Millenia Capital Casa de Bolsa S.A.

RUC N° 80086402-6

This document supplements the current Master Services Agreement. It does not replace, amend, or limit it.

Last updated: July 8, 2026

www.milleniacapital.com.py | info@milleniacapital.com.py | +595 (21) 3385620

Av. General José Gervasio Artigas No. 1750, Go Tower Building, 19th Floor, Office 1901, Asunción, Paraguay



SCOPE, GOVERNING FRAMEWORK AND ORDER OF PRECEDENCE

These policies govern the general use of the website of Millenia Capital Casa de Bolsa S.A. and certain informational matters relating to privacy, payments, account funding, cancellations and refunds processed through enabled electronic channels.

They shall be construed in accordance with Law No. 7572/2025, “Securities and Products Market,” the General Securities Market Regulations approved by CNV CG Resolution No. 35/2023, as amended, the rules issued by the Superintendencia De Valores of the Central Bank of Paraguay, the Master Services Agreement in effect, and all other applicable laws and regulations.

In the event of any conflict or difference in interpretation, the Master Services Agreement, orders, forms, annexes, fee schedule, risk disclosures and other specific contractual documentation executed or accepted by the client, as well as any applicable mandatory laws and regulations, shall prevail.

I. TERMS AND CONDITIONS OF USE

1. Nature of the Website

The website is institutional and informational in nature. Its content does not, in and of itself, constitute a public offering of securities, a personalized recommendation, individualized advice, a promise of returns, or a commitment to execute transactions.

2. Client Onboarding and Services

Mere use of the website does not establish a contractual relationship or open an account. The provision of securities brokerage services is subject to evaluation, internal approval, due diligence, the client’s profile, applicable documentation, and the execution or acceptance of the Master Services Agreement in effect.

3. Information, Risks and Investment Decisions

Published information may be changed without prior notice and should be verified before any decision is made. Every investment involves risks, including the partial or total loss of invested capital, price risk, liquidity, credit, market, foreign-exchange, operational, and regulatory risk.

4. Electronic Payments and Account Funding

Millenia Capital may provide electronic channels for payments, account funding, commissions, fees or services. The receipt or crediting of funds does not constitute automatic approval of the client, acceptance of an order or transaction, or agreement to provide a service. All payments and account funding are subject to validation, reconciliation, availability, internal controls, source-of-funds verification, applicable laws and regulations, and the Master Services Agreement.

Millenia Capital may reject, suspend, return or reverse a payment or account funding transaction, or request additional information, if there are inconsistencies, errors, alerts, operational limits, regulatory restrictions or insufficient documentation.

5. Third Parties, Costs and Availability

Certain transactions or services may involve securities exchanges, custodians, depositories, financial institutions, technology providers, payment processors or other third parties. Millenia Capital shall not be liable for delays, failures, rejections, chargebacks, interruptions, costs or errors attributable to third parties beyond its direct control, except to the extent such liability is imposed by law.

Transactions and services may be subject to commissions, charges, taxes, fees, third-party costs and applicable expenses in accordance with the Master Services Agreement, fee schedules, documentation accepted by the client, and applicable laws and regulations.

6. Proper Use and Intellectual Property

The user shall use the website lawfully and refrain from interfering with its operation, security, content or systems. Texts, trademarks, logos, images, designs and documents on the website are owned by Millenia Capital or used with authorization. Any unauthorized use is prohibited.

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7. Amendments and Contact

Millenia Capital may update these policies and the website content whenever it deems necessary. The current version shall be the version published on the institutional website. For inquiries: info@milleniacapital.com.py.

II. PRIVACY AND PERSONAL DATA PROTECTION POLICY

1. Introduction

Millenia Capital recognizes the importance of protecting the privacy of its clients, users and visitors. This policy provides a general description of how it collects, uses, retains and protects personal information in connection with its activities as a securities brokerage firm.

2. Data That May Be Collected

Millenia Capital may collect only the data strictly necessary based on the type of user, client, service or transaction, including identification and contact data, address, economic, financial, corporate, tax, banking, operational and payment information, client profile data, source-of-funds information, and website usage data.

3. Purposes of Processing

The data may be used to respond to inquiries, assess applications to establish a business relationship, perform obligations under the Master Services Agreement, provide securities brokerage services, process and reconcile payments or account funding, comply with legal and regulatory obligations, manage or mitigate legal and operational risks, respond to requests from competent authorities, and improve the security and operation of the website.

4. Confidentiality and Sharing

Millenia Capital maintains the confidentiality of the information it receives. Personal data will not be sold or otherwise used for commercial purposes. It may be shared only when necessary to provide services, perform contractual obligations, comply with legal or regulatory requirements, process payments, conduct audits, obtain professional advice, respond to requests from a competent authority, or engage necessary third parties, and in all cases only to the extent required for the applicable purpose.

5. Security and Retention

Millenia Capital implements reasonable technical, administrative and organizational measures to protect information against unauthorized access, loss, alteration or improper disclosure. Data will be retained for as long as necessary to fulfill the stated purposes, maintain the contractual relationship, and comply with applicable legal, regulatory, accounting, operational and recordkeeping obligations.

6. Rights of Data Subjects and Cookies

Data subjects may request access to, updating, rectification or erasure of their personal data, or withdrawal of consent where permitted by law, without affecting Millenia Capital’s retention obligations. Requests may be submitted to info@milleniacapital.com.py. The website may use cookies or similar technologies to improve the browsing experience and analyze website usage.

III. REFUND AND CANCELLATION POLICY

1. Scope

This policy applies solely to payments, account funding, commissions, fees or services carried out through enabled electronic channels. It does not govern investment results, market fluctuations, redemptions, withdrawals, securities transfers, securities transactions, executed orders, or specific rights and obligations under the Master Services Agreement.

2. Requests

Any request for cancellation, reversal or refund must be submitted in writing to info@milleniacapital.com.py and include the information necessary to identify the payment, account funding transaction or service. Millenia Capital may require additional information before deciding the request.

3. Grounds for Refund or Reversal

A full or partial refund or reversal may be available in cases of billing errors, duplicate payments, services not provided, unapplied funds, or rejection of a payment or account funding transaction following the applicable controls. No refund or reversal shall be available for services already provided, transactions executed, orders placed in accordance with valid instructions, market losses or fluctuations, or non-recoverable costs, commissions, taxes or third-party expenses.

4. Timeframes, Chargebacks and Costs

Eligible refunds will be processed within reasonable timeframes and will be subject to internal validation, reconciliation, applicable laws and regulations, and the processing times of payment processors, banks or other participating third parties. In the event of chargebacks, payment disputes or claims of unauthorized transactions, Millenia Capital may submit documentation supporting the transaction, payment or service.

5. Contractual Order of Precedence

This policy is supplementary. In the event of any conflict, the Master Services Agreement, specific contractual documentation, market rules, the client’s valid instructions, and applicable laws and regulations shall prevail.