Terms of Use

Last updated: April 23, 2026

This is a courtesy translation provided for convenience. In case of any discrepancy, the Portuguese version prevails.

These Terms of Use ("Terms") govern access to and use of the digital platform O Conselho, made available by HCAM Ltda., enrolled with the Brazilian corporate taxpayer registry (CNPJ) under No. 54.177.006/0001-68, with its registered office at Rua Gomes de Carvalho, 1195, 1st floor, Vila Olímpia, CEP 04547-004, São Paulo/SP, Brazil ("O Conselho", "we" or the "Platform"), through the domain oconselho.ai and any related domains, subdomains, applications, interfaces and digital environments.

The Platform is a mobile-first digital application, in PWA (Progressive Web App) format, focused on AI-assisted wealth management, with features for consolidating financial data, Open Finance integration, automated analyses, interaction with AI advisors and gamification.

By accessing or using the Platform, you declare that you have read, understood and freely, knowingly and unequivocally agree to these Terms and to the applicable Privacy Policy.

1. Acceptance

1.1. By accessing or using the Platform, you acknowledge that you have read and agreed to these Terms.

1.2. Use of the Platform is conditioned on full acceptance of these Terms and of the Privacy Policy.

1.3. If you do not agree with any provision of these Terms, you must not access or use the Platform.

1.4. Any tolerance of non-compliance with any obligation set out in these Terms shall not imply waiver of rights, novation or contractual amendment.

2. About the Platform

2.1. O Conselho is a digital platform for AI-assisted wealth management, made available in PWA (Progressive Web App) format, with a mobile-first experience, focused on consolidating wealth and financial data, generating automated analyses, interacting with AI advisors and gamification mechanics.

2.2. The Platform was developed to offer the user an integrated experience of wealth organization, financial tracking and analytical support, through features such as:

(a) digital authentication;
(b) creation and maintenance of a user profile;
(c) selection and recomposition of AI advisors;
(d) financial data integration via Open Finance;
(e) a consolidated dashboard of assets, liabilities and net worth;
(f) automated analyses and strategic insights;
(g) a real-time conversation environment with AI advisors (the "Boardroom");
(h) saving answers and recommendations as "Decisions"; and
(i) score, rank, archetype mechanics and other gamification features.

2.3. The Platform is predominantly informational, technological, organizational and assistive in nature, seeking to help the user visualize their wealth situation and reflect on financial strategies and contexts, with no guarantee of results, returns, specific suitability, analytical accuracy or achievement of personal or wealth goals. The advisors' responses may follow a structure defined by the Platform, including elements of diagnosis, direction and final takeaway, reinforcing that the final decision rests with the user.

2.4. O Conselho may, at its sole discretion, change, expand, restrict, test, remove or discontinue features, journeys, archetypes, integrations, conversational flows, score mechanics, gamification elements and any components of the user experience, including for testing, technical improvements, product strategy, security, compliance or regulatory requirements.

2.5. O Conselho does not act, under these Terms, as a bank, brokerage, portfolio manager, asset manager, securities consultant, securities analyst or attorney-in-fact for the user, except if and to the extent that a specific service is formally contracted under a separate instrument.

2.6. Use of the Platform does not replace individualized professional, legal, accounting, tax or regulatory advice.

3. Eligibility and capacity

3.1. The Platform is intended for natural persons with full legal capacity under Brazilian law.

3.2. O Conselho may restrict, suspend or prevent use by persons who:

(a) lack legal capacity;
(b) provide false, inaccurate, outdated or incomplete information;
(c) use the Platform in violation of these Terms; or
(d) engage in unlawful or fraudulent acts, or acts incompatible with the purpose of the Platform.

3.3. In a closed beta environment, access may be subject to eligibility criteria, invitation, progressive rollout, testing or limited availability.

4. Registration and access

4.1. Access to the Platform may require prior registration and user authentication.

4.2. Login is performed through LinkedIn OAuth, a system that redirects the user to the LinkedIn environment so they can authorize the sharing of certain professional profile data with the Platform. At this step, data such as name, photo and headline/role may be shared.

4.3. After authentication, the Platform may create, update, complement and organize the user's profile based on:

(a) the information authorized by the user during the login process;
(b) complementary public data obtained through enrichment services; and
(c) information derived from the use of the Platform itself, such as interaction history, preferences, saved decisions and usage data.

4.4. You are responsible for ensuring that the data you provide or authorize is correct, complete and up to date.

4.5. As part of onboarding, the user may be invited to select 3 (three) AI advisors from the archetypes made available by the Platform, which will make up their initial personalized experience. The selection is linked to the user's profile and may be changed later, according to the Platform's features.

4.6. Onboarding may also include the optional connection of financial data via Open Finance, the generation of an initial analysis (the "Reveal"), the calculation of score and rank, and directing the user to the smart feed or other areas of the Platform.

4.7. O Conselho may refuse, suspend, block or cancel registrations in the event of signs of fraud, misuse, violation of these Terms, requests from a competent authority or risk to the integrity of the Platform.

4.8. You are responsible for all activity carried out through your account and must adopt reasonable security measures for your devices, credentials and access.

5. Open Finance integration

5.1. The Platform may allow the user to connect their bank accounts, investments, loans, financing and credit cards through providers specialized in Open Finance, such as Pluggy, on an optional basis and subject to the user's own authorization.

5.2. User authentication with the financial institution takes place directly in the secure environment of the Open Finance provider, so the Platform does not receive or store the user's banking credentials.

5.3. Once the connection is authorized, the Platform may receive, synchronize, store and display the user's financial and wealth data, including, depending on the integration's availability:

(a) account balances;
(b) investment positions;
(c) data on fixed income, stocks, REIT-like funds (FIIs), crypto assets, pension plans and other classes;
(d) loans and financing;
(e) information on credit cards, bills and limits;
(f) net worth;
(g) composition by asset class; and
(h) periodic wealth evolution.

5.4. The user acknowledges that the availability, accuracy, scope, update frequency and consistency of the integrated data depend on third parties, including the Open Finance provider and the connected financial institutions.

5.5. The Platform may perform automatic synchronizations and/or allow manual synchronizations of the connected financial data, and new analyses and strategic summaries may be generated from the most recent available updates.

6. AI advisors, archetypes and the Boardroom

6.1. The Platform provides an environment called the Boardroom, in which the user can interact, in real time, with artificial intelligence advisors configured with distinct personalities, analytical styles and approaches.

6.2. The Platform may make available up to 9 (nine) advisor archetypes, inspired by distinct profiles and schools of thought in the financial universe, including, among others, profiles associated with conservatism, value investing, macroeconomics, passive income, asymmetric risk, venture capital, quantitative analysis, real assets and decentralization.

6.3. Each advisor may have its own attributes defined by the Platform, such as:

(a) tone of voice;
(b) areas of expertise;
(c) thematic boundaries and response restrictions;
(d) communication style;
(e) typical phrases;
(f) behavior in debate scenarios; and
(g) its own response-generation parameters.

6.4. The user may, according to the available features:

(a) interact with an active advisor;
(b) quickly switch between advisors;
(c) ask other advisors to comment on the same question; and
(d) recompose their council, replacing one or more of the 3 active advisors with other available archetypes.

6.5. O Conselho may change, add, remove, rename, recalibrate or restrict archetypes, styles, limits, responses, conduct rules, technical parameters, conversational identities and other characteristics of the AI advisors, at any time and without prior notice.

6.6. Responses generated in the Boardroom may take into account, as applicable and subject to the Platform's internal rules:

(a) user messages;
(b) history of previous interactions;
(c) professional profile data;
(d) integrated financial and wealth data;
(e) context from other screens of the Platform; and
(f) previous interactions of the council itself.

6.7. The user acknowledges that the AI advisors are technological resources for conversational and analytical support, and that their responses:

(a) are automated;
(b) may be incomplete, inaccurate, outdated, simplified or unsuitable for the specific case;
(c) do not constitute a promise of results; and
(d) do not replace specialized human analysis, individualized professional advice or any verification by the user.

7. Analyses, score, gamification and decisions

7.1. The Platform may generate initial and recurring automated analyses based on user data, including professional, financial, wealth and behavioral data, for the purpose of personalizing the experience, organizing information and presenting analytical insights.

7.2. Whenever the user's financial data is updated, the Platform may process information such as total assets, total liabilities, net worth, allocation by class and overall wealth context to generate strategic summaries, diagnoses and analytical directions.

7.3. The Platform may automatically detect financial context in user messages and, according to its internal rules, consider real data from the connected portfolio to contextualize the advisors' responses, when the system identifies expressions related to portfolio, wealth, investments and allocation.

7.4. The user may mark responses as important, save them, convert them into "Decisions" and track them in dedicated areas of the Platform, such as the Command Center, when these features are available. "Decisions" are internal records for organization, tracking and prioritization within the Platform, and do not imply automatic execution of any transaction, financial movement or mandatory implementation of a strategy.

7.5. O Conselho does not guarantee that any analysis, insight, recommendation, strategic direction, conversational response or saved decision is adequate, sufficient, convenient, timely or capable of producing any particular result.

7.6. Any wealth, financial or strategic decisions made by the user based on information from the Platform are the user's sole responsibility.

8. Operating rules and response limits

8.1. The Platform may apply internal structure and conduct rules to the AI advisors' responses, including regarding format, length, response style, form of takeaway, thematic boundaries, content prohibitions, semantic blocks and language parameters.

8.2. The user acknowledges that such internal rules may be modified at any time, for technical, strategic, regulatory, security, user experience or Platform adequacy reasons.

9. Gamification, score, rank and archetype

9.1. The Platform may assign gamification elements to the user, including score, rank, archetype, classification, progression and other derived metrics, for the purpose of increasing engagement, organizing the experience and visually representing certain aspects of the use of the Platform and of the user's consolidated wealth situation.

9.2. The user's identity within the Platform may be composed of elements such as:

(a) rank, associated with wealth ranges;
(b) archetype, related to the dominant pillar; and
(c) total score, distributed across pillars or categories defined internally by the Platform.

9.3. These elements are exclusively informational, visual, relational and user-experience in nature, and do not constitute a rating, certification, regulatory suitability, official wealth assessment, risk classification or guarantee of financial performance.

9.4. O Conselho may change, recalibrate, expand, restrict or discontinue criteria, ranges, naming, formulas, pillars, benefits, visual effects and other components of gamification, at any time.

10. User obligations

10.1. You undertake to use the Platform ethically, diligently and in compliance with applicable law.

10.2. It is forbidden to:

(a) use the Platform for unlawful, fraudulent or abusive purposes, or purposes contrary to good faith;
(b) insert, transmit, store or make available content that is offensive, discriminatory, defamatory, obscene, threatening, misleading or that violates third-party rights;
(c) engage in reverse engineering, improper scraping, unauthorized automated extraction, attempted unauthorized access, fraud, overload, interference, circumvention of technical protection measures or any conduct that compromises the integrity, stability or security of the Platform;
(d) use bots, scripts, automations or any mechanisms that impair the regular operation of the Platform or unduly interfere with other users' experience;
(e) reproduce, copy, commercialize, license, distribute or improperly exploit content, layouts, prompts, flows, trademarks, features, conversational identities or archetypes made available by the Platform;
(f) use the Platform to transmit, distribute or enable malware, viruses, worms, trojans or any other malicious code;
(g) use the Platform to impersonate someone, conceal authorship, mask the origin of communications or provide false, inaccurate, outdated or misleading information;
(h) use responses, analyses or content from the Platform as if they were professional opinions, guaranteed recommendations, promises of results or official statements from third parties.

10.3. The user is responsible:

(a) for the truthfulness, integrity and updating of the information provided or authorized;
(b) for the safe custody of their devices, credentials and access;
(c) for all activities carried out through their account; and
(d) for verifying, before making any wealth, financial, legal, accounting or tax decision, the suitability of the information made available by the Platform to their specific case.

10.4. The user shall be liable for losses and damages arising from improper or unlawful use, or use in violation of these Terms, without prejudice to other applicable measures.

11. Availability and technical limitations

11.1. O Conselho will use reasonable efforts to keep the Platform operational, but does not guarantee continuous availability, absence of errors, uninterrupted operation or failure-free functioning.

11.2. The Platform may be interrupted, suspended, limited or made temporarily unavailable for maintenance, updates, corrections, testing, security, technical adjustments or for reasons beyond O Conselho's control, including events attributable to integrated third parties.

11.3. O Conselho is not liable for losses arising from:

(a) temporary unavailability;
(b) failures of the user's internet, devices or systems;
(c) third-party failures;
(d) inaccurate information from external sources; or
(e) acts of God, force majeure, cyberattacks or equivalent events.

12. Intellectual property

12.1. All rights relating to the Platform, including, without limitation, software, source code and object code, architecture, structure, organization, interfaces, layout, design, visual identity, trademarks, business names, domain names, distinctive signs, texts, databases, documents, images, graphics, flows, features, prompts, interaction models, characters, archetypes, standardized responses, gamification elements and other content made available by O Conselho belong to O Conselho or to third parties that have validly licensed them, as applicable.

12.2. These Terms do not assign or transfer to the user any intellectual property rights over the Platform or its elements; only a limited, revocable, non-exclusive, non-transferable, non-sublicensable, personal-use license is granted for access to and use of the Platform strictly as set out herein.

12.3. Without prior and express authorization from O Conselho, the user may not:

(a) reproduce, copy, modify, adapt, translate, distribute, publish, display, license, assign, sell, commercially exploit or create derivative works from any element of the Platform;
(b) remove, hide or alter notices of ownership, authorship, trademark, copyright or any signs identifying rights;
(c) use trademarks, names, archetypes, texts, flows, prompts, structured outputs or any content of the Platform for training, feeding, replicating, benchmarking, developing or commercializing competing products or services;
(d) access, extract or reuse, in a systematic or automated manner, content, data or elements of the Platform without authorization.

12.4. Improper use of any protected element may subject the infringer to applicable judicial, extrajudicial, civil, criminal and administrative measures.

12.5. Any trademarks, content, software, databases or technologies belonging to third parties and integrated into the Platform remain subject to the rights of their respective owners.

13. Privacy and data processing

13.1. The processing of personal data within the Platform shall observe O Conselho's Privacy Policy.

13.2. By using the Platform, you acknowledge that certain registration, professional, financial, behavioral and contextual data may be processed to enable authentication, personalization, analyses, AI response generation, gamification, interaction history and other features of the Platform, as described in the Privacy Policy.

13.3. O Conselho may use cookies, tokens, identifiers and similar technologies for authentication, security, performance and experience improvement.

14. Third-party links, integrations and services

14.1. The Platform may integrate, use or depend on third-party technology services to enable certain features, including, among others:

(a) LinkedIn OAuth: authentication system used to allow the user to log in to the Platform through their LinkedIn account, with the sharing, upon the user's authorization, of certain professional profile data;
(b) Apify: public data enrichment service used to complement, where applicable, public information from the user's professional profile, such as academic background, current role and other publicly available data;
(c) Pluggy: Open Finance infrastructure provider used to allow, with the user's consent, connection with financial institutions and the import of financial, wealth and transactional data; bank authentication takes place directly in that provider's secure environment, without the Platform receiving the user's banking credentials;
(d) Perplexity Sonar: artificial intelligence model used to generate automated analyses, insights and personalized responses in the context of the Platform's automated analysis, conversational support and experience personalization features, including the initial analysis, strategic summaries and Boardroom interactions.

14.2. The use of these third-party services may additionally be subject to the terms of use, privacy policies, technical conditions and operational practices of the respective vendors.

14.3. O Conselho is not liable for unavailability, failures, delays, limitations, feature changes, discontinuation or errors attributable to independent third parties, including when they affect authentication, data synchronization, profile enrichment, automated response generation or other features of the Platform.

14.4. O Conselho may replace, add or remove third-party technology integrations at any time, according to product evolution, technical availability, security, operational strategy or legal/regulatory requirements.

15. Account suspension, blocking and termination

15.1. O Conselho may suspend, restrict, block or cancel the user's access, with or without prior notice, in the event of:

(a) violation of these Terms;
(b) signs of fraud, abuse, improper automated use or unlawful activity;
(c) risk to the security of the Platform, other users or third parties;
(d) legal, regulatory or judicial determination; or
(e) discontinuation, change or operational restriction of the Platform.

15.2. The user may also request termination of their account, subject to the legal, regulatory and security retention rules set out in the Privacy Policy.

16. Limitation of liability

16.1. To the maximum extent permitted by applicable law, O Conselho shall not be liable for indirect damages, loss of profits, loss of opportunity, loss of data, loss of revenue, reputational damage or any losses arising from the use of the Platform or from the user's adoption of strategies, decisions or omissions based on content, analyses, responses or insights made available by the Platform.

16.2. O Conselho does not guarantee:

(a) absolute accuracy of data imported from third parties;
(b) completeness, precision or adequacy of AI-generated responses;
(c) continuous availability of the Platform;
(d) permanent maintenance of any archetypes, integrations or features;
(e) real-time updating of financial information; or
(f) any wealth, financial or strategic result.

16.3. The user acknowledges that the Platform operates based on automated models, third-party integrations, imported data, algorithmic inferences and its own experience parameters, and that divergences, limitations, simplifications, delays or inconsistencies may occur.

17. Changes to these Terms

17.1. O Conselho may amend these Terms at any time, especially to reflect product evolution or operational, technological, regulatory or legal changes.

17.2. The current version will be available on the Platform. Continued use after an update may be considered awareness of and agreement with the new version, except where the law requires a specific acceptance mechanism.

17.3. If any provision of these Terms is held invalid, illegal or unenforceable, the remaining provisions shall remain valid and in full force.

18. Support

18.1. For questions, suggestions or requests related to the Platform, the user may get in touch through the following channel:

E-mail: suporte@oconselho.ai
Support page: oconselho.ai/support

19. Governing law and jurisdiction

19.1. These Terms are governed by the laws of the Federative Republic of Brazil.

19.2. The courts of the Judicial District of São Paulo/SP are elected as the competent forum, except where a mandatory legal provision states otherwise, to settle any disputes arising from these Terms.

HCAM Ltda. — CNPJ 54.177.006/0001-68