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Brazil

Brazil Privacy Policy

Welcome to Crypto.com’s Brazil Privacy Policy. The practices described below only apply to the processing of your personal data subject to Brazilian applicable local laws, with emphasis on the Brazilian General Data Protection Law (“LGPD”) (“Privacy Policy”). Please spend a few minutes reading it carefully before providing us with any information about you or any other person.
Last Update: 10 Sep 2024

1. Introduction

We respect your privacy, and we are committed to protecting your personal data. This Privacy Policy applies to the processing of personal data by Crypto.com companies (“Crypto.com”, we, us, our), details of which are available at Section 3 below in connection with:
  • use of any of our products, services or applications (together the “Services”),
  • visit or use of our websites (“Site”) or mobile application (“App”).
For services provided by other Crypto.com companies, please read the respective privacy notice or policy available on the Site, in the App or through the links below.
If you are not a Brazil resident, please check our Privacy Dashboard.

2. Purpose

This Privacy Policy aims to give you information on how we collect and process your personal data.
This Privacy Policy informs you about your privacy rights and how the data protection principles set out in the LGPD protect you.
It is important that you read this Privacy Policy together with any other policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other policies and notices and is not intended to override them.

3. Who we are

Data Controllers
Foris DAX Middle East FZE is established as a Free Zone Establishment in the Dubai World Trade Centre fee zone in the Emirate of Dubai, the United Arab Emirates, with limited liability, with company registration number 2125 and registered address at: the 8th floor, offices 4, One Central, Dubai World Trade Centre, Dubai, United Arab Emirates.
Foris GFS BR Ltda., a company organized under the laws of Brazil, with a registered address: Suite 719, 72 Rua Claudio Soares, Pinheiros 05422030, São Paulo, Brazil.
Data Protection Officer
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions or complaints related to this Privacy Policy or our privacy practices, or if you want to exercise your legal rights, please contact our DPO Team at [email protected].
Our duties and your duties in case of changes
We keep our Privacy Policy under regular review. This version was last updated on the date above written. Please check from time to time for new versions of the Privacy Policy. We will also additionally inform you on material changes of this Privacy Policy in a manner which will effectively bring the changes to your attention.
It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
The Site and any applicable web browser, the App or application programming interface required to access the Services (“Applications”), may include links to third-party websites, plug-ins and applications (“Third-Party Sites”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements and policies. When you leave our Site or Applications, we encourage you to read the privacy policy or notice of every Third-Party Site you visit or use.

4. What data we collect about you

Personal data
Personal data, or personal information means any information that relates to an identified or identifiable natural person. It does not include data related to someone who cannot be identified, considering the use of reasonable and available technical means at the time of the processing (anonymized data). Certain personal data examples may constitute sensitive data. In such instances, we will implement appropriate use controls and safeguarding measures that are prescribed by applicable law.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped in types as follows:
Type of personal data
Examples of specific pieces of personal data
Identity Data
  • first name,
  • maiden name,
  • last name,
  • username or similar identifier,
  • title,
  • date of birth and gender,
  • a visual image of your face,
  • tax identification number,
  • national identity cards,
  • passports or other form of identification documents,
  • proof of address such as a utility bill or bank statement
Social Identity Data
  • your group/company data,
  • information on who refers you,
  • political background,
  • close connections,
  • behavioural data,
  • risk assessment,
  • compliance assessment.
Contact Data
  • country of residence,
  • billing address,
  • home address,
  • work address,
  • email address,
  • telephone number.
Financial Data
  • bank account,
  • payment card details,
  • e-wallet amounts,
  • external e-wallet details,
  • source of funds (e.g. pay sheet, profits earned from your business, or from sale and purchase contract, bank loan etc.)
Transactional Data
  • details about payments to and from you,
  • other details of any transactions you enter into using products and services you have purchased from us.
Investment Data
  • information about your:
  • investment objectives,
  • investment experience,
  • prior investments.
Technical Data
  • internet protocol (IP) address,
  • your login data,
  • browser type and version,
  • time zone setting and location data,
  • browser plug-in types and versions,
  • operating system and platform, and
  • other technology or information stored on the devices you allow us access to when you visit the Site, or use the Services or the App, such as friends lists or other digital content.
Profile Data
  • your username and password,
  • your identification number as our user,
  • information on whether you have Crypto.com App account and the email associated with this account,
  • requests by you for products or services,
  • your interests, preferences, feedback and survey responses.
Usage Data
  • information about how you use:
  • our Site,
  • App,
  • products and services.
Marketing and Communications Data
  • your preferences in receiving marketing from:
  • us,
  • third parties,
  • your communication preferences.
As explained above under Identity Data, we will also collect a visual image of your face which we will use, in conjunction with our sub-contractors (See Section Sharing of your data below), to check your identity for onboarding purposes. This data falls within the scope of sensitive personal data. When we ask to collect a visual image of your face you will be asked for your specific consent, unless otherwise permitted by applicable law. You can refuse to provide this, but it means that we will be unable to register you and provide you with the Services.
Sensitive personal data
Except as otherwise permitted by applicable law, we will only use sensitive personal data for a specific purpose and if we are able to satisfy the conditions for such processing, such as:
  • based on specific and distinct consent;
  • ensuring the prevention of fraud and security assurance;
  • need of ordinary exercise of rights, including in a contract and in a judicial, administrative and arbitration procedure, the last in accordance with the Brazilian Arbitration Law;
  • need of compliance with a legal or regulatory obligation.
For example, we are required by law to process information from your ID documents including a photographic picture of you. See also the table below which describes the purposes for which we will use your personal data.
If you refuse to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you – for example, to provide you Services. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

5. How we collect your data

We use different methods to collect information from and about you, including through:
Direct interactions. You may give us your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data (as defined above) by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:
  • visit our Site or Applications;
  • apply for our products or services;
  • create an account;
  • subscribe to our service or publications;
  • make use of any of our Services;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey, including through social media channels;
  • give us feedback or contact us.
Automated technologies or interactions. As you interact with us via our Site or Applications, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We will also collect Transactional Data, Investment Data and Usage Data. We may also receive Technical Data and Marketing and Communications Data about you if you visit other websites employing our cookies. On our main website you will be informed about how we use cookies through the Cookie Preferences section of the www.crypto.com website.
Third parties or publicly available sources. We also obtain information about you, including Social Identity Data, from third parties or publicly available sources (fraud and crime prevention agencies and public blockchain).

6. How we use your data

Lawful basis
We will only use your personal data when the applicable legislation allows us to. In other words, we have to ensure that we have a lawful basis for such use.
Most commonly, we will use your personal data mainly in the following circumstances:
  • performance of a contract: means processing your data where it is necessary for the execution or preliminary procedures related to a contract of which you are a party, at your request; we use this basis for provision of our Services;
  • legitimate interests: means our interests (or those of a third party), where we make sure we use this basis as far as your fundamental rights and liberties which require data protection prevail;
  • compliance with a legal or regulatory obligation: means processing your personal data where we need to comply with a legal or regulatory obligation we are subject to;
  • consent: means free, informed and unambiguous manifestation whereby you agree to processing of your personal data for a given purpose; if there is a change in the specific purpose of the processing, the type and duration of the processing, being observed commercial and industrial secrecy, identification of the controller or the information regarding the shared use of data by us and the purpose, we will inform you accordingly with specific highlight of the content of the changes, in which case and if your consent is required, you may revoke it if you disagree with the change.
Purposes for which we use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose and/or activity
Types of personal data
Lawful basis for processing
    To register you as a new customer
  • Identity Data
  • Social Identity Data
  • Contact Data
  • Financial Data
  • Performance of a contract
  • Compliance with a legal or regulatory obligation
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
  • Ensuring fraud prevention and safety of data subjects, in identification and record authentication proceedings in electronic systems
    To process and deliver our Services and any App features to you, including to execute, manage and process any instructions or orders you make, manage, process, collect and transfer payments, fees and charges
  • Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Marketing and Communications Data
  • Performance of a contract
  • Legitimate interests: to prevent abuse of our Services and promotions
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
  • Ensuring fraud prevention and safety of data subjects, in identification and record authentication proceedings in electronic systems
    To manage our relationship with you which will include asking you to leave a review, take a survey or keeping you informed of our company's business and product development
  • Identity Data
  • Contact Data
  • Profile Data
  • Transactional Data
  • Marketing and Communications Data
  • Performance of a contract
  • Legitimate interests: to support and promote our activity, to keep our records updated and to study how customers use our products/services
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
  • Consent that will be required whenever applicable
    To manage, process, collect and transfer payments, fees and charges, and to collect and recover payments owed to us
  • Identity Data
  • Contact Data
  • Financial Data
  • Performance of a contract
  • Legitimate interests: ensuring good management of our payments, fees and charges and collection and recovery of payments owned to us
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
  • Ensuring fraud prevention and safety of data subjects, in identification and record authentication proceedings in electronic systems
    To manage risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, fraud and other background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and response to complaints and resolving them
  • Identity Data
  • Social Identity Data
  • Contact Data
  • Financial Data
  • Technical Data
  • Transactional Data
  • Investment Data
  • Sensitive Personal Data that you give us directly or that we receive from third parties and/or publicly available sources:
  • data which might be revealed by KYC or other background checks (for example, because it has been reported in the press or is available in public registers);
  • data that is revealed by photographic ID although we do not intentionally process this personal data;
  • Performance of a contract
  • Compliance with a legal or regulatory obligation
  • Legitimate interests: to ensure that we are not involved in dealing with proceeds of criminal activities and do not assist in any other unlawful or fraudulent activities, as well as to develop and improve how we deal with financial crime
  • For Sensitive Personal Data we will usually rely on ensuring fraud prevention and safety of data subjects, in identification and record authentication proceedings in electronic systems and need of compliance with a legal or regulatory obligation. You may refer to Sensitive personal data above for more information
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
    To enable you to partake in a prize draw, competition or complete a survey
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Performance of a contract
  • Legitimate interests: to support and promote our activity, to gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
  • Ensuring fraud prevention and safety of data subjects, in identification and record authentication proceedings in electronic systems
  • Consent that will be required whenever applicable
    To administer and protect our business, our Site, Applications and Social Media channels including bans, troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data
  • Identity Data
  • Contact Data
  • Financial Data
  • Technical Data
  • Transactional Data
  • Investment Data
  • Legitimate interests: to run our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise
  • Compliance with a legal or regulatory obligation
  • Ensuring fraud prevention and safety of data subjects, in identification and record authentication proceedings in electronic systems
    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Technical Data
  • Legitimate interests: to support and promote our activity, to study how customers use our products/services, to develop them, to grow our business and to form our marketing strategy
  • Consent that will be required whenever applicable
    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Technical Data
  • Usage Data
  • Legitimate interests: to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to form our marketing strategy
  • Consent that will be required whenever applicable
    To make suggestions and recommendations to you about goods or services that may be of interest to you
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing and Communications Data
  • Investment Data
  • Legitimate interests: to support and promote our activity, to develop our products/services and grow our business
  • Consent that will be required whenever applicable
    To use the services of social media platforms or advertising platforms which will use the personal data they receive for their own purposes, including marketing purposes
  • Technical Data
  • Usage Data
  • Legitimate interests: to support and promote our activity, to develop our products/services and grow our business
  • Consent that will be required whenever applicable
    To use the services of financial institutions, crime and fraud prevention companies, risk measuring companies, which will use the personal data they receive for their own purposes in their capacity of independent controllers
  • Identity Data
  • Social Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Investment Data
  • Тechnical Data
  • Usage Data
  • Legitimate interests: to conduct our business activities on the market of financial services, to participate actively in the prevention of crime and fraud
  • Consent that will be required whenever applicable
    To record voice calls for compliance, quality assurance and training purposes
  • Identity Data
  • Social Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Legitimate interests: to comply with the industry standards and requirements in payments services, to ensure quality of our service, including by proper training of our personnel
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
    To establish and maintain business relationships with other companies
  • Identity Data (partially)
  • Contact Data (partially)
  • Performance of a contract
  • Legitimate interests: to maintain a business correspondence
  • Ordinary exercising of rights, including in the context of contracts, court, administrative, or arbitration proceedings
  • Ensuring fraud prevention and safety of data subjects, in identification and record authentication proceedings in electronic systems
Marketing
We may use your Identity Data, Contact Data, Technical Data, Transactional Data, Investment Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
If you have requested information or purchased from us, you will receive marketing communications, if you have not opted out of receiving such communications. We will use your Marketing and Communications Data for our respective activities.
Third-party marketing
We will get your respective consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Further, you can let us know directly that you prefer not to receive any marketing messages by emailing [email protected].
Where you opt out of receiving marketing messages, this will not apply to service messages which are directly related to the use of our Services (e.g. maintenance, change in the terms and conditions and so forth).
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Site may become inaccessible or not function properly. For more information about the cookies we use, please review the Cookie Preferences section of the www.crypto.com website.
Change of purpose
We will only use your personal data for the specific purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is such a change, we will inform you, with specific highlight of the content of the change. If your consent is required, you may revoke it, if you disagree with the change. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

7. Sharing of your data

We share your personal data with our third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates (as described below) in order to complete tasks and provide the Services and use of the Applications to you on our behalf. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.
We pass your personal data to the following entities:
  • companies and organizations that assist us in processing, verifying or refunding transactions/orders you make and in providing any of the Services that you have requested;
  • identity verification agencies to undertake required verification checks;
  • fraud or crime prevention agencies to help fight against crimes including fraud, money- laundering and terrorist financing;
  • organizations which assist us with customer service facilities;
  • anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services;
  • any third party because of any restructure, sale or acquisition of our group or any affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and
  • regulatory and law enforcement authorities where the law allows or requires us to do so.

8. International transfers

Some of your personal data, or all of it, may be transferred abroad, for example when it is stored by us on cloud computing servers located outside Brazil. For this, we observe all requirements established by the relevant legislation and adopt the best security and privacy practices to guarantee the integrity and confidentiality of your personal data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Brazil.

9. Data security

We have adopted appropriate security, technical and administrative measures to protect your personal data from unauthorized accesses and accidental or unlawful situations of destruction, loss, alteration, communication or any type of improper or unlawful processing. These measures are complied with as from the conception phase of the Services until their execution.
We treat the security of your personal data with the utmost care and aim to comply with the best practices adopted in the market, such as:
  • staff training and policy development;
  • physical protection of data, pseudonymization and encryption; and
  • ensuring appropriate back-ups of personal data are held.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the Agência Nacional de Proteção de Dados (“ANPD”) in a reasonable time period of a security incident that may create risk or relevant damage to you where we are legally required to do so.
If you want to know more about our security practices, please visit this link.

10. Data retention

We will keep your personal data in a safe and controlled environment for the entire period that we store it.
We will keep your personal data for the necessary period according to the legal basis that justifies the retention of the data.
When applicable, and even after the closure of your account, cancellation of your card or other Services, we may store your personal data for an additional period for audit purposes, compliance with legal, regulatory, tax, accounting or other obligations and for exercise of rights.
Here are some exemplary factors which we usually consider when determining how long we need to retain your personal data:
  • in the event of a complaint;
  • if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims (e.g. email addresses and content, chats, letters) will be kept until expiration of the respective statutory limitation periods;
  • to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data:
    • under the anti-money laundering legislation we may be obliged to retain your personal data for a period of 5 years after the end of the relationship between us as a company and you as a customer;
    • Information needed for audit purposes and so forth; or
  • in accordance with relevant industry standards or guidelines;
  • in accordance with our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer’s personal data for the time of the promotion and for a certain period after its end to prevent the appearance of abusive behavior.
Please note that under certain condition(s), you can ask us to delete your data: see your legal rights below for further information. We will honor your deletion request only if the condition(s) is met.

11. Your legal rights

You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal data. If you need more detailed information or wish to exercise any of the rights set out below, please contact us.
  • Confirmation of the existence of processing
The fact that you provide us with your personal data (before or after becoming our customer) means that we process the respective data, even if only by storing it. You can ask us to confirm that your personal data is being processed.
  • Access
You can request that we provide you with information and the personal data we have in relation to you. Information and the data may be provided, at your discretion, either by electronic means safe and suitable for this purpose, or in printed form.
  • Correction of incomplete, inaccurate or out-of-date data
If you find that your personal data is incomplete, inaccurate or out-of-date, you can ask us for its completion, correction or update. For this purpose you may need to send a document that proves the complete, accurate and up-to-date personal data.
  • Anonymization, blocking or deletion
You may ask for anonymization, blocking or deletion of unnecessary or excessive data or data processed in non-compliance with the LGPD.
  • Portability of the data to another service or product provider
You can ask us to transfer your personal data to another service or product provider, by means of an express request and subject to commercial and industrial secrecy.
  • Deletion of personal data processed with your consent
You may ask us to delete personal data processed. We will delete the data, except under certain circumstances, where we are authorized to store the data for specific purposes, as provided by the LGPD or other applicable law.
  • Information about sharing information with public and private entities
You are entitled to receive information about sharing your data.
  • Denying consent
You are entitled to receive information about the option to deny consent and the consequences of such denial. For example, if your consent is required to access or use a particular Service, you can ask us to clarify whether it is possible to access or use the Service without providing consent for the processing of your personal data, or what are the consequences of not providing consent for the respective case.
  • Revoking consent
If you have given your consent for the processing of your personal data, you can revoke it at any time by express request, through a facilitated and free of charge procedure. The processing carried out under previously given consent remains valid as long as there is no request for deletion pursuant to LGPD.
The revocation of consent may result in the inability to use some features of the Services, or even in the termination of the Services. It does not prevent the use of anonymized data and data whose processing is based on another legal ground as per the LGPD.
  • Automated decisions
You can request a review of decisions made solely on the basis of automated processing of personal data that affects your interests. If you do so, we have to provide clear and adequate information regarding the criteria and procedures used for an automated decision, subject to commercial and industrial secrecy. It is important to note that we do not guarantee a result different from the first decision.
  • Right of complaint
You have the right to lodge a complaint about the way we process your personal data to the ANPD.
We would, however, appreciate the chance to deal with your concerns before you approach the ANPD, so please feel free to contact us in the first instance.
Please note that these rights are not absolute and may not be applicable in certain circumstances. For example, we may continue to process and maintain certain personal data despite your request for anonymization, blocking, deletion or revoking consent, in order to comply with legal, contractual, and/or regulatory obligations, as well as to safeguard and exercise rights, including in judicial, administrative, and arbitration proceedings, and in other cases provided for by law. If you wish to exercise any of your rights, contact us by e-mail on [email protected].
What we may need from you
In order to exercise your rights, we may request proof of your identity as a security measure and for the purposes of fraud prevention.
We may also contact you to ask you for further information in relation to your request to speed up our response.