RADAR EXYNAX
Foreign Trade Intelligence Platform
Consolidated Legal Document — Version 1.0
Jurisdiction: Rio de Janeiro, Brazil
Last Updated: March 2026
CONFIDENTIAL — FOR EXCLUSIVE USE OF THE RADAR EXYNAX PLATFORM
TABLE OF CONTENTS
- 1. Legal Compliance and Purpose
- 2. Data Source, Aggregation and Cross-Referencing
- 3. Data Processing and Commercial Intelligence
- 4. Global Data Protection (GDPR / CCPA / LGPD)
- 5. Limitation of Liability and Legal Disclaimer
- 6. Accuracy, Rectification and Disputes
- 7. License of Use and Intellectual Property
- 8. Credential Security and Responsibility
- 9. Payment, Credits and Billing Policy
- 10. Refund and Cancellation Policy
- 11. Privacy and Data Protection Policy
- 12. Ethics and Global Compliance Policy
- 13. Artificial Intelligence (AI) Usage Policy
- 14. Synthetic Data, Deepfakes and Sanctions Gap
- 15. Dual-Use Restriction and Geopolitical Security
- 16. International Transfer and Data Sovereignty
- 17. SLA, Redundancy and Continuity
- 18. Data Retention and Purge Policy
- 19. Audit and Monitoring
- 20. Jurisdiction and Venue
1. LEGAL COMPLIANCE AND PURPOSE
The RADAR EXYNAX platform provides Business Intelligence (BI) and Open Source Intelligence (OSINT) services for strictly professional use within the scope of foreign trade.
By accessing and using the data provided by the platform, the User declares and warrants that the search is conducted for purposes of Legitimate Interest, specifically for:
- Global Supply Chain Due Diligence
- Commercial Risk Assessment (B2B)
- Compliance and auditing of commercial partners
- Commercial prospecting and market intelligence
2. DATA SOURCE, AGGREGATION AND CROSS-REFERENCING
2.1. Nature of Data
The information provided by the platform is aggregated from publicly available sources, including but not limited to:
- Publicly accessible web data (OSINT).
- Voluntary corporate registrations on the platform.
The User acknowledges that the platform acts as a Data Processor and Aggregator, and not as the original creator of the source data. Data is collected through OSINT methods and cross-referenced with the sole purpose of identifying real Importing/Exporting Companies.
2.2. Consent to Sharing
The User agrees that their registration data may be shared with Companies of mutual interest for commercial matching purposes.
The User acknowledges that, once registered on the platform, their data may be provided to third parties in a commercially monetized manner, as described in Section 3 of this document.
2.3. User Responsibility
The User is solely and fully responsible for ensuring that the use of data complies with the local data protection laws applicable in their jurisdiction.
RADAR EXYNAX does not manage responses or close business deals between Companies.
2.4. Limitation of Liability Regarding Data
The liability of RADAR EXYNAX is limited to delivering the collected and processed information, and it shall not be held responsible for:
- Improper use of data by the User
- Fraud or lack of integrity of identified third parties
- Unsuccessful business dealings resulting from decisions based on the data
3. DATA PROCESSING AND COMMERCIAL INTELLIGENCE
3.1. Consent to Cross-Referencing and Matching
By registering and using the features of RADAR EXYNAX, the User declares awareness and grants express authorization for all data provided, as well as information collected from public and private sources linked to their profile, to be processed, integrated and cross-referenced with third-party databases and other registered companies.
This processing aims to identify market intelligence opportunities, commercial prospecting and the establishment of business matching.
3.2. Monetization and Third-Party Access
The User acknowledges that the platform operates under a data intelligence model, where access to consolidated information, compliance reports and matching indicators may be commercialized to other users, partners or external entities.
The User authorizes RADAR EXYNAX to charge third parties for access to processed data.
3.3. No Financial Consideration
The User agrees and accepts that the identification of commercial matching, the display of their data to third parties, or the generation of business through the platform does not, under any circumstances, create a right to rewards, commissions, royalties, profit-sharing, or any other form of financial compensation.
The consideration for use of the system resides exclusively in the intelligence and network functionalities made available by the ecosystem to the User.
3.4. Irrevocability of Authorization
This authorization is an essential condition for maintaining an active account. The digital acceptance at the time of registration constitutes proof of free, informed and unequivocal consent for data processing as described in this clause, in full compliance with the commercial promotion purpose of the system.
4. GLOBAL DATA PROTECTION (GDPR / CCPA / LGPD)
RADAR EXYNAX operates in compliance with global privacy and data protection standards. Below are the legal bases for operation in each jurisdiction, focusing on Data Protection, Legitimate Interest and Exceptions for Public Data (OSINT).
4.1. Americas
| Country | Legislation | Key Provision |
|---|---|---|
| Brazil | LGPD (Law 13,709/18) | Art. 7, IX / Art. 10 |
| Argentina | Law No. 25,326 | Art. 5(2)(c) |
| United States | CCPA / FCRA | Sec. 1798.140(v) |
| Canada | PIPEDA | Section 7(1)(b) |
| Mexico | LFPDPPP | Art. 10, II |
| Chile | Law No. 19,628 | Art. 4 |
| Colombia | Law No. 1581/2012 | Art. 10(a) |
| Peru | Law No. 29,733 | Art. 14(1) |
| Uruguay | Law No. 18,331 | Art. 9(C) |
| Paraguay | Law No. 6534/20 | Art. 5 |
| Ecuador | LOPDP (2021) | Art. 7(8) |
| Panama | Law No. 81/2019 | Art. 8 |
| Costa Rica | Law No. 8968 | Art. 8 |
| Dominican Rep. | Law No. 172-13 | Art. 5 |
| Jamaica | Data Protection Act 2020 | Section 23 |
| Trinidad & Tobago | Data Protection Act 2011 | Section 6 |
| Bahamas | Data Protection Act 2003 | Section 13 |
| Barbados | Data Protection Act 2019 | Section 6 |
| Belize | Data Protection Act 2021 | Section 7 |
| Guyana | Data Protection Act 2023 | Section 15 |
| Antigua & Barbuda | Data Protection Act 2013 | Section 6 |
| Dominica | Data Protection Act 2012 | Section 6 |
| Saint Lucia | Data Protection Act 2011 | Section 7 |
| Nicaragua | Law No. 787 | Art. 11 |
| Honduras | Transparency Act | Art. 3 |
| El Salvador | Freedom of Info Act | Art. 6 |
| Guatemala | Constitution / Decree 57-2008 | Art. 9 |
| Bolivia | Federal Constitution (Art. 130) | Habeas Data |
| Venezuela | Constitution (Art. 28) | Habeas Data |
| Cuba | Law 149/2022 | State interest |
| Haiti | Constitution / Civil Code | Commercial secrecy |
| Suriname | Civil Code / Const. | Privacy & commerce |
4.2. Europe and United Kingdom (GDPR Block)
For all European countries (Albania, Germany, Andorra, Austria, Belgium, Belarus, Bosnia, Bulgaria, Croatia, Cyprus, Denmark, Slovakia, Slovenia, Spain, Estonia, Finland, France, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Moldova, Monaco, Montenegro, Norway, Netherlands, Poland, Portugal, Romania, San Marino, Serbia, Sweden, Switzerland, Ukraine, Vatican and the United Kingdom), the legal basis is unified:
| Element | Description |
|---|---|
| Legislation | GDPR (EU Regulation 2016/679) or mirrored national laws |
| Art. 6(1)(f) | Processing is necessary for the legitimate interests pursued by the controller or by a third party (Audit and Compliance). |
| Art. 14(5)(b) | Exemption from the duty to inform if the data is in the public domain and the effort would be disproportionate. |
4.3. Asia and Oceania
| Country | Legislation | Key Provision |
|---|---|---|
| China | PIPL | Art. 13(2) |
| Japan | APPI | Art. 18(2) |
| South Korea | PIPA | Art. 15 |
| India | DPDP Act 2023 | Sec. 7(a) |
| Indonesia | PDP Law (2022) | Art. 20 |
| Singapore | PDPA | Section 13 |
| Thailand | PDPA | Section 24(5) |
| Vietnam | PDP Decree (2023) | Art. 17 |
| Malaysia | PDPA 2010 | Section 6 |
| Philippines | Data Privacy Act 2012 | Sec. 12(f) |
| Taiwan | PDPA | Article 19 |
| Pakistan | PDPA (Draft) | Common Law |
| Australia | Privacy Act 1988 | APP 6.2(e) |
| New Zealand | Privacy Act 2020 | IPP 11 |
| Bangladesh | Digital Security Act 2018 | Data sovereignty |
4.4. Middle East and Africa
| Country | Legislation | Key Provision |
|---|---|---|
| South Africa | POPIA | Section 11(1)(f) |
| Saudi Arabia | PDPL | Art. 6 |
| UAE | Federal Decree-Law 45/2021 | Art. 4 |
| Egypt | Law 151/2020 | Art. 3 |
| Nigeria | NDPA 2023 | Section 25 |
| Kenya | Data Protection Act 2019 | Section 30 |
| Israel | PPA | Section 2 |
| Turkey | KVKK | Art. 5(2)(f) |
| Ghana | Data Protection Act 2012 | Sec. 20 |
| Algeria | Law 18-07 | Art. 10 |
4.5. Countries Without Specific Legislation
For countries that do not have specific data protection laws (e.g., South Sudan, Yemen, Somalia, Nauru, Tuvalu), RADAR EXYNAX relies on International Commercial Law and the Berne Convention (Art. 2(5)), which protects the database as intellectual property.
5. LIMITATION OF LIABILITY AND LEGAL DISCLAIMER
5.1. No Warranty (As-Is)
All data is provided "AS IS" and "AS AVAILABLE." While the platform uses advanced algorithms to ensure accuracy, there is no guarantee that the information is free from errors, complete or up to date.
5.2. No Financial Advice
The content provided by RADAR EXYNAX does not constitute, under any circumstances:
- Investment recommendation or financial advice
- A substitute for the User's independent professional due diligence
- Legal, commercial or tax advice
All commercial decisions are made solely at the User's own account and risk.
5.3. Indemnification
The User agrees to indemnify and hold the Platform harmless from any claims, damages or losses resulting from commercial decisions made based on the reports/data provided.
The User acknowledges that RADAR EXYNAX shall not be liable for any direct and/or indirect damages, lost profits or financial losses resulting from business decisions based on its data.
Maximum cumulative liability: limited to the amount paid for the specific report or service.
5.4. Independent Verification
The User acknowledges that, before making any decision, they must verify the information provided through their own means, as the data is collected, analyzed and generated by Artificial Intelligence and is susceptible to errors.
6. ACCURACY, RECTIFICATION AND DISPUTES
6.1. Right of Rectification
The platform offers a mechanism for companies to request the update or correction of outdated information. RADAR EXYNAX acts as a neutral channel for public information; therefore, disputes regarding the validity of a record must be addressed directly with the Primary Data Source (e.g., Government Registry or Sanctions Body).
6.2. Contact Dispute Policy
RADAR EXYNAX undertakes to refund, in the form of platform credits, the amounts corresponding to contacts that were previously known to the User, provided they are duly substantiated with documentary evidence.
Evidence accepted for disputes:
- Air Waybill (AWB) dated prior to the query
- Bill of Lading (BL) dated prior to the query
- Road Consignment Note (CMR/CRT) dated prior to the query
- Rail Consignment Note (CIM) dated prior to the query
Important: Disputes shall only be analyzed upon submission of actual documentary evidence. In case of any dispute, credit refunds are limited to the amount actually paid.
6.3. Adverse Information and Right of Reply
If the User detects factually incorrect information about their own company or a partner, they must formally request corrections.
Investigation period: 15 to 30 days to investigate the source of the information. If the error is confirmed, the platform will rectify the global database.
7. LICENSE OF USE AND INTELLECTUAL PROPERTY
All information, algorithms, methodologies and data structures are the exclusive property of RADAR EXYNAX.
7.1. Prohibitions
The following are strictly prohibited:
- Web scraping, crawlers or automated data collection from the platform
- Reverse engineering, decompilation or any attempt to extract the source code
- Sharing, selling, leasing or licensing reports to third parties without express authorization
- Total or partial redistribution of data without a specific contract
Notice: Limit individual access and never share passwords to avoid violating the Intellectual Property clause.
7.2. FCRA Compliance
The User undertakes to use the data exclusively for Commercial Risk Assessment (B2B) purposes, in compliance with FCRA (Fair Credit Reporting Act) restrictions where applicable.
8. CREDENTIAL SECURITY AND RESPONSIBILITY
Access credentials (logins and passwords) are individual and non-transferable.
- The User is fully responsible for any activity performed under their account
- Any suspicion of credential leakage or unauthorized access must be reported within a maximum of 24 hours
- The platform shall not be held responsible for unauthorized access resulting from User negligence in safeguarding their credentials
9. PAYMENT, CREDITS AND BILLING POLICY
9.1. Subscription Models
Access to RADAR EXYNAX services is available through the following modalities:
- Credit Packages (Pay-per-use): advance purchase of credit units, debited as reports are generated
- Automatic card payment upon data delivery
9.2. Pricing Structure and Taxes
- Price Variation: RADAR EXYNAX reserves the right to adjust prices without prior notice
- All amounts quoted in proposals are net; additional taxes may apply according to the User's jurisdiction
- Credit Validity: purchased credits are valid for 12 months. Unused credits at the end of the period expire and are neither refundable nor transferable
10. REFUND AND CANCELLATION POLICY
Irrevocability: once a purchase order is generated, the full amount is due. There is no refund for discontinuation of use by the client.
Billing Disputes: any billing dispute must be filed within 15 days of receipt, failing which tacit acceptance is assumed.
11. PRIVACY AND DATA PROTECTION POLICY
11.1. Role of the Parties
RADAR EXYNAX acts as the Data Controller for raw data. The User acts as an Independent Controller when deciding how to use the information resulting from reports and searches.
11.2. Personal Data
The platform applies PII Sanitization techniques (removal of personally identifiable data) before any processing by Artificial Intelligence.
12. ETHICS AND GLOBAL COMPLIANCE POLICY
12.1. Modern Slavery
RADAR EXYNAX guarantees, and requires the User to guarantee, that it does not use forced or child labor in any part of its data supply chain.
12.2. Ethical Use of Data
Data provided by the platform must be used exclusively for lawful purposes of commercial intelligence and compliance. Any use that violates human rights or international legislation is prohibited.
13. ARTIFICIAL INTELLIGENCE (AI) USAGE POLICY
13.1. Probabilistic Nature
The User acknowledges that AI-generated insights are probabilistic and not deterministic. The final decision must always include human oversight (Human-in-the-Loop).
13.2. Limitations
Despite validation mechanisms, the platform does not guarantee a complete absence of errors in AI-processed data. The User must always perform independent verification before making critical decisions.
14. SYNTHETIC DATA, DEEPFAKES AND SANCTIONS GAP
14.1. Disclaimer on Synthetic Data and Deepfakes
The User acknowledges that OSINT methodologies capture data from public sources that may be subject to external manipulation. RADAR EXYNAX shall not be held responsible for information based on Deepfakes (audio, video or image) or documents forged by third parties prior to collection.
The system acts as a technical mirror; the authenticity of the primary source is at the exclusive risk of the original publisher.
14.2. Sanctions Gap Clause (Propagation Interval)
Queries to Sanctions Lists (OFAC, UN, EU, etc.) and global Watchlists depend on the update frequency of government APIs.
Propagation Gap: the User accepts an interval of up to 48 hours between the official publication of a sanction and its indexation in consolidated reports.
For "Immediate Block" decisions, dual verification against the government source cited in the report is recommended.
15. DUAL-USE RESTRICTION AND GEOPOLITICAL SECURITY
The use of RADAR EXYNAX for the following purposes is strictly prohibited:
- State espionage
- Political persecution
- Monitoring of dissidents
- Any activity that violates international Human Rights treaties
Data usage is restricted to Commercial Due Diligence and Compliance (B2B). Any deviation from this purpose will result in immediate banning from the platform and notification to the competent authorities.
16. INTERNATIONAL TRANSFER AND DATA SOVEREIGNTY
To enable distributed processing and system redundancy, the User authorizes the international transfer of technical data to processing centers in multiple jurisdictions (USA, EU and Asia).
This procedure is intended exclusively for system resilience (Failover) and critical error reduction, operating under end-to-end encryption protocols.
17. SLA, REDUNDANCY AND CONTINUITY
RADAR EXYNAX targets an availability of 99.5% (ninety-nine point five percent).
The User acknowledges that instabilities in third-party AI models or global API outages may trigger continuity protocols, causing momentary variations in the analytical depth of reports. Such variations do not constitute contractual default.
18. DATA RETENTION AND PURGE POLICY
In compliance with LGPD/GDPR:
- Generated reports remain available to the User for 90 (ninety) days
- After this period, intermediate audit raw data is permanently deleted to ensure the privacy of those involved
- Only financial transaction log records are retained for a period of 5 (five) years, in accordance with legal obligations
19. AUDIT AND MONITORING
RADAR EXYNAX reserves the right to:
- Monitor traffic and access patterns to ensure compliance with these terms
- Conduct periodic audits on User systems to verify proper use of databases
- Immediately suspend access upon detection of anomalous behavior or violation of compliance clauses
20. JURISDICTION AND VENUE
These terms are governed by International Commercial Law.
Any disputes shall be resolved through arbitration in the city of Rio de Janeiro, Brazil, using internationally recognized arbitration rules.
DIGITAL ACCEPTANCE
By clicking "I Accept the Terms of Service" or by using the RADAR EXYNAX platform, the User declares that they have read, understood and fully agree with all clauses, conditions and policies described in this document.
The digital acceptance constitutes proof of free, informed and unequivocal consent for all legal purposes.