Privacy Policy
Terms of Use
These Terms of Use govern the contractual relationship between the user (hereinafter "Client") and BASE Consultoria, registered with CNPJ no. 55.152.104/0001-03 (hereinafter "BASE"), regarding the use of the platform accessible at basevlp.com.
By accepting these Terms, the Client declares having read, understood and fully agreed to its provisions, forming a valid legal bond between the parties.
Clause 1 — Object
BASE offers the Client, according to the contracted plan, access to a digital platform for personal and business financial organization, based on the proprietary B.A.S.E. method (Benchmarking, Analytics, Sustainability and Ethics).
Under the self-service plan (Platform), the Client uses the platform independently, without an assigned consultant. Under the consultancy plans, access to the platform is accompanied by an assigned BASE consultant, to the extent provided in the contracted plan.
The platform is intended for centralized recording of the Client's financial movements, generation of reports and indicators, recording of goals and habits, and, where applicable, structured interactions with the consultant.
Clause 2 — Nature of the service
2.1. BASE is not a financial institution, brokerage firm, or company authorized to operate in the capital markets.
2.2. BASE is not a securities advisory firm registered with CVM (Brazilian SEC) and, therefore, does not issue specific recommendations to buy, sell or hold financial assets. The platform's investment fields are intended for the Client's own recording of operations he or she has carried out.
2.3. BASE does not provide accounting services. Bookkeeping or tax-filing demands should be directed to a licensed professional.
2.4. The content of the platform Manual and monthly reports is educational. Financial decisions remain the Client's sole responsibility.
Clause 3 — Conditions of use
To create an account, the Client must: (i) be at least 18 years old; (ii) provide truthful identification; and (iii) accept these Terms and the Privacy Policy.
Access may be contracted directly by the Client, in self-service, or by invitation sent by a BASE consultant, according to the chosen plan.
BASE may refuse or terminate the account of any Client who breaches these Terms, provides false information or uses the platform in a way that harms other users or the service.
Clause 4 — Account and credentials
4.1. The Client is responsible for keeping the access password confidential, and all activities performed with the credentials are presumed to be performed by the Client.
4.2. Upon suspected unauthorized access, the Client shall change the password immediately in "Edit Profile" and notify BASE at contact@basevlp.com.
4.3. The platform allows spouse access by Client-side configuration, revocable at any time.
Clause 5 — Fees, right of withdrawal and cancellation
5.1. Amounts and payment methods are those of the contracted plan, whether contracted directly by the Client (self-service) or as set forth in a proposal presented by a BASE consultant.
5.2. Right of withdrawal: in contracting carried out over the internet, the Client may withdraw within 7 (seven) calendar days from acceptance, with full refund of any amounts paid, under article 49 of the Brazilian Consumer Defense Code.
5.3. Cancellation: the Client may cancel at any time, simply and immediately, through the platform itself or via contact@basevlp.com, by means as easy as those of contracting, under Decree no. 11,034/2022, without penalty and without lock-in.
5.4. Non-payment may result in suspension of access after prior notice by e-mail.
5.5. Before termination, the Client may export data through the platform's available feature.
Clause 6 — Recorded data
6.1. All content recorded by the Client on the platform belongs to the Client. BASE stores and processes such data within the limits necessary for the service.
6.2. The Client is responsible for the accuracy and updating of the data recorded.
6.3. The Client is forbidden from recording third-party data without proper authorization.
Clause 7 — Availability
BASE will make reasonable efforts to keep the platform available, allowing for scheduled maintenance windows or unscheduled unavailability due to technical failure.
BASE does not guarantee uninterrupted or error-free operation and commits to fixing failures within a reasonable period.
Daily automated backups are kept as a prevention measure, without prejudice to the recommendation that the Client periodically export the data.
Clause 8 — Limitation of liability
BASE shall not be liable for:
(i) financial decisions made by the Client based on information from the platform;
(ii) losses arising from investment operations, since the platform merely records information provided by the Client;
(iii) unavailability due to force majeure, fortuitous event or third-party provider failure, observed BASE's reasonable diligence;
(iv) content sent by other users;
(v) use of the platform contrary to its purpose.
BASE's total liability in any dispute arising from the use of the platform shall be limited to the amount actually paid by the Client during the 12 (twelve) months preceding the event, except in cases of proven willful misconduct or gross negligence.
Clause 9 — Intellectual property
The BASE brand, the basevlp.com name, the B.A.S.E. method, layouts, source code, manuals and platform texts are the exclusive property of BASE Consultoria.
The Client receives a non-exclusive, non-transferable and revocable license for personal use of the platform under this instrument, and is forbidden from copying, redistributing, reverse-engineering or creating derivative product without written authorization.
Data recorded by the Client remains its property.
Clause 10 — Communications
BASE will send the Client operational communications essential to the service (confirmations, password recovery, contracted notifications).
Motivational or non-essential informational communications will only be sent upon express opt-in by the Client, configurable on the platform itself.
Clause 11 — Changes
BASE may update these Terms to reflect changes in the service or legislation. Each new version receives number and effective date. In case of material change, the Client will be notified and a new acceptance may be required. Disagreement entitles the Client to terminate the account.
Clause 12 — Applicable law and forum
These Terms are governed by the laws of the Federative Republic of Brazil.
The Forum of the Capital of the State of São Paulo is hereby elected to settle any controversies arising from this instrument, with express waiver of any other, however privileged it may be.
Privacy Policy
BASE Consultoria respects your privacy. This Privacy Policy explains what data is collected when you use the BASE platform, accessible at basevlp.com, the purposes for which it is used, with whom it may be shared, and your rights as data subject, in compliance with the Brazilian General Data Protection Law (Law no. 13,709/2018 — LGPD).
Clause 13 — Data controller
BASE Consultoria — CNPJ 55.152.104/0001-03.
Full address and other contact details are available upon request through the channel indicated below.
Data Protection Officer (DPO): contact@basevlp.com
Clause 14 — Data collected
BASE collects only the data strictly necessary to deliver the contracted service.
14.1. Data provided directly by the data subject: full name, e-mail, phone, date of birth, profile photo (optional), financial data the subject chooses to record (income, expenses, checking-account entries, credit card, investments, goals, life events, journal notes) and, where applicable to the Business plan, company data (legal name, tax ID, tax regime, cash flow).
14.2. Data collected automatically: access logs (IP address, browser, date and time), essential technical cookies (session, CSRF, preferred language) and record of acceptance of this Policy and the Terms (date, IP, version accepted).
14.3. Data from financial institutions: when the subject imports a bank statement (OFX, PDF, Excel) or a credit-card invoice, data from those files is processed by the platform and stored in the subject's account. BASE does not directly connect to financial institutions via Open Banking in this version of the service — imports are always initiated by the subject.
Clause 15 — Purposes
Data is used for:
(i) service delivery — organizing transactions, generating reports, displaying charts and indicators, providing follow-up by the assigned BASE consultant;
(ii) operational communication — confirmation messages, agreed notifications, and contracted reminders;
(iii) technical support — clarifying questions, fixing failures, and improving the platform;
(iv) compliance with regulatory, tax and fraud-prevention obligations.
Clause 16 — Legal grounds
Processing is based on the grounds set forth in article 7 of LGPD, in particular: performance of a contract (item V), compliance with legal obligation (item II), legitimate interest (item IX) and consent (item I), the latter only for specific, revocable cases expressly signaled to the subject.
Clause 17 — Sharing
Personal and financial data are not sold or transferred for commercial or advertising purposes of third parties.
Sharing occurs solely with:
(i) BASE consultants assigned to the subject, strictly limited to what is necessary for the contracted service;
(ii) technical infrastructure providers (hosting and transactional e-mail), acting under BASE's instructions and confidentiality obligations, exclusively to enable the service;
(iii) public authorities, when required by court order or competent-authority request.
Clause 18 — Retention
Data is kept while the subject is an active client. Upon termination of the relationship, data is retained for up to 5 (five) years for defense in eventual judicial or administrative proceedings, observing applicable limitation periods. After such period, data is anonymized or deleted.
Acceptance records are kept while the account exists and for 5 (five) years after termination.
Clause 19 — Security
BASE adopts reasonable technical and organizational measures to protect data, including encrypted transmission (HTTPS/TLS), password storage with one-way hashing, SSH-key access control, daily automated backups, role-based segregation and session cookies with HttpOnly and Secure flags.
In case of a security incident involving risk to data subjects, BASE will notify those affected and the Brazilian Data Protection Authority (ANPD) under article 48 of LGPD.
Clause 20 — Rights of the data subject
At any time, by request to the DPO at the e-mail indicated, the subject may: confirm processing; access the data; correct it; request anonymization, blocking or deletion of unnecessary or non-compliant data; request portability; revoke consent given for specific cases; object to processing based on legitimate interest; and file a complaint with the ANPD.
BASE will respond to requests within 15 (fifteen) business days.
Clause 21 — Cookies
The platform uses only essential technical cookies (session, CSRF, language). No advertising tracking cookies, social-media pixels or behavioral analytics tools that identify the subject are used.
Clause 22 — International transfer
Data is stored on servers located in Brazil. BASE does not carry out international transfer of personal data in this version of the service.
Clause 23 — Updates to this Policy
BASE may update this Policy to reflect legal or service changes. Each new version receives number and effective date. In case of material change, the subject will be notified by e-mail or notice on the platform and a new acceptance may be required.