Privacy Policy
Updated on May 3, 2024.
This Privacy Policy is intended to inform users about how their data is collected, stored, protected, and used by Perfect Pay.
The protection of your personal data is of utmost importance to us. Therefore, we adhere to strict policies for handling such data in accordance with applicable legal and regulatory standards, aiming to ensure and respect your privacy and provide transparency in the processing of your data.
Our aim is to enable you to make informed decisions about the information you share with us. Thus, this Privacy Policy seeks to reinforce our commitment to privacy and data protection in the processing of personal data.
Important Definitions:
Data Processing Agents: Individuals or legal entities responsible for the processing of Personal Data, namely the Controller and the Operator.
Anonymization: A technique by which a data point loses the possibility of association, directly or indirectly, with an individual, making it impossible to identify the data subject.
ANPD: The Brazilian National Data Protection Authority, a federal public administration body with responsibilities related to the protection of personal data and privacy, including the oversight of LGPD compliance throughout the national territory.
Consent: A free, informed, and unequivocal expression by which the data subject agrees with the processing of their personal data for a specific purpose.
Controller: A natural or legal person responsible for decisions regarding the processing of personal data.
Personal Data: Information that directly or indirectly identifies a natural person. Examples include name, address, CPF, RG, email, identity documents, telephone, access logs to internet applications (date and time of use, IP address used for access), among others.
Sensitive Data: Personal Data related to racial or ethnic origin, religious belief, political opinion, union membership or membership in religious, philosophical, or political organizations, data concerning health or sex life, genetic or biometric data when linked to a natural person.
Device: Any electronic device used by the User to access Perfect Pay systems, such as desktop computers, laptops, TVs, mobile phones, tablets, smartphones, or other internet-connected devices.
Data Protection Officer (DPO): A person appointed by the data processing agents to act as a communication channel between the Controller, the data subjects, and the ANPD, ensuring compliance with privacy laws and regulations. The contact information for the Perfect Pay DPO is available in Section 11 of this Privacy Policy.
LGPD: The Brazilian General Data Protection Law (Law No. 13.709), enacted on August 14, 2018, which regulates personal data processing activities, including digital processing, by natural persons or legal entities of public or private law, aiming to protect fundamental rights of freedom, privacy, and the free development of the personality of the natural person.
Perfect Pay: PERFECT PAY TECNOLOGIA, SERVIÇOS E INTERMEDIAÇÃO LTDA., a private legal entity, registered with the CNPJ under No. 28.059.320/0001-36, headquartered at Av. Marcos Penteado de Ulhôa Rodrigues, No. 939 – 8th Floor – Tower 1, Jacarandá Building, Tamboré, Barueri/SP, ZIP Code: 06460-040, sole and exclusive owner of the domain: www.perfectpay.com.br.
Operator: A natural or legal person who processes personal data on behalf of the Controller, following their instructions.
Platform: Any electronic platforms or websites owned by Perfect Pay.
Prospective Collaborator: Individuals interested in working or providing services to Perfect Pay by submitting their professional résumé through the designated channels on the Platform or via job vacancy websites.
Prospective User: Individuals who have not yet used the Platform as a User but are exploring the services offered by Perfect Pay.
Data Subject: A natural person to whom the personal data being processed refers.
Processing: Any operation performed on personal data, whether automated or not. This includes the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction of personal data.
Affiliate User: An individual who promotes, advertises, and sells physical and/or digital products, using the Platform for transaction processing and management.
Producer User: An individual who sells physical and/or digital products, either owned or authorized, using the Platform for transaction processing and management.
Buyer User: An individual who purchases digital and/or physical products made available on the sites of Producer Users and/or Affiliate Users, using the Platform’s checkout provided to the seller.
User: Refers collectively to the Affiliate User, Producer User, and/or Buyer User.
HOW DOES PERFECT PAY COLLECT YOUR PERSONAL DATA?
Collection of Affiliate User Personal Data: Personal data may be collected during the registration process on the Platform and/or prior to requesting any Perfect Pay services. Data may also be collected while browsing our websites, downloading the app, or using Perfect Pay services. This includes data from public administration databases, regulatory agencies, credit bureaus, compensation services, and positive credit registries, especially for fraud prevention and/or document submission necessary to fulfill the purposes of this Privacy Policy.
Collection of Producer User Personal Data: Personal data may be collected during the registration process on the Platform and/or prior to requesting any Perfect Pay services. Data may also be collected while browsing our websites, downloading the app, or using Perfect Pay services. This includes data from public administration databases, regulatory agencies, credit bureaus, compensation services, and positive credit registries, especially for fraud prevention and/or document submission necessary to fulfill the purposes of this Privacy Policy.
Collection of Buyer User Personal Data: Personal data may be collected during the purchase process on the Platform (whether or not the purchase is completed) and/or prior to requesting any Perfect Pay services. Data may also be collected while browsing our websites, or while requesting and using Perfect Pay services, from public administration databases, regulatory agencies, credit bureaus, compensation services, and positive credit registries, especially for fraud prevention, when requesting a refund for a purchase made via Perfect Pay’s checkout, and/or document submission necessary to fulfill the purposes of this Privacy Policy.
Collection of Prospective User Personal Data: Data may be collected through participation in events (online and offline), communication with Perfect Pay, and/or form submissions, registration sheets, questionnaires, attendance lists, and similar means, including during the purchase process (even if the purchase is not completed) using the Platform’s checkout.
Collection of Prospective Collaborator Personal Data: Personal data may be collected via form completion, questionnaire responses, and/or submission of documents containing personal data (e.g., résumés), during professional recruitment events or hiring processes conducted by Perfect Pay.
Automatically Collected Personal Data via the Platform: Perfect Pay may collect certain files and/or information stored on your devices when you visit our websites and/or use our online services or products. These files or pieces of information are called “cookies” and are used to facilitate use and optimize our sites according to your interests, preferences, and needs. If desired, cookies can be disabled via your browser settings. To learn more, consult our Cookie Policy.
The accuracy and truthfulness of the information provided to Perfect Pay are the sole responsibility of the users. Providing false or incomplete data may result in immediate user exclusion and may constitute a crime.
Users may request specific information about the processing of their personal data by contacting our support channel at any time.
WHAT PERSONAL DATA IS PROCESSED BY PERFECT PAY?
Perfect Pay will process the following Personal and Sensitive Data to the extent necessary to achieve the purposes outlined in this Privacy Policy.
In addition to the data listed, Perfect Pay may request additional personal data according to the user profile, through support channels or user requests. In such cases, the user will always be informed of the purpose for which the data is being collected.
Affiliate User: Full name, gender, marital status, date of birth, CPF, CNPJ, RG, full address, email, phone numbers, nationality, place of birth, emancipation declaration, parentage, professional license number, profession, banking details, login credentials, biometric data, social media accounts, sales and average billing data, platform usage frequency, connection and activity logs, browsing history, geolocation, IP addresses, cookies, photo, voice.
Producer User: Same as Affiliate User.
Buyer User: Full name, email, phone number, date of birth, CPF, gender, banking details, profession, marital status, CNPJ, full address, financial transaction ID token.
Prospective User: Full name, email, phone, CPF, date of birth, full address, gender, age, image, voice, workplace, average billing, emancipation declaration.
Prospective Collaborator: Full name, email, phone, full address, CPF, date of birth, marital status, nationality, place of birth, academic background, profession, gender, photo.
Automatically Collected Data: Browser, IP address, access date and time, geolocation, device OS, platform actions.
Perfect Pay is committed to using only the minimum information necessary for the intended processing purposes.
Users control their profile data and may access and update it using their login and password.
Login credentials are the user’s responsibility, and any misuse is not the responsibility of Perfect Pay. Perfect Pay does not collect data from minors unless legally emancipated or with legal guardian authorization.
Any unauthorized processing of children or adolescent data will result in removal.
You may request information on what data Perfect Pay processes via the support channel.
WHAT ARE THE PURPOSES OF PROCESSING PERSONAL DATA?
Perfect Pay processes personal data for legitimate, specific, and informed purposes, including:
Providing services, customer support, fraud prevention, transaction processing, compliance with legal obligations, platform improvement, sending relevant communication.
Perfect Pay is against any spam practices and ensures communication is of interest to the recipient. Users can change email preferences or close their account at any time.
Unsolicited spamming by users may result in account termination.
LEGAL BASES FOR PROCESSING PERSONAL DATA
As per LGPD, personal data can be processed under the following legal bases:
- Consent by the data subject
- Compliance with legal or regulatory obligations
- Public administration for public policy execution
- Research organizations
- Contract performance
- Exercise of rights in legal proceedings
- Protection of life or physical integrity
- Health protection by professionals or authorities
- Legitimate interests of the controller or third parties
- Credit protection
Sensitive data has specific bases such as:
- Consent
- Legal obligation compliance
- Public policy execution
- Research studies
- Legal rights exercise
- Life/health protection
- Fraud prevention and authentication
All processing is legitimized by one of the above. We regularly review our practices for compliance.
We maintain records of processing activities, subject to inspection by data subjects and authorities.
Some processing may occur without consent, such as legal requirements or contract performance. When consent is needed, you will be informed and may refuse or revoke it at any time.
WITH WHOM MAY WE SHARE YOUR PERSONAL DATA?
Your personal data may be shared with:
- Perfect Pay group companies
- Service providers (IT, cloud, credit bureaus, recruitment, event management, etc.)
- Public authorities, for legal or regulatory compliance
- Entities involved in corporate restructuring
- Other users, when necessary for transactions or legal investigations
Processors are contractually obligated to follow Perfect Pay’s data protection guidelines.
Perfect Pay may also act as a Processor in certain transactions between users, but is not responsible for misuse by Producer Users.
SHARING OF PERSONAL DATA ABROAD
Data may be transferred to international service providers (e.g., cloud storage). We adopt appropriate safeguards to protect data during such transfers.
DATA RETENTION PERIOD
Data is retained for the duration necessary for legal compliance, service provision, legitimate interests, or legal defense. Data will be deleted when:
- The purpose is achieved
- Data becomes unnecessary or excessive
- Consent is revoked (if applicable)
- Ordered by the ANPD for LGPD violations
You may request data deletion via our support form.
YOUR RIGHTS UNDER THE LGPD
You have the right to:
- Confirm processing
- Access your data
- Correct or update data
- Request anonymization, blocking, or deletion
- Request data portability
- Revoke consent
- Object to processing
- File a complaint with ANPD or consumer protection agencies
- Request review of automated decisions
Requests must be sent to [email protected]. Identity verification may be required.
DATA SECURITY MEASURES
Perfect Pay implements technical and organizational measures including:
- Encryption and secure storage
- Restricted access to data
- Secure password and credit card hashing
- Staff awareness and legal confidentiality agreements
External links may lead to third-party sites. Perfect Pay is not responsible for their data handling practices.
CONTACTING PERFECT PAY
For questions or requests regarding data protection, please use the support form: https://forms.gle/xDRJUfjrDbYmSegG7