1. Our marketplace and borrowers.

At Howlett Capital SA we provide an alternative financing market (the "Marketplace") via the Website that facilitates participation by our investor clients ("Investors") in loans granted to companies in Costa Rica.

The credits that we publish in our Marketplace are exclusively credits granted to small and medium-sized companies in Costa Rica and physical persons ("Borrowers").

2. The role of howlett capital SA

It should be expressly noted that we do not provide the credits, exclusively performing the following services and other services stipulated or referred to in these Conditions (our "Services"):

  1.  (a) We mediate in the granting of loans and loans through promissory notes to small and medium-sized Costa Rican companies;
  2. (b) We provide our Investors with facilities to acquire shares in credits;

3. In order to operate in our Marketplace you must accept these Conditions, so you confirm that:

  •  (a) It is an individual, a commercial company, a foundation, or a public organization;
  •  (b) If you are a natural person, (i) you are 18 years of age or older and are capable of assuming responsibility for your own actions if you wish to invest through Howlett Capital SA or. is in permanent resident conditions;
  • (c) If it is a commercial company, it is duly registered. or (d) If it is a foundation, be duly registered
  • (e) You have a valid account in a Costa Rican bank in your name;
  • (f) You have the legal capacity to contract and enter into a legal agreement with us;
  •  (g) Is the person whose details have been provided in the application for your Howlett Capital SA Account ("Howlett Capital SA" or "Account") during the registration process;
  • (h) You will not allow any other person to invest money via your Account;
  • (i) You agree to use our Services only for the purpose of acquiring credits in the manner contemplated by these Conditions;
  • (j) You agree that you are responsible for any taxes, fees or duties arising from your use of our Marketplace;
  • (k) You agree to use the services and contents of the Website in accordance with the Law, these Conditions, the conditions of use and the particular conditions of the services offered by Howlett Capital SA at all times.

4. Important information about the risks associated with participating in our Marketplace.

By accepting these Conditions and / or using our Services, you confirm that you understand and accept the risks associated with acquiring and / or having participations in credits through our Marketplace, including, among others, the following:

  • (a) While we advise investors to diversify their investments among multiple credits, each of these, treated individually, carries a certain risk of not obtaining the expected return, in the event that the borrower could not meet its obligations of payment (partially or completely). In addition, the value of a loan can decrease or increase. Therefore, you may get less of your borrowed capital;
  • (b) Howlett Capital SA is not an investment services company or credit institution; and is not attached to any investment guarantee fund or deposit guarantee fund;
  • (c) The credits published on our website are not subject to authorization or supervision by any National Commission of financial markets or by any bank or state entity, therefore the information provided on the credits has not been reviewed by them. Howlett Capital SA is a participatory financing platform authorized for the development of the activities provided for in articles 15 and 15bis of Law 7786
  • (d) Compared to loans rated “investment grade”, loans to SMEs have a higher risk of default or variation in value due to changes in circumstances or in the credit quality of the borrower.
  • (e) The credits are not insured or guaranteed by the Guarantee Fund or any other state entity;
  • (f) Fixed income investments (such as loans) are particularly affected by inflation.
  • (g) The value of a loan may vary when making a purchase in the secondary market
  • (h) The figures referring to expected returns and losses quoted on our Website are merely indicative and are not guaranteed. Said actual expected returns and losses may be higher or lower than said figures;
  • (i) Howlett Capital SA is not responsible at any time for the loss of value, or complete loss in its case, of the value of a loan.

5. Information on the services of Howlett Capital SA

Howlett Capital SA aims to carry out the following activities, among others:
  • (a) The reception and selection of credit applications;
  • (b) Advice to borrowers in relation to the granting of loans, including the provision of services and advice in the areas of information technology, marketing, advertising and design, finance, accounting;
  • (c) The analysis of the borrowers and loan applications, the determination of the level of risk that each possible loan implies;
  • (d) The development, establishment and exploitation of communication tools and channels to facilitate the granting of credits;
  • (e) The development, establishment and exploitation of communication tools and channels so that Investors can value the credits published on our website, acquire shares in credits and keep track of their shares made in credits;
  • (f) The making available to the parties of the model contracts necessary for the granting of credits and the subsequent sale of shares in the credits to Investors;
  • (g) The transmission to Investors of the information provided by the Borrower on the evolution of its business, as well as on the most relevant corporate events; Y
  • (h) The judicial and extrajudicial claim of the credit rights, acting on behalf of the Investors or on their own behalf if the Investors assign their credit right.

It should be expressly noted that Howlett Capital SA does not act as a borrower under any Credit agreement, despite having third party rights under these agreements as administrator.

We will not perform any investment management functions on your behalf. You maintain complete control and discretion over whether or not you want to participate in a credit, as well as over the management of any participation in credits that you acquire or maintain through our Marketplace.

The services we provide on advice or recommendation regarding a particular loan or to make any decision in relation to a share in credit acquired or maintained through our Marketplace are personal criteria of each executive based on their experience and academic education, not You may commit Howlett Capital SA for any inconvenience that these services present, the investor will always have full responsibility for your investment.

We provide each credit with a risk rating, based on the information included in the Borrower's request and the results of checks carried out by external sources, such as credit reference databases. The liability of Howlett Capital SA for this risk classification is limited.Therefore it is important that you form your own opinion in relation to the creditworthiness of a Borrower and that you carry out your own investigation, analysis and evaluation of the Borrower in question and, in if necessary, seek your own independent financial advice.

Howlett Capital SA is not responsible for all information from outside sources.

6. Information about the credits published in our Marketplace.

All credits are carefully reviewed by our credit team, which assigns a risk classification to the requested credit based on Howlett Capital SA's internal risk classification system.

When a credit is published on our Marketplace, we create an online tab regarding the credit (a “Tab”), which summarizes key information about the credit and the Borrower and which investors can review on our Marketplace.

7. The loan auction process.

The auction of a loan will be open during the period established for the auction (“auction period”).

There is no maximum or minimum period established for the auction process. The auction period contemplated for a certain credit will be specified in the corresponding file, but we reserve the right to reduce or increase this period.

We also reserve the right to suspend or withdraw any auction at any time and for any reason.

There are no requirements for a loan auction to be fully subscribed. Acquisitions of shares in a loan by different investors will be completed independently.

If Howlett Capital SA becomes aware of a material and adverse change in the specific circumstances of the Borrower, it will suspend the auction of the loan in question. However, the offers made before the suspension will be completed unless the investor has canceled it before the acquisition of its participation has been completed.

8.Our authorization to complete the acquisition of credit shares on your behalf.

By accepting these Conditions, you designate Howlett Capital SA as your agent or representative with the authority to:

  • (a) Communicate to the relevant counterparties all the offers that you make through our Marketplace;
  • (b) Complete transactions, on your behalf and on your behalf, including the execution and / or formalization on your part and on your behalf of all contracts or other documents necessary to complete the transactions you have carried out through our Marketplace. These contracts and documents may include (but will not be limited to): a transfer contract effecting the transfer with respect to the participation of the credit in question and any guarantee or other collateral related thereto.

These contracts and documents may include (but will not be limited to): a transfer contract effecting the transfer with respect to the participation of the credit in question and any guarantee or other collateral related thereto.

Transfers will be formalized according to our Transfer Terms and a confirmation of each transfer will either be sent to your email or will be available at your Howlett Capital SA

The moment you register as an investor, you will be asked to accept our Standard Contracts. You must tacitly accept this document by checking a box when prompted, once you have read and accepted it.


The corresponding Credit Agreement will regulate the principal and interest payments with respect to a Credit. Howlett Capital SA is responsible for coordinating the collection of said payments, which will be assigned to investors in proportion to the amount and duration of each investor's participation in the Credit.

The principal and interest payments received with respect to each credit in which you participate will be credited to your Destination Account and can be viewed on the My Account page.

Each credit in which it participates will be under the conditions and for the period specified in the corresponding credit Agreement.

Howlett Capital SA will send you annually, and as a summary, a list of the principal and interest payments that you have received and the amounts that have been withheld and deposited.


You can check your loan portfolio through your Howlett Capital SA Account

Under the terms of our Standard Credit Agreements, each Borrower agrees that, during the term of the Credit, certain key information will be provided to us (in turn) that enables us to monitor the Borrower's financial situation. See our Standard Credit Agreements for more details on the information our borrowers agree to provide.

We undertake to update the File for each loan to reflect all significant information that we receive from the Borrower in accordance with their corresponding loan agreement.

In relation to each credit in which you participate through our Marketplace, you designate us, by these conditions, as your agent with the authority to:

  • (a) Request and receive information from the Borrower in relation to the credit in accordance with the corresponding Credit Agreement;
  • (b) Exercise on your part all your rights, in the broadest aspect, under the Credit Agreement related to the Credit.


We promise to provide the following information in your Howlett Capital SA Account on our Website:

Available balance

  • (a) The available balance in your Howlett Capital Account; Offers and acceptances
  • (b) All offers that you have made and their status (pending, accepted or rejected); Participations in credits
The following information in relation to each participation in credit that you have at any given time:
  • (c) The amount of the principal of the loan and its participation in the Credit;
  • (d) Interest received and paid to your Howlett Capital SA Account with respect to the Credit;
  • (e) Basic information regarding the credit and the Borrower (our standard “Credit Card”);
  • (f) Our Credit Rating;
  • (g) Details of any non-payment of principal or interest with respect to the loan with a non-payment period of more than 7 days, together with a description of the actions taken with respect to the non-payment;
  • (h) Details of any incident with respect to the Credit, of which we are aware in each case and moment, together with our opinion about the seriousness and possible consequences of said incident.


You agree that if a Borrower defaults on a payment in respect of a loan in which you have an interest, or is in default:

  • (a) We may, on your behalf, take the necessary administrative steps set out later in this section;
  • We can act externally and / or in advance of this process to recover defaulted payments or credits (whether formally delinquent or not) in which we consider acting in favor of investors.

Late payments

If a Borrower defaults on a payment, or only partially pays an overdue amount, we (by our means or through an agent acting on our behalf) will contact the Borrower to request that they proceed to make the pending payment as soon as possible. If our attempts to recover the outstanding payment are unsuccessful within 5 business days after the original due date, the credit will be treated as overdue and we will continue to attempt to recover the payment. We may assign the file to a collection agency that attempts to recover the money from you and from other investors (and you authorize us to designate such a collection agency in the way we deem appropriate on your part (a "Recovery Agency"). Any fees or costs incurred during the recovery of late payments will be borne by the relevant Borrower and will not reduce the amount available for distribution to investors.


If a Borrower defaults or does not pay, or only partially pays one or more installments, or if the Borrower defaults in any other way a Credit Agreement, and we also consider that the recovery of the total amount of the outstanding debt is unlikely, the credit may enter in default and we could ask a Collection Agency to try to recover the total outstanding amount of the Credit. A Collection Agency normally charges a fee of up to 25% of the amounts recovered, along with the corresponding VAT. These fees will be borne by the relevant Borrower, so as not to reduce the amount available to distribute to investors. However, in circumstances where only a partial recovery is made from the Borrower, the fees of the Collection Agency will be deducted from the amounts recovered and the remaining amounts obtained will be distributed among investors.

If an amount is still unpaid after taking these steps, we:

  • (a) We will calculate (with advice where appropriate) the probable amount that could be successfully recovered through the courts;
  • (b) In the event that we consider it appropriate and necessary:
    • (i) We will engage legal claims attorneys on your behalf to recover the debt.
    • (ii) We will agree on your behalf to renegotiate the loan with the Borrower, which may include an extension of the payment terms.
    • (iii) We will sell the credit on your behalf to a third party (the third party will not have any connection with Howlett Capital SA or any of its subsidiaries or its directors or employees).
  • (c) We will pay all the amounts recovered to investors with shares in the Credit, after deducting the costs and expenses incurred during the process. In doing so, we will always act fairly and equitably to achieve the maximum recovery for all affected investors.

Recovery of amounts in arrears

We will keep you promptly informed about the progress of our efforts to recover any defaulted payments. All progress updates can be viewed from your Account.

When there is a delay of more than 30 days with respect to an entity that is debtor under more than one credit published in our Marketplace, any amount recovered from said debtor will be distributed among the investors of all relevant credits proportionally to the nominal value of their participation, on the entire outstanding principal of the relevant credits. For the purposes of this section, a loan will no longer be considered in arrears if (i) the amount in arrears has been fully satisfied (including ordinary and delinquent interest) or (ii) if a debt restructuring agreement has been entered into with the debtor, as long as the latter does not breach the terms thereof.


In relation to the credits in which you participate in our Marketplace, you hereby accept that we can on your behalf and on your behalf:

  • (a) Subcontract the recovery of defaulted payments by the relevant Borrower (to a Howlett Capital SA company or any other collection agent that we may choose from time to time) in accordance with the recovery procedure;
  • (b) Authorize any person to act on your behalf with respect to any credit and any related security or collateral;
  • (c) Make any decision and take any action or refrain from taking any action in relation to the administration or recovery of any Credit, including: (a) the initiation of any enforcement action or legal process against a Borrower or guarantor;
  • (b) waiving any security before all principal and interest owed to you have been returned.
You agree that the costs and expenses of any recovery action will be paid with the amounts recovered. You will only be liable for the payment of such recovery costs to the extent that such costs cannot be recovered from the relevant Borrower.

14. Howlett Capital SA's fees and other charges.

In consideration of our services provided, we apply the following fees with respect to credits provided through our Marketplace (our "Charges"):

With respect to the Borrowers:
  • (a) We charge each Borrower a fee for the analysis and management of the credit from a 5% to a 10% for the principal amount only once, being able to establish a minimum rate agreed between the parties.
  • (b) We charge the borrowers a management fee for unpaid loans in those cases in which the borrower has not satisfied the payment of the loan by the due date, for which a fee of 10% 0 20% of arrears is applied. which is fixed as a commission for the claim of non-payment.
  • (c) All fees invoiced to the Borrowers for the services rendered will include their corresponding VAT.
Regarding Investors:
  • (a) Currently we do not charge for acquiring participations in credits;
  • (b) As of the 3rd investment, we will begin to charge a commission based on the annualized net return of your loan portfolio, from the date of your first investment:
    • (i) Said commission will be a maximum of 0.5% until 1% and will be charged to the extent that said net return (after losses and after this commission, but before taxes) exceeds a certain threshold determined (initially set at 4% ), at the time of calculation.
    • (ii) This commission is payable monthly.
We recover the charges and expenses of third parties with respect to our credits as follows:
  • -We recover from the relevant borrowers all the expenses incurred in relation to the opening, administration or recovery of a Credit, for example (i) notary fees and expenses and (ii) the charges and expenses of any third party designated to recover defaults.
  • -In the event that a Borrower does not pay these charges and expenses, they will be deducted from any recovery made from a Borrower with priority to any distribution of principal or interest to investors. We reserve the right to modify our Charges and the bases on which we recover external charges and expenses.

15. Unsubscribe from Howlett Capital SA

If you no longer wish to be a client of Howlett Capital SA, and as long as you do not have participations in outstanding credits, you can let us know and we will cancel you. We have the right to unsubscribe at any time and for any reason, including but not limited to, if:

  • (a) You violate any of these Conditions.
  • (b) You violate a Credit Agreement;
  • (c) We suspect that you have committed fraud, are involved in money laundering or other criminal activities;
  • (d) There is no activity on your Howlett Capital SA Account for a period of 12 months. After cancellation, we will credit your Registered Bank Account with the funds remaining in your Account or we will send a nominative check to the last address you have provided.
All disclaimers, indemnities and exclusions in these Conditions will survive the termination of our Agreement.

16. Our responsibility for risk analysis and information that we provide you with respect to borrowers and credits.

Our risk analysis and classification processes

We assign a risk classification ("Rating") to each credit published in our Marketplace. This Rating is based on:
    • Information provided by the Borrower;
    • Information obtained from third party sources, for example external databases of credit references.

In our rating system, you will find a description of our current risk analysis processes and our rating methodology. These are subject to change from time to time and may vary for credits of different types and duration.

Our responsibility to you for our Ratings

We promise to use due rigor and diligence in determining the Rating of each credit included in our Marketplace.

We will periodically review each Rating.

Our responsibility to you for other information regarding borrowers and credits

With the exception of their Rating, each Borrower is responsible for the accuracy and completeness of the information displayed on the Website in relation to the Borrower and the credits published in our Marketplace ("Borrower Information"). This responsibility is manifested by the Borrower in the corresponding Credit Agreement.

We are committed to employing due diligence to avoid any errors in Borrower Information. In any case, you expressly agree that:

  • (a) We will not be responsible for the accuracy or completeness of any Borrower Information, except to the extent that an inaccuracy or incompleteness of such information is due to negligence on our part;
  • (b) Except for our Ratings, we will not be liable for the financial condition or credit risk of any Borrower or its ability to pay any amount it has incurred to pay. We will periodically amend the Borrower Information available on our Website to reflect the significant information we receive regarding a Borrower or Credit.

17. Other limitations on our liability.

You agree that all investment activities you conduct through our Marketplace are done entirely at your own risk.

Likewise, you accept that our liability to you in relation to these Conditions, your status as a registered user of Howlett Capital SA and the use of our Services will be limited to any amount not recovered with respect to the participations in credits that you have acquired through our Marketplace.

Limitations on our liability for other information on our Website

The information that we provide on our Website regarding possible expected loss or delinquency in credits is provided for guidance purposes and is not guaranteed.

The information we provide on our Website does not constitute an endorsement of any credit or Borrower.

We will not be responsible for content on our Website that has been downloaded or posted by investors or borrowers, nor do we edit content of this type.

We do not assume any responsibility for the discrepancies that may exist between the printed documents and the electronic version published on the Website. In the event of a discrepancy between the printed version and the one published on the Website, the printed version will prevail.

Our Website may contain links to other websites. We do not accept responsibility or liability for materials supplied or contained in any third party website that is linked from our Marketplace, or any use of personal data by that third party.

Overwhelming force

We will endeavor to provide you with uninterrupted access to our Website and Marketplace. However, we reserve the right to suspend, restrict or terminate your access at any time.

We will endeavor to provide you with uninterrupted access to our Website and Marketplace. However, we reserve the right to suspend, restrict or terminate your access at any time.

We are not responsible for any damages that may be caused to users by improper use of the Website.

We do not guarantee the availability and continuity of the operation of the Website or of those other websites with which a link has been established. Likewise, we will not be responsible for any damages that may arise from:

  • (a) The lack of availability or accessibility to the Website or to those other sites with which a link has been established;
  • (b) The interruption in the operation of the Website or computer failures, telephone breakdowns, disconnections, delays or blockages caused by deficiencies or overloads in the telephone lines, in the Internet system or in other electronic systems produced in the course of its operation ;
  • (c) The lack of suitability of the Website for the specific needs of users; or
  • (d) Other damages that may be caused by third parties through unauthorized interference beyond the control of Howlett Capital.

We will not be responsible for any loss or damage that you may suffer due to: natural disaster; electricity cut; trade or labor dispute; breach or omission of any government or authority; obstruction or failure of telecommunications services; or any other delay or failure caused by a third party. In such case, we reserve the right to cancel or suspend our services without incurring any liability.

Exclusion of special losses We will not be responsible for any:
    • (a) Loss of operations, loss of data, loss of contracts or loss of customers;
    • (b) Increased costs and / or expenses; me
    • (c) Any type of special, indirect or consequential loss;
In each case including such losses and damages suffered by you as a result of any action caused by a third party, even if such loss was reasonably foreseeable.

18. Use of our Services.

We provide our clients with support services (i) by email and (ii) by phone. However, you are responsible for understanding the contents and operation of these Conditions and of our Website. We reserve the right to change the format of our Website or our Services at any time and we reserve the right to record all telephone calls to Howlett Capital SA and to track all information related to our clients' accounts, for which purpose purpose you consent in accordance with the requirements of the applicable legislation.

You expressly accept never and under no circumstances:

  • (a) Register with Howlett Capital SA more than once;
  • (b) Register with Howlett Capital SA on behalf of any other individual than you, or with a false identity;
  • (c) Register with Howlett Capital SA on behalf of any entity without the prior written authorization of the entity;
  • (d) Impersonate any other person or entity, or falsely state or otherwise misrepresent your identity, age, personal circumstances, or affiliation with any person or entity
  • (e) Using or attempting to use another person's Howlett Capital SA Account without our authorization;
  • (f) Request passwords or personally identifiable information from us for commercial or illegal purposes;
  • (g) Make transactions in our Marketplace except in accordance with these Conditions;
  • (h) Download or print content from our Website for a purpose other than your personal use or to the extent necessary to use our services as an investor;
  • (i) Use our Website or any information accessible on it or obtained from it for commercial purposes directed at our investor clients or Borrowers;
  • (j) Use our Website or Marketplace:
    • (i) In any way that causes, or is likely to cause, the platform or its access to be interrupted or damaged in any way;
    • (ii) For fraudulent purposes, or in connection with criminal purposes;
    • (iii) To send, use or reuse any material that is illegal, offensive, abusive, indecent, defamatory, obscene or threatening; or as a breach of copyright, trademark, trust, privacy or any other right; or that is otherwise harmful to third parties; or objectionable; or that consists of or contains software viruses, political campaigns, commercial promotions, chain letters, mass mails or any type of "spam" or other "junk mail";
    • (iv) To cause unnecessary inconvenience, discomfort, or anxiety;
  • (k) Access or use the Website except for its intended purpose, nor attempt to hack, make unauthorized alterations or to introduce any type of malicious code to the Website or Howlett Capital SA by any means;
  • • (l) Unless previously approved by Howlett Capital SA or otherwise permitted by law, (a) recreate or decompile (either partially or totally) any software available through the Website; or (b) make copies, modify, reproduce, transmit, alter or distribute all or any part of the Website or any material or information contained therein;
  • • (m) Disguise, or interfere in any way with the IP address of the computer you use to access the Website or take other measures to prevent us from being able to correctly identify the real IP address of the computer you use while accessing the Website.

19. Protection and use of data.

Data Protection

Howlett Capital SA expresses the utmost respect and attaches a decisive importance to the protection of its clients' data. Howlett Capital SA will scrupulously respect the decisions of its clients and users regarding the use and dissemination of their data, said decisions being under its responsibility. Howlett Capital complies with the Law on Protection of Personal Data and with any other regulations in force on the matter, and maintains a Data Protection Policy on personal data, which mainly establishes the use that Howlett Capital SA makes of personal data, customers and users are informed in detail of the essential circumstances of such use and of the security measures that are applied to their personal data, to prevent unauthorized third parties from accessing them.

In compliance with the Personal Data Protection Law, Howlett Capital SA informs you that the personal data that you provide us or derive from your subsequent relationship with us, will be incorporated into a data processing whose responsible and owner is Howlett Capital SA. data provided to any other entity with which Howlett Capital SA has any type of relationship, will not be the responsibility of Howlett Capital SA. The referred sending of personal data constitutes the express consent to their treatment, albeit revocable and without effect. retroactive.

The purpose of the processing of personal data will be the maintenance of the contractual relationship with Howlett Capital SA, the management of queries, transactions, operations, request for a contract, contracting services, as well as the sending of technical, operational and commercial information about the services offered, in order to adapt and design commercial offers that are to your liking.

The only personal data to which Howlett Capital SA will have access will be those that the user voluntarily provides. In this sense, it is necessary for the user to know that to register and register for some products or services offered through the Website, personal data will be requested. In the cases and with respect to the data in which the user is expressly indicated, if they do not provide them, they will not be able to access or use the aforementioned services and contents.

Likewise, we inform you that your data is treated confidentially and used exclusively internally and for the indicated purposes. Therefore, we do not transfer or communicate your data to any third party, except in the cases provided by law, or that the user expressly authorizes us. The data provided will be treated solely and exclusively for the determined, explicit and legitimate purposes for which they were obtained and these will not be communicated to outside entities.

Use of data

You agree that any and all information that you provide to us as a user of Howlett Capital SA may be collected, stored, processed and used in accordance with the following privacy policy.

We may use personal information related to you to provide our Services; to manage your Howlett Capital SA Account and keep you informed about credits; to identify, prevent, detect or address fraud, money laundering or other crimes; to carry out regulatory controls; to calculate, collect and make payments on loans, interest and other amounts described in these Conditions; to identify which products, ours or others, may interest you and inform you about them; and for statistical analysis and market research.

We may also disclose your personal information:

  • (a) To our agents and suppliers for any of the purposes described in the previous paragraph;
  • (b) To government agencies for the purpose of identifying, preventing, detecting or addressing fraud, money laundering and other crimes;
  • (c) To fulfill our obligations to any government agency; Y
  • (d) If we are required by law or if it is done in the public interest.

By submitting personal information to Howlett Capital SA, you agree that it may be used in the ways described above. We will not be responsible for any misuse or misuse of your personal data by others, but you agree to promptly inform us of any misuse of the Marketplace or Website that you become aware of.

Finally, we inform you that you have the possibility of exercising at any time, free of charge, the rights of access, rectification, cancellation and opposition of your data and revocation of your authorization without retroactive effects (in the terms specified in the Organic Law of Protection of Personal Data, in accordance with the legally established procedure), by writing to Howlett Capital SA

20. Commercial information.

You confirm that you consent to Howlett Capital SA to collect and process your data in order to receive commercial communications (advertising), and you may revoke said consent at any time. In any case, Howlett Capital SA will comply with the provisions of the Law.

21 Intellectual property.

Howlett Capital SA and the Howlett Capital SA logo are registered trademarks of You agree not to make unauthorized use of the Howlett Capital SA trademarks and any unauthorized use that may result in prosecution.

www.howlettcapitalcr.com is our Company's uniform resource locator ("URL"). You will not use this URL (or any other URL in our possession) on any other website or digital platform without our prior written consent.

Howlett Capital SA owns all rights to any pricing information and related content on our Marketplace. Your registration and use of our Marketplace does not grant you any rights to the content and related intellectual property rights in our Marketplace. You agree not to follow, use or copy web pages or any content on the Marketplace, including without limitation any pricing information. Any unauthorized use or reproduction can be charged.

You will retain ownership of all copyrights in the data that you upload or submit to our Website. You grant us an exclusive, worldwide, royalty-free, perpetual license to use, copy, distribute, publish, and transmit such information in any form.

We do not guarantee or represent that the content of our Website does not infringe the rights of third parties. Any information licensed to Howlett Capital SA by third parties is provided for use on the Website only and may not be used for commercial use without the consent of the third parties.

The content of the Website (including, but not limited to, texts, images, audio and video components) is protected by the Intellectual Property Law. The modification, distribution, transmission, copying or any use of the content of the website for public or commercial purposes, without the authorization of Howlett Capital SA, is an offense typified and penalized by current legislation.