This Privacy Policies (the “Privacy Policies ”)
applies to Dlocal Limited and its group of companies (“we” or “us”)
and shows how we will Process your Personal data as Data Controllers. We are
committed to the protection of your Personal Data, and our purpose is to inform
you about the way we Process your Personal Data, including references to which
data we Process, how, why, for how long, together with information about your
rights as a Data Subject.
Please read the
following carefully to understand our views and practices regarding your
Personal Data and how we will treat it.
1. Definitions
“Data
Controller” means any person who alone or jointly with others
determines the purposes and means of the Processing of Personal Data;
“Data
Subjects” means any natural person whose personal data is processed by
a controller or processor
“Processing”
and “Processing of Personal Data” means any operation or set of
operations which is taken in regard to personal data, whether or not it occurs
by automatic means, and includes the collection, recording, organisation,
storage, adaptation, alteration, retrieval, gathering, use, disclosure by
transmission, dissemination or otherwise making information available,
alignment or combination, blocking, erasure or destruction of such data;
“Personal Data”
means any information relating to an identified or identifiable natural person;
an identifiable person is one who can be identified, directly or indirectly, in
particular by reference to an identification number or to one or more factors
specific to his physical, physiological, mental, economic, cultural or social
identity;
“Dlocal
Entities” means either Dlocal Corp LLP, Dlocal Inc, Dlocal Limited or
Dlocal LLP.
2. Personal
Data we may collect from you, and with which purpose
2.1 You may provide us with Personal Data
about you, for example when you enquire for or apply for our services, by
filling in forms on our website, subscribing to our newsletter, participating
in one of our events, or by corresponding with us by phone, e-mail, or any
other means of communication.
2.2 We will use this Personal Data to
provide you with assistance on your queries, and/or to assess your application
for a merchant or partner account. As such, this Personal Data will be used by
us to establish or perform our (future) contract with you and for our
legitimate interests in following up with you. We will also use the
abovementioned Personal Data for our legitimate interest of conducting business
with you and managing our internal administration, conducting marketing
research with the purpose of improving our products and services to be able to
offer our tailored services.
2.3 Additionally, we may collect
information about you through automatic means, for example by using cookies
when you visit our websites. When you browse on our website, we process your IP
address, Google Analytics ID, internet browser and device type, location data
and your use of our website, including which pages you visited, how you got to
our website, the time and length of your visit and your language preferences.
We use this data for our legitimate interests of making sure our website works
properly, including debugging, to be able to deliver you its content, for DDOS
mitigation on our website, and improving our website and performing statistical
analyses for optimizing the quality of our website. We also use this
information to provide you with personal offers tailored to your needs and
customizing what we show you to your preferences, with your prior consent.
2.4 We would also like to inform you that
we may also obtain data about you from third parties, such us credit references
and fraud prevention agencies.
2.5 If you desire to register to our
services, we will collect the Personal Data necessary in order to establish and
perform a commercial agreement with you, including your contact information,
address, tax information and payment details. We will use this information to
set up our products and services for you, and to provide you with support on
the boarding process, integration and installation. In addition, we will use
your information with the purpose of managing our internal administration and
complying with our legal obligations, such as taxation obligations.
2.6 We also collect
data about your use of our services, including your login credentials, queries,
comments and complaints you send us in relation to our business relationship.
2.7 We will collect
information on you to comply with national and international laws and
regulations on money laundering prevention and crime or financing terrorism
processes.
2.8 We will use this
Personal Data to ensure the safety and integrity of our operations, by aiming
to identify, prevent and counter illegal conduct and to comply with our legal
know-your-customer and anti-money laundering obligations.
3. DISCLOSURE OF YOUR INFORMATION
3.1 We will not
disclose your Personal Data to anyone except as described in this Notice.
3.2 We may share your
Personal Data with any company within any of Dlocal Entities.
3.3 We may share your Personal Data with
third parties to provide you with the products we offer, including service
providers, credit reference agencies and financial institutions. We may also
share your Personal Data with third parties to prevent crime and reduce risk,
if required to do so by law, where we deem it appropriate to do so, to respond
to legal process or to protect the rights or property of Dlocal, our customers
or others.
4. Where we transfer
your Personal Data and data security
4.1 We are committed to secure your
Personal Data therefore we have taken steps to prevent unauthorized access to
your data, and we have put in place a range of technical and organizational
measures to safeguard and secure the information we collect and Process from
you.
4.2 Your Personal
Data may be shared with other Dlocal Entities outside of the European Economic
Area (“EEA”), when this is necessary for the purposes mentioned in this Notice.
These countries include the countries in which we have operations. It also
includes the countries in which some of our service providers are located.
4.3 To protect your data when these are
transferred to countries outside of the EEA, we have implemented appropriate
safeguards. Every transfer of Personal Data is protected by a data processing
agreement containing Standard Contractual Clauses. If you want to receive more
information about these safeguards, you can contact us using the details below
under (“Contacting us”).
5. Your rights as Data
Subject
5.1 Under current Data Protection
Legislation, you are entitled to object to us Processing your Personal Data,
including profiling. You may also ask us for an overview of your information or
ask for a copy, and request us to correct or delete certain data, restrict
Processing of your Personal Data, or ask us to transfer some of this
information to other organisations. In some cases,
you may object to the Processing of your Personal Data and, where we have asked
for your consent to process Personal Data, you can withdraw this consent at any
time. Where we Process your Personal Data for our legitimate interests, you can
contact us if you want more information about these.
There are some
exceptions to these rights, however. For example, it will not be possible for
us to delete your data if we are required by law to keep it or if we hold it in
connection with a contract with you. Similarly, access to your Personal Data
may be refused if making the information available would reveal Personal Data
about another person or if we are legally prevented from disclosing such
information.
5.2 If you wish to exercise any of these
rights, or you need further information on the rights granted under Data
Protection Legislation, please contact us using the details below.
6. Cookies
We use cookies
and similar techniques, such as tags/beacons and javascripts,
which are small text files stored on your device. Using cookies is a way for us
to make sure that our website is continuously improved, meets your needs and
can be used as a tool to optimize our marketing strategy. In order for us to do
this, we place functional cookies to make the website function as well as
marketing cookies which help us target the right people and show them
advertisements. Some of these cookies track your use of our website and visits
to other websites and allow us to show you advertisements when you browse other
websites.
7. Contacting us,
questions and complaints
Questions,
comments, requests or complaints concerning this Notice and the way we Process
your Personal Data can be addressed to our Data Protection Officer, at, or
Regus Tower Business Centre, Tower Street, 2nd Floor, Swatar, BKR4013, Malta.
8. CHANGES TO OUR PRIVACY POLICIES
Any changes we
may make to this Notice in the future will be uploaded to the website and,
where appropriate, notified to you by e-mail. Please check back frequently to
see any updates or changes to our Privacy POLICIES