1.1. Acceptance of these Terms

By accessing, browsing or interacting with Cortex's institutional website, with the support WebChat or with any relationship channel referred to herein, you declare that you have read, understood and agree to these Terms of Use.

Continued use of the website and the WebChat after these Terms are made available constitutes acceptance by affirmative action. When you start a conversation in the WebChat or submit a contact form, Cortex may record the date and time of the acceptance and of the interaction, for evidentiary and security purposes, in accordance with the Privacy Policy.

If you do not agree with these Terms, you must stop using the website and the WebChat.

1.2. What these Terms govern

These Terms govern your use of the following public environments of Cortex:

• the institutional website www.cortex.je, its pages, content and materials;
• the institutional WebChat for support and pre-sales, including when assisted by artificial intelligence;
• the contact forms and relationship channels (e.g., commercial email, meeting scheduling, request for materials);
• other institutional resources that Cortex makes publicly available on the website.

1.3. What these Terms do NOT govern

These Terms do not govern:

• the provision of the B2B SaaS service (Atena and Apolo agents, WebChat-only operation), which is governed by the Service Provision Agreement and its Annexes (Annex I, Plans; Annex II, SLA; Annex III, DPA; Annex IV, Public Policies; Annex V, Security White Paper) entered into with each corporate client;
• the interaction of end users with the WebChat embedded in the product or service of a B2B client of Cortex, in which case the client is the Controller of the data and responsible for the relationship with that end user (see Section 8). These Terms apply to such interaction only on a subsidiary basis and to the extent of the technological services provided by Cortex.

1.4. Use scenarios (who you are)

These Terms consider, in a non-exhaustive manner, the following profiles of use of the institutional website and WebChat:

• Institutional visitor: you access Cortex's website and/or WebChat as an interested party, lead, partner, journalist, candidate or member of the general public, without an active contractual relationship;
• Representative of a B2B client or prospect: you represent a company that is or intends to become a Cortex client and use the website/WebChat for commercial, pre-sales support or relationship purposes;
• Embedded end user (subsidiary use): you interact with Cortex technology (WebChat) within the product or service of a B2B client. In this case, the terms and privacy policy of the B2B client, which is the Controller, prevail (see Section 8).

1.5. Related terms and policies

The following complement these Terms, when available on Cortex's official website:

• Privacy Policy (LGPD);
• Cookie Policy (LGPD);
• Information Security Policy;
• transparency notices about artificial intelligence displayed in the WebChat itself, when available;
• other notices and guidance displayed in the website environment itself.

In the event of a conflict between documents: in the relationship with a B2B client, the Service Provision Agreement and its Annexes prevail; in other cases, the most specific document for the matter shall prevail, adopting an interpretation in accordance with the applicable Brazilian legislation.

2.1. Cortex

SLB Consultoria em Tecnologia da Informação LTDA, maintainer of the institutional website and of the support WebChat, and B2B supplier of WebChat-only conversational AI technology.

2.2. Institutional website

The website www.cortex.je, its pages, content, materials, forms and public resources.

2.3. Institutional WebChat

Conversation channel made available on Cortex's website for support, questions and pre-sales, which may be assisted by artificial intelligence and/or by human support.

2.4. AI Assistant

Layer of the WebChat that uses artificial intelligence (including third-party language models, such as LLM providers) to answer questions and support institutional service. The AI Assistant is informative, may generate inaccurate responses and does not replace professional advice or a formal commercial proposal.

2.5. Visitor / user

A person who accesses or interacts with the institutional website and/or with Cortex's WebChat under the terms of Section 1.4.

2.6. Content submitted by you

Messages, questions, contact data, attachments and other information that you enter in the WebChat, in forms or in Cortex's relationship channels.

2.7. Technical data

Data necessary for operation and security, such as IP address, date and time records, session identifiers (chat Session ID), user agent, browser, device, operating system, pages visited, performance events and security logs, as detailed in the Privacy Policy.

2.8. Personal data

Information related to you that identifies you directly or indirectly, in accordance with the Lei Geral de Proteção de Dados, LGPD (Lei nº 13.709/2018).

2.9. B2B client

A legal entity that contracts Cortex's SaaS services through the Service Provision Agreement. This concept belongs to the B2B contract and is cited here only for context; except for the distinction of privacy roles (Section 8), it creates no rights or obligations for you, the institutional visitor.

2.10. Agreement

The Service Provision Agreement (B2B SaaS) of Cortex and its Annexes, which governs the relationship with corporate clients and prevails over these Terms in that relationship.

3.1. What the institutional website and WebChat do

Cortex's institutional website and WebChat allow you to:

• get to know Cortex, its products (the Atena and Apolo agents) and its WebChat-only conversational AI solutions;
• consult institutional content, materials and public information;
• ask questions through the WebChat, assisted by AI and/or human support;
• request commercial contact, materials or meeting scheduling via the WebChat or forms.

3.2. Informative nature of the institutional WebChat

The institutional WebChat is a channel for information and relationship. You understand and agree that:

• the responses of the AI Assistant are informative and indicative in nature, given the probabilistic nature of the technology, and may contain errors, inaccuracies or outdated information;
• information about plans, prices, deadlines, SLAs, scope and commercial conditions presented on the website or in the WebChat is merely indicative and does not constitute a binding offer. The official commercial conditions are set out in a formal proposal and in the Agreement entered into between the parties;
• no WebChat response (whether from AI or a human) creates, by itself, a contractual bond, a service provision obligation or an acquired right.

3.3. Limits of the AI Assistant

The AI Assistant of the institutional WebChat does not:

• provide legal, regulatory, financial, accounting or specialized technical advice;
• issue a binding professional opinion or assessment;
• replace the analysis of a qualified professional, of Cortex's commercial or legal team;
• guarantee the accuracy, completeness or timeliness of the information generated.

For relevant decisions, in particular contracting, compliance, iGaming, responsible gaming, data protection and security, you must confirm the information directly with the Cortex team through the official channels (Section 13) and, when applicable, with your own advisors.

3.4. Availability

The website and the WebChat may become unavailable due to maintenance, technical instabilities, third-party dependencies (hosting, AI/LLM providers, CDN) or the connectivity of your device. Cortex makes commercially reasonable efforts to keep them available, with no guarantee of uninterrupted availability (see Section 9).

4.1. Acceptable use

You must use the website and the WebChat only for lawful purposes that are compatible with their institutional, informative and relationship purpose.

4.2. Prohibited conduct

The following is prohibited, by way of example:

• attempting to break into, exploit flaws in, compromise or overload the website, the WebChat or Cortex's infrastructure;
• performing reverse engineering, decompiling or attempting to extract models, prompts, flows, internal rules, system prompts or parameters of the AI Assistant, including through prompt injection, jailbreak techniques or induction to reveal system instructions;
• automating access, generating artificial load, or using robots, crawlers, scrapers or scripts for data scraping, systematic collection or unauthorized indexing of content;
• circumventing controls for security, authentication, rate limiting or stability;
• inserting or transmitting illegal, offensive, discriminatory, threatening, defamatory or malicious content (including malware), or content that violates the rights of third parties;
• inserting personal data of third parties without authorization or unnecessary sensitive data;
• using the website, the WebChat or their content to develop, train or improve a competing solution to Cortex;
• using Cortex's trademarks, content or visual identity to mislead third parties, create fake pages, phishing or redirects simulating Cortex.

4.3. Care with the content you insert

You must avoid inserting, in the WebChat or in forms, unnecessary passwords, codes, banking data, payment data, personal documents or sensitive personal data. If you insert unnecessary data, Cortex will process it only to the extent strictly necessary to operate the channel, maintain security and comply with legal obligations, seeking minimization and disposal when possible, in accordance with the Privacy Policy.

4.4. Protection measures

In the event of abuse, risk or violation of these Terms, Cortex may, to the extent permitted by law, apply immediate measures to protect the website, the WebChat and third parties, including limiting interactions, terminating sessions, blocking access by technical identifiers, removing content and cooperating with authorities when there is a legal obligation.

5.1. Responsibility for content

You are responsible for the Content submitted by you and for any misuse. You declare that you hold the necessary rights over the content you insert and that you will hold Cortex harmless from damages arising from illegal content that you insert or from the violation of third-party rights committed by you.

5.2. Limited license to operate the channel

You grant Cortex a limited, non-exclusive and revocable license to use the Content submitted by you only to: (i) operate and respond to the service; (ii) maintain quality, security and stability; (iii) prevent abuse and fraud; (iv) carry out technical audits; and (v) comply with legal obligations.

5.3. Use of content for improvement and AI

For service improvement purposes, Cortex will use only previously anonymized/de-identified and aggregated content, in line with the Privacy Policy. Identifiable content of visitors will not be used to train AI models without an adequate legal basis. As for B2B client data, the prohibition on use for training set out in the Agreement and in the DPA applies.

5.4. Moderation

Cortex may moderate interactions in the WebChat to protect users, the platform and third parties, including by limiting, terminating or blocking abusive interactions and recording technical events for security and audit purposes.

6.1. Cortex's rights

The website, the WebChat and their components are protected by intellectual property rights. Your use does not transfer any right over:

• software, code, interface, layout and visual identity;
• AI models, logic, flows, prompts, system prompts and the Assistant's system texts;
• trademarks, names, logos, content, materials and documentation of Cortex.

6.2. License of use

You receive a limited, revocable, non-exclusive and non-transferable license to access and use the institutional website and WebChat only for informative and relationship purposes, in accordance with these Terms.

6.3. Third-party content

Trademarks, names and content of third parties that may be displayed on the website belong to their respective holders and are used in accordance with authorization or legal provision.

6.4. Intellectual property in the B2B context

Cortex's ownership of the AI engine, proprietary prompts, models, flows and other components of the service, as well as the allocation of rights over AI outputs in the context of the contracted provision, are governed by the Agreement (including its intellectual property clauses). These Terms do not expand or reduce those rights.

7.1. Reference to the Privacy Policy and the Cookie Policy

The processing of personal data related to the website, the WebChat and the forms is described in detail in Cortex's Privacy Policy (LGPD) and Cookie Policy (LGPD), to which these Terms refer and which they incorporate for data protection purposes.

7.2. Cortex's role (Controller / Processor)

The identification of Cortex's role follows the same rule as the Privacy Policy:

• Institutional context (Cortex as Controller): when you directly use Cortex's institutional website or WebChat, Cortex is the Controller of the navigation, support and relationship data (e.g., technical data, chat content, contact forms, optional marketing and relationship, subject to the applicable legal basis);
• Embedded context (Cortex as Processor): when you use the WebChat embedded in the product or service of a B2B client, the B2B client is the Controller and Cortex acts as Processor, processing data in accordance with contractual instructions and the DPA. In this case, the Agreement and the DPA entered into with the client prevail.

If you have any doubt about Cortex's role in your case, contact dpo@thecortex.digital; the request will be forwarded to the correct Controller in accordance with the deadlines of the Privacy Policy.

7.3. Cookies

The website and the WebChat use cookies and similar technologies for operation, security, preferences, measurement and, subject to consent, marketing. You may accept, reject or configure preferences through the banner and Preferences Center, respecting essential cookies, in accordance with the Cookie Policy.

7.4. Automated decisions

On the institutional website and the public WebChat, Cortex does not make solely automated decisions that produce legal effects on visitors. Automated flows with relevant effects on the data subject occur only in the B2B context, under the instruction of the Controller client, with the right to review by a natural person ensured (art. 20 of the LGPD), in accordance with the Privacy Policy.

7.5. Your rights and the evidentiary value of records

You may exercise the data subject rights provided for in the LGPD in accordance with the Privacy Policy (channel: dpo@thecortex.digital). The records kept by Cortex, including logs of acceptance of these Terms, display of notices and technical logs of the WebChat, may be used as evidence in judicial or administrative proceedings, under the terms of the Marco Civil da Internet (Lei nº 12.965/2014) and procedural legislation.

8.1. Institutional visitor

When you interact with the website or the WebChat of Cortex itself (at www.cortex.je), you are an institutional visitor, Cortex is the Controller of your data and these Terms apply in full to your interaction.

8.2. Embedded end user

When you interact with the WebChat embedded in the product, website or channel of a B2B client of Cortex (for example, an iGaming operator that uses the Atena/Apolo agents):

• the B2B client is the Controller of your data and responsible for the consumer relationship, the content, journeys and regulatory compliance (including iGaming and responsible gaming rules);
• Cortex acts as Processor, providing the technology in accordance with the Agreement and the DPA;
• the terms of use and privacy policy of the B2B client apply to you on a priority basis; these Cortex Terms apply only on a subsidiary basis and to the extent of the technological services provided by Cortex;
• requests regarding your data in this context must be directed to the B2B client (Controller); if directed to Cortex, they will be forwarded to the correct Controller.

8.3. Persons over 18 years of age and iGaming

The institutional website and WebChat are not intended for minors under 18 years of age and do not promote or enable betting. Cortex is a technology supplier; the content, journeys and compliance of iGaming operations are the exclusive responsibility of the B2B client Controller, under the terms of the Agreement. The processing of data of children and adolescents complies with art. 14 of the LGPD, in accordance with the Privacy Policy.

9.1. Nature of the website and the WebChat

The institutional website and WebChat are digital tools for information and relationship, and the AI Assistant is an informative resource based on probabilistic technology. You acknowledge that:

• the responses of the AI Assistant may be inaccurate, incomplete or outdated, and do not constitute professional advice or a binding offer (Section 3);
• commercial information (plans, prices, deadlines, SLAs, scope) on the website/WebChat is indicative; the conditions of the formal proposal and of the Agreement apply;
• Cortex does not control the connectivity of your device or third-party services used in the delivery of the website/WebChat (hosting, CDN, AI/LLM providers).

9.2. Limitation of liability

To the maximum extent permitted by the applicable Brazilian legislation:

• Cortex is not liable for indirect damages, loss of profits, loss of opportunity, loss of data by third parties or consequential damages arising from the use or the impossibility of using the institutional website or WebChat;
• Cortex is not liable for connectivity failures, unavailability of internet, power or third-party services outside its reasonable control;
• Cortex is not liable for decisions that you make based solely on informative responses of the AI Assistant, without confirmation through the official channels;
• Cortex is not liable for misuse of the website or the WebChat by you or by third parties.

Nothing in these Terms excludes or limits liability in situations in which the law does not permit exclusion or limitation. When the consumer relationship is applicable, these limitations comply with the Consumer Defense Code, without preventing the redress of directly suffered damages that are duly proven; in the event of a conflict, the more protective legal rule prevails.

9.3. Liability in the B2B context

Cortex's liability towards B2B clients and towards embedded end users is governed by the Agreement (including limitation of liability, cap, allocation of risk by third parties and indemnities) and by the DPA, prevailing over these Terms in that relationship.

9.4. Reasonable expectation of service

Cortex will make commercially reasonable efforts to keep the website and the WebChat available and secure, with no guarantee of uninterrupted availability or of result, to the maximum extent permitted by the applicable legislation.

10.1. Suspension for violation

If you violate these Terms, especially in cases of intrusion attempts, scraping, reverse engineering of prompts, overload, fraud or phishing simulating Cortex, Cortex may suspend or block your access immediately, to the extent permitted by law, without prejudice to the applicable legal measures.

10.2. Unavailability

The website and the WebChat may be suspended, in whole or in part, for maintenance, security fixes or due to third-party dependencies, without this constituting a breach by Cortex.

11.1. Updates and effect

Cortex may update these Terms to reflect changes in the website/WebChat, legal requirements or security improvements. The version in effect will always be the one made available on the website, with the update date.

When the change is material, Cortex will present a highlighted notice on the website before it takes effect. Continued use after it takes effect constitutes agreement with the new version; those who do not agree must stop using the website and the WebChat.

12.1. Applicable law

These Terms are governed by the laws of the Federative Republic of Brazil.

12.2. Jurisdiction

The courts of the District of São Paulo/SP are elected to settle disputes arising from these Terms, except, when the consumer relationship is applicable, for the jurisdiction of the consumer's domicile, under the terms of the applicable legislation.

12.3. Relationship with the B2B Agreement

For the relationship with B2B clients, the resolution of conflicts follows the Service Provision Agreement, which provides for mediation and arbitration (CAMARB or CAM-CCBC, headquartered in São Paulo/SP) and the jurisdiction of São Paulo/SP for urgent measures and enforcement of the arbitral award. In the event of a conflict with these Terms in that relationship, the Agreement prevails.

13.1. Contacts

• Legal: legal@thecortex.digital
• Privacy / DPO: dpo@thecortex.digital
• Security: security@thecortex.digital

13.2. Severability

If any provision of these Terms is deemed invalid, illegal or unenforceable, the remaining provisions will remain in full effect.

13.3. No waiver

Any tolerance regarding the breach of any obligation will not constitute a waiver of right nor prevent its subsequent exercise.

13.4. Integration with the policy package

These Terms, together with the Privacy Policy, the Cookie Policy and the Information Security Policy, make up the package of Public Policies of Cortex referenced in Annex IV of the Agreement. In the relationship with B2B clients, in the event of a conflict, the Agreement prevails.