Terms of Use

• Customer: the company, law firm or other organization that subscribes to the platform and on whose behalf the accounts are used.
• User: the individual with a login to the platform, linked to one or more customer organizations.
• Customer Data: all information, files and personal data that the Customer or its Users enter, upload or generate on the platform.
• AI Content: suggestions, summaries, transcriptions, classifications, texts and other outputs produced by artificial intelligence models on the platform.
• Agreement: these Terms, the Privacy Policy and, where applicable, any commercial proposal, order or specific contract signed with the Customer.

Anyone who accepts these Terms on behalf of an organization represents that they have the authority to bind it. The service is intended for professional use by people over 18. If there is a specific contract signed with the Customer, it prevails over these Terms to the extent they differ.

Wintegrity is software offered as a service (SaaS) to organize governance, risk, compliance and integrity programs, and to support the legal management of companies and law firms. Depending on the plan, it includes modules such as standards and requirements, risks, controls and evidence, audits, tasks, meetings, contracts, third-party management and due diligence, lawsuit monitoring, Integrity Channel, employees, PPE (personal protective equipment), reports and an artificial intelligence assistant.

Wintegrity is a technology tool.It does not provide legal services, legal advice, independent audit, certification, investigation or accounting services, and use of the platform does not guarantee legal compliance, passing audits, certifications or admission to programs such as Pró-Ética (the Brazilian government’s corporate integrity recognition program). Decisions made with the support of the platform are the sole responsibility of the Customer and its professionals.

The service evolves frequently. We may add, change or discontinue features, provided that we do not substantially reduce the essential features of the subscribed plan during the period already paid for.

• Registration information must be true, complete and up to date.
• Logins are personal and non-transferable. Each User is responsible for keeping their password confidential and for everything done with their credentials. Notify us immediately if you suspect any misuse.
• The Customer’s administrators decide who accesses the organization, with which role and to which modules. The Customer is liable for the acts of its Users, including external guests, such as auditors.
• We may require additional identity or authorization checks to protect the account and Customer Data.

• Plans and prices: the plans, limits (such as standards, storage, AI credits, monitored terms and checks) and prices are those published on the website or in the commercial proposal at the time of purchase. Limits not used in one period do not roll over to the next, unless otherwise provided.
• Free trial: we may offer a trial period, without a card, once per organization. At the end of the trial, if no plan is purchased, the organization moves to the free plan, with limited features, without losing its data.
• Billing: plans are prepaid, on a monthly or annual basis, and renew automatically at the end of each period until canceled. Payments are processed by Stripe; we do not store card data.
• Price adjustment:prices may be adjusted annually according to the IPCA/IBGE (Brazil’s official consumer price index), or another index that replaces it. Other price changes apply from the following renewal and will be communicated at least 30 days in advance.
• Partnership codes and discounts: they are personal to the eligible organization, apply only under the published conditions (for example, restricted to members of a given entity or to monthly plans) and may be revoked if eligibility is not proven or ceases to exist.
• Taxes: prices include applicable taxes, unless otherwise indicated in the proposal.
• Non-payment: if a payment is not completed, the organization may be moved to the free plan or have access to paid features suspended until the situation is regularized, without prejudice to the collection of amounts due.

• There is no minimum term. The Customer may cancel at any time through the platform’s billing portal. Cancellation takes effect at the end of the period already paid for, with no additional charge.
• Monthly plans are non-refundable, including for partial periods.
• Annual plans may be canceled with a full refund if the request is made within 30 days of the first annual purchase. After that period, the plan continues until the end of the contracted term, with no pro rata refund.
• Where the Customer is a consumer under the Brazilian Consumer Protection Code (Código de Defesa do Consumidor), the rights provided by that law are guaranteed, including the right of withdrawal.

The Customer is solely responsible for Customer Data and for its use of the platform. In particular, the Customer represents and warrants that it:

• has an appropriate legal basis, under the LGPD (Brazil’s General Data Protection Law), for each item of personal data it enters or asks the platform to obtain, and has informed data subjects about the processing, including employees, assessed third parties, monitored parties, signatories and meeting participants;
• uses background checks, certificates, lawsuit searches, restricted-party lists and adverse media only for legitimate purposes and within legal limits, without discriminatory practices (including those prohibited by Brazilian Law 9,029/1995 and labor case law) and without making decisions based solely on these results;
• is authorized to provide the platform with credentials for third-party systems, such as digital certificates, government portal passwords and integration tokens, and for the platform to use them on its behalf;
• holds the necessary rights over the documents, technical standards, templates and other content it uploads, including licenses to use copyright-protected standards;
• obtains the necessary authorizations to record meetings and informs the participants;
• keeps its own copies of documents and information essential to its business, when required by law or prudence.

The following, among other conduct, is prohibited:

• using the platform for unlawful or discriminatory purposes, harassment, abusive surveillance or retaliation against whistleblowers;
• attempting to identify the authors of anonymous Integrity Channel reports;
• entering personal data without a legal basis, or content that is unlawful, offensive, fraudulent or that infringes third-party rights;
• accessing or attempting to access data of other organizations, or circumventing access controls, plan limits or security measures;
• reverse engineering, copying, reselling, sublicensing or making the platform available to third parties, except with written authorization;
• extracting data by automated means, overloading the infrastructure or introducing malicious code;
• using the platform or AI Content to develop a competing product.

• AI Content is generated automatically and may contain errors, omissions or inaccuracies. It does not constitute a legal opinion, expert report, auditor opinion or professional advice.
• AI suggestions remain pending until human review. The Customer must review all AI Content before using it and is responsible for the decisions it makes based on it.
• To generate AI Content, excerpts of Customer Data are processed by AI providers engaged by Wintegrity, as described in the Privacy Policy. These providers do not use the data to train their models.
• Use of AI is subject to the plan’s credits and limits. The Customer can turn off automatic analyses in the organization’s settings.

Several features gather information from public and third-party sources, such as courts, official gazettes, the Brazilian Federal Revenue Service (Receita Federal), sanctions lists, government registries, certificate issuers and news outlets.

• Wintegrity does not control these sources and does not guarantee that they are complete, accurate, up to date or available. Sources may go offline, change format or delay publications.
• Results may include namesakes and false positives, or miss existing records. They are indications for analysis and must be confirmed in the official source before any decision.
• Alerts and monitoring of procedural deadlines are support tools and do not replace official follow-up by the responsible professional. Wintegrity is not liable for missed deadlines, publications or court notices.

The platform provides the infrastructure to receive and handle reports, including anonymous ones. Receiving and investigating reports, the measures taken and communication with the reporter are the sole responsibility of the Customer, which must protect the reporter’s confidentiality and prohibit retaliation, in accordance with applicable law. Wintegrity does not investigate reports or act as an independent ombudsman, unless specifically contracted to do so.

Some features depend on third-party services, such as electronic signature (Clicksign), payments (Stripe), email delivery, government portals (eSocial, ANS) and data providers. These services have their own terms, which the Customer accepts when enabling them. Wintegrity is not a party to agreements entered into between the Customer and its suppliers, counterparties or signatories, and is not liable for failures, unavailability or changes of these services.

With respect to Customer Data, the Customer is the controller and Wintegrity is the processor (“operador”), under the LGPD. As processor, Wintegrity undertakes to:

• process Customer Data only to provide the service and in accordance with the Customer’s instructions expressed through use of the platform and in the Agreement;
• maintain appropriate technical and administrative security measures;
• require confidentiality from anyone with access to the data;
• use sub-processors under equivalent obligations, listed in the Privacy Policy, which discloses any changes;
• notify the Customer, within a reasonable time, of security incidents affecting Customer Data;
• assist the Customer, to a reasonable extent, in responding to data subjects and authorities;
• make Customer Data available for export and erase it at the end of the Agreement, in accordance with section 19.

Processing in which Wintegrity is the controller is described in the Privacy Policy. Customers who need a specific data processing agreement may request one.

• The platform, software, trademarks, templates, catalogs and other Wintegrity materials belong to Wintegrity or its licensors. The Customer receives a limited, non-exclusive, non-transferable and revocable license to use them during the term of the Agreement, for internal purposes.
• Customer Data belongs to the Customer. The Customer authorizes Wintegrity to process it to the extent necessary to provide, maintain and protect the service.
• AI Content and documents generated from Customer Data may be freely used by the Customer.
• Wintegrity may use aggregated and anonymized usage data, which does not identify the Customer or individuals, to operate and improve the service.
• Suggestions and feedback sent about the product may be used freely by Wintegrity, with no obligation to pay compensation.

Each party will keep confidential the other party’s non-public information to which it has access because of the Agreement, using it only to perform the Agreement, during its term and for 5 years after its termination. Information is not confidential if it was already public, was already lawfully known to the party, or must be disclosed by law or order of an authority, in which case the party will notify the other when permitted.

We use commercially reasonable efforts to keep the platform available and secure, but we do not guarantee uninterrupted or error-free operation. There may be interruptions for maintenance, updates, failures of providers or networks, or due to acts of God and force majeure. Specific service levels apply only when provided for in a signed contract. Support is provided through the channels indicated on the platform, on business days and during business hours.

To the extent permitted by law, the platform is provided “as is”, and Wintegrity offers no warranties beyond those expressly provided in the Agreement, including fitness for a particular purpose, results, or that the service will meet all of the Customer’s regulatory requirements.

• Wintegrity is liable only for direct damages proven to have been caused by it, and is not liable for lost profits, loss of revenue, opportunity or reputation, indirect damages, fines and penalties imposed on the Customer, or loss of data resulting from acts of the Customer or its Users.
• Wintegrity’s total liability related to the Agreement is limited to the amount actually paid by the Customer in the 12 months preceding the event that gave rise to the damage.
• Wintegrity is not liable for decisions made by the Customer based on the platform, AI Content or information from public and third-party sources, or for failures of the third-party services referred to in section 11.
• These limitations do not apply to damages caused by willful misconduct and do not exclude rights that the law deems non-waivable, including consumer rights, where applicable.

The Customer will hold Wintegrity harmless from claims, lawsuits, fines and expenses, including reasonable attorneys’ fees, arising from Customer Data, from the lack of a legal basis for its processing, from use of the platform in breach of these Terms or the law, or from decisions made by the Customer based on the service.

• We may suspend or terminate access, in whole or in part, in the event of a breach of these Terms, a risk to the security of the platform or third parties, an order from an authority or non-payment. Whenever possible and proportionate, we will give prior notice and a period to remedy.
• The Customer may stop using the service at any time by canceling the plan and, if it wishes, deleting the organization in the settings.
• Once the Agreement ends, Customer Data remains available for export for 30 days, upon request. After that period, Wintegrity may erase or anonymize it, except for what it must keep due to a legal obligation or for the regular exercise of rights.
• Clauses that by their nature should survive termination (such as amounts due, confidentiality, intellectual property, limitation of liability and indemnification) remain in force.

We may change these Terms. Material changes will be communicated at least 15 days in advance, by email or a notice on the platform. Continued use of the service after the changes take effect means acceptance of the new version; if it does not agree, the Customer may cancel before that date, in accordance with section 5.

• These Terms are governed by the laws of the Federative Republic of Brazil.
• The courts of the City of São Paulo, State of São Paulo, Brazil, are chosen to settle any dispute, to the exclusion of any other, except for the consumer’s place of domicile, where applicable.
• Communications between the parties may be made by email and by notices on the platform. Electronic acceptance of these Terms has the same validity as a signature.
• The Customer may not assign the Agreement without Wintegrity’s consent. Wintegrity may assign it to a company of the same group or to a successor in a corporate transaction.
• Tolerance of a breach does not constitute a waiver of the right. If any clause is held invalid, the remaining clauses remain valid.
• Questions about these Terms: gabriel.matos@wintegrity.app.