Terms and conditions
We have brought together all the usage policies and legal pages of the Cartpanda platform.
Privacy Policy
1. PURPOSE
CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV” and collectively as “CARTPANDA” long with other companies within its Economic Group recognize and prioritize the privacy and security of your data. We acknowledge that safeguarding privacy is essential in demonstrating respect for our customers, partners, and collaborators. In addition to adhering to applicable laws, we are committed to conducting our operations based on the principles of transparency, partnership, security, and expertise. Consequently, CARTPANDA's Privacy Policy ("Policy") serves the following purposes:
a) Reinforce our commitment to privacy and security in the treatment of collected information;
b) Demonstrate, in a transparent and straightforward manner, what data we process, the reason and manner in which we collect, store, process, transfer, and query such data;
c) Present how we protect your data; and
d) Define when and how you can control your privacy preferences.
CARTPANDA is committed to adhering to stringent data security and protection standards to safeguard the confidentiality and integrity of our users' information. We consistently update our processes and technologies to align with the best practices in information security and current legislation.
Furthermore, we welcome feedback and suggestions from our Users to continuously enhance our services and privacy practices. Should you have any questions or concerns regarding our Privacy Policy, please feel free to contact us via email at our Data Protection Officer (DPO) at dpo@cartpanda.com. We are dedicated to assisting you and ensuring that your experience with us is secure and satisfactory.
2. SCOPE
This Policy covers all areas of CARTPANDA, its Administrators, Merchants, Merchants’ Consumers, Collaborators, Suppliers, and Business Partners, who must agree, adhere to, and commit to respecting what is established here.
CARTPANDA's Privacy Policy applies to all services offered by CARTPANDA that use Personal Data (as defined below) of customers, collaborators, and/or third parties ("Data Subjects").
Nevertheless, occasionally, we may make changes to this Policy. When we make relevant changes to this Policy, Data Subjects will be notified, either through a notice on our website, email, or other available means of communication.
Moreover, by accessing and utilizing the services provided by CARTPANDA, the Merchant and their Consumers fully acknowledge and consent to the provisions outlined in this Policy.
We advise you to always make sure to carefully read any notice of this nature.
3. DEFINITIONS
Data Processing Agents: those responsible for the Processing of Personal Data and are separated into two categories: the Controller and the Processor. The Controller is the person or company responsible for decisions regarding the Processing of Personal Data. The Processor, in turn, is the person or company that processes Personal Data on behalf of the Controller, following their instructions.
Anonymization: a technique by which data loses the possibility of direct or indirect association with an individual, so that it is subsequently impossible to re-identify even through technical solutions.
Cookies: small files containing a sequence of characters, created and sent by websites to your computer whenever you visit them. They help remember your preferences and customize your access, making your browsing safer, faster, and more enjoyable. You can configure your browser to not accept cookies or to notify you when a cookie is being sent, but without them, some features or services of the site may be compromised and limited.
Personal Data: information related to an identified natural person or information that allows their identification, such as name, address, individual taxpayer registry number), identity card, identity documents in general, phone number, among others.
Sensitive Data: Personal Data about racial or ethnic origin, religious belief, political opinion, membership in a union or religious, philosophical, or political organization, data relating to health or sexual life, genetic or biometric data when linked to a natural person.
Device: can be used to access the services offered by CARTPANDA, such as desktop computers, tablets, and smartphones.
Data Protection Officer ("DPO"): is responsible for ensuring that CARTPANDA complies with privacy laws and regulations, ensuring the protection of Personal Data and serving as the communication interface with regulatory entities and Data Subjects.
IP Address: is the number assigned to each Device connected to the internet, known as the Internet Protocol (IP) address. Generally, these numbers are assigned in geographical blocks. An IP address can be used to identify, for example, from which location a Device is connecting to the Internet.
Geolocation: a feature that, when activated by the Data Subject, allows for the precise or approximate position of a Device to be determined and provides information such as the country, state, city, and street where that Device is located, also providing the time it was accessed.
Economic Group: CARTPANDA TECNOLOGIA DE PAGAMENTOS LTDA, registered under CNPJ/MF No. 26.224.823/0001-94, headquartered at Avenida Francisco Monteiro, No. 1206, 3rd Floor, Room 306, Santana, Ribeirão Pires - SP, ZIP Code: 09406-300, hereinafter referred to as "Cartpanda BR"; CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV”.
Data Subject: any identified or identifiable natural person to whom the processed personal data refers. These include, for example, our clients, collaborators, third parties, service providers, job applicants, among others.
Processing: comprises any operation carried out with Personal Data, whether automated or not, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.
Users: Merchants of Cartpanda and their consumers.
4. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Considering the current legislation, we are committed to complying with the minimum requirements for registration, also ensuring an efficient and secure system for our Merchants and their Consumers.
In this context, various information is collected when you use our services or access our electronic channels, which fall into two distinct categories:
4.1. INFORMATION PROVIDED BY THE MERCHANT AND THEIR CONSUMERS
These are the types of information supplied by Merchants and their Consumers during interactions, contracting, or utilization of any services provided by CARTPANDA, including but not limited to: name, email, phone number, individual taxpayer registry number, address, and financial details such as credit card number and expiration date. We exclusively employ this information for financial purposes and to fulfill orders. Should any complications arise during order processing, we utilize this information to communicate with you.
Moreover, CARTPANDA Merchants may need to furnish images of their official identification documents, or any other Personal Data provided, to establish or modify their access accounts on the CARTPANDA Platform, or to engage in or terminate any services provided by CARTPANDA.
The verification and confirmation of personal data may, at the discretion of CARTPANDA, be conducted by third-party companies with whom CARTPANDA partners, subject to adherence to the same security and privacy criteria outlined herein.
It is important to emphasize that the Merchant shall bear sole and exclusive responsibility for the accuracy of the Personal Data provided to CARTPANDA during registration or when contracting any services.
CARTPANDA does not have any responsibility for the accuracy of the data provided, as well as for any data resulting from the inaccuracy and/or obsolescence of such information.
Therefore, if you reach out to us via email, we may retain your contact details along with a copy of the correspondence. Nevertheless, we maintain the prerogative to utilize your email address and any other personally identifiable information furnished by you to address your inquiries and disseminate promotional materials regarding our products and services. Rest assured, we shall refrain from disclosing your information to third parties for the purpose of soliciting their products and services.
Thus, it is emphasized that you have the option to modify your personally identifiable information, request the deletion of your data, or opt out of receiving marketing material at any time. Simply send an email to dpo@cartpanda.com to make such requests.
4.2. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Herein lie the data points collected by CARTPANDA during your browsing and/or utilization of its services, delineated as follows.
Navigation Data: This encompasses the information we gather regarding your interactions with our website, including:
a) Comments: When users leave comments on our site, we collect the information contained in the comment form, in addition to the IP address and information about the browser, we do this to be able to detect and prevent any spam.
b) Media: If you want to upload images to our site (in comments, for example), avoid sending images with embedded location data (EXIF GPS). Any site user can download and extract location information from the image.
c) Contact forms: If you leave a comment on our site, you may choose to save your name, email, and website using cookies. They are here only for your convenience so that you do not have to enter all your data again every time you want to comment on something. These cookies last for one year.
d) Cookies: If you have an account and log in to our site, we will create a temporary cookie to determine if your browser accepts cookies. This temporary cookie does not contain any personal information and is discarded as soon as you close your browser. When you log in, we create several cookies to save your login information and your display preferences. Login cookies last for two days, and display preference cookies last for one year. If you select "Remember me," the login cookie will have its duration extended to two weeks. If you log out of your account, login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie does not contain any personal information and is only used to indicate the ID of the article you made/edited. It expires after 1 day.
e) Embedded content from other websites: Pages and articles on this site may have embedded content (such as images, videos, external links, etc.). Embedded content from other sites should be considered exactly as if the user had accessed the other site. These sites may collect some information about you, use cookies, and other tracking and monitoring software regarding your interaction with embedded content if you have an account and are logged into that site.
f) Devices: Like most websites, our site may contain "pixel tags," cookies, or other similar tracking technologies, which allow us to look at user actions on our site. Pixel tags and cookies are used to collect non-personally identifiable information, such as your internet service provider's name, the type of browser you are using, the operating system, the type of device you are accessing our site on, and the date and time of access. We may aggregate your information with similar information to help us make improvements to our products, services, applications, content, and features offered on our site. We do not use non-personally identifiable information to create or maintain a profile of you or collect new information.
g) Geolocation: These are information we collect about your location, which allows us to: (i) ensure greater security for your transactions based on geographical location points (anti-fraud); (ii) identify the origin of a call received in our customer service channels. To determine your location, we use the following means: GPS (tracking the origin of the call) and/or IP Address (access to the system). The types of location data we collect depend on the Device and settings. You can enable or disable location tracking via GPS by accessing the Settings/Privacy option on your Device.
5. PERSONAL DATA PROCESSED BY CARTPANDA
The Personal Data collected, as per this Policy, are used for the following purposes by CARTPANDA:
a) Comply with our contractual obligations, especially the execution of the terms of your contract;
b) Conduct checks required by the current legislation in Brazil through service providers;
c) Improve fraud prevention and anti-money laundering procedures;
d) Provide you with our services;
e) Address complaints, inquiries, or requests;
f) Enhance our security and protection procedures to provide a safer and more effective service;
g) Administer our service provision;
h) Compliance with legal and/or regulatory obligations imposed on CARTPANDA, including internal Know Your Customer, Anti-Money Laundering, and Counter-Terrorism Financing standards and others;
i) Perform internal operations, including customer support, issue resolution, data analysis, testing, research, and statistics;
j) Improve and enhance our services, ensuring they are presented in the most effective way for you;
k) Assess or understand the effectiveness of the advertising we serve, aiming to provide relevant advertisements to you;
l) Allow you to participate in interactive features of our services, when you choose to do so;
m) Provide information about other services and/or products we offer, similar to those already contracted by you;
n) Produce evidence and assist in conducting legal, administrative, or arbitration proceedings, as well as assist in meeting other legal requirements;
o) Investigations and measures to prevent and combat illegal activities, fraud, financial crimes, and ensure the security of Clients and their end Consumers and the financial system;
p) Marketing, prospecting, market research, and opinion polls;
q) Contact for updating registration information, in order to comply with legal obligations or clarify doubts regarding the receipt of any judicial or administrative process; and
r) Make automated decisions regarding the use of our services.
If you wish to receive more details on how your personal data will be processed by CARTPANDA based on the purposes described in this item, please send an email to dpo@cartpanda.com. All data provided by you actively or collected by us is considered confidential.
Therefore, we commit to adopting all technical and administrative measures capable of protecting your Personal Data, observing the guidelines on security standards established by current legislation.
6. RETENTION PERIOD OF PERSONAL DATA
The processing period of your Personal Data by CARTPANDA will vary according to:
a) The types of products and services contracted/provided/supplied;
b) The purposes of the processing; and
c) The applicable contractual and legal provisions.
Thus, Personal Data will be deleted by CARTPANDA, except if their storage is mandatory due to legal or regulatory compliance, in the following situations:
a) When the purpose for which the information was collected is achieved or when the Personal Data are no longer necessary or relevant for the purpose;
b) When consent is revoked; and
c) Upon determination by the competent authority for this purpose.
7. RIGHTS OF THE DATA SUBJECT
Depending on the law applicable to the processing of your personal data, you may have certain specific rights in relation to your personal information. A list of the applicable rights are given below:
Access to Data: You have the right to request a copy of your personal data processed by us, either electronically, through secure and appropriate means, or in hard copy, according to your preference.
Rectification: You have the right to request the correction of your personal data that is incomplete, inaccurate, or outdated.
Anonymization, Blocking, or Exclusion: If the processed data is unnecessary, excessive, or not compliant with regulations, you have the right to request its anonymization, blocking, or even deletion.
Portability: You have the right to request the portability of your personal data to other platforms, as per the regulations issued by the National Data Protection Authority, while ensuring the commercial and industrial secrecy of CARTPANDA.
Information on Sharing: You have the right to request information about the public and private entities with whom we share your personal data.
Information on Consent Denial: You have the right to receive information about the option to withhold consent, particularly when consent is the applicable legal basis for personal data processing, along with the indication of consequences resulting from such denial.
Consent Revocation: At any time, you have the right to easily and freely revoke previously given consent. It is important to note that revoking consent does not invalidate or render illegitimate any prior data processing activities.
Objection to Processing: In cases where consent is not the legal basis for processing your personal data, and when there is non-compliance with data protection laws, you have the right to object to the processing, providing your reasons for doing so. CARTPANDA will assess the justification of your objection and take necessary measures to suspend processing or provide grounds for lawful and permitted processing.
Complaint: You have the right to file a complaint regarding the processing of your personal data by CARTPANDA with the National Data Protection Authority. However, we encourage you to give us the opportunity to address any doubts or complaints directly before taking this step.
Deletion of Consent-based Data: In cases where consent serves as the legal basis for processing activities, you have the right to request deletion of such data, unless we are obligated to retain the data for legal or regulatory compliance purposes, or for defense in legal, administrative, or arbitral proceedings.
To assert your rights concerning the handling of your Personal Data, please direct your inquiries to our Data Protection Officer:
Data Protection Officer's Name: MATHEUS DE LIMA CARLOS.
Email Address: dpo@cartpanda.com
This channel is exclusively dedicated to addressing the rights of data subjects. CARTPANDA will make necessary efforts to fulfill such requests in the shortest possible timeframe. We emphasize that we may keep some data and/or continue processing, even in case of requests for deletion, objection, blocking, or anonymization, under certain circumstances, such as to comply with legal, contractual, and regulatory obligations, to safeguard and exercise CARTPANDA's rights, those of the Clients and their End Consumers, for the prevention of illicit acts, and in judicial, administrative, and arbitration proceedings, including third-party challenges to your activities, and in other cases provided for by law.
8. SHARING OF PERSONAL DATA
CARTPANDA values the privacy of its customers and, in compliance with data protection regulations and best market practices, only shares their information for the purposes outlined in this Policy.
Thus, we may share your information with the third parties listed below:
a) Among companies related to CARTPANDA;
b) With service providers, suppliers, and subcontractors for the perfect and correct execution of contracts entered into with them or with you;
c) With advertising and marketing companies, to select and deliver relevant ads to you, as authorized; and
d) With search engine and analytics providers, to assist in improvements and optimizations of our electronic channels, such as our website.
We may also disclose your personal information to third parties:
a) In the event of transactions and corporate changes involving CARTPANDA, in which case the transfer of data will be necessary for the continuity of the services offered;
b) To comply with applicable legislation;
c) To comply with contracts or other agreements with our clients;
d) To ensure greater security in transactions, preventing fraud attempts and other crimes, as well as for the protection of the rights and properties of CARTPANDA, our clients, or third parties. This includes the exchange of information for the purpose of fraud protection, money laundering prevention, and credit risk reduction;
e) To protect the interests of CARTPANDA in cases of demands and conflicts, including in judicial, administrative, and arbitration proceedings;
f) Upon court order or request from competent administrative authorities with legal competence for their request;
g) To evaluate financial risks; and
h) To pursue debt collection from customers and/or debt recovery.
Do not worry, any sharing of information is strictly limited to what is necessary and is conducted in accordance with stringent standards of security, confidentiality, and privacy protection regulations. We consistently uphold and ensure that third parties adhere to the confidentiality of your information.
9. INTERNATIONAL TRANSFER
CARTPANDA may share your Personal Data with business partners, service providers, suppliers, and subcontractors located in other countries for the purposes described in this Policy, such as:
a) Performing internal operations, including customer support;
b) Troubleshooting;
c) Data storage and analysis;
d) Testing;
e) Research and statistics; and
f) Fulfilling our contractual obligations, especially the execution of the terms of your contract with CARTPANDA and the provision of our products and services.
CARTPANDA will ensure that the transmission of your Personal Data complies with relevant privacy laws and that appropriate contractual, technical, and organizational measures are implemented to enhance the security of your Personal Data
10. FINAL CONSIDERATIONS
The terms of this Policy may be modified at any time due to legislative changes or changes in the services we provide, resulting from the updating of technological tools or at our discretion, such as due to the offering of new services.
Therefore, we recommend to our clients to always check the current Privacy Policy. If the changes are significant, you will be notified and will have the opportunity to review the new version of the Policy before deciding to continue using our services. This includes notification by email and pop-ups when accessing our electronic communication channels.
Your information will always be processed in accordance with this Policy. We will never reduce your rights established in this Policy without your explicit consent and in compliance with the Data Protection Law.
Any clause or condition of this Policy that, for any reason, is 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.
CARTPANDA's failure to enforce any rights or provisions of this Policy shall not constitute a waiver, and CARTPANDA may regularly exercise its right within the legal deadlines.
The use of our services implies express acceptance of the terms and conditions of the Privacy Policy in force on the date of use.
For Users who do not agree with the current Privacy Policy, we advise refraining from using the services. Non-acceptance or refusal to provide the requested information may result in the inability to provide such services.
This Policy comes into effect on the date of its publication and remains in force indefinitely.
11. LEGAL BASES OF PROCESSING
Legal Bases: The processing of personal data by CARTPANDA is always grounded on a legal basis provided for in the applicable legislation. The legal bases used by CARTPANDA may vary depending on the context of processing, and include the following:
Consent: When the User agrees to the processing of personal data, for instance, when consenting to receiving advertising or survey communications. This consent may be revoked at any time by the User.
Compliance with Legal or Regulatory Obligations: When CARTPANDA is obligated to process personal data due to a legal or regulatory requirement, such as storing access records for compliance with legislation on money laundering prevention.
Execution of Contract or Procedures Related to the Contract: When the processing of personal data is necessary for the execution of a contract signed between CARTPANDA and the data subject, or for procedures preliminary to the contract, such as processing payment data during a purchase on the Platform.
Exercise of Legal Rights in Judicial, Administrative, or Arbitral Proceedings: When there is a necessity to process personal data due to judicial, administrative, or arbitral action.
Legitimate Interest: When CARTPANDA decides to proceed with the processing of personal data after careful analysis, involving the evaluation of the purpose and necessity of the processing for the User, and the User's expectations regarding the processing of Personal Data. This legal basis is used, for example, when CARTPANDA sends out a newsletter related to the User's interests, based on their interaction with the Platform, to support and promote CARTPANDA's activities and enterprises. In such cases, CARTPANDA always provides the User with the option to unsubscribe from these communications.
12. VERSION HISTORY
1) Privacy Policy | EN-GB-001 | April 19, 2024.
1. PURPOSE
CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV” and collectively as “CARTPANDA” long with other companies within its Economic Group recognize and prioritize the privacy and security of your data. We acknowledge that safeguarding privacy is essential in demonstrating respect for our customers, partners, and collaborators. In addition to adhering to applicable laws, we are committed to conducting our operations based on the principles of transparency, partnership, security, and expertise. Consequently, CARTPANDA's Privacy Policy ("Policy") serves the following purposes:
a) Reinforce our commitment to privacy and security in the treatment of collected information;
b) Demonstrate, in a transparent and straightforward manner, what data we process, the reason and manner in which we collect, store, process, transfer, and query such data;
c) Present how we protect your data; and
d) Define when and how you can control your privacy preferences.
CARTPANDA is committed to adhering to stringent data security and protection standards to safeguard the confidentiality and integrity of our users' information. We consistently update our processes and technologies to align with the best practices in information security and current legislation.
Furthermore, we welcome feedback and suggestions from our Users to continuously enhance our services and privacy practices. Should you have any questions or concerns regarding our Privacy Policy, please feel free to contact us via email at our Data Protection Officer (DPO) at dpo@cartpanda.com. We are dedicated to assisting you and ensuring that your experience with us is secure and satisfactory.
2. SCOPE
This Policy covers all areas of CARTPANDA, its Administrators, Merchants, Merchants’ Consumers, Collaborators, Suppliers, and Business Partners, who must agree, adhere to, and commit to respecting what is established here.
CARTPANDA's Privacy Policy applies to all services offered by CARTPANDA that use Personal Data (as defined below) of customers, collaborators, and/or third parties ("Data Subjects").
Nevertheless, occasionally, we may make changes to this Policy. When we make relevant changes to this Policy, Data Subjects will be notified, either through a notice on our website, email, or other available means of communication.
Moreover, by accessing and utilizing the services provided by CARTPANDA, the Merchant and their Consumers fully acknowledge and consent to the provisions outlined in this Policy.
We advise you to always make sure to carefully read any notice of this nature.
3. DEFINITIONS
Data Processing Agents: those responsible for the Processing of Personal Data and are separated into two categories: the Controller and the Processor. The Controller is the person or company responsible for decisions regarding the Processing of Personal Data. The Processor, in turn, is the person or company that processes Personal Data on behalf of the Controller, following their instructions.
Anonymization: a technique by which data loses the possibility of direct or indirect association with an individual, so that it is subsequently impossible to re-identify even through technical solutions.
Cookies: small files containing a sequence of characters, created and sent by websites to your computer whenever you visit them. They help remember your preferences and customize your access, making your browsing safer, faster, and more enjoyable. You can configure your browser to not accept cookies or to notify you when a cookie is being sent, but without them, some features or services of the site may be compromised and limited.
Personal Data: information related to an identified natural person or information that allows their identification, such as name, address, individual taxpayer registry number), identity card, identity documents in general, phone number, among others.
Sensitive Data: Personal Data about racial or ethnic origin, religious belief, political opinion, membership in a union or religious, philosophical, or political organization, data relating to health or sexual life, genetic or biometric data when linked to a natural person.
Device: can be used to access the services offered by CARTPANDA, such as desktop computers, tablets, and smartphones.
Data Protection Officer ("DPO"): is responsible for ensuring that CARTPANDA complies with privacy laws and regulations, ensuring the protection of Personal Data and serving as the communication interface with regulatory entities and Data Subjects.
IP Address: is the number assigned to each Device connected to the internet, known as the Internet Protocol (IP) address. Generally, these numbers are assigned in geographical blocks. An IP address can be used to identify, for example, from which location a Device is connecting to the Internet.
Geolocation: a feature that, when activated by the Data Subject, allows for the precise or approximate position of a Device to be determined and provides information such as the country, state, city, and street where that Device is located, also providing the time it was accessed.
Economic Group: CARTPANDA TECNOLOGIA DE PAGAMENTOS LTDA, registered under CNPJ/MF No. 26.224.823/0001-94, headquartered at Avenida Francisco Monteiro, No. 1206, 3rd Floor, Room 306, Santana, Ribeirão Pires - SP, ZIP Code: 09406-300, hereinafter referred to as "Cartpanda BR"; CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV”.
Data Subject: any identified or identifiable natural person to whom the processed personal data refers. These include, for example, our clients, collaborators, third parties, service providers, job applicants, among others.
Processing: comprises any operation carried out with Personal Data, whether automated or not, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.
Users: Merchants of Cartpanda and their consumers.
4. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Considering the current legislation, we are committed to complying with the minimum requirements for registration, also ensuring an efficient and secure system for our Merchants and their Consumers.
In this context, various information is collected when you use our services or access our electronic channels, which fall into two distinct categories:
4.1. INFORMATION PROVIDED BY THE MERCHANT AND THEIR CONSUMERS
These are the types of information supplied by Merchants and their Consumers during interactions, contracting, or utilization of any services provided by CARTPANDA, including but not limited to: name, email, phone number, individual taxpayer registry number, address, and financial details such as credit card number and expiration date. We exclusively employ this information for financial purposes and to fulfill orders. Should any complications arise during order processing, we utilize this information to communicate with you.
Moreover, CARTPANDA Merchants may need to furnish images of their official identification documents, or any other Personal Data provided, to establish or modify their access accounts on the CARTPANDA Platform, or to engage in or terminate any services provided by CARTPANDA.
The verification and confirmation of personal data may, at the discretion of CARTPANDA, be conducted by third-party companies with whom CARTPANDA partners, subject to adherence to the same security and privacy criteria outlined herein.
It is important to emphasize that the Merchant shall bear sole and exclusive responsibility for the accuracy of the Personal Data provided to CARTPANDA during registration or when contracting any services.
CARTPANDA does not have any responsibility for the accuracy of the data provided, as well as for any data resulting from the inaccuracy and/or obsolescence of such information.
Therefore, if you reach out to us via email, we may retain your contact details along with a copy of the correspondence. Nevertheless, we maintain the prerogative to utilize your email address and any other personally identifiable information furnished by you to address your inquiries and disseminate promotional materials regarding our products and services. Rest assured, we shall refrain from disclosing your information to third parties for the purpose of soliciting their products and services.
Thus, it is emphasized that you have the option to modify your personally identifiable information, request the deletion of your data, or opt out of receiving marketing material at any time. Simply send an email to dpo@cartpanda.com to make such requests.
4.2. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Herein lie the data points collected by CARTPANDA during your browsing and/or utilization of its services, delineated as follows.
Navigation Data: This encompasses the information we gather regarding your interactions with our website, including:
a) Comments: When users leave comments on our site, we collect the information contained in the comment form, in addition to the IP address and information about the browser, we do this to be able to detect and prevent any spam.
b) Media: If you want to upload images to our site (in comments, for example), avoid sending images with embedded location data (EXIF GPS). Any site user can download and extract location information from the image.
c) Contact forms: If you leave a comment on our site, you may choose to save your name, email, and website using cookies. They are here only for your convenience so that you do not have to enter all your data again every time you want to comment on something. These cookies last for one year.
d) Cookies: If you have an account and log in to our site, we will create a temporary cookie to determine if your browser accepts cookies. This temporary cookie does not contain any personal information and is discarded as soon as you close your browser. When you log in, we create several cookies to save your login information and your display preferences. Login cookies last for two days, and display preference cookies last for one year. If you select "Remember me," the login cookie will have its duration extended to two weeks. If you log out of your account, login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie does not contain any personal information and is only used to indicate the ID of the article you made/edited. It expires after 1 day.
e) Embedded content from other websites: Pages and articles on this site may have embedded content (such as images, videos, external links, etc.). Embedded content from other sites should be considered exactly as if the user had accessed the other site. These sites may collect some information about you, use cookies, and other tracking and monitoring software regarding your interaction with embedded content if you have an account and are logged into that site.
f) Devices: Like most websites, our site may contain "pixel tags," cookies, or other similar tracking technologies, which allow us to look at user actions on our site. Pixel tags and cookies are used to collect non-personally identifiable information, such as your internet service provider's name, the type of browser you are using, the operating system, the type of device you are accessing our site on, and the date and time of access. We may aggregate your information with similar information to help us make improvements to our products, services, applications, content, and features offered on our site. We do not use non-personally identifiable information to create or maintain a profile of you or collect new information.
g) Geolocation: These are information we collect about your location, which allows us to: (i) ensure greater security for your transactions based on geographical location points (anti-fraud); (ii) identify the origin of a call received in our customer service channels. To determine your location, we use the following means: GPS (tracking the origin of the call) and/or IP Address (access to the system). The types of location data we collect depend on the Device and settings. You can enable or disable location tracking via GPS by accessing the Settings/Privacy option on your Device.
5. PERSONAL DATA PROCESSED BY CARTPANDA
The Personal Data collected, as per this Policy, are used for the following purposes by CARTPANDA:
a) Comply with our contractual obligations, especially the execution of the terms of your contract;
b) Conduct checks required by the current legislation in Brazil through service providers;
c) Improve fraud prevention and anti-money laundering procedures;
d) Provide you with our services;
e) Address complaints, inquiries, or requests;
f) Enhance our security and protection procedures to provide a safer and more effective service;
g) Administer our service provision;
h) Compliance with legal and/or regulatory obligations imposed on CARTPANDA, including internal Know Your Customer, Anti-Money Laundering, and Counter-Terrorism Financing standards and others;
i) Perform internal operations, including customer support, issue resolution, data analysis, testing, research, and statistics;
j) Improve and enhance our services, ensuring they are presented in the most effective way for you;
k) Assess or understand the effectiveness of the advertising we serve, aiming to provide relevant advertisements to you;
l) Allow you to participate in interactive features of our services, when you choose to do so;
m) Provide information about other services and/or products we offer, similar to those already contracted by you;
n) Produce evidence and assist in conducting legal, administrative, or arbitration proceedings, as well as assist in meeting other legal requirements;
o) Investigations and measures to prevent and combat illegal activities, fraud, financial crimes, and ensure the security of Clients and their end Consumers and the financial system;
p) Marketing, prospecting, market research, and opinion polls;
q) Contact for updating registration information, in order to comply with legal obligations or clarify doubts regarding the receipt of any judicial or administrative process; and
r) Make automated decisions regarding the use of our services.
If you wish to receive more details on how your personal data will be processed by CARTPANDA based on the purposes described in this item, please send an email to dpo@cartpanda.com. All data provided by you actively or collected by us is considered confidential.
Therefore, we commit to adopting all technical and administrative measures capable of protecting your Personal Data, observing the guidelines on security standards established by current legislation.
6. RETENTION PERIOD OF PERSONAL DATA
The processing period of your Personal Data by CARTPANDA will vary according to:
a) The types of products and services contracted/provided/supplied;
b) The purposes of the processing; and
c) The applicable contractual and legal provisions.
Thus, Personal Data will be deleted by CARTPANDA, except if their storage is mandatory due to legal or regulatory compliance, in the following situations:
a) When the purpose for which the information was collected is achieved or when the Personal Data are no longer necessary or relevant for the purpose;
b) When consent is revoked; and
c) Upon determination by the competent authority for this purpose.
7. RIGHTS OF THE DATA SUBJECT
Depending on the law applicable to the processing of your personal data, you may have certain specific rights in relation to your personal information. A list of the applicable rights are given below:
Access to Data: You have the right to request a copy of your personal data processed by us, either electronically, through secure and appropriate means, or in hard copy, according to your preference.
Rectification: You have the right to request the correction of your personal data that is incomplete, inaccurate, or outdated.
Anonymization, Blocking, or Exclusion: If the processed data is unnecessary, excessive, or not compliant with regulations, you have the right to request its anonymization, blocking, or even deletion.
Portability: You have the right to request the portability of your personal data to other platforms, as per the regulations issued by the National Data Protection Authority, while ensuring the commercial and industrial secrecy of CARTPANDA.
Information on Sharing: You have the right to request information about the public and private entities with whom we share your personal data.
Information on Consent Denial: You have the right to receive information about the option to withhold consent, particularly when consent is the applicable legal basis for personal data processing, along with the indication of consequences resulting from such denial.
Consent Revocation: At any time, you have the right to easily and freely revoke previously given consent. It is important to note that revoking consent does not invalidate or render illegitimate any prior data processing activities.
Objection to Processing: In cases where consent is not the legal basis for processing your personal data, and when there is non-compliance with data protection laws, you have the right to object to the processing, providing your reasons for doing so. CARTPANDA will assess the justification of your objection and take necessary measures to suspend processing or provide grounds for lawful and permitted processing.
Complaint: You have the right to file a complaint regarding the processing of your personal data by CARTPANDA with the National Data Protection Authority. However, we encourage you to give us the opportunity to address any doubts or complaints directly before taking this step.
Deletion of Consent-based Data: In cases where consent serves as the legal basis for processing activities, you have the right to request deletion of such data, unless we are obligated to retain the data for legal or regulatory compliance purposes, or for defense in legal, administrative, or arbitral proceedings.
To assert your rights concerning the handling of your Personal Data, please direct your inquiries to our Data Protection Officer:
Data Protection Officer's Name: MATHEUS DE LIMA CARLOS.
Email Address: dpo@cartpanda.com
This channel is exclusively dedicated to addressing the rights of data subjects. CARTPANDA will make necessary efforts to fulfill such requests in the shortest possible timeframe. We emphasize that we may keep some data and/or continue processing, even in case of requests for deletion, objection, blocking, or anonymization, under certain circumstances, such as to comply with legal, contractual, and regulatory obligations, to safeguard and exercise CARTPANDA's rights, those of the Clients and their End Consumers, for the prevention of illicit acts, and in judicial, administrative, and arbitration proceedings, including third-party challenges to your activities, and in other cases provided for by law.
8. SHARING OF PERSONAL DATA
CARTPANDA values the privacy of its customers and, in compliance with data protection regulations and best market practices, only shares their information for the purposes outlined in this Policy.
Thus, we may share your information with the third parties listed below:
a) Among companies related to CARTPANDA;
b) With service providers, suppliers, and subcontractors for the perfect and correct execution of contracts entered into with them or with you;
c) With advertising and marketing companies, to select and deliver relevant ads to you, as authorized; and
d) With search engine and analytics providers, to assist in improvements and optimizations of our electronic channels, such as our website.
We may also disclose your personal information to third parties:
a) In the event of transactions and corporate changes involving CARTPANDA, in which case the transfer of data will be necessary for the continuity of the services offered;
b) To comply with applicable legislation;
c) To comply with contracts or other agreements with our clients;
d) To ensure greater security in transactions, preventing fraud attempts and other crimes, as well as for the protection of the rights and properties of CARTPANDA, our clients, or third parties. This includes the exchange of information for the purpose of fraud protection, money laundering prevention, and credit risk reduction;
e) To protect the interests of CARTPANDA in cases of demands and conflicts, including in judicial, administrative, and arbitration proceedings;
f) Upon court order or request from competent administrative authorities with legal competence for their request;
g) To evaluate financial risks; and
h) To pursue debt collection from customers and/or debt recovery.
Do not worry, any sharing of information is strictly limited to what is necessary and is conducted in accordance with stringent standards of security, confidentiality, and privacy protection regulations. We consistently uphold and ensure that third parties adhere to the confidentiality of your information.
9. INTERNATIONAL TRANSFER
CARTPANDA may share your Personal Data with business partners, service providers, suppliers, and subcontractors located in other countries for the purposes described in this Policy, such as:
a) Performing internal operations, including customer support;
b) Troubleshooting;
c) Data storage and analysis;
d) Testing;
e) Research and statistics; and
f) Fulfilling our contractual obligations, especially the execution of the terms of your contract with CARTPANDA and the provision of our products and services.
CARTPANDA will ensure that the transmission of your Personal Data complies with relevant privacy laws and that appropriate contractual, technical, and organizational measures are implemented to enhance the security of your Personal Data
10. FINAL CONSIDERATIONS
The terms of this Policy may be modified at any time due to legislative changes or changes in the services we provide, resulting from the updating of technological tools or at our discretion, such as due to the offering of new services.
Therefore, we recommend to our clients to always check the current Privacy Policy. If the changes are significant, you will be notified and will have the opportunity to review the new version of the Policy before deciding to continue using our services. This includes notification by email and pop-ups when accessing our electronic communication channels.
Your information will always be processed in accordance with this Policy. We will never reduce your rights established in this Policy without your explicit consent and in compliance with the Data Protection Law.
Any clause or condition of this Policy that, for any reason, is 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.
CARTPANDA's failure to enforce any rights or provisions of this Policy shall not constitute a waiver, and CARTPANDA may regularly exercise its right within the legal deadlines.
The use of our services implies express acceptance of the terms and conditions of the Privacy Policy in force on the date of use.
For Users who do not agree with the current Privacy Policy, we advise refraining from using the services. Non-acceptance or refusal to provide the requested information may result in the inability to provide such services.
This Policy comes into effect on the date of its publication and remains in force indefinitely.
11. LEGAL BASES OF PROCESSING
Legal Bases: The processing of personal data by CARTPANDA is always grounded on a legal basis provided for in the applicable legislation. The legal bases used by CARTPANDA may vary depending on the context of processing, and include the following:
Consent: When the User agrees to the processing of personal data, for instance, when consenting to receiving advertising or survey communications. This consent may be revoked at any time by the User.
Compliance with Legal or Regulatory Obligations: When CARTPANDA is obligated to process personal data due to a legal or regulatory requirement, such as storing access records for compliance with legislation on money laundering prevention.
Execution of Contract or Procedures Related to the Contract: When the processing of personal data is necessary for the execution of a contract signed between CARTPANDA and the data subject, or for procedures preliminary to the contract, such as processing payment data during a purchase on the Platform.
Exercise of Legal Rights in Judicial, Administrative, or Arbitral Proceedings: When there is a necessity to process personal data due to judicial, administrative, or arbitral action.
Legitimate Interest: When CARTPANDA decides to proceed with the processing of personal data after careful analysis, involving the evaluation of the purpose and necessity of the processing for the User, and the User's expectations regarding the processing of Personal Data. This legal basis is used, for example, when CARTPANDA sends out a newsletter related to the User's interests, based on their interaction with the Platform, to support and promote CARTPANDA's activities and enterprises. In such cases, CARTPANDA always provides the User with the option to unsubscribe from these communications.
12. VERSION HISTORY
1) Privacy Policy | EN-GB-001 | April 19, 2024.
1. PURPOSE
CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV” and collectively as “CARTPANDA” long with other companies within its Economic Group recognize and prioritize the privacy and security of your data. We acknowledge that safeguarding privacy is essential in demonstrating respect for our customers, partners, and collaborators. In addition to adhering to applicable laws, we are committed to conducting our operations based on the principles of transparency, partnership, security, and expertise. Consequently, CARTPANDA's Privacy Policy ("Policy") serves the following purposes:
a) Reinforce our commitment to privacy and security in the treatment of collected information;
b) Demonstrate, in a transparent and straightforward manner, what data we process, the reason and manner in which we collect, store, process, transfer, and query such data;
c) Present how we protect your data; and
d) Define when and how you can control your privacy preferences.
CARTPANDA is committed to adhering to stringent data security and protection standards to safeguard the confidentiality and integrity of our users' information. We consistently update our processes and technologies to align with the best practices in information security and current legislation.
Furthermore, we welcome feedback and suggestions from our Users to continuously enhance our services and privacy practices. Should you have any questions or concerns regarding our Privacy Policy, please feel free to contact us via email at our Data Protection Officer (DPO) at dpo@cartpanda.com. We are dedicated to assisting you and ensuring that your experience with us is secure and satisfactory.
2. SCOPE
This Policy covers all areas of CARTPANDA, its Administrators, Merchants, Merchants’ Consumers, Collaborators, Suppliers, and Business Partners, who must agree, adhere to, and commit to respecting what is established here.
CARTPANDA's Privacy Policy applies to all services offered by CARTPANDA that use Personal Data (as defined below) of customers, collaborators, and/or third parties ("Data Subjects").
Nevertheless, occasionally, we may make changes to this Policy. When we make relevant changes to this Policy, Data Subjects will be notified, either through a notice on our website, email, or other available means of communication.
Moreover, by accessing and utilizing the services provided by CARTPANDA, the Merchant and their Consumers fully acknowledge and consent to the provisions outlined in this Policy.
We advise you to always make sure to carefully read any notice of this nature.
3. DEFINITIONS
Data Processing Agents: those responsible for the Processing of Personal Data and are separated into two categories: the Controller and the Processor. The Controller is the person or company responsible for decisions regarding the Processing of Personal Data. The Processor, in turn, is the person or company that processes Personal Data on behalf of the Controller, following their instructions.
Anonymization: a technique by which data loses the possibility of direct or indirect association with an individual, so that it is subsequently impossible to re-identify even through technical solutions.
Cookies: small files containing a sequence of characters, created and sent by websites to your computer whenever you visit them. They help remember your preferences and customize your access, making your browsing safer, faster, and more enjoyable. You can configure your browser to not accept cookies or to notify you when a cookie is being sent, but without them, some features or services of the site may be compromised and limited.
Personal Data: information related to an identified natural person or information that allows their identification, such as name, address, individual taxpayer registry number), identity card, identity documents in general, phone number, among others.
Sensitive Data: Personal Data about racial or ethnic origin, religious belief, political opinion, membership in a union or religious, philosophical, or political organization, data relating to health or sexual life, genetic or biometric data when linked to a natural person.
Device: can be used to access the services offered by CARTPANDA, such as desktop computers, tablets, and smartphones.
Data Protection Officer ("DPO"): is responsible for ensuring that CARTPANDA complies with privacy laws and regulations, ensuring the protection of Personal Data and serving as the communication interface with regulatory entities and Data Subjects.
IP Address: is the number assigned to each Device connected to the internet, known as the Internet Protocol (IP) address. Generally, these numbers are assigned in geographical blocks. An IP address can be used to identify, for example, from which location a Device is connecting to the Internet.
Geolocation: a feature that, when activated by the Data Subject, allows for the precise or approximate position of a Device to be determined and provides information such as the country, state, city, and street where that Device is located, also providing the time it was accessed.
Economic Group: CARTPANDA TECNOLOGIA DE PAGAMENTOS LTDA, registered under CNPJ/MF No. 26.224.823/0001-94, headquartered at Avenida Francisco Monteiro, No. 1206, 3rd Floor, Room 306, Santana, Ribeirão Pires - SP, ZIP Code: 09406-300, hereinafter referred to as "Cartpanda BR"; CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV”.
Data Subject: any identified or identifiable natural person to whom the processed personal data refers. These include, for example, our clients, collaborators, third parties, service providers, job applicants, among others.
Processing: comprises any operation carried out with Personal Data, whether automated or not, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.
Users: Merchants of Cartpanda and their consumers.
4. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Considering the current legislation, we are committed to complying with the minimum requirements for registration, also ensuring an efficient and secure system for our Merchants and their Consumers.
In this context, various information is collected when you use our services or access our electronic channels, which fall into two distinct categories:
4.1. INFORMATION PROVIDED BY THE MERCHANT AND THEIR CONSUMERS
These are the types of information supplied by Merchants and their Consumers during interactions, contracting, or utilization of any services provided by CARTPANDA, including but not limited to: name, email, phone number, individual taxpayer registry number, address, and financial details such as credit card number and expiration date. We exclusively employ this information for financial purposes and to fulfill orders. Should any complications arise during order processing, we utilize this information to communicate with you.
Moreover, CARTPANDA Merchants may need to furnish images of their official identification documents, or any other Personal Data provided, to establish or modify their access accounts on the CARTPANDA Platform, or to engage in or terminate any services provided by CARTPANDA.
The verification and confirmation of personal data may, at the discretion of CARTPANDA, be conducted by third-party companies with whom CARTPANDA partners, subject to adherence to the same security and privacy criteria outlined herein.
It is important to emphasize that the Merchant shall bear sole and exclusive responsibility for the accuracy of the Personal Data provided to CARTPANDA during registration or when contracting any services.
CARTPANDA does not have any responsibility for the accuracy of the data provided, as well as for any data resulting from the inaccuracy and/or obsolescence of such information.
Therefore, if you reach out to us via email, we may retain your contact details along with a copy of the correspondence. Nevertheless, we maintain the prerogative to utilize your email address and any other personally identifiable information furnished by you to address your inquiries and disseminate promotional materials regarding our products and services. Rest assured, we shall refrain from disclosing your information to third parties for the purpose of soliciting their products and services.
Thus, it is emphasized that you have the option to modify your personally identifiable information, request the deletion of your data, or opt out of receiving marketing material at any time. Simply send an email to dpo@cartpanda.com to make such requests.
4.2. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Herein lie the data points collected by CARTPANDA during your browsing and/or utilization of its services, delineated as follows.
Navigation Data: This encompasses the information we gather regarding your interactions with our website, including:
a) Comments: When users leave comments on our site, we collect the information contained in the comment form, in addition to the IP address and information about the browser, we do this to be able to detect and prevent any spam.
b) Media: If you want to upload images to our site (in comments, for example), avoid sending images with embedded location data (EXIF GPS). Any site user can download and extract location information from the image.
c) Contact forms: If you leave a comment on our site, you may choose to save your name, email, and website using cookies. They are here only for your convenience so that you do not have to enter all your data again every time you want to comment on something. These cookies last for one year.
d) Cookies: If you have an account and log in to our site, we will create a temporary cookie to determine if your browser accepts cookies. This temporary cookie does not contain any personal information and is discarded as soon as you close your browser. When you log in, we create several cookies to save your login information and your display preferences. Login cookies last for two days, and display preference cookies last for one year. If you select "Remember me," the login cookie will have its duration extended to two weeks. If you log out of your account, login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie does not contain any personal information and is only used to indicate the ID of the article you made/edited. It expires after 1 day.
e) Embedded content from other websites: Pages and articles on this site may have embedded content (such as images, videos, external links, etc.). Embedded content from other sites should be considered exactly as if the user had accessed the other site. These sites may collect some information about you, use cookies, and other tracking and monitoring software regarding your interaction with embedded content if you have an account and are logged into that site.
f) Devices: Like most websites, our site may contain "pixel tags," cookies, or other similar tracking technologies, which allow us to look at user actions on our site. Pixel tags and cookies are used to collect non-personally identifiable information, such as your internet service provider's name, the type of browser you are using, the operating system, the type of device you are accessing our site on, and the date and time of access. We may aggregate your information with similar information to help us make improvements to our products, services, applications, content, and features offered on our site. We do not use non-personally identifiable information to create or maintain a profile of you or collect new information.
g) Geolocation: These are information we collect about your location, which allows us to: (i) ensure greater security for your transactions based on geographical location points (anti-fraud); (ii) identify the origin of a call received in our customer service channels. To determine your location, we use the following means: GPS (tracking the origin of the call) and/or IP Address (access to the system). The types of location data we collect depend on the Device and settings. You can enable or disable location tracking via GPS by accessing the Settings/Privacy option on your Device.
5. PERSONAL DATA PROCESSED BY CARTPANDA
The Personal Data collected, as per this Policy, are used for the following purposes by CARTPANDA:
a) Comply with our contractual obligations, especially the execution of the terms of your contract;
b) Conduct checks required by the current legislation in Brazil through service providers;
c) Improve fraud prevention and anti-money laundering procedures;
d) Provide you with our services;
e) Address complaints, inquiries, or requests;
f) Enhance our security and protection procedures to provide a safer and more effective service;
g) Administer our service provision;
h) Compliance with legal and/or regulatory obligations imposed on CARTPANDA, including internal Know Your Customer, Anti-Money Laundering, and Counter-Terrorism Financing standards and others;
i) Perform internal operations, including customer support, issue resolution, data analysis, testing, research, and statistics;
j) Improve and enhance our services, ensuring they are presented in the most effective way for you;
k) Assess or understand the effectiveness of the advertising we serve, aiming to provide relevant advertisements to you;
l) Allow you to participate in interactive features of our services, when you choose to do so;
m) Provide information about other services and/or products we offer, similar to those already contracted by you;
n) Produce evidence and assist in conducting legal, administrative, or arbitration proceedings, as well as assist in meeting other legal requirements;
o) Investigations and measures to prevent and combat illegal activities, fraud, financial crimes, and ensure the security of Clients and their end Consumers and the financial system;
p) Marketing, prospecting, market research, and opinion polls;
q) Contact for updating registration information, in order to comply with legal obligations or clarify doubts regarding the receipt of any judicial or administrative process; and
r) Make automated decisions regarding the use of our services.
If you wish to receive more details on how your personal data will be processed by CARTPANDA based on the purposes described in this item, please send an email to dpo@cartpanda.com. All data provided by you actively or collected by us is considered confidential.
Therefore, we commit to adopting all technical and administrative measures capable of protecting your Personal Data, observing the guidelines on security standards established by current legislation.
6. RETENTION PERIOD OF PERSONAL DATA
The processing period of your Personal Data by CARTPANDA will vary according to:
a) The types of products and services contracted/provided/supplied;
b) The purposes of the processing; and
c) The applicable contractual and legal provisions.
Thus, Personal Data will be deleted by CARTPANDA, except if their storage is mandatory due to legal or regulatory compliance, in the following situations:
a) When the purpose for which the information was collected is achieved or when the Personal Data are no longer necessary or relevant for the purpose;
b) When consent is revoked; and
c) Upon determination by the competent authority for this purpose.
7. RIGHTS OF THE DATA SUBJECT
Depending on the law applicable to the processing of your personal data, you may have certain specific rights in relation to your personal information. A list of the applicable rights are given below:
Access to Data: You have the right to request a copy of your personal data processed by us, either electronically, through secure and appropriate means, or in hard copy, according to your preference.
Rectification: You have the right to request the correction of your personal data that is incomplete, inaccurate, or outdated.
Anonymization, Blocking, or Exclusion: If the processed data is unnecessary, excessive, or not compliant with regulations, you have the right to request its anonymization, blocking, or even deletion.
Portability: You have the right to request the portability of your personal data to other platforms, as per the regulations issued by the National Data Protection Authority, while ensuring the commercial and industrial secrecy of CARTPANDA.
Information on Sharing: You have the right to request information about the public and private entities with whom we share your personal data.
Information on Consent Denial: You have the right to receive information about the option to withhold consent, particularly when consent is the applicable legal basis for personal data processing, along with the indication of consequences resulting from such denial.
Consent Revocation: At any time, you have the right to easily and freely revoke previously given consent. It is important to note that revoking consent does not invalidate or render illegitimate any prior data processing activities.
Objection to Processing: In cases where consent is not the legal basis for processing your personal data, and when there is non-compliance with data protection laws, you have the right to object to the processing, providing your reasons for doing so. CARTPANDA will assess the justification of your objection and take necessary measures to suspend processing or provide grounds for lawful and permitted processing.
Complaint: You have the right to file a complaint regarding the processing of your personal data by CARTPANDA with the National Data Protection Authority. However, we encourage you to give us the opportunity to address any doubts or complaints directly before taking this step.
Deletion of Consent-based Data: In cases where consent serves as the legal basis for processing activities, you have the right to request deletion of such data, unless we are obligated to retain the data for legal or regulatory compliance purposes, or for defense in legal, administrative, or arbitral proceedings.
To assert your rights concerning the handling of your Personal Data, please direct your inquiries to our Data Protection Officer:
Data Protection Officer's Name: MATHEUS DE LIMA CARLOS.
Email Address: dpo@cartpanda.com
This channel is exclusively dedicated to addressing the rights of data subjects. CARTPANDA will make necessary efforts to fulfill such requests in the shortest possible timeframe. We emphasize that we may keep some data and/or continue processing, even in case of requests for deletion, objection, blocking, or anonymization, under certain circumstances, such as to comply with legal, contractual, and regulatory obligations, to safeguard and exercise CARTPANDA's rights, those of the Clients and their End Consumers, for the prevention of illicit acts, and in judicial, administrative, and arbitration proceedings, including third-party challenges to your activities, and in other cases provided for by law.
8. SHARING OF PERSONAL DATA
CARTPANDA values the privacy of its customers and, in compliance with data protection regulations and best market practices, only shares their information for the purposes outlined in this Policy.
Thus, we may share your information with the third parties listed below:
a) Among companies related to CARTPANDA;
b) With service providers, suppliers, and subcontractors for the perfect and correct execution of contracts entered into with them or with you;
c) With advertising and marketing companies, to select and deliver relevant ads to you, as authorized; and
d) With search engine and analytics providers, to assist in improvements and optimizations of our electronic channels, such as our website.
We may also disclose your personal information to third parties:
a) In the event of transactions and corporate changes involving CARTPANDA, in which case the transfer of data will be necessary for the continuity of the services offered;
b) To comply with applicable legislation;
c) To comply with contracts or other agreements with our clients;
d) To ensure greater security in transactions, preventing fraud attempts and other crimes, as well as for the protection of the rights and properties of CARTPANDA, our clients, or third parties. This includes the exchange of information for the purpose of fraud protection, money laundering prevention, and credit risk reduction;
e) To protect the interests of CARTPANDA in cases of demands and conflicts, including in judicial, administrative, and arbitration proceedings;
f) Upon court order or request from competent administrative authorities with legal competence for their request;
g) To evaluate financial risks; and
h) To pursue debt collection from customers and/or debt recovery.
Do not worry, any sharing of information is strictly limited to what is necessary and is conducted in accordance with stringent standards of security, confidentiality, and privacy protection regulations. We consistently uphold and ensure that third parties adhere to the confidentiality of your information.
9. INTERNATIONAL TRANSFER
CARTPANDA may share your Personal Data with business partners, service providers, suppliers, and subcontractors located in other countries for the purposes described in this Policy, such as:
a) Performing internal operations, including customer support;
b) Troubleshooting;
c) Data storage and analysis;
d) Testing;
e) Research and statistics; and
f) Fulfilling our contractual obligations, especially the execution of the terms of your contract with CARTPANDA and the provision of our products and services.
CARTPANDA will ensure that the transmission of your Personal Data complies with relevant privacy laws and that appropriate contractual, technical, and organizational measures are implemented to enhance the security of your Personal Data
10. FINAL CONSIDERATIONS
The terms of this Policy may be modified at any time due to legislative changes or changes in the services we provide, resulting from the updating of technological tools or at our discretion, such as due to the offering of new services.
Therefore, we recommend to our clients to always check the current Privacy Policy. If the changes are significant, you will be notified and will have the opportunity to review the new version of the Policy before deciding to continue using our services. This includes notification by email and pop-ups when accessing our electronic communication channels.
Your information will always be processed in accordance with this Policy. We will never reduce your rights established in this Policy without your explicit consent and in compliance with the Data Protection Law.
Any clause or condition of this Policy that, for any reason, is 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.
CARTPANDA's failure to enforce any rights or provisions of this Policy shall not constitute a waiver, and CARTPANDA may regularly exercise its right within the legal deadlines.
The use of our services implies express acceptance of the terms and conditions of the Privacy Policy in force on the date of use.
For Users who do not agree with the current Privacy Policy, we advise refraining from using the services. Non-acceptance or refusal to provide the requested information may result in the inability to provide such services.
This Policy comes into effect on the date of its publication and remains in force indefinitely.
11. LEGAL BASES OF PROCESSING
Legal Bases: The processing of personal data by CARTPANDA is always grounded on a legal basis provided for in the applicable legislation. The legal bases used by CARTPANDA may vary depending on the context of processing, and include the following:
Consent: When the User agrees to the processing of personal data, for instance, when consenting to receiving advertising or survey communications. This consent may be revoked at any time by the User.
Compliance with Legal or Regulatory Obligations: When CARTPANDA is obligated to process personal data due to a legal or regulatory requirement, such as storing access records for compliance with legislation on money laundering prevention.
Execution of Contract or Procedures Related to the Contract: When the processing of personal data is necessary for the execution of a contract signed between CARTPANDA and the data subject, or for procedures preliminary to the contract, such as processing payment data during a purchase on the Platform.
Exercise of Legal Rights in Judicial, Administrative, or Arbitral Proceedings: When there is a necessity to process personal data due to judicial, administrative, or arbitral action.
Legitimate Interest: When CARTPANDA decides to proceed with the processing of personal data after careful analysis, involving the evaluation of the purpose and necessity of the processing for the User, and the User's expectations regarding the processing of Personal Data. This legal basis is used, for example, when CARTPANDA sends out a newsletter related to the User's interests, based on their interaction with the Platform, to support and promote CARTPANDA's activities and enterprises. In such cases, CARTPANDA always provides the User with the option to unsubscribe from these communications.
12. VERSION HISTORY
1) Privacy Policy | EN-GB-001 | April 19, 2024.
1. PURPOSE
CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV” and collectively as “CARTPANDA” long with other companies within its Economic Group recognize and prioritize the privacy and security of your data. We acknowledge that safeguarding privacy is essential in demonstrating respect for our customers, partners, and collaborators. In addition to adhering to applicable laws, we are committed to conducting our operations based on the principles of transparency, partnership, security, and expertise. Consequently, CARTPANDA's Privacy Policy ("Policy") serves the following purposes:
a) Reinforce our commitment to privacy and security in the treatment of collected information;
b) Demonstrate, in a transparent and straightforward manner, what data we process, the reason and manner in which we collect, store, process, transfer, and query such data;
c) Present how we protect your data; and
d) Define when and how you can control your privacy preferences.
CARTPANDA is committed to adhering to stringent data security and protection standards to safeguard the confidentiality and integrity of our users' information. We consistently update our processes and technologies to align with the best practices in information security and current legislation.
Furthermore, we welcome feedback and suggestions from our Users to continuously enhance our services and privacy practices. Should you have any questions or concerns regarding our Privacy Policy, please feel free to contact us via email at our Data Protection Officer (DPO) at dpo@cartpanda.com. We are dedicated to assisting you and ensuring that your experience with us is secure and satisfactory.
2. SCOPE
This Policy covers all areas of CARTPANDA, its Administrators, Merchants, Merchants’ Consumers, Collaborators, Suppliers, and Business Partners, who must agree, adhere to, and commit to respecting what is established here.
CARTPANDA's Privacy Policy applies to all services offered by CARTPANDA that use Personal Data (as defined below) of customers, collaborators, and/or third parties ("Data Subjects").
Nevertheless, occasionally, we may make changes to this Policy. When we make relevant changes to this Policy, Data Subjects will be notified, either through a notice on our website, email, or other available means of communication.
Moreover, by accessing and utilizing the services provided by CARTPANDA, the Merchant and their Consumers fully acknowledge and consent to the provisions outlined in this Policy.
We advise you to always make sure to carefully read any notice of this nature.
3. DEFINITIONS
Data Processing Agents: those responsible for the Processing of Personal Data and are separated into two categories: the Controller and the Processor. The Controller is the person or company responsible for decisions regarding the Processing of Personal Data. The Processor, in turn, is the person or company that processes Personal Data on behalf of the Controller, following their instructions.
Anonymization: a technique by which data loses the possibility of direct or indirect association with an individual, so that it is subsequently impossible to re-identify even through technical solutions.
Cookies: small files containing a sequence of characters, created and sent by websites to your computer whenever you visit them. They help remember your preferences and customize your access, making your browsing safer, faster, and more enjoyable. You can configure your browser to not accept cookies or to notify you when a cookie is being sent, but without them, some features or services of the site may be compromised and limited.
Personal Data: information related to an identified natural person or information that allows their identification, such as name, address, individual taxpayer registry number), identity card, identity documents in general, phone number, among others.
Sensitive Data: Personal Data about racial or ethnic origin, religious belief, political opinion, membership in a union or religious, philosophical, or political organization, data relating to health or sexual life, genetic or biometric data when linked to a natural person.
Device: can be used to access the services offered by CARTPANDA, such as desktop computers, tablets, and smartphones.
Data Protection Officer ("DPO"): is responsible for ensuring that CARTPANDA complies with privacy laws and regulations, ensuring the protection of Personal Data and serving as the communication interface with regulatory entities and Data Subjects.
IP Address: is the number assigned to each Device connected to the internet, known as the Internet Protocol (IP) address. Generally, these numbers are assigned in geographical blocks. An IP address can be used to identify, for example, from which location a Device is connecting to the Internet.
Geolocation: a feature that, when activated by the Data Subject, allows for the precise or approximate position of a Device to be determined and provides information such as the country, state, city, and street where that Device is located, also providing the time it was accessed.
Economic Group: CARTPANDA TECNOLOGIA DE PAGAMENTOS LTDA, registered under CNPJ/MF No. 26.224.823/0001-94, headquartered at Avenida Francisco Monteiro, No. 1206, 3rd Floor, Room 306, Santana, Ribeirão Pires - SP, ZIP Code: 09406-300, hereinafter referred to as "Cartpanda BR"; CARTPANDA INC., a corporation organized and existing under the laws of the State of Delaware, having its business address at 251 Little Falls Drive, Wilmington, New Castle, Delaware 19808, hereinafter referred to as “Cartpanda USA”; and CARTPANDA B.V., a Dutch company, headquartered at Grubbehoeve 431, Amsterdam, Netherlands, 1103GZ, KVK registration No. 93401116 and VAT: NL866381193B01 hereinafter referred to as “Cartpanda BV”.
Data Subject: any identified or identifiable natural person to whom the processed personal data refers. These include, for example, our clients, collaborators, third parties, service providers, job applicants, among others.
Processing: comprises any operation carried out with Personal Data, whether automated or not, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.
Users: Merchants of Cartpanda and their consumers.
4. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Considering the current legislation, we are committed to complying with the minimum requirements for registration, also ensuring an efficient and secure system for our Merchants and their Consumers.
In this context, various information is collected when you use our services or access our electronic channels, which fall into two distinct categories:
4.1. INFORMATION PROVIDED BY THE MERCHANT AND THEIR CONSUMERS
These are the types of information supplied by Merchants and their Consumers during interactions, contracting, or utilization of any services provided by CARTPANDA, including but not limited to: name, email, phone number, individual taxpayer registry number, address, and financial details such as credit card number and expiration date. We exclusively employ this information for financial purposes and to fulfill orders. Should any complications arise during order processing, we utilize this information to communicate with you.
Moreover, CARTPANDA Merchants may need to furnish images of their official identification documents, or any other Personal Data provided, to establish or modify their access accounts on the CARTPANDA Platform, or to engage in or terminate any services provided by CARTPANDA.
The verification and confirmation of personal data may, at the discretion of CARTPANDA, be conducted by third-party companies with whom CARTPANDA partners, subject to adherence to the same security and privacy criteria outlined herein.
It is important to emphasize that the Merchant shall bear sole and exclusive responsibility for the accuracy of the Personal Data provided to CARTPANDA during registration or when contracting any services.
CARTPANDA does not have any responsibility for the accuracy of the data provided, as well as for any data resulting from the inaccuracy and/or obsolescence of such information.
Therefore, if you reach out to us via email, we may retain your contact details along with a copy of the correspondence. Nevertheless, we maintain the prerogative to utilize your email address and any other personally identifiable information furnished by you to address your inquiries and disseminate promotional materials regarding our products and services. Rest assured, we shall refrain from disclosing your information to third parties for the purpose of soliciting their products and services.
Thus, it is emphasized that you have the option to modify your personally identifiable information, request the deletion of your data, or opt out of receiving marketing material at any time. Simply send an email to dpo@cartpanda.com to make such requests.
4.2. DATA COLLECTED UPON ACCESSING CARTPANDA’S SERVICES
Herein lie the data points collected by CARTPANDA during your browsing and/or utilization of its services, delineated as follows.
Navigation Data: This encompasses the information we gather regarding your interactions with our website, including:
a) Comments: When users leave comments on our site, we collect the information contained in the comment form, in addition to the IP address and information about the browser, we do this to be able to detect and prevent any spam.
b) Media: If you want to upload images to our site (in comments, for example), avoid sending images with embedded location data (EXIF GPS). Any site user can download and extract location information from the image.
c) Contact forms: If you leave a comment on our site, you may choose to save your name, email, and website using cookies. They are here only for your convenience so that you do not have to enter all your data again every time you want to comment on something. These cookies last for one year.
d) Cookies: If you have an account and log in to our site, we will create a temporary cookie to determine if your browser accepts cookies. This temporary cookie does not contain any personal information and is discarded as soon as you close your browser. When you log in, we create several cookies to save your login information and your display preferences. Login cookies last for two days, and display preference cookies last for one year. If you select "Remember me," the login cookie will have its duration extended to two weeks. If you log out of your account, login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie does not contain any personal information and is only used to indicate the ID of the article you made/edited. It expires after 1 day.
e) Embedded content from other websites: Pages and articles on this site may have embedded content (such as images, videos, external links, etc.). Embedded content from other sites should be considered exactly as if the user had accessed the other site. These sites may collect some information about you, use cookies, and other tracking and monitoring software regarding your interaction with embedded content if you have an account and are logged into that site.
f) Devices: Like most websites, our site may contain "pixel tags," cookies, or other similar tracking technologies, which allow us to look at user actions on our site. Pixel tags and cookies are used to collect non-personally identifiable information, such as your internet service provider's name, the type of browser you are using, the operating system, the type of device you are accessing our site on, and the date and time of access. We may aggregate your information with similar information to help us make improvements to our products, services, applications, content, and features offered on our site. We do not use non-personally identifiable information to create or maintain a profile of you or collect new information.
g) Geolocation: These are information we collect about your location, which allows us to: (i) ensure greater security for your transactions based on geographical location points (anti-fraud); (ii) identify the origin of a call received in our customer service channels. To determine your location, we use the following means: GPS (tracking the origin of the call) and/or IP Address (access to the system). The types of location data we collect depend on the Device and settings. You can enable or disable location tracking via GPS by accessing the Settings/Privacy option on your Device.
5. PERSONAL DATA PROCESSED BY CARTPANDA
The Personal Data collected, as per this Policy, are used for the following purposes by CARTPANDA:
a) Comply with our contractual obligations, especially the execution of the terms of your contract;
b) Conduct checks required by the current legislation in Brazil through service providers;
c) Improve fraud prevention and anti-money laundering procedures;
d) Provide you with our services;
e) Address complaints, inquiries, or requests;
f) Enhance our security and protection procedures to provide a safer and more effective service;
g) Administer our service provision;
h) Compliance with legal and/or regulatory obligations imposed on CARTPANDA, including internal Know Your Customer, Anti-Money Laundering, and Counter-Terrorism Financing standards and others;
i) Perform internal operations, including customer support, issue resolution, data analysis, testing, research, and statistics;
j) Improve and enhance our services, ensuring they are presented in the most effective way for you;
k) Assess or understand the effectiveness of the advertising we serve, aiming to provide relevant advertisements to you;
l) Allow you to participate in interactive features of our services, when you choose to do so;
m) Provide information about other services and/or products we offer, similar to those already contracted by you;
n) Produce evidence and assist in conducting legal, administrative, or arbitration proceedings, as well as assist in meeting other legal requirements;
o) Investigations and measures to prevent and combat illegal activities, fraud, financial crimes, and ensure the security of Clients and their end Consumers and the financial system;
p) Marketing, prospecting, market research, and opinion polls;
q) Contact for updating registration information, in order to comply with legal obligations or clarify doubts regarding the receipt of any judicial or administrative process; and
r) Make automated decisions regarding the use of our services.
If you wish to receive more details on how your personal data will be processed by CARTPANDA based on the purposes described in this item, please send an email to dpo@cartpanda.com. All data provided by you actively or collected by us is considered confidential.
Therefore, we commit to adopting all technical and administrative measures capable of protecting your Personal Data, observing the guidelines on security standards established by current legislation.
6. RETENTION PERIOD OF PERSONAL DATA
The processing period of your Personal Data by CARTPANDA will vary according to:
a) The types of products and services contracted/provided/supplied;
b) The purposes of the processing; and
c) The applicable contractual and legal provisions.
Thus, Personal Data will be deleted by CARTPANDA, except if their storage is mandatory due to legal or regulatory compliance, in the following situations:
a) When the purpose for which the information was collected is achieved or when the Personal Data are no longer necessary or relevant for the purpose;
b) When consent is revoked; and
c) Upon determination by the competent authority for this purpose.
7. RIGHTS OF THE DATA SUBJECT
Depending on the law applicable to the processing of your personal data, you may have certain specific rights in relation to your personal information. A list of the applicable rights are given below:
Access to Data: You have the right to request a copy of your personal data processed by us, either electronically, through secure and appropriate means, or in hard copy, according to your preference.
Rectification: You have the right to request the correction of your personal data that is incomplete, inaccurate, or outdated.
Anonymization, Blocking, or Exclusion: If the processed data is unnecessary, excessive, or not compliant with regulations, you have the right to request its anonymization, blocking, or even deletion.
Portability: You have the right to request the portability of your personal data to other platforms, as per the regulations issued by the National Data Protection Authority, while ensuring the commercial and industrial secrecy of CARTPANDA.
Information on Sharing: You have the right to request information about the public and private entities with whom we share your personal data.
Information on Consent Denial: You have the right to receive information about the option to withhold consent, particularly when consent is the applicable legal basis for personal data processing, along with the indication of consequences resulting from such denial.
Consent Revocation: At any time, you have the right to easily and freely revoke previously given consent. It is important to note that revoking consent does not invalidate or render illegitimate any prior data processing activities.
Objection to Processing: In cases where consent is not the legal basis for processing your personal data, and when there is non-compliance with data protection laws, you have the right to object to the processing, providing your reasons for doing so. CARTPANDA will assess the justification of your objection and take necessary measures to suspend processing or provide grounds for lawful and permitted processing.
Complaint: You have the right to file a complaint regarding the processing of your personal data by CARTPANDA with the National Data Protection Authority. However, we encourage you to give us the opportunity to address any doubts or complaints directly before taking this step.
Deletion of Consent-based Data: In cases where consent serves as the legal basis for processing activities, you have the right to request deletion of such data, unless we are obligated to retain the data for legal or regulatory compliance purposes, or for defense in legal, administrative, or arbitral proceedings.
To assert your rights concerning the handling of your Personal Data, please direct your inquiries to our Data Protection Officer:
Data Protection Officer's Name: MATHEUS DE LIMA CARLOS.
Email Address: dpo@cartpanda.com
This channel is exclusively dedicated to addressing the rights of data subjects. CARTPANDA will make necessary efforts to fulfill such requests in the shortest possible timeframe. We emphasize that we may keep some data and/or continue processing, even in case of requests for deletion, objection, blocking, or anonymization, under certain circumstances, such as to comply with legal, contractual, and regulatory obligations, to safeguard and exercise CARTPANDA's rights, those of the Clients and their End Consumers, for the prevention of illicit acts, and in judicial, administrative, and arbitration proceedings, including third-party challenges to your activities, and in other cases provided for by law.
8. SHARING OF PERSONAL DATA
CARTPANDA values the privacy of its customers and, in compliance with data protection regulations and best market practices, only shares their information for the purposes outlined in this Policy.
Thus, we may share your information with the third parties listed below:
a) Among companies related to CARTPANDA;
b) With service providers, suppliers, and subcontractors for the perfect and correct execution of contracts entered into with them or with you;
c) With advertising and marketing companies, to select and deliver relevant ads to you, as authorized; and
d) With search engine and analytics providers, to assist in improvements and optimizations of our electronic channels, such as our website.
We may also disclose your personal information to third parties:
a) In the event of transactions and corporate changes involving CARTPANDA, in which case the transfer of data will be necessary for the continuity of the services offered;
b) To comply with applicable legislation;
c) To comply with contracts or other agreements with our clients;
d) To ensure greater security in transactions, preventing fraud attempts and other crimes, as well as for the protection of the rights and properties of CARTPANDA, our clients, or third parties. This includes the exchange of information for the purpose of fraud protection, money laundering prevention, and credit risk reduction;
e) To protect the interests of CARTPANDA in cases of demands and conflicts, including in judicial, administrative, and arbitration proceedings;
f) Upon court order or request from competent administrative authorities with legal competence for their request;
g) To evaluate financial risks; and
h) To pursue debt collection from customers and/or debt recovery.
Do not worry, any sharing of information is strictly limited to what is necessary and is conducted in accordance with stringent standards of security, confidentiality, and privacy protection regulations. We consistently uphold and ensure that third parties adhere to the confidentiality of your information.
9. INTERNATIONAL TRANSFER
CARTPANDA may share your Personal Data with business partners, service providers, suppliers, and subcontractors located in other countries for the purposes described in this Policy, such as:
a) Performing internal operations, including customer support;
b) Troubleshooting;
c) Data storage and analysis;
d) Testing;
e) Research and statistics; and
f) Fulfilling our contractual obligations, especially the execution of the terms of your contract with CARTPANDA and the provision of our products and services.
CARTPANDA will ensure that the transmission of your Personal Data complies with relevant privacy laws and that appropriate contractual, technical, and organizational measures are implemented to enhance the security of your Personal Data
10. FINAL CONSIDERATIONS
The terms of this Policy may be modified at any time due to legislative changes or changes in the services we provide, resulting from the updating of technological tools or at our discretion, such as due to the offering of new services.
Therefore, we recommend to our clients to always check the current Privacy Policy. If the changes are significant, you will be notified and will have the opportunity to review the new version of the Policy before deciding to continue using our services. This includes notification by email and pop-ups when accessing our electronic communication channels.
Your information will always be processed in accordance with this Policy. We will never reduce your rights established in this Policy without your explicit consent and in compliance with the Data Protection Law.
Any clause or condition of this Policy that, for any reason, is 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.
CARTPANDA's failure to enforce any rights or provisions of this Policy shall not constitute a waiver, and CARTPANDA may regularly exercise its right within the legal deadlines.
The use of our services implies express acceptance of the terms and conditions of the Privacy Policy in force on the date of use.
For Users who do not agree with the current Privacy Policy, we advise refraining from using the services. Non-acceptance or refusal to provide the requested information may result in the inability to provide such services.
This Policy comes into effect on the date of its publication and remains in force indefinitely.
11. LEGAL BASES OF PROCESSING
Legal Bases: The processing of personal data by CARTPANDA is always grounded on a legal basis provided for in the applicable legislation. The legal bases used by CARTPANDA may vary depending on the context of processing, and include the following:
Consent: When the User agrees to the processing of personal data, for instance, when consenting to receiving advertising or survey communications. This consent may be revoked at any time by the User.
Compliance with Legal or Regulatory Obligations: When CARTPANDA is obligated to process personal data due to a legal or regulatory requirement, such as storing access records for compliance with legislation on money laundering prevention.
Execution of Contract or Procedures Related to the Contract: When the processing of personal data is necessary for the execution of a contract signed between CARTPANDA and the data subject, or for procedures preliminary to the contract, such as processing payment data during a purchase on the Platform.
Exercise of Legal Rights in Judicial, Administrative, or Arbitral Proceedings: When there is a necessity to process personal data due to judicial, administrative, or arbitral action.
Legitimate Interest: When CARTPANDA decides to proceed with the processing of personal data after careful analysis, involving the evaluation of the purpose and necessity of the processing for the User, and the User's expectations regarding the processing of Personal Data. This legal basis is used, for example, when CARTPANDA sends out a newsletter related to the User's interests, based on their interaction with the Platform, to support and promote CARTPANDA's activities and enterprises. In such cases, CARTPANDA always provides the User with the option to unsubscribe from these communications.
12. VERSION HISTORY
1) Privacy Policy | EN-GB-001 | April 19, 2024.
Start your online business on Cartpanda
