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This is the Privacy Notice of EBANX LTDA., CNPJ 13.236.697/0001-46, headquartered at Rua Marechal Deodoro, 630, Praça San Marco, CEP 80010-010, Centro, Curitiba, PR, as well as of all companies of the EBANX economic group, represented herein by its headquarters ("EBANX"). This Notice is available through the https://www.ebanx.com website, where you can access information about all services provided by us.  The privacy of your Personal Data is a key priority for EBANX, and we are committed to your security throughout your browsing and use of our services. 

The purpose of this Notice is to explain how your Personal Data is collected, used, and shared by us. Here we also tell you how you can access, update, correct your Personal Data and have control over your information. 

Glossary

• Controller: natural or legal person, under public or private law, who is responsible for decisions regarding the processing of Personal Data.

• Personal Data(s): any information relating to an identified or identifiable natural person.

• EBANX: all companies of the EBANX economic group, including, but not limited to, EBANX S.A. (Argentina), Zilver S.A. (Argentina), EBANX Bahamas Ltd., EBANX Payment Institution Ltda. (Brazil), EBANX Brasil Holding Ltda., EBANX Holding de Pagamentos Ltda. (Brazil), EBANX Ltda. (Brazil), EBANX Pagamentos Ltda. (Brazil), Frontier Payments Brasil Ltda., EBANX Serviços Digitais Ltda. (Brazil), EBANX Holdings LLC, EBANX Chile Limitada, Frontier Payments Chile SpA, EBANX Chile Local Payments SPA, EBANX Shanghai Technology Information Co. Ltd. (China), EBANX Colombia Local Payments S.A.S, EBANX Colombia S A S, Frontier Payments Colombia S.A.S, EBANX Costa Rica SRL, EBANX LLC (Egypt), EBANX de El Salvador S.A., EBANX Ecuador S.A, EBANX Guatemala S.A., EBANX India Private Limited, EBX Jamaica Limited, EBAKE Limited, EBANX de México S. de RL. de CV, FTR Payments, S.R.L de C.V (Mexico), EBANX Mexico Local Payments S.A. de C.V., E3X Pay Limited (Nigeria), EBANX Panama S.A., EBANX Paraguay S.R.L., EBANX Peru S.A.C., Frontier Payments Peru S.A.C., EBANX República Dominicana SRL, EBANX PTE. LTD. (Singapore), EBANX South Africa, EBANX Uruguay S.A.

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

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

• Operator: natural or legal person, under public or private law, who processes Personal Data on behalf of the controller.

• Third: individuals or legal entities, of a public or private nature, that supply products or provide services to EBANX.

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

• You: any natural person who uses our services.

Index

1. Commitment to the security of your Personal Data

2. EBANX's role with your Personal Data

3. Data collected by EBANX

4. How We Use Your Personal Data

5. How we log your activities

6. Sharing and Disclosure of Personal Data

7. Storage, retention and deletion of Personal Data

8. Your Rights, Choices, and Controls

8.1. Right to lodge a complaint with the data protection authority

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 with us. Therefore, your Personal Data will be kept in the strictest confidentiality and will not be sold, exchanged or disclosed to any third party, except in the cases expressly established in this Notice.

2. EBANX's role with your Personal Data

EBANX's role in the processing of your Personal Data may vary depending on the specific context and the contractual agreement established with each Merchant. In many cases, as reflected in our Data Processing Agreements (DPAs), EBANX acts as a Controller independently or jointly with the Merchant (Joint Controllers), especially in activities related to payment processing, fraud prevention, risk analysis and regulatory compliance.

However, in situations where the contract establishes that the Merchant will be the sole Controller of the Personal Data and EBANX will act exclusively in accordance with its documented instructions, EBANX may be classified as an Operator. This distinction is determined by the contractual clauses applicable to each commercial relationship.

This approach reflects our commitment to transparency and compliance with Personal Data protection legislation, such as the LGPD, GDPR and other applicable local regulations.

3. Personal Data collected by EBANX

We may collect your Personal Data at different times: (i) when you access our website and browse through items made available; (ii) when you contact us through our communication channels; (iii) when you make purchases from partners who have contracted our payment services; and (iv) when you maintain a commercial relationship as a client company of EBANX.

In these scenarios mentioned above, EBANX may process some information, such as: 

4. How We Use Your Personal Data

We may use your Personal Data for the purpose of achieving certain purposes, as described below. Take a look:

EBANX may also use your data for automated purposes, especially for fraud prevention and risk assessment. In this way, we were able to analyze suspicious transactional patterns and anomalous behavior in transactions. 

In some countries, data subjects have the right to review exclusively automated decisions, request human intervention. To learn more, see "8. Your Rights, Options and Controls", or access the EBANX Privacy Portal.

5. How we record your activities

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

To help us in this process, we may use technologies to monitor the activities carried out on the platform, including:

• Cookies - Cookies are small text files that may be placed on your device by the websites or web services  you use. Cookies  can be used for many things, such as remembering you and your preferences and tracking your visits and activities related to the platform. The platform may also utilize locally stored objects to deliver certain content, such as video on demand, video clips, or animation. The cookies used cannot be disabled, 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 will be subject to your browser settings and limitations.

• Analytics tools - These tools can collect information such as how you visit the platform, including which pages you visited and when, as well as other websites that were visited before, among others.

All technologies used by us will at all times abide by the terms and limits set forth in this Notice.

6. Sharing and Disclosure of Personal Data

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

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

• Among the companies of the EBANX group, to offer you the best experience while using our payment services;

• With Third Parties, for the protection of EBANX's interests in case of conflict, including in lawsuits and in case of transactions and corporate changes involving EBANX, in this case, the sharing 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 for the provision of the service/product or improvement of our services. For example, it can be with partners to monitor transactions carried out through our platform, with the aim of preventing fraud and money laundering; 

• With the Central Bank of Brazil and other regulatory bodies, or financial institutions, payment institutions and other applicable institutions, in accordance with legal requirements; and

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

7. Storage, Retention and Deletion of Personal Data

Your Personal Data will only be kept for as long as necessary to fulfill the purposes for which we collected it, respecting the principles of data protection. Due to the financial nature of our operations, EBANX is required by law to store some of your Personal and transactional Data even if we are no longer processing your payments. These deadlines are established by local regulations and can be retained between 5 and 15 years. In addition to these hypotheses, Personal Data may also be stored in accordance with contractual needs, exercise of rights or fraud prevention. 

Access to Personal Data is restricted internally, and is accessed or processed only when absolutely necessary. The deletion of Personal Data that is no longer required by legal obligation is done automatically. Deletion methods include anonymization, purging and destruction, and secure hardware disposal.

8. Your Rights, Choices, and Controls

You have rights and guarantees in relation to your Personal Data. We provide mechanisms, detailed below, so that you have clarity and transparency in the exercise of your rights, depending on the country where the Personal Data is collected and/or processed.

You may exercise your Data Subject rights – including the right to withdraw consent where this is the legal basis for processing – through our EBANX Privacy Portal. To learn more, check out this link.

For countries that do not have specific data protection legislation that establishes formal rights of the holders, EBANX maintains its commitments to transparency and security in the processing of Personal Data. If you reside in one of these countries and have questions about the processing of your Personal Data, please contact us through EBANX Privacy Portal.

Before we respond to any request to exercise the rights mentioned above, we will ask you for certain information to confirm your identity. We will fulfill your request after your identity has been validated.

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

8.1 Right to lodge a complaint with the data protection authority

In South Africa, you also have the right to lodge a complaint with the Data Regulatory Body by following the instructions in the form available at this link.

9. International Transfer

Your Personal Data may be transferred to other countries in the course of providing our services, either between EBANX representatives  from other countries or to third parties. In such cases, we will take the steps required by law to ensure that your Personal Data remains protected and that such transfer is carried out in accordance with one of the transfer mechanisms provided for by applicable law, depending on the country.

10. Internet security

We strive to protect the Data we hold for our records, but we cannot guarantee the most complete security. Some factors such as unauthorized access or use, hardware or software failure, among others, may compromise the security of the Data.

But it is necessary to remember that the transmission of Data over the internet is not completely secure due to several factors, such as network and operation and, therefore, EBANX cannot guarantee the complete security of the transmitted Data. Although we do our best to protect your Data, we cannot guarantee the security of the network you use to access our platform. Any such transmission is at your sole risk, and by agreeing to this Notice, you expressly acknowledge and assume such responsibility.

Once received by us, we are committed to ensuring your safety. To prevent unauthorized access to or disclosure of your Data, we have put in place physical, electronic, and managerial procedures to ensure that the Data we collect is secure.

11. Changes to the Privacy Notice

We are always evolving, so it may be that the agreements of this Notice will also change. Therefore, we recommend that you access it frequently, or whenever there are doubts, to keep up with any updates. Changes will be communicated right here, on the page of this Notice.

In the event that changes to this Notice imply changes in Personal Data processing practices that depend on your consent, you will be asked to consent to the new terms so that you can continue browsing our website or using our services.

12. Contact us

In case of any questions, suggestions and/or complaints regarding the provisions contained in this Privacy Notice or if you want to submit any request regarding your Personal Data, you may contact us through the EBANX Privacy Portal, your request will be handled by our Data Officer, Giovanna Michelato Almada, and her team,  within the time frame established by the privacy laws applicable to your country.