V5Pay Group Companies

Depending on the jurisdiction in which your account is located, we may share your personal information within the V5Pay Group of Companies, including but not limited to the companies listed below, in order to provide you with our payment services:

We will only share information with other companies within the V5Pay Group in accordance with data protection laws and will strictly control its security and data accessibility. The way in which information is accessed, processed, and transferred and our level of security will be consistent across the group.

Thus, this policy was constructed to demonstrate V5PAY’s commitment to protecting the privacy of our user(s) and client(s), under the terms of the General Law of Data Protection (Federal Law 13.709/208) and in compliance with Republic Act No. 10173 respecting our client(s) and potential clients, as well as honoring the pillars of transparency, partnership, security, and positive experience.

Thus, the Privacy Policy aims to:

• Commitment to data privacy and security in the treatment of information collected from customers;
• Demonstrate, which are the data processed by V5PAY, the reason and the way used for collection, storage, processing, disposal and query of that data;
• Present how data protection is carried out;
• Define how to control privacy preferences, in updating, transferring and managing user information through access to the service platform;
• Establish rules about the entire life cycle of data in the V5PAY, from collection, registration, storage, use, sharing, to the elimination of collected data.

1. Policy

The stipulations of this Policy apply to all services offered by V5PAY and which use Personal Data from customers, potential customers, employees and third parties (“Data Subjects”).

When accessing and using the services, financial or non-financial, offered by V5PAY, the user agrees and fully accepts the provisions of the Policy.

The personal data collected by V5PAY are voluntarily granted by the holder of the personal data, through registration on our digital platform (“APP”), upon acceptance of the individual and simplified consent form in accordance with Law No. 13,709/2018, art. 7, item I. Personal data is understood as information relating to an identified or identifiable natural person, including information that can be combined with others to identify the data subject.

As a rule, V5PAY does not process data of persons under 18 years of age, except those related to employees and dependents of employees, in accordance with the law. Exceptionally, in cases where there is a need to process the data of children and adolescents, V5PAY will take all possible measures to obtain the consent of the respective legal guardians.

2. Definitions

General Data Protection Law (LGPD): Federal Law No. 13,709 published on August 14, 2018, which regulates Personal Data Processing activities, including digital media, by natural persons or by public and private legal entities, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the personality of the natural person.

Processing Agents: responsible for the Processing of Personal Data and are separated into two categories: Controller and Operator.

• Controller Responsible for decisions regarding the Processing of Personal Data.

• Operator Performs the Processing of Personal Data on behalf of the Controller, following its instructions.

Anonymization : technique through which data loses the possibility of association, directly or indirectly, with an individual, so that it is subsequently impossible to re-identify even using technical solutions.

National Authority for the Protection of Personal Data (ANPD): body of the federal public administration with duties related to the protection of personal data and privacy, including supervision for compliance with the LGPD.

Cookies: is a text file that contains a sequence of characters, created and sent by websites to the user’s device whenever accessed, where they are stored, and allow device recognition, remembering user preferences that personalize access, making the more pleasant navigation.

Personal Data: considered in the LGPD as information related to an identified or identifiable natural person, or information that, alone or combined with others, allows the identification of name, address, identity documents in general, telephone number, and other relevant information.

Sensitive Data: are conceptualized in the LGPD as Personal Data about racial or ethnic origin, religious conviction, political opinion, membership of a union or organization of a religious, philosophical or political nature, data referring to health or sex life, genetic or biometric data when linked to a natural person.

Anonymized data: data relating to the holder who cannot be identified, considering the use of reasonable technical means available at the time of processing.

Device: is the device that can be used to access the services offered by V5PAY, desktop computers, notebooks, tablets and smartphones.

IP address: is the number assigned to each connected V5PAY device, known as the V5PAY protocol (Internet Protocol or IP) address.

An IP address can be used to identify from which location a device is connecting to the V5PAY.

Geolocation : feature that, when activated by the Data Subject, allows defining the precise or approximate position of a device and brings information where that Device is located, also providing the time at which it was accessed.

V5PAY: trademark used by V5PAY to promote its services and products.

Data Subject: any identified or identifiable natural person to whom the processed personal data refer.

Processing: any operation carried out with Personal Data whether or not it is automated. That is, it is the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction.

3. About the information processed

The information is treated to better develop and improve the services. However, in some cases, the user will be able to manage the information collected and/or used by V5PAY, through one of the service channels for privacy matters indicated in this Policy, as well as through the way in which he will use the services.

Depending on the relationship established with V5PAY, different information is collected when the user uses the Website and they fall into three categories:

4. Collection and processing of personal data

Personal Data may be collected for different purposes depending on the relationship that the holder maintains with V5PAY, mainly for the following purposes:

• Fulfill contractual obligations, in particular the execution of the terms of the contract with V5PAY;
• Comply with applicable legal and/or regulatory requirements;
• Notify about any changes in the services;
• Safety and protection procedures, aimed at providing a safe and effective service;
• Perform operations, including supporting customers and other data subjects, troubleshooting, data analysis, testing, research and statistics;
• Evaluate the effectiveness of the advertising that is served, aiming to provide relevant advertising to the user;
• Produce evidence and assist in the conduct of legal, administrative or arbitration proceedings, as well as assist in complying with other legal requirements; It is
• Provide services (digital account, credit card, loans, recharges and service plans, online purchases, and others), as per the table below:

All data that the user actively provides or collected by V5PAY is considered confidential. Thus, the commitment to adopt technical and administrative measures capable of protecting Personal Data, observing guidelines on security standards established in current legislation.

5. Storage and retention term

The processing period of your Personal Data by V5PAY will vary according to the types of services contracted, rendered or provided; and for the purposes of the Treatment.

After the end of the purpose, data retention is authorized for compliance with legal or regulatory obligations, regular exercise of rights, transfer to a third party, provided that the data processing requirements are respected, and exclusive use by V5PAY, provided that the data are anonymised. data.

Thus, Personal Data will be deleted by V5PAY, except if the storage is carried out due to legal or regulatory obligation, when:

• Personal Data is no longer necessary or relevant to achieve this purpose;
• Consent is withdrawn;
• The determination of the competent authority.

The holder’s information will be stored in its own or third party data center (cloud), established in Brazil or abroad, depending on the relationship maintained between the holder and V5PAY.

The headquarters and internal operation of V5PAY take place in Brazil, however, some suppliers, service providers and business partners may have headquarters and/or operations abroad. In these cases, it may be necessary to transfer personal data abroad.

If personal data is stored abroad, V5PAY will make every effort to adopt all the security measures it practices, as well as observe the LGPD commands.

6. Rights as holder personal data

The LGPD grants a series of rights to Data Subjects. Therefore, the Data Subject may make requests to V5PAY, as detailed below:

1. Confirmation of the existence of treatment;
2. Access to data;
3. The correction of incomplete, inaccurate or outdated data;
4. The anonymization, blocking or deletion of unnecessary data;
5. Data portability, upon express request (data will be delivered to the holder in digital format [PDF, txt, CSV or another to be chosen by V5PAY], without any integration of systems and observing commercial and industrial secrets);
6. The deletion of processed personal data, except when data conservation is authorized;
7. Information about the shared use of data;
8. Information about the possibility of not providing consent and the consequences of the refusal;
9. The revocation of consent.
10. In order to exercise any of the rights established above, as well as determine preferences in the treatment and use by V5PAY of personal data, the user may send an email compliance@v5pay.com. You will receive a response within 15 (fifteen) days from the date of the request.
11. V5PAY may request additional data to confirm the identity and authenticity of the requesting user.

7. Sharing of personal data

V5PAY, in the interest of data privacy, in compliance with data protection and bank secrecy rules, only shares user information for the purposes set out in this Privacy Policy or with defined legal bases.

• Among the companies of the V5PAY;
• With commercial partners, service providers, suppliers and subcontractors for the execution of concluded contracts;
• With advertising and marketing companies, to select and serve advertisements relevant to the user; It is
• With search engine and analytics providers to assist with website improvements and optimizations.

It may also disclose personal information to third parties:

• In case of transactions and corporate changes involving any company of the V5PAY, in which case the transfer of data will be necessary for the continuity of the services offered;
• In compliance with current legislation;
• To ensure greater security in transactions, avoiding attempts at fraud and other crimes. This includes exchanging information for the purposes of protecting against fraud, money laundering and reducing credit risk;
• For the protection of V5PAY in cases of claims and conflicts, including judicial, administrative and arbitration proceedings;
• By court order, police order or competent administrative authorities that have the legal competence to request it.
• For risk assessment;
• Carry out collections from insolvent customers and data subjects and/or recover debts.
• If the user wishes to obtain more information about the third parties with whom V5PAY shares Personal Data, contact them through the service channels.

8. Service channels for privacy issues

For Privacy related matters, you must:

• Forward email to compliance@v5pay.com

9. Data manager

The data officer (or Data Protection Officer – DPO) acts as a communication channel between the V5PAY, the data subjects and the National Data Protection Authority (ANPD).

The name of the person appointed to act as data controller for the V5PAY can be consulted at any time through the service channels made available by the V5PAY.

10. General provisions

The terms of this Policy may be modified at any time, due to legislative changes or services provided, due to the updating of technological tools or, even, due to the offer of new services. Data Subjects will be notified of relevant changes through a notice on the Website, by email or by any other means of communication available, at the discretion of V5PAY.

Any clause or condition of this Policy that, for whatever reason, may be deemed null or ineffective by any court or tribunal, will not affect the validity of the other provisions of this Policy, which will remain fully valid and binding, generating effects to their fullest extent.

This Policy is governed exclusively by the Laws of the Federative Republic of Brazil, as well as any actions arising from violation of these Terms.

The use of services, financial or non-financial, will imply express acceptance of the terms and conditions of the Privacy Policy in force on the date of use.

For data holders who do not agree with the current Privacy Policy, we recommend not using our services.

Non-acceptance or refusal to provide the requested information may prevent the provision of services.

11. Applicable lay and dispute resolution

Any and all disputes arising from the terms set out in this Privacy Policy will be resolved in accordance with Brazilian law, with jurisdiction in the city of São Paulo/SP.

The use of services and/or orders issued outside Brazilian territory, as the case may be, or even those resulting from operations initiated abroad, may also be subject to the legislation and jurisdiction of the authorities of the countries where they are commanded or initiated.