Terms of Use & Privacy Policy

These Terms of Use and Privacy Policy ("Terms") govern access to and use of my.zappy.com.br, the dashboard provided by ZAPPYPAG DIGITAL LTDA., a private legal entity registered under CNPJ No. 38.344.590/0001-42 ("ZappyPag"), intended exclusively for its business clients and authorized users ("Users"), for the management, viewing, and monitoring of financial services provided through the Banking as a Service (BaaS) infrastructure supplied by FITBANK INSTITUIÇÃO DE PAGAMENTOS ELETRÔNICOS S.A. ("FitBank").

By accessing or using my.zappy.com.br, the User declares that they have read, understood, and fully agreed to these Terms, as well as to the applicable related contractual instruments, including but not limited to the BaaS Service Agreement entered into between ZappyPag and FitBank, the Account Opening Terms, the Rules of Use, FitBank's Policies, and applicable legislation.

• 2.1. my.zappy.com.br is a technology interface layer and does not constitute a financial institution, payment institution, or bank. It serves exclusively as a dashboard for consulting, operational management, and monitoring of the functionalities contracted by ZappyPag from FitBank.
• 2.2. FitBank is the payment institution responsible for opening and maintaining accounts, processing transactions, executing payments, financial settlement, safeguarding funds, and complying with the rules of the Central Bank of Brazil, KYC, AML/CFT, and other regulatory obligations.
• 2.3. ZappyPag is exclusively responsible for its platform, business rules, client relationships, operational reconciliations carried out in its environment, and the use that its clients make of my.zappy.com.br, expressly exempting FitBank from any liability for such activities, pursuant to the agreement entered into between the parties.

• 3.1. Access to my.zappy.com.br is restricted to duly incorporated legal entities that have been previously approved through the registration, verification, and validation processes conducted by FitBank and ZappyPag.
• 3.2. The User declares that all information provided is true, complete, and up to date, and commits to keeping their data accurate throughout the contractual relationship.

Through my.zappy.com.br, the User may, depending on the services effectively contracted:

• View account balances and statements;
• Monitor financial transactions;
• Manage payments, Pix, and payment services;
• Track operational statuses and reports;
• Access transaction histories and consolidated information.

my.zappy.com.br does not execute, settle, or authorize financial operations autonomously; such activities are the exclusive responsibility of FitBank.

• 5.1. The User is fully responsible for the activities carried out through my.zappy.com.br, including commands, authorizations, configurations, and reconciliations performed on their platform.
• 5.2. The User commits to using my.zappy.com.br in strict compliance with applicable legislation, Central Bank of Brazil regulations, anti-money laundering rules, counter-terrorism financing measures, anti-fraud standards, and other regulatory obligations.
• 5.3. The use of my.zappy.com.br is prohibited for:
  • Unlawful activities;
  • Money laundering, fraud, or tax evasion;
  • Operations that violate contractual and regulatory rules;
  • Violation of third-party rights.

• 6.1. ZappyPag and FitBank are independent parties, with no joint liability, partnership, mandate, or representation between them.
• 6.2. FitBank shall not be held liable for any damages arising from acts performed by the User or by ZappyPag through my.zappy.com.br.
• 6.3. FitBank's liability, when applicable and proven, is limited to the amounts and conditions expressly set forth in the agreement entered into with ZappyPag.

7.1. Access to my.zappy.com.br may be suspended or terminated at any time in the event of:

• Breach of these Terms;
• Legal or regulatory determination;
• Request from FitBank;
• Suspicion of irregularities, fraud, or registration inconsistencies.

• 8.1. All intellectual property rights related to my.zappy.com.br belong exclusively to ZappyPag.
• 8.2. The User commits not to reproduce, copy, modify, or commercially exploit any element of my.zappy.com.br without express authorization.

• 9.1. The processing of personal data shall fully comply with the Brazilian General Data Protection Law (Law No. 13,709/2018 — LGPD).
• 9.2. FitBank shall process personal data in accordance with its Privacy Policy, available through its official channels, and is responsible for regulated and financial activities.
• 9.3. ZappyPag may process data strictly necessary for the operation of my.zappy.com.br, respecting the principles of purpose, necessity, security, and transparency.
• 9.4. Data may be shared between ZappyPag and FitBank exclusively for the execution of contracted services and compliance with legal and regulatory obligations.

The User and their representatives may exercise, at any time, the rights provided for under the LGPD, including access, correction, anonymization, portability, and revocation of consent, where applicable.

• 11.1. Information accessed through my.zappy.com.br is confidential.
• 11.2. FitBank may, under the contractual terms, conduct audits to verify legal, regulatory, and data protection compliance.

These Terms may be amended at any time to accommodate legal, regulatory, or operational changes. Amendments will be communicated through my.zappy.com.br or official channels.

These Terms shall be governed by the laws of the Federative Republic of Brazil. The courts of the district of São Paulo/SP are hereby elected as the exclusive forum, waiving any other, regardless of how privileged it may be.