Licence

End User Licence Agreement (EULA) — FCX 3.0, version 1.5 This End User Licence Agreement (the "EULA") is a legal contract between you (the "User" or "You") and FCX Solutions Inteligência de Negócios Ltda. ("FCX", "We" or the "Company"), headquartered in the City of São Paulo, State of São Paulo, Brazil, registered under Brazilian company registry (CNPJ) No. 54.288.721/0001-78, for the use of the FCX 3.0 platform, including its associated services, tools and solutions (the "Service"). By accessing or using the Service, You agree to comply with the terms of this EULA. If You do not agree with these terms, do not access or use the Service. 1. Definitions For the purposes of this EULA, the following terms have the meanings set out below: 1.1 Service: The FCX 3.0 commercial intelligence platform, which turns scattered commercial data into strategic reading, prioritization and guidance for action through the Guided Analysis, the agentic AI ATTO, its four specialized engines, authorized connectors, permitted enrichments and auditable reports. 1.2 User: Any individual or legal entity that accesses or uses the Service, including their representatives, employees or authorized agents. 1.3 User Data: Any information, documents, records, data or content made available by the User to FCX or accessed by the Service through Authorized Connectors. 1.4 Subscription Plan: The access tier contracted by the User, which may be Free, Pro or Max, in accordance with this EULA, the applicable Commercial Proposal, where one exists, and FCX's commercial policy in force. 1.5 ATTO: The agentic AI that coordinates the Service and operates in a cycle of observing, orienting, deciding, acting and reabsorbing results. ATTO organizes evidence, maintains versioned state and memory, compares buyer signals, offer characteristics and the context of the commercial field, applies rules, policies and validation mechanisms, coordinates the Guided Analysis engines and produces substantiated recommendations. Language models are used subordinately to the platform's data, rules, controls and validation schemas, and do not, on their own, constitute a source of truth. 1.6 Guided Analysis: The main module of FCX 3.0, coordinated by ATTO, which classifies each offer as a product or a service — as a suggestion subject to the User's confirmation — and runs four specialized engines in order: (i) Up-sell and Cross-sell, which identifies expansion opportunities in the current customer base and suggests the offer, the rationale, the likely objection, the timing and the approach; (ii) Persona, which refines buying profiles, pains, objections, triggers and disqualification criteria based on observed behavior; (iii) Opportunities, which analyses segments, markets, territories, channels and commercial timing windows; and (iv) Leads, which defines criteria, exclusions and priorities from the learning produced by the previous engines. The final report may present the engines that contributed, recommendations, evidence, confidence level, information gaps, tensions identified, the risks of a poorly calibrated action and the suggested next actions. 1.6.1 Simple Guided Analysis: The mode of running the Guided Analysis over 1 (one) single offer, product or service, issuing a report in summary format corresponding to the One Page model made available on the platform, and without comparative execution between offers, periods or competitors. There is no limit on documents per run. It is the mode made available on the Free Plan, within the limits of Clause 1.11. 1.7 Credit: The Service's unit of consumption, debited according to the frequency, depth and complexity of the operations performed, including diagnostics, Guided Analyses, engine activation, document processing, information enrichment, report generation and other intelligent operations of the platform. Credits are fungible across engines and features, with no sub-wallets by purpose. 1.8 Credit Wallet: The User's Credit balance, in which the Monthly Allowance and the Extra Credits purchased are recorded separately. The Monthly Allowance is consumed before the Extra Credits balance. 1.9 Monthly Allowance: The quantity of Credits included in the Subscription Plan in force and made available at each renewal cycle. The Monthly Allowance is not cumulative, so unused Credits are not carried over to the following cycle. 1.10 Extra Credits: Pre-paid Credits purchased separately from the Monthly Allowance, whose purchase is available exclusively on the Pro and Max Plans, at a unit price of BRL 10.00 (ten reais) per Extra Credit. The corresponding amount is charged immediately to the credit card on file at the time of purchase or top-up. Once purchased, Extra Credits become part of the Credit Wallet and the amount paid remains due regardless of whether they are subsequently used, without prejudice to the refund upon definitive account closure set out in Clause 2.8.1. 1.11 Free Plan: The free tier for trying out the platform, limited to 1 (one) simple Guided Analysis of 1 (one) product per month, without prejudice to Clauses 2.5.1 and 2.5.2. 1.12 Authorized Connectors: Integrations enabled by the User to access sources related to their operation, such as CRM, e-mail, calendar, messaging, calls, transcripts, products, proposals, subscriptions, uploaded documents and other integrations made available by FCX. 1.13 Evidence: Authorized and traceable information, associated with its source, permission, moment of observation and technical record, used to substantiate ATTO's states, hypotheses, inferences and recommendations. 1.14 Operational Memory: The versioned set of states, results and relationships learned by ATTO from the User's authorized operations. Each new version preserves the traceability of the history and may be used to contextualize future analyses. 1.15 Audit Trail: The sequential record of the Service's executions, including evidence used, rules and controls applied, model and instruction versions, results, blocks, gaps, reviews and reabsorbed commercial outcomes, maintained so that the chain that substantiated each analysis can be reconstructed. 1.16 Confidential Information: Any non-public information disclosed by FCX or by the User, including analytical data, reports, methods and proprietary technology. 2. Grant of Licence 2.1. Subject to full compliance with this EULA and, where applicable, to payment of the corresponding fees, FCX grants the User a limited, non-exclusive, non-transferable and revocable licence to access and use the Service solely for internal business purposes, in accordance with the selected Subscription Plan. 2.2. The Service is provided as software as a service (SaaS). The User receives no ownership rights over the underlying software, its algorithms, rules, analytical models, connectors or any technological component of the platform. 2.3. The operations performed in the Service consume Credits from the User's Wallet according to the consumption table in force, published on the platform and forming an integral part of this EULA for all purposes. Consumption may vary according to the frequency, depth, computational complexity, data volume and resources invoked in each operation. Any change to the consumption table follows the prior-notice regime set out in Clause 12.2. 2.3.1. Before confirming an operation that consumes Credits, the platform presents the User with the corresponding consumption estimate. The final debit follows the actual use of the operation. In the event of a processing failure, the corresponding Credits are fully reversed to the Credit Wallet. 2.4. Once the Monthly Allowance is exhausted, the User may continue using the Service through Extra Credits previously purchased and available in their Credit Wallet, including while on the Free Plan. Before Extra Credit consumption begins, the platform informs the User that the Monthly Allowance has been exhausted. If there is no balance available, operations requiring new Credits remain unavailable until the Monthly Allowance renews or Extra Credits are purchased on an eligible Plan. 2.5. The Free Plan provides 1 (one) simple Guided Analysis of 1 (one) product per month. Users on the Free Plan may not purchase Extra Credits or contract top-ups. Continued use beyond the monthly limit requires contracting a Pro or Max Plan, or the existence of a remaining Extra Credit balance purchased while the User was on a paid Plan. 2.5.1. While a remaining Extra Credit balance exists in the Credit Wallet, the User on the Free Plan may continue performing operations that consume Credits, debited from that balance, until it is exhausted. Once the balance is exhausted, the account remains restricted to the monthly limit of the Free Plan. 2.5.2. The remaining Extra Credit balance funds the operations that consume Credits in the same modes available to the User on the paid Plan under which the respective Credits were purchased, even where the account is on the Free Plan, consistent with the fungibility set out in Clause 1.7. Operational limits, processing capacity and priority, and support remain those of the Subscription Plan in force. 2.6. Enabling and purchasing Extra Credits on the Pro and Max Plans require a valid credit card on file. The User may purchase Extra Credits directly and authorize automatic top-ups when the available balance is insufficient. The amount and the quantity of Credits of each purchase or top-up are presented to the User before enabling or confirmation and charged immediately to the card on file. 2.6.1. The User may set maximum daily and weekly limits for Extra Credit consumption or opt for unlimited consumption, without such caps. Setting a limit does not in itself represent an advance purchase or a charge for the entire quantity indicated; only the Credits actually acquired in a purchase or top-up are charged. 2.6.2. Automatic top-ups observe the limits configured by the User. If the balance is exhausted, if a limit is reached, if the top-up is declined or if the feature is disabled, additional consumption is interrupted until a new purchase, a change to the applicable limit or the renewal of the Monthly Allowance. 2.6.3. The User may disable Extra Credits or automatic top-ups at any time. Disabling prevents new top-ups and automatic charges but does not cancel purchases already completed. Extra Credits acquired do not expire, remain available for an indefinite period and continue to be recorded in the Credit Wallet regardless of the Subscription Plan in force, without conversion into money, transfer or refund, save for rights that cannot legally be waived and the definitive account closure set out in Clause 2.8.1. 2.7. The User may upgrade or downgrade between the Free, Pro and Max Plans. The effective date of the change, the treatment of the current cycle's Monthly Allowance Credits and any billing adjustment are presented before confirmation and follow the conditions published on the platform. A downgrade, including to the Free Plan, does not extinguish, block or reduce the Extra Credit balance already purchased, which remains available in the Credit Wallet until it is exhausted. 2.8. The Pro and Max Plans operate on an automatic monthly renewal cycle. There is no minimum term and no cancellation penalty. Save for the right of withdrawal set out in Clause 2.9, the User may cancel the subscription at any time, taking effect at the end of the current cycle, with access maintained until that date. Unused Monthly Allowance Credits are not refundable and are not carried over to the following cycle. Cancelling the paid subscription does not affect the Extra Credit balance already purchased, which remains available in the Credit Wallet for as long as the account exists, subject to Clause 2.8.1. At the end of the cycle, the account moves to the Free Plan, with the User Data history, the Extra Credit balance and its use preserved, under Clauses 2.5.1 and 2.5.2. 2.8.1. The User may request, at any time, the definitive closure of their account. Where an unused Extra Credit balance exists on the closure date, FCX refunds the corresponding amount in full, calculated at the unit price actually paid on purchase, by the same means of payment used or by another agreed with the User. The refund does not cover Monthly Allowance Credits, which are not refundable. 2.9. As the contract is entered into over the internet, a User who qualifies as a consumer may exercise the right of withdrawal within the statutory period of 7 (seven) calendar days, counted from the initial contracting of the paid Plan, through the channels made available by FCX. Where the right is validly exercised, the amounts paid are refunded in accordance with the applicable legislation. 2.10. In addition to the Monthly Allowance, the Plans may observe limits on volume, operational capacity, processing, support, connectors, integrations, depth of analysis and advanced use of the engines. The operational limits applicable to each Plan are published on the platform and form an integral part of this EULA for all purposes, and may be supplemented by the applicable Commercial Proposal, where one exists. Any change to those limits follows the prior-notice regime set out in Clause 12.2. 3. Use Restrictions 3.1. The Service is intended exclusively for commercial intelligence and to support the prioritization of opportunities and the User's internal decision-making. The User is expressly prohibited from: — Using the Service as a credit granting tool, for default analysis, financial risk scoring, credit bureau activity or as a fraud prevention system; — Selling, assigning, sublicensing or making the Service or the results of the analyses available to third parties not linked to the User's internal operation, except with FCX's written authorization; — Copying, modifying, decompiling, reverse engineering or creating derivative works from the Service; — Using the Service for illegal or discriminatory purposes, or in violation of data protection, competition, anti-corruption or anti-money laundering legislation; — Sharing access credentials with unauthorized third parties or attempting to access data from another account or organization; — Enabling Authorized Connectors without holding permission to make the respective data available to the Service; — Using the Service for indiscriminate scraping, access to authentication-protected content, acquisition or import of external personal dossiers, or extraction of contacts without an applicable legal basis; — Requesting or using inferences about sensitive personal data, protected attributes or external profiles of natural persons in breach of the LGPD; — Attempting to circumvent policies, blocks, exposure limits, output controls or other ATTO security mechanisms; — Presenting an ATTO hypothesis, inference, estimate or recommendation as proven fact when the report itself indicates uncertainty, a gap or the need for validation. 4. Fees and Payment 4.1. The Plans and their main conditions are: — Free: BRL 0.00 per month, with 1 (one) simple Guided Analysis of 1 (one) product per month, without prejudice to Clauses 2.5.1 and 2.5.2; — Pro: BRL 3,995.00 per month, with 500 (five hundred) monthly Credits, access to ATTO's four engines, complete reports, the connectors and integrations made available for the Plan, and the possibility of consuming Extra Credits; — Max: BRL 7,990.00 per month, with 1,000 (one thousand) monthly Credits, access to ATTO's four engines, complete reports, the connectors and integrations made available for the Plan, greater operational capacity, processing priority, priority support, and the possibility of consuming Extra Credits. The amounts above do not include taxes levied on the provision of the services, which are added where required by the applicable legislation. Where contracting takes place through self-service, the applicable conditions are exclusively those set out in this EULA and those published on the platform. Where a Commercial Proposal exists, additional features, limits and support levels may be detailed in it. 4.2. Payments for paid Plans are due monthly, by credit card on recurring billing or by another means made available by FCX. Extra Credits are pre-paid and cost BRL 10.00 (ten reais) per unit. Each purchase or top-up is charged immediately to the credit card on file, separately from the Plan's monthly fee. The daily and weekly limits only control additional consumption and do not correspond to amounts automatically charged. Once a purchase or top-up is completed, its amount is due even if the respective Credits are not used, save for rights that cannot legally be waived and the refund upon definitive account closure set out in Clause 2.8.1. 4.3. Late payment subjects the User to a late-payment penalty of 2% on the outstanding amount and default interest of 1% per month, calculated pro rata die. Once default is identified, FCX notifies the User and grants a period of 72 (seventy-two) hours for regularization, during which access to the contracted Plan is maintained. If the default persists, the account reverts automatically to the Free Plan, with the User Data history, the Extra Credit balance already paid and its use preserved under Clause 2.5.1. Reactivation depends on settlement of the outstanding amounts, without prejudice to termination for persistent default exceeding 30 (thirty) days. 5. Intellectual Property 5.1. The Service, including software, architecture, algorithms, rules, engines, models, interfaces, standardized reports and underlying technology, is the exclusive property of FCX or its licensors and is protected by the applicable legislation. The User receives only the limited rights of use described in this EULA. 5.2. The User retains ownership of their User Data and grants FCX a non-exclusive, limited licence, valid for the period necessary to provide the Service, process the requested operations, generate reports, maintain the Operational Memory of their account, comply with legal obligations and improve the Service through aggregated, anonymized or de-identified data. 5.3. The reports and recommendations generated may be used by the User for their internal business purposes, without any transfer of rights over FCX's technological components, methods or models. 6. Data Use and Privacy 6.1. FCX processes personal data in accordance with the Brazilian General Data Protection Law (LGPD), observing the principles of purpose, adequacy, necessity, transparency, security, prevention and non-discrimination, as well as protection measures from the design of the Service onwards. 6.2. The User is responsible for holding an adequate legal basis, authorization and transparency to provide User Data, enable Authorized Connectors and determine the processing purposes under their responsibility. FCX records the scope and origin of the accesses performed by its connectors. 6.3. ATTO uses data from Authorized Connectors, voluntarily uploaded documents and permitted public sources about companies, products, markets and territories. The unavailability or revocation of a connector may reduce the confidence, depth or currency of the analyses. 6.4. Lead discovery may use permitted public information about accounts and professional contacts. Making a professional contact available requires a permitted source, associated Evidence, a documented legal basis, a legitimate commercial purpose, a proportionality assessment and a channel for objection or opt-out. In the absence of these requirements, the contact is discarded, even though the respective company may remain a candidate account. 6.5. As part of the regular operation of FCX 3.0, FCX does not use purchased external personal dossiers, inference of sensitive personal data, scraping of authentication-protected content, contact extraction without a legal basis, or identifiable reuse of data across distinct accounts. 6.6. Data, states, memories and relationships are isolated by account or organization. Any learning across accounts is limited to aggregated information, calibrated parameters or de-identified patterns, without exposing User Data or identified or identifiable persons. 6.7. FCX may monitor atypical usage patterns, investigate breaches of this EULA and provide information to the competent authorities when required by law, within the limits of the applicable legislation. 7. Warranties and Disclaimers 7.1. FCX provides the Service with reasonable technical diligence and in accordance with any service levels contracted. FCX does not guarantee specific commercial results, including increased sales, conversion, retention, expansion or financial performance. 7.2. The Service is a decision-support instrument. The decision to adopt, adapt, validate or discard any recommendation, strategy or next action suggested by ATTO is the User's responsibility, and the User must consider their context, their sector regulation, their contracts and the applicable legislation. 7.3. ATTO's outputs may contain evidence, inferences, hypotheses, estimates, confidence levels, tensions, exclusion criteria, validation questions and suggested actions. These outputs may contain error, omission or inadequacy arising, among other causes, from incomplete, outdated, imprecise or insufficient data. The recommendations do not constitute legal, financial, accounting, credit or compliance advice. 7.4. ATTO operates on a fail-safe principle. Where the chain of Evidence is insufficient, the platform may lower the confidence level, formulate a hypothesis, request validation, limit a recommendation or block an action. The classification of an offer as a product or a service is a suggestion by ATTO, and the User's confirmation prevails. The unavailability of a source does not authorize the platform to invent or presume missing data. 7.5. The User may request human review of an automated recommendation or block that produces a material effect on their use of the Service, through the channels made available by FCX. The review considers the available Evidence, the rules applied and the relevant technical and legal limitations, and its outcome is recorded in the Audit Trail. 7.6. FCX maintains an Audit Trail sufficient to reconstruct the executions of the Guided Analysis, including the classification of the offer, the sequence of the four engines, the Evidence and sources used, the rules and controls applied, the relevant models and versions, the results, the critical gaps, the blocks, the reviews and the reabsorbed outcomes. Records are versioned and are not overwritten by later updates. 7.7. The Operational Memory may reabsorb replies, meetings, advances, losses, silence and other authorized commercial outcomes in order to improve future analyses. This learning preserves the link to the Evidence, the version history and the isolation between accounts, without turning a hypothesis or a decontextualized memory into a source of truth. 8. Limitation of Liability 8.1. FCX's total liability towards the User for direct damages demonstrably arising from a failure in the provision of the Service is limited to the greater of: (a) the amount actually paid by the User to FCX in the 12 (twelve) months immediately preceding the event giving rise to the damage; or (b) the liability floor of the Subscription Plan in force on the date of the event, under Clause 8.1.1. The 12 (twelve) month window in item (a) is a criterion for calculating the amount paid and does not establish a minimum term, a loyalty period or a commitment to contract for an equivalent period, subject to Clause 2.8. 8.1.1. The liability floor per Subscription Plan is: (a) BRL 500.00 (five hundred reais) on the Free Plan; (b) the amount of 1 (one) monthly fee of the Plan in force on the date of the event, on the Pro and Max Plans. The floor applies even where no payment has been made to FCX in the period referred to in item (a) of Clause 8.1. 8.2. The limitations set out in this EULA do not apply to damages caused by wilful misconduct or gross negligence on the part of FCX, nor to instances of liability that cannot be limited or excluded by the applicable legislation, including data protection and consumer protection legislation. 8.3. To the maximum extent permitted by law, FCX is not liable for indirect or consequential damages, loss of profits, loss of revenue, loss of commercial opportunities or reputational damage that do not arise from wilful misconduct or gross negligence on the part of FCX. 8.4. The User shall indemnify FCX for third-party claims arising from unlawful use of the Service, breach of this EULA or data processing determined by the User without an adequate legal basis, save for FCX's own responsibilities. 9. Force Majeure 9.1. Neither party is liable for delays or failures in performing its obligations arising from events beyond its reasonable control, including natural disasters, epidemics, pandemics, acts of government, wars, widespread failures of telecommunications or electrical infrastructure, and large-scale cyber attacks ("Force Majeure"). 9.2. The party affected by a Force Majeure event must notify the other party within 5 (five) business days of the start of the event, describing its nature and estimated impact. If the event persists for more than 30 (thirty) calendar days, either party may terminate this EULA without penalty, upon formal notice. 10. Termination 10.1. This EULA remains valid for as long as the User's account is active. The User may cancel their Plan under the terms of Clause 2.8. FCX may terminate the EULA upon 30 (thirty) days' prior notice, or immediately in the event of a material breach not cured within 10 (ten) days of formal notice, save for situations requiring immediate suspension for security, fraud, illegality or the protection of third parties. 10.2. Once the paid subscription cycle ends, access to the features exclusive to the paid Plans ceases, save for the operations funded by the Extra Credit balance, under Clauses 2.5.1 and 2.5.2. Unused Monthly Allowance Credits are not refundable. The Extra Credit balance remains available for as long as the account exists. Upon definitive account closure, any Extra Credit balance is refunded under Clause 2.8.1. User Data is retained for the period necessary to comply with legal obligations, to exercise rights in the regular course and to observe security periods and, at the end of that period, is deleted or anonymized in accordance with the LGPD. 11. Governing Law and Dispute Resolution 11.1. This EULA is governed by the laws of the Federative Republic of Brazil. Before filing any claim, the parties shall make good-faith efforts to reach a consensual solution within 30 (thirty) days of formal notice of the dispute. If the impasse persists, the courts of the District of São Paulo, State of São Paulo, are elected, without prejudice to the legally competent forum where a consumer relationship applies. 12. General Provisions 12.1. This EULA constitutes the entire agreement between the parties in relation to the use of the Service. Where contracting takes place through self-service and in the absence of a Commercial Proposal or Services Agreement, this EULA is the sole and prevailing contractual instrument, without prejudice to the Privacy Policy. Where a Commercial Proposal or a Services Agreement has actually been entered into between the parties, those instruments supplement this EULA, and the specific instrument prevails solely as to its subject matter, subject to rights that cannot legally be waived. 12.2. FCX may amend this EULA upon at least 15 (fifteen) days' prior notice and publication of the new version on the platform. Amendments affecting privacy, data use, limitation of liability or material use restrictions require explicit acceptance before access continues. Operational, commercial or purely editorial amendments may be accepted through continued use after the notice period. This version 1.5 fully replaces version 1.4 and, because it affects clauses on limitation of liability and the commercial conditions of Credits, requires the User's explicit acceptance before access to the Service continues. 12.3. The version applicable to each User is the one in force on the date of their express or tacit acceptance, recorded with the version number, date and time and the technical elements necessary for evidentiary purposes. Each new version accepted replaces the previous one for contractual and evidentiary purposes. 12.4. For questions or requests relating to this EULA, the User may contact FCX at suporte@fcxsolutions.com.br. By using the Service, You confirm that You have read, understood and agreed to the terms of this EULA in the version indicated at the time of acceptance. Version 1.5, last updated: 12 August 2026.