Terms of Use

1. Purpose of the Website

The Website is operated to present information about Gyroscope, its philosophy, approach, behavioral wealth governance framework, and related institutional activities.

The Website may also provide:

• educational and institutional content;
• information regarding behavioral finance and decision discipline;
• the Gyroscope Discipline Score (“GDS”) Assessment;
• introductory or eligibility questionnaires;
• publications, reports, or downloadable materials;
• forms through which visitors may request a conversation with Gyroscope;
• information regarding the distinct roles of Gyroscope and regulated financial providers.

The Website is not an e-commerce platform and is not designed for the execution of financial transactions, securities trades, investment orders, deposits, withdrawals, custody instructions, or portfolio-management transactions.

2. Informational Nature of the Content

Unless expressly stated otherwise, all content made available through the Website is provided for general informational, educational, and institutional purposes only.

Content on the Website should not be interpreted as:

• investment advice;
• investment recommendations;
• portfolio-management advice;
• securities research;
• a recommendation to purchase, sell, hold, or otherwise transact in any financial instrument;
• an asset-allocation recommendation;
• financial planning advice;
• legal advice;
• tax advice;
• accounting advice;
• an offer or solicitation to purchase or sell securities or financial products;
• a guarantee or projection of investment performance.

Visitors should obtain appropriate independent professional advice before making financial, investment, legal, tax, or other decisions requiring professional evaluation.

3. Role of Gyroscope

Gyroscope focuses on behavioral wealth governance, including matters such as:

• financial organization;
• clarification of objectives and long-term priorities;
• behavioral awareness;
• decision discipline;
• consistency;
• liquidity considerations;
• family and long-term perspectives.

Gyroscope’s role should not be confused with the regulated activities performed by financial institutions or other authorized financial providers.

Unless otherwise expressly established through a separate legally valid arrangement, Gyroscope does not use the Website to provide regulated services such as:

• investment advice;
• securities selection;
• asset allocation;
• portfolio management;
• trade execution;
• securities custody;
• brokerage services;
• financial-product distribution.

Such services, where applicable, are provided independently by appropriately regulated financial providers under their own contractual, legal, regulatory, and compliance frameworks.

4. Regulated Financial Providers

The Website may refer to financial institutions, investment advisers, portfolio managers, custodians, banks, brokers, or other regulated financial providers.

These providers are independent from Gyroscope unless expressly stated otherwise.

Any investment advice, security selection, portfolio management, execution, custody, suitability determination, risk profiling, or other regulated financial activity must be performed by the relevant authorized provider.

Gyroscope is not responsible for the investment decisions, services, systems, products, performance, contractual obligations, or regulatory responsibilities of independent financial providers.

Visitors should review the documentation, disclosures, privacy policies, agreements, and regulatory status of any financial provider before entering into a relationship with that provider.

5. Gyroscope Discipline Score (GDS)

The Website may offer access to the Gyroscope Discipline Score (“GDS”), a proprietary behavioral assessment designed to encourage reflection on behavioral patterns associated with financial decision-making.

The GDS may evaluate behavioral themes such as consistency, reactions to market information, adherence to previously established parameters, and other behavioral tendencies.

The GDS:

• is a behavioral assessment tool;
• is not a psychological or clinical assessment;
• is not a financial knowledge test;
• is not an investment-risk profile;
• is not a suitability assessment;
• does not determine investment capacity or tolerance for financial losses;
• does not recommend financial products or securities;
• does not determine asset allocation;
• does not constitute investment advice;
• does not predict future behavior;
• does not predict investment returns;
• does not guarantee financial outcomes.

Any score, classification, interpretation, or other output generated through the GDS should be viewed as a behavioral reference intended to support awareness and dialogue.

The methodology, scoring system, classifications, questions, and related intellectual property associated with the GDS may be modified or refined over time.

6. Eligibility Questionnaires

Certain areas or interactions on the Website may include introductory or eligibility questions.

Completion of these questions:

• does not guarantee acceptance as a Gyroscope client;
• does not establish an advisory or contractual relationship;
• does not constitute a suitability assessment;
• does not constitute an investment recommendation;
• does not guarantee access to any financial product or service.

Gyroscope may determine, in its discretion and subject to applicable law, whether a conversation or further interaction is appropriate based on jurisdictional, operational, regulatory, or other considerations.

7. No Client Relationship Created by Website Use

Accessing the Website, completing an assessment, downloading material, subscribing to communications, or submitting a Request a Conversation does not, by itself, create:

• a client relationship;
• an advisory relationship;
• a fiduciary relationship;
• an investment-management relationship;
• a contractual financial-services relationship;
• any obligation for Gyroscope to provide services.

Any formal relationship with Gyroscope must be separately established through the applicable onboarding process and documentation.

Similarly, no relationship with a regulated financial provider is created merely because that provider is mentioned, linked, referenced, or discussed through the Website.

8. No Offer or Solicitation

Nothing contained on the Website constitutes or should be construed as an offer, invitation, solicitation, recommendation, or inducement to acquire, dispose of, subscribe for, or transact in any security, financial instrument, investment product, or financial service.

The Website is not intended to distribute investment products or solicit securities transactions.

Information appearing on the Website may not be appropriate or legally available in every country or jurisdiction.

Visitors are responsible for ensuring that their access to the Website and any subsequent interaction complies with laws and regulations applicable in their jurisdiction.

9. Market and Financial Information

The Website may contain information relating to financial markets, behavioral finance, investing, economic conditions, historical events, research, studies, or other financial topics.

While Gyroscope seeks to present information considered relevant and reliable, such information may:

• become outdated;
• contain estimates or interpretations;
• originate from third-party sources;
• be subject to revision;
• reflect market conditions that have subsequently changed.

Past performance, historical market behavior, illustrations, simulations, hypothetical examples, or research findings should not be interpreted as guarantees of future results.

Financial markets involve uncertainty, and no methodology, framework, assessment, or behavioral process can eliminate investment risk or guarantee financial outcomes.

10. Intellectual Property

Unless otherwise indicated, the Website and its contents are owned by or licensed to Gyroscope and are protected by applicable intellectual-property laws.

This includes, without limitation:

• trademarks;
• logos;
• brand elements;
• text;
• graphics;
• illustrations;
• photographs;
• videos;
• animations;
• Website layouts;
• reports;
• methodologies;
• assessments;
• questionnaires;
• scoring systems;
• the GDS methodology and related materials;
• downloadable publications.

Access to the Website does not transfer any ownership or intellectual-property rights to the visitor.

Content may not be copied, reproduced, modified, distributed, published, commercially exploited, reverse engineered, or otherwise used beyond normal personal Website access without prior written authorization from Gyroscope or the applicable rights holder.

Brief quotations or references permitted by applicable law must preserve appropriate attribution and must not misrepresent the source or context.

11. Acceptable Use

Visitors agree not to use the Website in a manner that:

• violates applicable law;
• interferes with Website operation or security;
• attempts to gain unauthorized access to systems, servers, accounts, or data;
• introduces malware, viruses, malicious code, or other harmful technology;
• performs unauthorized automated extraction, scraping, crawling, or systematic copying of Website content;
• attempts to manipulate or reverse engineer assessments, algorithms, or protected methodologies;
• impersonates another person or provides intentionally misleading information;
• infringes intellectual-property, privacy, or other rights;
• uses Website forms for spam, unsolicited advertising, abusive communications, or unlawful purposes.

Gyroscope may restrict or suspend access where reasonably necessary to protect the Website, its users, intellectual property, or systems.

12. Third-Party Links and Services

The Website may contain links to external websites, platforms, financial institutions, publications, scheduling systems, social media services, or other third-party resources.

Links are provided for convenience or informational purposes and do not necessarily constitute endorsement, recommendation, partnership, or approval.

Gyroscope does not control independent third-party websites and is not responsible for:

• their content;
• their availability;
• their privacy practices;
• their cybersecurity;
• their products or services;
• their accuracy;
• transactions entered into through them.

Use of third-party websites is subject to the terms and policies established by the relevant third party.

13. Website Availability

Gyroscope seeks to maintain the Website in an appropriate operational condition but does not guarantee uninterrupted, permanent, error-free, or continuously available access.

The Website may become temporarily unavailable as a result of:

• maintenance;
• technical changes;
• hosting or infrastructure issues;
• cybersecurity measures;
• third-party service failures;
• events outside Gyroscope’s reasonable control.

Gyroscope may modify, suspend, discontinue, replace, or restrict any Website feature or content where reasonably necessary.

14. Disclaimer of Warranties

The Website and its content are provided on an “as available” basis, subject to applicable law.

While reasonable efforts may be made to maintain accuracy, relevance, and functionality, Gyroscope does not warrant that:

• all content will always be complete or current;
• the Website will be free from technical errors;
• access will always be uninterrupted;
• all third-party information will be accurate;
• any assessment or methodology will produce a particular result;
• use of Website information will achieve any financial or investment outcome.

Nothing in these Terms excludes warranties or protections that cannot legally be excluded under applicable law.

15. Limitation of Liability

To the extent permitted by applicable law, Gyroscope will not be liable for losses arising solely from reliance on Website content as a substitute for professional financial, investment, legal, tax, or other advice.

Gyroscope is also not responsible for losses arising from:

• independent investment decisions made by visitors;
• services provided by third-party financial providers;
• transactions executed outside Gyroscope;
• failures or actions of third-party platforms;
• temporary Website unavailability;
• unauthorized or unlawful use of the Website by another party;
• information submitted voluntarily through inappropriate or unsecured channels.

Nothing in these Terms limits liability where such limitation is prohibited by applicable law.

16. Privacy and Personal Data

Personal data collected through the Website is processed in accordance with the Privacy Policy.

The use of cookies and similar technologies is described separately in the Cookie Notice.

Visitors should review both documents before submitting personal information through the Website.

17. Adults and Legal Capacity

The Website and the interactions described through it are intended for adults with the legal capacity necessary to understand and enter into the relevant relationships.

Gyroscope does not knowingly invite minors to complete the GDS, submit financial-context information, or initiate conversations relating to wealth governance services through the Website.

18. Changes to These Terms

Gyroscope may update these Terms from time to time to reflect changes to:

• Website functionality;
• services;
• assessments;
• business practices;
• applicable law;
• regulatory requirements.

The most current version will be made available on this page, together with its corresponding “Last updated” date.

Continued use of the Website following publication of updated Terms will be subject to the version then in effect.

Where a change requires additional notice or consent under applicable law, appropriate measures will be taken.

19. Governing Law and Jurisdiction

These Terms are governed by the laws of the Federative Republic of Brazil, without prejudice to mandatory rights or protections applicable under other laws.

Any dispute relating to the Website or these Terms shall be submitted to the competent courts determined in accordance with applicable law.

Nothing in this section restricts rights regarding jurisdiction or venue that cannot legally be waived.

20. Contact

Questions regarding these Terms of Use may be submitted to Gyroscope through the contact channels made available on the Website.