing, fraudulent, or harmful material;

Attempt to probe, scan, or test the vulnerabilities of the Platform's networks or systems;

Introduce malicious software, viruses, worms, or trojans into the Platform;

Harvest or collect personal information of other users without consent;

Use the Platform in any manner that could damage, disable, overburden, or impair its server infrastructure.

Breach of this Acceptable Use Policy will result in the immediate suspension or termination of access without any right to a refund.

15. Governing Law and Dispute Resolution

15.1 Governing Law

This Agreement shall be governed by and construed in accordance with the laws of the State of Florida, USA, without regard to its conflict of laws principles.

15.2 Pre-Arbitration Dispute Resolution

Before initiating formal proceedings, the parties agree to attempt in good faith to resolve any dispute through direct negotiation for a period of thirty (30) days from written notice of the dispute.

15.3 Binding Arbitration

All disputes not resolved by mutual agreement shall be definitively settled by binding arbitration administered by the American Arbitration Association (AAA) in accordance with its Commercial Arbitration Rules. The arbitration shall be conducted in Miami-Dade County, Florida, in the English language. The arbitral award shall be final and binding, and judgment on the award may be entered in any court having jurisdiction.

15.4 Class Action Waiver

THE CUSTOMER AND VERITRADE AGREE THAT ANY PROCEEDING SHALL BE CONDUCTED EXCLUSIVELY ON AN INDIVIDUAL BASIS AND NOT AS PART OF ANY CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION. THIS WAIVER CONSTITUTES AN ESSENTIAL ELEMENT OF VERITRADE'S WILLINGNESS TO ENTER INTO THIS AGREEMENT.

15.5 Injunctive Relief

Notwithstanding the foregoing, either party may seek immediate injunctive or equitable relief before a court of competent jurisdiction to prevent irreparable harm, particularly regarding intellectual property infringement or breaches of confidentiality.

16. Amendments to the Agreement

Veritrade reserves the right to modify these Terms at any time. In the event of material changes, at least thirty (30) days' prior notice will be provided via : (i) a prominent notice on the Platform; or (ii) an email sent to the registered administrator account. Continued use of the Platform after the effective date of changes implies full acceptance of the updated Terms. If you do not agree to the modified Terms, you must cease using the Platform and notify Veritrade in writing to execute termination under Section 10.

17. General Provisions

17.1 Entire Agreement: This Agreement, along with all applicable Order Forms and the Privacy Policy, constitutes the entire understanding between the parties and supersedes all prior agreements.

17.2 Severability: If any provision is declared invalid or unenforceable by a court, the remaining provisions shall remain in full force and effect.

17.3 Waiver: Failure to exercise or enforce any right does not constitute a waiver of such right. All waivers must be in writing.

17.4 Assignment: The Customer may not transfer or assign this Agreement without prior written consent; Veritrade may freely assign it.

17.5 Force Majeure: Neither party shall be liable for failures arising from force majeure events, including acts of God, war, terrorism, pandemics, or issues beyond its technical control.

17.6 Notices: Legal notices must be directed to: Veritrade Corp., Attn: Legal Department, 2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA; or via email to legal@veritradecorp.com.

17.7 Independent Contractors: The parties are independent contractors. This Agreement does not create any partnership, joint venture, agency, or employment relationship.

17.8 Export Controls: The Customer shall comply with all applicable US and international export control laws and regulations, including EAR and OFAC sanctions programs.

18. Contact Information

For inquiries regarding these Terms, contact us at: Veritrade Corp., 2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA. Inquiries: legal@veritradecorp.com. Website: www.veritradecorp.com. © 2025 Veritrade Corp. All rights reserved.

These Terms of Service were last updated on June 18, 2026.

VERITRADE CORP. PRIVACY POLICY

Effective Date: June 18, 2026.

Last Updated: June 18, 2026.

Veritrade Corp. («Veritrade», «we», «us», or «our») is committed to protecting the privacy and security of the information of its business clients and users. This Privacy Policy describes how we collect, use, store, transfer, and protect personal data within the framework of providing our B2B business intelligence services, in compliance with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and other applicable data protection regulations.

IMPORTANT — This Policy forms an integral part of Veritrade's Terms of Service . By using the Platform, the Customer acknowledges having read and accepted the terms described herein.

1. Data Controller Identification

The Data Controller for the personal data collected through the Platform is:

Field

Detail

Company Name

Veritrade Corp.

Registered Address

2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA

Legal Email

legal@veritradecorp.com

Website

www.veritradecorp.com

2. Scope of Application

This Policy applies to:

Visitors to Veritrade's public website (marketing and sales environment);

Business clients (B2B) with an active subscription accessing the private Platform via login credentials;

Authorized Users operating under the client's corporate account pursuant to the Terms of Service.

Veritrade operates under a SaaS model with two distinct digital environments:

Environment

Description

Public Website

Accessible to the general public. Technical, statistical, and marketing cookies are applied subject to the user's prior consent.

Private Platform (SaaS)

Accessible exclusively via access credentials. Only strictly necessary cookies are used for security and contractual performance. B2B confidentiality is a priority.

3. Personal Data We Collect

3.1 Data provided directly by the business client: Corporate information (company name, tax ID/TIN, registered address, sector of activity) ; contact data of representatives (first and last name, role, corporate email address, phone number) ; billing data (billing address, payment information processed securely via Stripe; Veritrade does not store credit card data in its systems) ; access credentials (username and encrypted password for Authorized Users).

3.2 Data collected automatically during Platform use: Technical navigation data (IP address, browser type and version, operating system, device identifiers) ; usage telemetry (searches performed, filters applied, reports generated, pages visited, session duration, and frequency of access) ; cookies and tracking data (pursuant to Veritrade's Cookie Policy).

3.3 International trade transaction data (not personal data): Import and export records available on the Platform are compiled from official public customs registries and third-party data providers. These records contain information about companies and commercial operations, and are not considered personal data in the context of B2B processing. Nevertheless, Veritrade applies equivalent security measures for their protection.

4. Purposes and Legal Bases for Processing

The following table summarizes the purposes of processing personal data and their corresponding legal bases under the GDPR:

Purpose

Description

Legal Basis (GDPR)

Service Provision

Account management, Platform access, technical support, and customer care.

Performance of a contract (Art. 6.1.b GDPR).

Billing and Payments

Secure processing of annual subscriptions and issuance of invoices.

Performance of a contract / Legal obligation (Art. 6.1.b & 6.1.c GDPR).

Security & Fraud Prevention

Detection of unauthorized access, abusive use of the Platform, and infrastructure protection via Stripe and Cloudflare technical cookies.

Legitimate interest (Art. 6.1.f GDPR).

Service Improvement

Analysis of usage behavior to optimize functionalities and user experience.

Legitimate interest (Art. 6.1.f GDPR).

Marketing & Lead Generation

Sending commercial communications and tracking demo requests via HubSpot (limited strictly to the public website).

Consent (Art. 6.1.a GDPR) / Legitimate interest for existing clients.

Legal Compliance

Responding to requests from competent authorities, tax record retention, and regulatory compliance.

Legal obligation (Art. 6.1.c GDPR).

5. Service Providers and International Data Transfers

For service provision, Veritrade utilizes the following trusted sub-processors:

Provider

Service

Location

International Transfer Safeguards

HubSpot

CRM, marketing automation, and web analytics.

USA.

Standard Contractual Clauses (SCC) adopted by the European Commission.

Stripe

Payment processing and fraud prevention.

USA.

Standard Contractual Clauses (SCC) adopted by the European Commission.

Cloudflare

CDN, DDoS protection, and bot mitigation.

USA / Global.

Standard Contractual Clauses (SCC) and GDPR compliance certifications.

Veritrade guarantees that all international data transfers to third countries are carried out with the appropriate safeguards provided in Chapter V of the GDPR, primarily through the execution of Standard Contractual Clauses (SCC) approved by the European Commission. For detailed information about cookies used by these providers, please consult Veritrade's Cookie Policy, available in the footer of the website.

6. Data Retention Periods

Veritrade retains personal data only for the time necessary to fulfill the purposes described in this Policy or to meet applicable legal obligations:

Account and Contract Data: During the term of the Subscription and up to 5 years after its termination, due to potential legal and tax liabilities.

Billing and Payment Data: 7 years from the transaction date, pursuant to applicable tax and accounting regulations.

Security Logs and Usage Telemetry: 12 months from generation, unless necessary for investigating a active security incident.

Marketing Communications (Leads): Until consent is withdrawn or for 2 years from the last active contact.

Non-Essential Cookies Data: Pursuant to the duration indicated in the Cookie Policy (maximum 6 months for HubSpot analytical cookies).

7. Rights of Data Subjects

The representatives and Authorized Users of the Client, as natural persons whose data are processed, may exercise the following rights before Veritrade:

Right of Access (Art. 15 GDPR): Obtain confirmation on whether Veritrade processes their personal data and access a copy.

Right to Rectification (Art. 16 GDPR): Request the correction of inaccurate or incomplete data.

Right to Erasure / To Be Forgotten (Art. 17 GDPR): Request the deletion of their data when they are no longer necessary for the original purpose, among other grounds.

Right to Restriction of Processing (Art. 18 GDPR): Request that the processing of their data be restricted under certain legal conditions.

Right to Data Portability (Art. 20 GDPR): Receive their data in a structured, commonly used format when processing is based on consent or a contract.

Right to Object (Art. 21 GDPR): Object to the processing of their data based on legitimate interest or for direct marketing purposes.

Right to Withdraw Consent: At any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, the data subject must send a formal written request, proving their identity, to: legal@veritradecorp.com or via post to 2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA. Veritrade will respond to requests within a maximum period of thirty (30) business days from receipt, as required by the GDPR. If a satisfactory response is not obtained, the data subject has the right to lodge a complaint with the competent Data Protection Supervisory Authority in their EU Member State.

8. Data Security

Veritrade implements technical, organizational, and physical security measures in accordance with the current state of technology to protect personal data against unauthorized access, loss, destruction, or accidental disclosure. These measures include, among others:

Encryption of communications using TLS/HTTPS protocols in all data transmissions;

Role-based access control (RBAC) and secure authentication for Authorized Users;

Continuous infrastructure monitoring via Cloudflare for automated threat detection and mitigation;

Secure payment processing via Stripe, with PCI-DSS certification. Veritrade does not store credit card data in its systems;

Periodic security audits and vulnerability assessments.

In the event of a security breach affecting personal data, Veritrade will notify data subjects and competent authorities within the legally established timeframes (72 hours for the authority notification, pursuant to Art. 33 GDPR).

9. Specific Regulatory Compliance

9.1 GDPR (Europe): Veritrade acts as a data processor or independent controller, giving strict compliance to the GDPR. Upon client request, Veritrade is prepared to execute a Data Processing Agreement (DPA) incorporating the guarantees required by Chapter IV of the GDPR. Requests must be addressed to legal@veritradecorp.com.

9.2 CCPA / CPRA (California, USA): We declare that we do not sell or share consumers' personal information. To exercise rights under California privacy law, please contact legal@veritradecorp.com.

9.3 Latin American Regulations: We comply with local data protection laws in the countries where we provide services, including—but not limited to—Law No. 29733 of Peru, Law 1581/2012 of Colombia, the LGPD of Brazil, and equivalent regulations in Mexico, Ecuador, and Chile.

10. Minors / 11. Updates

The Platform strictly prohibits registration by individuals under 18 years of age. Material modifications to this policy will be notified with 30 days' advance notice within the software dashboard or via corporate email.

12. Privacy Contact Information

Email: legal@veritradecorp.com

Postal Address: Veritrade Corp. Attn: Privacy & Data Protection · 2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA

Privacy Policy · Version: June 18, 2026.

COOKIE POLICY - VERITRADE

Date: June 18, 2026.
Last Updated: June 18, 2026.

Veritrade Corp. · 2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA.

This document regulates the use of cookies and other data storage and tracking technologies on the Website and Business Intelligence Platform of Veritrade, in compliance with applicable international data protection regulations, including the General Data Protection Regulation (GDPR) and the ePrivacy Directive.

1. Identification of the Data Controller

The Website and the Platform are managed by the following entity acting as the Data Controller:

Company Name: Veritrade Corp.
Registered Address: 2030 South Douglas Rd. Suite 214, Coral Gables, FL 33134, USA
Privacy Contact Email: legal@veritradecorp.com

2. Scope of Application and Division of Environments (SaaS Model)

As a Software as a Service (SaaS) provider, Veritrade divides its web ecosystem into two clearly differentiated sections with specific legal and technical implications:

A. Public Website (Marketing and Sales Environment): Accessible to the general public. In this section, technical, statistical, and marketing cookies are used to optimize visits, analyze web traffic, track demo requests, and perform non-invasive advertising actions based on user behavior. The deployment of non-essential cookies in this environment is strictly subject to the user's prior consent via the interactive cookie banner.

B. Private Platform (Subscriber Environment): Accessible exclusively to active clients via corporate Login. In this private and secure environment, Veritrade prioritizes the B2B confidentiality of client data. Therefore, only strictly necessary and technical cookies are deployed, aimed at ensuring security, mitigating financial fraud, controlling malicious automated bot access, and maintaining user session stability. Being indispensable for the performance of the contractual service, these technical cookies are not subject to an opt-out or deactivation mechanism.

3. Technical Breakdown of Cookies Used

Category I: Strictly Necessary Cookies (Technical and Security)

These cookies are essential for the proper functioning of the platform and do not collect information for commercial or marketing purposes. They activate automatically in both public navigation and private access.

Category II: Statistics and Marketing Cookies (Subject to Consent)

These cookies belong to the integrated HubSpot ecosystem and are limited strictly to the public website for commercial lead generation. They are not deployed disruptively inside the private SaaS product.

4. International Data Transfers

The use of advanced technology tools provided by HubSpot and Stripe involves the storage or processing of technical browsing data in secure data centers located in the United States of America. Veritrade guarantees that all its international providers are bound by protection mechanisms endorsed by GDPR directives, having executed the corresponding Standard Contractual Clauses (SCC) adopted by the European Commission, ensuring a technical and legal level of protection equivalent to the highest privacy standards.

5. How to Manage and Revoke Consent

The user has the inalienable right to grant, deny, or customize the scope of non-essential cookie use at any time. In compliance with European regulations, Veritrade provides permanent access for tracking configuration: "You can change or withdraw your consent at any time from the Cookie Settings Panel located in the footer of our website."

Additionally, the user may block, restrict, or delete cookies installed on their device through the native settings configuration panels of their respective internet browser (Google Chrome, Microsoft Edge, Mozilla Firefox, Apple Safari, among others).

6. Updates to this Policy

Veritrade reserves the right to modify the technical scope of these clauses to adapt them to future software tools or data privacy legislative amendments. Users are advised to review this notice periodically.

Last Updated: June 18, 2026.