Privacy Policy - Primefy

PARTIES

1.1. CONSIDERING THAT:

a) User refers to the user who makes a purchase on the website of the company Client of Primefy.

b) Client refers to the company that hires the services offered by Primefy to be inserted on its website. It may also be referred to as “Primefy Client,” “Client of Primefy,” and terms derived from these.

c) Primefy: the company providing local payment solution services between “Client” and “User.”

DATA COLLECTION

2.1. The user declares aware and authorizes Primefy to collect, store, and use, exclusively to execute and/or enhance its services, without prejudice to the other clauses of this Privacy Policy and the General Terms and Conditions of Use, the following data and information:

a) Identification Data: All those that include information about the User's identity, including, but not limited to, full name, date of birth, address, phone number, email, mother's name, tax identification number;

b) Financial Data: include banking information, information about the payment method used, and other details about the payment made by the User on the Primefy Client website.

c) Usage Data: include all information on how the User uses our services including, but not limited to, transaction volume, purchasing behavior, and profile.

d) Biometric Data: are those that include information about the User's face or fingerprints, including, but not limited to personal photos, photos of their identification documents, etc.

e) Access Data: are all those referring to where, how, and when you used the services of Primefy. Access data including, but not limited to, information about IP, Cookies, geolocation, time, and date, etc.

2.2. The above-identified data are collected through the user's registration directly on the Primefy website, on the “check out” page of the Primefy Client's website, or, still, when contacting us through our Help Center.

2.3. The user authorizes, from now on, Primefy to automatically collect all types of data from Users who interact and use our services, including, but not limited to, all the examples mentioned in Clause 2 of this Privacy Term.

2.4. Primefy may receive, store, and use the data of the User who makes purchases on Clients' websites and uses the payment processing service of Primefy.

2.5. All data and information collection are used to enhance and execute the services offered by Primefy.

2.6. According to art.11, of Circular No. 3,461, of July 24, 2009, as well as art. 195, caput and sole paragraph of the National Tax Code, we must keep the User's information stored for at least 5 years, counted from the date of data collection extendable upon request by the Public Ministry or administrative authorities.

2.7. The user declares aware that Primefy may keep the data stored for a period longer than provided in item “2.6”, for the purpose of:

a) compliance with a legal or regulatory obligation imposed on Primefy;

b) study by a research body, guaranteed, by Primefy, the anonymization of personal data;

c) transfer to a third party, provided that the data processing requirements set forth in Law are respected;

2.8. It is Primefy's responsibility, if there is a need to use its data for purposes other than those mentioned in this Privacy Policy or its Terms and Conditions, to notify the user and explain the reasons.

2.9. The user declares aware that Primefy adopts strict security standards to collect, store, and transmit the User's data. However, Primefy cannot guarantee the total security of its data transmitted online since the transmission of information via the internet is not completely secure and there is no way to guarantee its total security.

DATA PROTECTION AND STORAGE

3.1. It is Primefy's responsibility, as a data operator, to ensure the integrity of the information and data that are directly provided to its system, through direct registration or on the “check out” page of each of the Primefy Clients, in accordance with the clauses that follow.

3.2. Primefy will keep confidential all data of the transactions carried out by Clients and Users, except when such information is requested by judicial, administrative, or arbitral order, required by law, by the Card Brands and/or by service providers of Primefy, as well as, the provision in article “6” of this instrument.

3.3. For the contracted services, the Client and User, irrevocably and irrevocably, agree to authorize Primefy for the following:

a) Share Confidential Information and other information with its strategic partners and service providers, in Brazil or abroad, for the purpose of fulfilling the obligations established herein, credit assessment, verification, risk management, and fraud.

b) Use their Confidential Information and other information for database formation.

c) Inform credit protection agencies about the data related to the lack of payment of obligations assumed by the Client or the User with Primefy.

d) Use the Database for assessing financial risks, combating and preventing money laundering, corruption, and terrorism financing, including applicable national and international standards and internal policies of Primefy in this regard, as provided in Law No. 9,613, of March 3, 1998.

3.4. In the case provided in item “d”, Primefy reserves the right to block the registration of the involved party(s) or even exclude them, preventively or definitively.

3.5. Primefy may refuse to perform transfers of values made by the User when verifying that such transfers do not comply with our operation standards and risk policy. Such verification will be operated through partner companies that perform our analysis of individual registration data at any time.

3.6. The User and the Client may, at the end of the service provision relationship, request the destruction of their personal data. However, it is important to note that due to Law No. 9,613/98, Primefy has the duty to keep all data stored during the service provision relationship for at least 5 (five) years, as well as, the provision in item “2.6”.

a) If the request for data personal exclusion occurs before the legally prescribed period, Primefy will delete the User's data as soon as the legal period is completed or when determined based on legal obligations or by the request of a competent authority, except as provided in item “2.7” of this Privacy Policy.

3.7. Primefy is responsible for processing the payments of product or service purchases made by the User on the website(s) of the Primefy Client. Thus, Primefy acts as the User's data operator.

3.8. It is not Primefy's responsibility for any service or product offered by its Clients and, under no circumstances, shall it respond for the security and integrity of the information stored by them.

USE OF COLLECTED DATA

4.1. The User authorizes and declares aware that, by using the Services of Primefy, their data can and will be used by Primefy for the purposes of:

a) Adequate provision of Primefy's services, including but not limited to payment processing, refund, chargeback, cancellations, sending notifications, identification, fraud prevention, data analysis, system maintenance and/or any other type of maintenance, and/or any other activity aimed at complying with the legal and regulatory obligations it has;

b) Data analysis, transactions, profile, behavior, in order to prevent fraud and/or general information analysis to improve the services offered by Primefy;

c) Direct and indirect relationship with the User, including all types of support services offered and direct marketing, allowing Primefy to use the User's data for direct or indirect contact with them, to confirm their identity and prevent fraud and possible security breaches.

PRIMEFY'S RIGHTS

5.1. Primefy may collect, store, and use Aggregated Data of the User. By aggregated data is meant those information derived from personal data, which do not reveal, directly or indirectly, the identity of the User, such as demographic and/or statistical data.

5.2. Primefy may, at any time, request the Biometric Data of the User exclusively for the purpose of preventing security threats, fraud, and/or for identity confirmation.

5.3. Primefy may also receive data about the User from third parties and public sources for security purposes and service improvement. This includes, but is not limited to, fraud prevention agencies, service providers, state bodies, among others.

5.4. When User data is received, Primefy reserves the right to use these contact information to disseminate important notices related to the transaction performed, our services, and direct contact means with Primefy.

5.5. Primefy must collect the User's data in accordance with Brazilian law, but may transfer information internationally for the purpose of providing its services. Primefy also ensures that the international transfer of the User's data will fulfill and follow all norms described by this Privacy Term.

EXCEPTIONS

6.1. The personal data of the User will never be shared by Primefy, except for:

a) when such information is requested by judicial order;

b) when such information is requested by administrative order;

c) when such information is requested by arbitral order;

d) when such information is required by law;

e) when such information is requested by the Card Brands;

f) when such information is requested by service providers of Primefy for the perfect execution of their related services;

g) When the user asks and/or expressly authorizes the sharing of such data with third parties;

6.2. The User declares aware and agrees that, by using the services and/or providing their personal data directly to Primefy, may have their information processed and transferred internationally, according to the necessity of Primefy to adequately complete the offered service.

USER RESPONSIBILITIES

7.1. The payment method chosen by the User may be subject to the Terms and Conditions and Privacy Policies established by the card issuing institutions or financial institutions. It is the User's responsibility to search, agree, and accept such information.

7.2. By using the payment processing service of Primefy, the User agrees and authorizes Primefy to receive, store, and use their data informed when making a purchase on the website of Clients.

USER RIGHTS

8.1. Any changes to this Privacy Policy or our Terms and Conditions will be changed on this page and, when necessary, will be sent to the email informed by the User for contact.

8.2. The User may, at any time, request a pause in the sending of direct marketing and/or any other type of disclosure that is not strictly related to their payment transaction, at any time. In this way, they will no longer receive information about the services, promotions, and/or any other notices not related to the payment transaction made with us.

8.3. The User's data may not, under any circumstances, be sold or licensed by Primefy for the purpose of obtaining profit and/or in any other way contrary to what is mentioned in the Internal Policies.

LEGISLATION AND CHOICE OF JURISDICTION

9.1. The Parties agree to act in accordance with applicable laws and regulations.

9.2. The Parties elect the Court of the City of Blumenau, Santa Catarina, Brazil, as the only competent jurisdiction to settle issues arising from this Contract, with express waiver of any other, however privileged it may be.