AML/CFT Policy

Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT Policy)

NUUVEM LTDA.
CNPJ: 17.126.332/0001-10
Address: Rua Lauro Muller, 116, Room 503 (part), Botafogo, Rio de Janeiro/RJ, ZIP 22290-160
Last Updated: February 2026

1. Institutional Commitment

1.1 Company Overview

NUUVEM LTDA., a company operating in the gaming industry and running a digital marketplace for the intermediation of electronic game licenses and digital content, conducts its business in accordance with the highest standards of integrity, transparency, and legal compliance.

1.2 Regulatory Framework

Nuuvem observes, in its operations, the principles and best practices established by Lei nÂș 9.613/1998 (Brazilian Anti-Money Laundering Act), Lei nÂș 12.846/2013 (Brazilian Anti-Corruption Act), Lei nÂș 13.709/2018 (Brazilian General Data Protection Law — LGPD), Lei nÂș 15.211/2025 (Brazilian Digital Child and Adolescent Protection Act — ECA Digital), the guidelines issued by the Financial Activities Control Council (Conselho de Controle de Atividades Financeiras — COAF), and the regulations issued by the Central Bank of Brazil (Banco Central do Brasil — BCB) applicable to foreign exchange transactions and cross-border payments.

2. Customer Registration and Identification (KYC)

2.1 Registration Process

Access to Nuuvem's services requires prior registration, through which the user provides the information necessary for their identification. The main controls applied at the registration stage and upon the first transaction include:

  • Single-registration rule per Brazilian Individual Taxpayer Registry number (CPF), with automatic blocking in the event of duplicate records.
  • Automated validation of registration data against official government databases at the time of the first purchase attempt.
  • Automatic blocking of registrations that are inconsistent with official records.
  • Supplementary Know Your Customer (KYC) checks applied by payment gateways duly authorized by Nuuvem.

2.2 Additional Documentation

Nuuvem reserves the right to request additional information and supporting documentation to confirm a user's identity, in accordance with its Terms of Use.

2.3 Age Compliance

The acquisition of content on the platform observes the applicable age rating classifications, in compliance with Lei nÂș 15.211/2025 (ECA Digital).

3. Transaction Monitoring and Customer Due Diligence

3.1 Continuous Monitoring

Nuuvem maintains continuous monitoring of its users' transactional behavior through automated mechanisms for detecting unusual activity and generating internal alerts. When patterns requiring further analysis are identified, the relevant accounts are subjected to enhanced Customer Due Diligence (CDD/EDD) procedures conducted by the compliance team, which may include, among other measures:

  • Screening against national and international restrictive lists, including sanctions lists and counter-terrorism watchlists.
  • Verification of Politically Exposed Person (PEP) status, as well as that of their family members and close associates.
  • Analysis of the user's profile and transactional history.
  • Identification of transactions conducted by third parties on behalf of the account holder, or transactions that are inconsistent with the user's profile.
  • A reasoned decision regarding the continuation, restriction, or termination of the business relationship.

4. Financial Flow Management and Accepted Payment Methods

4.1 Payment Gateway Operations

Nuuvem operates exclusively through financial institutions and payment gateways authorized by the Central Bank of Brazil, ensuring full transaction traceability. The payment methods currently accepted, all of which are subject to anti-fraud controls, are:

  • Credit card.
  • Pix (Brazilian instant payment system) and bank transfer.
  • Boleto bancĂĄrio (Brazilian bank-issued payment slip).
  • Authorized digital wallets (Google Pay, PicPay).
  • Nuuvem Wallet, a prepaid virtual wallet for personal, non-transferable use.

4.2 Payment Restrictions

Cash payments, electronically untraceable financial transactions, or any form of financing or credit extension for the acquisition of games are not accepted under any circumstances. In connection with its cross-border remittances, Nuuvem also does not permit the use of virtual assets (cryptocurrencies) for the settlement of obligations.

5. Data Sharing with Payment Gateways

5.1 Data Sharing Purposes

Payment processing requires the sharing of users' personal data with the payment gateways authorized by Nuuvem, exclusively for the following purposes:

  • Transaction processing.
  • Fraud prevention.
  • Suspicious transaction monitoring.
  • Payer identification.
  • Compliance with applicable anti-money laundering regulations.

5.2 Data Protection Compliance

Such sharing is fully compliant with Lei nÂș 13.709/2018 (LGPD), in particular the principles of purpose limitation, adequacy, necessity, security, and transparency. Payment partners are contractually required to implement technical and organizational measures consistent with the applicable data protection framework. Detailed information on the processing of personal data, processing purposes, and data subject rights is available in Nuuvem's Privacy Policy.

6. Position Regarding Cross-Border Payment and Transfer Services (eFX)

6.1 eFX Service Provider Status

Nuuvem operates exclusively as a customer of the foreign exchange market and of cross-border payment and transfer services (eFX). Nuuvem does not provide eFX services within the meaning of BCB Resolution No. 277 of December 31, 2022, as amended by BCB Resolution No. 561 of April 30, 2026. All cross-border remittances required in the course of Nuuvem's business are carried out through banking institutions duly authorized by the Central Bank of Brazil, subject to the applicable regulations and controls governing such institutions.

7. Access to the Full Policy and Contact Channels

7.1 Full Policy Availability

This public-facing version is provided for informational purposes only. The full version of the AML/CFT Policy, which sets out in detail the procedures, operational parameters, governance structure, and internal responsibilities, is maintained on a confidential basis and may be made available to partners, counterparties, and competent authorities upon request to the compliance team and, where applicable, following the execution of a non-disclosure agreement.

7.2 Contact and Reporting Channels

For inquiries, clarifications, or to request the full version of this policy, please contact us at legal@nuuvem.com or through our Help Center. Reports of unusual activity, suspected fraud, or whistleblower disclosures may be submitted to support@nuuvem.com.

This policy applies to Nuuvem Ltda. and its operations under Brazilian law.