For customer

EBANX's Privacy Notice

March 7, 2024

This is EBANX's Privacy Notice, available at https://www.ebanx.com, where you can access information about all our services. EBANX takes your privacy very seriously and is committed to protecting your Personal Data throughout browsing and using our services.

This Notice explains how EBANX collects, uses, and shares your Personal Data. It also tells you how to access, update, and correct your Personal Data and exercise control over your information.


Glossary

  • Applicable Law: any legislation or regulation that addresses privacy and data protection matters, according to the jurisdiction where EBANX operates.

  • Controller: a natural or legal person governed by public or private law who is responsible for decisions regarding processing Personal Data.

  • Personal Data: any information about an identified or identifiable natural person.

  • EBANX: all the companies are part of EBANX's economic group.

  • Merchant: platforms or sites, national or international, that use EBANX as the means of processing payments.

  • Platform: the website https://www.ebanx.com and the EBANX API.

  • Processor: a natural or legal person, governed by public or private law, who processes Personal Data on behalf of the controller.

  • Processing: is any operation carried out with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, sharing, distribution, processing, archiving, storage, elimination, evaluation, or control of the information, modification, communication, transfer, dissemination or extraction.

  • Third Parties: natural or legal persons who supply products or provide services to EBANX, whether public or private.

  • You: any natural person who uses our services.


Summary

  1. Commitment to the security of your Personal Data

  2. EBANX's role when Processing your Personal Data

  3. Data collected by EBANX

  4. How EBANX Uses Your Personal Data

  5. Activity log

  6. Sharing and disclosure of Personal Data

  7. Storage, retention, and deletion of Personal Data

  8. Your rights, options, and controls

  9. International transfer

  10. Internet security

  11. Changes to the Privacy Notice

  12. Contact us


1. Commitment to the security of your Personal Data

EBANX protects your Personal Data when you browse, access, or use the platform. We are committed to the security of your data throughout your experience on the platform. For this reason, your Personal Data will be kept strictly confidential and will not be sold, exchanged, or disclosed to any Third Party except in the cases expressly set out in this Notice.


2. EBANX's role when Processing your Personal Data

According to the Applicable Law, EBANX is considered both the "Controller" and "Processor" of your Personal Data.

We are responsible for processing payments you make on our Merchants' websites or platforms. EBANX acts as a Processor of your Personal Data for processing payments on these sites.

EBANX may also act as a Controller in certain situations, such as when we adopt preventive and reactive measures to identify, prevent, and remedy fraud and security threats.


3. Data collected by EBANX

EBANX may collect your Personal Data at different times, such as (i) when you access our website and browse through the available items; (ii) when you contact us through our communication channels; and (iii) when you make purchases from partners who have retained our payment services.

In these scenarios mentioned above, EBANX may process certain information, such as (1) identity data; (2) financial data; (3) technical data; and (4) usage data.

(1) Identity Data

  • Full name;

  • Tax identification number;

  • Date of birth;

  • Address;

  • E-mail;

  • Mother's name;

  • Telephone number;

  • Biometrics; and

  • Document photo.

(2) Financial Data

  • Payment details;

  • Bank details (bank, account, branch); and

  • Payment method used.

(3) Technical Data

  • IP address;

  • Access time;

  • Date accessed;

  • Data on the access device; and

  • Cookies.

(4) Usage data

  • Information on purchases made (type of product, services, values);

  • Information about your behavior profile; and

  • Volume of transactions.


4. How EBANX Uses Your Personal Data

EBANX can use your Personal Data for specific purposes, as described below:

Type of DataWhat is the collection for?
Identity Data - To provide our services, including payment processing, chargebacks and refunds, sending transaction notifications and complying with our legal and regulatory obligations; - For the identification and prevention of fraud and security threats, data analysis, system maintenance, and data hosting; - To manage our relationship with you, including service via our communication and customer service channels, which may involve procedures to confirm your identity and prevent fraud; and - For sending direct marketing communications to you via email, text, or digital channels.
Financial Data- To provide our services, including payment processing, chargebacks, and refunds, sending transaction notifications, and complying with our legal and regulatory obligations; and - For identifying and preventing fraud and security threats, data analysis, system maintenance, and data hosting.
Technical Data- To provide our services, including payment processing, chargebacks and refunds, sending transaction notifications, identifying and preventing fraud and security threats, analyzing data, maintaining systems, hosting data, and complying with our legal and regulatory obligations; - To analyze transactions and consumer profiles for behavioral analysis and the prevention of fraud and security threats to monitor and improve our performance and enhance our services; and - To manage our relationship with you, including service via our communication and customer service channels, which may involve procedures to confirm your identity and prevent fraud.
Usage Data- To manage our relationship with you, including service via our communication and customer service channels, which may involve procedures to confirm your identity and prevent fraud.

5. How EBANX records your activities

When you access our platform, we may record your activities to create logs (records of activities on websites, applications, and products). The logs record your IP address and actions on the platform, including the date and time of each action taken and information about the device used, such as the operating system version of your smartphone, computer, or browser.

To help us in this process, we can use technologies to monitor the activities carried out on the platform, such as

  • Cookies. Cookies are small text files that can be placed on your device by the websites or web services you use. Cookies can be used for many things, such as remembering your preferences and tracking your visits and activities related to the platform. The platform may also use locally stored objects to provide certain content, such as video on demand, video clips, or animation. The cookies used cannot be turned off, removed, or blocked because if you try to disable or remove cookies, some parts of the platforms may stop working, and your ability to limit cookies is subject to the settings and limitations of your browser.

  • Analytics tools. These tools can collect information such as how you visit the platform, including which pages you visit and when, and other sites that have been visited.

Rest assured that all technologies used by us will always respect the terms and limits established by this Notice.


6. Sharing and disclosure of Personal Data

Sometimes, it will be necessary to share your Personal Data. We may use, access, and share it when required and always within the limits and purposes of the business, respecting the applicable legislation.

We may share your Personal Data in specific situations, such as:

  • Between the companies of the EBANX group to offer you the best experience when using our payment services;

  • With Third Parties, for the protection of EBANX's interests in case of conflict, including in legal claims and the case of transactions and corporate changes involving EBANX. In this case, the transfer of data will be necessary for the continuity of the products and services offered;

  • With Third-Party service and product providers to the extent that such data is necessary to provide the service/product or improve our services. For example, it may be with partners for monitoring transactions carried out through our platform to prevent fraud and money laundering;

  • With the Brazilian Central Bank and other regulatory bodies, or financial institutions, payment institutions, and other applicable institutions, following legal requirements; and

  • With judicial, police or government authorities, or other Third Parties to whom we are bound by law, regulatory rule, or court order.


7. Storage, retention, and deletion of Personal Data

Your IP address with date and time of access is stored in a secure and controlled environment for a minimum period of 6 (six) months, under the terms of the Applicable Law, considering the available technology.

These data are stored on our servers (our own or retained, whether in your country or abroad), according to the Applicable Law requirements. They may also be stored by cloud computing technology or other emerging technologies, aiming always to improve and perfect our products and your experience when using our services.

Other data will be kept for the period permitted or required by law following the purpose and nature of the processing. This includes, but is not limited to: (i) compliance with legal or regulatory obligations; (ii) provision of services; (iii) customer service through communication channels; and (iv) improving our products and services.


8. Your rights, options, and controls

You have rights and guarantees concerning your Personal Data. We provide mechanisms, detailed below, so that you have clarity and transparency when exercising your rights, depending on the country where the Personal Data is collected and processed.

Your Data Subject rights may vary according to the country where you are and the Applicable Law. On EBANX's Privacy Portal, you can find the Data Subject rights you are entitled to by selecting Your Country.

Before we respond to any request to exercise the rights mentioned above, we may ask you for some information to confirm your identity. We will respond to your request once we have validated your identity.

These rights are not absolute and may not apply in certain circumstances. For example, in certain cases, we may continue to process and retain Personal Data regardless of your request for deletion, opposition, blocking, or anonymization to comply with legal, contractual, and regulatory obligations, safeguard and exercise rights, including in judicial, administrative and arbitration proceedings and other cases provided for by law.

You can contact us through EBANX's Privacy Portal to exercise your rights or ask questions. EBANX strives to respond to all requests within the legal period of 15 (fifteen) days.


9. International transfer

Your Personal Data may be transferred to other countries during our services, either between EBANX representatives in different countries or to Third Parties. In such cases, we will take the measures required by Applicable Law to ensure that your Personal Data remains protected and that this transfer is carried out following one of the transfer mechanisms.


10. Internet security

We strive to protect the data we store in our records, but we cannot guarantee complete security. Factors such as unauthorized access or use and hardware or software failure, among others, may compromise the security of the data.

Please remember that data transmission over the Internet is only partially secure due to various factors, such as network and operation. Therefore, EBANX cannot guarantee the complete security of the data transmitted. Although we do our best to protect your data, we cannot guarantee the network security you use to access our platform. Any transmission is your sole responsibility, who, by agreeing to this Notice, expressly acknowledges and assumes such responsibility.

Once received, we undertake to ensure its security. To prevent unauthorized access or disclosure of your data, we have implemented physical, electronic, and administrative procedures to ensure that the data we collect is secure.


11. Changes to the Privacy Notice

EBANX is constantly evolving, so this Notice's terms may also change. Therefore, we recommend that you access this document often or whenever in doubt to keep up with any updates.


12. Contact us

If you have any questions, suggestions, or complaints regarding the provisions of this Privacy Notice, or if you would like to submit any request regarding your Personal Data, you may contact us via EBANX's Privacy Portal.

If you need to contact the EBANX Person in Charge, you can do so by email at privacy@ebanx.com.