Privacy Policy
Last updated: October 2, 2026
Galloway Capital Gestora de Recursos Ltda respects the privacy of users and is committed to protecting personal data processed through its digital channels.
This Privacy Policy explains how we collect, use, store and protect personal data when you access the Galloway Capital website at www.galloway.com.br or contact us through the channels made available on the website.
Who We Are
Galloway Capital Gestora de Recursos Ltda., registered with the Brazilian National Registry of Legal Entities (CNPJ) under No. 12.489.853/0001-18, is an investment management company authorized and regulated by the Brazilian Securities and Exchange Commission (CVM).
For purposes of applicable data protection laws, including Brazilian Law No. 13,709/2018, the Brazilian General Data Protection Law (“LGPD”), Galloway is responsible for the processing of personal data carried out in connection with this website and its contact channels.
Personal Data We May Collect
Depending on how you use the website, we may collect:
Information provided directly by you, including:
• name;
• email address;
• telephone number;
• information regarding your interests in our products and services;
• financial assets information provided through our contact form;
• other information voluntarily provided when contacting us.
Information collected automatically, such as technical information related to your browsing, including IP address, device type, browser, operating system, pages visited and date and time of access, when technically made available to the website.
We do not intentionally request sensitive personal data through the website unless there is a specific purpose and an appropriate legal basis for processing such data.
How We Use Personal Data
Personal data may be used to:
• respond to requests, questions and messages submitted through the website;
• contact individuals who express an interest in Galloway products, funds or services;
• understand and respond to users’ needs;
• provide requested information regarding Galloway and its products;
• make fund-related documents and materials available;
• maintain the security and proper operation of the website;
• prevent fraud, abuse and unauthorized access;
• comply with legal and regulatory obligations and orders from competent authorities;
• exercise Galloway’s rights in judicial, administrative or arbitration proceedings;
• carry out other activities compatible with the purposes described herein and permitted by applicable law.
Legal Bases
Depending on the circumstances, personal data may be processed on the basis of legal grounds provided under the LGPD and other applicable laws, including:
• consent;
• compliance with legal or regulatory obligations;
• performance of a contract or steps prior to entering into a contract;
• exercise of legal rights;
• legitimate interests of Galloway, where applicable and subject to the rights and fundamental freedoms of the data subject;
• credit protection, where applicable;
• other legal bases provided by applicable law.
Where processing is based on consent, the data subject may withdraw consent at any time, subject to applicable legal retention requirements.
Sharing of Personal Data
Galloway may share personal data, when necessary and in accordance with applicable law, with:
• service providers supporting our systems and operations;
• technology, hosting, information security and maintenance providers;
• advisers, consultants, auditors and professional service providers;
• financial institutions, administrators, distributors, custodians and other market participants when necessary for services related to investment funds and investments and as permitted or required by applicable law;
• public authorities, regulators and supervisory bodies where legally or regulatorily required;
• third parties where necessary to exercise legal rights or comply with legal obligations.
Galloway does not sell users’ personal data.
International Data Transfers
In certain circumstances, personal data may be processed or stored by service providers located outside Brazil or otherwise involve international transfers of personal data.
Where applicable, Galloway will adopt the safeguards and mechanisms required by applicable data protection laws to protect personal data and the rights of data subjects.
Cookies and Similar Technologies
The website may use cookies and similar technologies to enable its operation, improve the browsing experience, maintain security and, where applicable, understand how the website is used.
The types of cookies used and their purposes may vary depending on the tools and functionalities available on the website.
Users may configure their browsers to block or delete certain cookies. However, disabling cookies that are necessary for the website’s operation may affect certain functionalities.
Data Security
Galloway adopts reasonable technical, administrative and organizational measures designed to protect personal data against unauthorized access, loss, destruction, alteration, disclosure or other inappropriate or unlawful processing.
Nevertheless, no electronic system or internet transmission can be guaranteed to be completely secure. Accordingly, absolute security of information cannot be guaranteed.
Data Retention
Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected.
After the relevant purpose has been fulfilled, data may be deleted or anonymized unless retention is necessary for:
• compliance with legal or regulatory obligations;
• the exercise of legal rights;
• contractual obligations;
• fraud prevention and security purposes;
• other circumstances permitted or required by applicable law.
Data Subject Rights
Subject to applicable legal conditions and limitations, data subjects may request:
• confirmation of whether their personal data is being processed;
• access to their personal data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data;
• data portability, subject to applicable regulations;
• deletion of data processed on the basis of consent, except where retention is legally required;
• information regarding the sharing of their personal data;
• information regarding the possibility of refusing consent and the consequences of such refusal;
• withdrawal of consent;
• objection to processing, where applicable;
• review of decisions based solely on automated processing, where applicable.
Requests and questions regarding privacy and the processing of personal data may be submitted to:
Galloway may request additional information to verify the identity of the requester and protect personal data against fraudulent requests.
Minors
The Galloway website is not directed to children or minors and is not intended to knowingly collect personal data from minors.
If a parent or legal guardian becomes aware that personal data of a minor has been improperly provided through the website, they may contact us using the channel indicated in this Privacy Policy.
Third-Party Links
The website may contain links to third-party websites, platforms, documents or services.
This Privacy Policy does not apply to websites or services that are not controlled by Galloway. Users should review the applicable privacy policies before providing personal data to third parties.
Changes to This Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in our practices, services, technologies or applicable laws.
The most recent version will always be available on the Galloway website and will include its applicable update date.
Contact
For questions, requests or information regarding the processing of personal data, please contact:
Galloway Capital Gestora de Recursos Ltda.
CNPJ: 12.489.853/0001-18
Rua Joaquim Floriano, 960
Itaim Bibi, São Paulo – SP
04534-004, Brazil
Email: sales@galloway.com.br
Phone: +55 11 97771-7046
TERMS OF USE
Last updated: October 2, 2026
Welcome to the website of Galloway Capital Gestora de Recursos Ltda. (“Galloway”).
By accessing or using www.galloway.com.br, you agree to these Terms of Use. If you do not agree with any provision of these Terms, please do not use the website.
About the Website
The Galloway website is institutional and informational in nature and provides information about Galloway Capital, its team, investment strategies, funds, documents, publications and contact channels.
The content available on the website is provided for informational purposes only and does not, by itself, constitute an offer, recommendation, solicitation or individualized investment advice.
Investment Information
Information, materials, presentations, fact sheets, letters, reports, documents and other content available on the website should not be considered the sole basis for any investment decision.
Investments involve risks, including the possibility of partial or total loss of invested capital.
Past performance is not indicative of future results.
Before making any investment decision, investors should carefully assess the characteristics, risks, costs, liquidity and other conditions applicable to the relevant product, taking into consideration their investment objectives and risk profile, and should review the applicable official and regulatory documentation.
Fund Documents
Materials made available through the areas designated for Brazilian and international investors may include prospectuses, regulations, legal documents, financial statements, fact sheets, investor letters and other information related to investment funds.
These documents contain their own terms, limitations, disclosures and regulatory information and should be reviewed together with the applicable official materials.
In the event of any discrepancy between summarized information presented on the website and official fund documentation, the applicable official documentation and regulations shall prevail.
Brazilian and International Investors
The website provides separate areas for Brazilian and international investors.
Access to specific content or documents does not mean that any product or fund is available, suitable or may be offered to every person in every jurisdiction.
The availability of products and services is subject to applicable laws, regulations, eligibility requirements and restrictions in the investor’s relevant jurisdiction.
No Individualized Advice
Information provided on the website does not constitute individualized legal, tax, accounting or financial advice.
No content on the website should be interpreted as a personalized recommendation to purchase, sell or hold any financial asset or investment product.
Investors should seek independent professional advice when appropriate.
Accuracy of Information
Galloway seeks to keep the information available on the website accurate and up to date.
However, information may change as a result of market conditions, regulatory developments, changes to funds or updates to official documentation.
Accordingly, Galloway does not guarantee that all website content will always be complete, current or free from errors or omissions.
Intellectual Property
All content available on the website, including text, trademarks, logos, images, graphics, presentations, documents, visual elements, layout, code and other materials, is owned by Galloway or lawfully used by Galloway, as applicable.
Reproduction, distribution, publication, modification or commercial use of website content without prior authorization is prohibited, except where expressly permitted by applicable law.
Access to materials available on the website does not transfer any intellectual property rights to the user.
Acceptable Use
Users agree to use the website lawfully and in accordance with these Terms of Use and applicable laws.
Users may not, among other things:
• use the website for unlawful purposes;
• attempt to gain unauthorized access to systems or restricted areas;
• interfere with the operation of the website;
• introduce code, files or mechanisms that may compromise its security;
• use website information for fraudulent or unlawful activities;
• reproduce or commercially exploit protected content without authorization.
Third-Party Links and Websites
The website may contain links to third-party websites, platforms or services.
Such links are provided for convenience and do not necessarily constitute an endorsement, recommendation or assumption of responsibility by Galloway for the content, products, services, policies or practices of such third parties.
Users are responsible for reviewing the terms and policies applicable to third-party websites they access.
Website Availability
Galloway may modify, suspend or discontinue, temporarily or permanently, website functionalities or content, including for maintenance, updates, security or regulatory compliance purposes.
Galloway does not guarantee that the website will be continuously available or free from interruptions, failures or downtime.
Limitation of Liability
To the extent permitted by applicable law, Galloway shall not be liable for losses or damages arising solely from the use of information made available on the website, particularly where a user makes investment decisions without conducting their own analysis or reviewing the applicable official documentation.
Nothing in these Terms is intended to exclude or limit any liability that cannot legally be excluded or limited under applicable law.
Changes to These Terms
Galloway may update these Terms of Use periodically.
The current version will be available on the website and identified by its applicable update date.
Continued use of the website after changes have been published constitutes acknowledgment of the updated Terms.
Applicable Law
These Terms of Use shall be interpreted in accordance with Brazilian law, without prejudice to mandatory provisions that may apply to users in their respective jurisdictions.
Issues relating to investment products will also be subject to applicable regulations and the relevant official documentation.
Contact
For questions regarding the website or these Terms of Use, please contact:
Galloway Capital Gestora de Recursos Ltda.
CNPJ: 12.489.853/0001-18
Rua Joaquim Floriano, 960
Itaim Bibi, São Paulo – SP
04534-004, Brazil
Email: sales@galloway.com.br
Phone: +55 11 97771-7046