Terms and Condition of Use

COMBATEAFRAUDE TECNOLOGIA DA INFORMAÇÃO SA, a limited liability company, duly constituted and existing in accordance with the laws of Brazil, registered with the CNPJ under nº 34.102.645/0001-57, headquartered at Rua Tiradentes, nº 1077 - 5th floor - Centro, Venâncio Aires - RS, CEP 95800-000, represented in accordance with the terms of its constitutive documents.

• COMBATE A FRAUD offers, through the website (“Platform”), a Software that allows the performance of services aimed at data analysis to combat irregularities and fraud.
• These Terms and Conditions of Use (“Term”) establish the terms and conditions applicable to the use of the Software and the Platform. By adhering to the Commercial Proposal, and/or using the Software and/or accessing the Platform, the USER assumes and expressly agrees with this Term.
• ‍If these “Terms and Conditions of Use” conflict with the “Service Provision Agreement”, or another specific contract signed by the PARTIES, these will prevail over this “Terms and Conditions of Use".
• ‍These Terms reflect the way COMBAT A FRAUD business works, the laws that apply to our company and certain points we have always believed. As a result, this Term helps to define COMBATE A FRAUD's relationship with the USER in terms of their interaction with our services.
• Understanding these Terms is important because, in order to use our services, you must accept them.
• In addition, we also publish a Privacy Policy on our website. We recommend that you read and accept it in order to better understand how data is treated by COMBATE A FRAUD. You can also request the privacy policy and ask questions by contacting our DPO (Personal Data Protection Officer) at the e-mail address: dpo@combateafraude.com.

OF THE OBJECT

COMBATE A FRAUD gives the USER the limited, non-exclusive, non-transferable, onerous right for a specified period of time to use the contracted services (“Contracted Services”), under the terms of the (“Commercial Proposal”) of services or agreement between COMBATE A FRAUD and the USER.

USE PERMISSION

The permission we grant you to use our services will last as long as you fulfill your defined responsibilities:

• In this Term; and
• Privacy Policy; and
• Non-Disclosure Agreement (NDA); and/or
• Proof of Concept (POC); and/or
• Contract for services.

In order for us to guarantee the best possible demonstration of our services, we need you to be aware of and accept this Term.

FRAUD FIGHTING SERVICES AND GUIDELINES

The USER can access the link below to find out about COMBATE A FRAUD services and more about their operation, as well as clarify doubts and find solutions whether in Beta access, demo and/or others available. The USER acknowledges that he must follow this Term in all environments and integrations that the COMBATE A FRAUD Platform provides.

• https://docs.combateafraude.com/docs/api/conhecendo-produto/visao-geral/
• The USER declares that he is aware that for the correct and adequate use of COMBATE A FRAUD services, he must, by himself, by his authorized users or by the DATA HOLDERS: (i) ensure the technical conditions necessary for access to the platform, such as computer and/or smartphone with internet connection, use of Internet Explorer, Google Chrome, Mozilla Firefox browsers; (ii) adhere to and respect the Terms of Use and Privacy Policy, available on the system access portal, with a view to observing and preserving its purposes, data processing, security rules and conditions of use of the platform; (iii) observe the minimum conditions of luminosity, focus and framing of the images to be captured or inserted, as well as the correct typing of the data, and COMBATE A FRAUD will not be responsible for errors resulting from incorrect or improper use or failures caused by the USER.
• Access to the Service will be released immediately by COMBATE A FRAUD upon acceptance of this Term or as agreed between COMBATE A FRAUD and the USER.
• The USER will be able to monitor, through the COMBATE A FRAUD platform, the report of consultations carried out, to be constantly updated with each new consultation.
• COMBATE A FRAUDE will provide technical support services for the use of our services, and, to that end, will provide a communication channel by email and online chat (Slack), in order to guarantee their full functioning. All USER requests must be made through the aforementioned service channels or others, as long as previously agreed with COMBATE A FRAUD.

‍REGISTER ON THE PLATFORM‍

The USER's registration on the Platform will be carried out by assigning a login and access password, and the USER undertakes to keep them confidential.

• The USER is fully responsible (i) for keeping his password confidential, and (ii) for the veracity, accuracy, authenticity and timeliness of the data and information provided to COMBATE A FRAUD, being responsible for any damages caused to the Contractor and third parties.
• If COMBATE A FRAUD finds that the information is in any way incomplete, inaccurate, false or out of date, the USER may have their registration on the Platform suspended or cancelled, at the sole discretion of COMBATE A FRAUD, without prejudice to other applicable measures, in which case no refunds will be due.
• The service will be made available in the state in which it is, without COMBATE A FRAUD making any adaptation or conformity in order to meet the specific needs and demands of the USER who, in turn, declares and acknowledges that he will use the service on his own in risk.
• The use of the Service (i) due to improper and unauthorized sharing of Login and password by an Authorized User; or (ii) for purposes of sublicensing, subleasing, assignment or any other legal transaction that implies or allows someone who is not directly linked to the USER to use the Service, it is prohibited and will be the USER's entire responsibility.
• The USER, an individual who registers on the Platform on behalf of a legal entity, declares and certifies that he has powers to represent it with regard to this Term and other provisions regarding the use of COMBATE A FRAUD services. The USER who registers on behalf of a legal entity will be liable to COMBATE A FRAUD for any violation of this Term or the applicable legislation.
• The USER undertakes to immediately inform COMBATE A FRAUD about the possibility that his login and password are being used improperly.
• Only individuals and legal entities that maintain a statutory, employment or contractual relationship with the USER are considered directly linked to the USER, excluding any others.

FRAUD FIGHTING OBLIGATIONS

COMBATE A FRAUD services and their functionalities are presented to the USER in the way they are available, and may undergo constant improvements and updates, forcing COMBATE A FRAUD to:

• Preserve its functionality, with unbroken links and using a layout that respects usability and navigability, whenever possible;
• Display the functionalities and services in a clear, complete, precise and sufficient way so that there is an exact perception of the operations carried out, and to third parties,
• Comply with and enforce the documents and agreements signed.

OBLIGATIONS OF THE USER

USERS are responsible for and undertake to:

• Use our services fairly and ethically, respecting the conditions governing their use and purpose;
• Provide accurate, true, complete and up-to-date information and registration data, in addition to informing a contact channel capable of being activated for the best fulfillment of the services, being civilly and criminally responsible for all the information provided, committing to update them at all times that there is any change by email or telephone;
• Have compatible devices and equipment, Internet connection service with antivirus and firewall enabled, and duly updated software;
• Leave your antispam systems, similar filters or message redirection settings adjusted so that they do not interfere with the receipt of communications and materials from the Company, no excuse being acceptable if you have not had access to any e-mail or electronic message due to the mentioned resources;
• Respect all intellectual property rights owned by COMBATE A FRAUD or third parties;
• Not transmit materials containing computer viruses or other malicious computer code, files, scripts, agents or programs;
• Not to maliciously exploit the services for the practice of illicit acts, prohibited by law and by this Term, harmful to the rights and interests of COMBATE A FRAUD and third parties, or that, in any way, may damage, disable, overload or deteriorate the goods and COMBATE A FRAUD services;
• Be solely responsible for any damage caused by you to COMBATE A FRAUD or to third parties due to non-compliance with the obligations set forth herein or the non-truthfulness of the information provided, not having to speak of subsidiarity of the obligation, nor solidarity of COMBATE A FRAUD;
• The USER is solely and fully responsible for the information entered or forwarded by him to COMBATE A FRAUD, being certain that he will be solely responsible for the civil and criminal sanctions that eventually result from the inaccuracy of such data;
• The USER undertakes to use the services made available in good faith and in compliance with all applicable legal, regulatory and contractual precepts, with public order, social and professional rules and standards of conduct accepted or regarded as good practices.

SERVICE AVAILABILITY

COMBATE A FRAUD will use its best efforts to guarantee the availability of its platform during 99% of the contracting period or as stipulated in the Service Provision Agreement, routine updates being carried out outside business hours.

• The availability percentage above refers only to the COMBATE A FRAUD platform, that is, services that depend on third parties, such as databases that we consult in private and/or government databases (Ex: SPC, Federal Revenue Service, etc.), If these sites or third parties are unavailable, COMBATE A FRAUD is not responsible for any losses or damages caused.
• Any and all unavailability of the Service during the Contract Period that is demonstrably motivated by failure and/or unavailability of platforms and/or databases managed by third parties, will not be considered in the calculation of the percentage availability of the Contract Period, as described in point above.
• Without prejudice to the other provisions of this Term, in calculating the percentage availability of the Contract Period, any unavailability occurring during:

(a) Routine maintenance carried out between 23:59 (twenty-three hours and fifty-nine minutes) on Saturday until 23:59 (twenty-three hours and fifty-nine minutes) on Sunday; and

(b) Unscheduled maintenance occurring outside business hours, provided that the USER is notified by email at least 2 (two) days in advance.

• The provision of complementary services of “Documentoscopy” (manual), if contracted by the User, by an internal team in cases where the technological solution is not sufficient, will observe business hours (i.e. [07:00-22:00]), with a deadline for response per query of up to 30 (thirty) minutes, EXCEPT when dealing with serious indications of fraud, which will observe a reasonable period for its proper analysis.
• The provision of complementary services referred to in the previous point will occur through the composition of a board with members of the COMBATE A FRAUD technical staff, in adequate numbers and qualifications as the COMBATE A FRAUD deems necessary for the analysis of the specific case.
• Any and all corrections that may be necessary due to one or more hidden defects, as well as any and all maintenance that may be necessary for the Service to function in a uniform, expected manner and in accordance with the stipulated terms, will be carried out by COMBATE A FRAUD , at its own cost, without additional fees being charged to the USER.
• The USER must ensure that the use of the Platform is not harmful to their stability and availability.
• The USER must not use the Platform to carry out acts prohibited by law and by these Terms of Use, or acts that may damage, disable, overload or deteriorate the Platform, the computer equipment of other users or other Internet users (hardware and software ), as well as documents, files and all kinds of content stored on its computer equipment (cracking) or prevent the normal use of said tool, computer equipment and documents, files and content by other users and other customers.
• COMBATE A FRAUD does not guarantee, in addition to the availability provided for in this Term or in the Service Provision Agreement, that the system will be available at all times and that it is free of errors, failures, or even that it will meet all the requirements and needs of the USER. .
• In the event of disasters, acts of God or force majeure, the service standards and respective quality indexes for the contingency period may be changed by COMBATE A FRAUD.
• Any unavailability of the Amazon Web Services (AWS) system will not be considered for the purposes of determining non-compliance with these Terms.
• It is the USER's obligation to expressly inform COMBATE A FRAUD, at least 20 (twenty) days in advance, about the possibility of any extraordinary event occurring in its operations that implies an increase of at least 20% (twenty percent) of the average monthly volume of COMBAT FRAUD consultations, volume calculated on the average of the last 03 (three) months to the date of occurrence of the extraordinary event, under penalty of non-application of the Service Level Agreement and Platform Availability referred to above to the detriment FIGHTING FRAUD.
• In the event of non-compliance with the levels of service and availabilities agreed above, due to the exclusive and proven fault of COMBATE A FRAUD, the USER will be entitled to seek a discount proportional to the proven attempts at queries not answered by COMBATE A FRAUD during the period of unavailability, which must be agreed upon and resolved amicably with COMBATE A FRAUD.

LIMITATION OF LIABILITY

The USER acknowledges that inappropriate use and/or non-compliance with national legislation may constitute an illegal act under the terms of article 186 of the civil code.

• The USER expressly acknowledges that COMBATE A FRAUD will not be liable if the impossibility or impairment of the proper use of the Platform is caused by a fact not attributable to COMBATE A FRAUD, which includes, but is not limited to, failure in the infrastructure of external servers, telecommunications and energy, failure of essential equipment for access to the Platform or software by Users, wars, uprisings, natural disasters, among others. Pandemic state cases and strikes are not considered as acts of God or force majeure.
• The USER expressly acknowledges that COMBATE A FRAUD, under no circumstances, will be liable for damages, loss of profits and/or damages resulting from the improper use of the software or platform in relation to other users and/or third parties.
• The only commitments we assume with respect to our services, including their content, specific functions or reliability, availability or ability to meet your needs are (1) described in the service provision agreement and/or in this Term and in the Policy Privacy Policy, (2) stated in the service-specific additional terms, or (3) determined in accordance with applicable law. We make no other commitments regarding our services.
• Unless required by law, we make no implied warranties, such as the implied warranties of merchantability, fitness for a particular purpose and non-infringement.
• The USER is fully responsible for any setback arising from incorrect handling of the system.

CONFIDENTIALITY

COMBATE A FRAUD and the USER - (PARTIES) acknowledge that any and all information made available as a result of access to the Platform, including but not limited to (i) information relating to the business of each Party, as well as information, data, content , technical specifications, product performance indicators, projects, studies, documents, product plans, costs, prices, customer names, statistics, financial information not published in the media, prices and product names, finance, business opportunities, research , development, know-how and other documents of any nature, tangible or intangible, made available in any media or physical, visual or sound medium, including electronic and digital, communicated in writing, verbally or otherwise; (ii) any information identified by any of the PARTIES as “confidential” or “proprietary”; (ii) Personal Data; and (iv) the information shared and any information eventually received and/or developed due to the execution of the object of this Term are Confidential Information (“Information” or “Confidential Information(s)”) and therefore the PARTIES to use them only for the purposes set forth in this Agreement, using the same precautions they would use to maintain the confidentiality of their own information, as well as maintaining the confidentiality of the Information, for a period of 5 years from the end of the relationship between the PARTIES.

INTELLECTUAL PROPERTY

The commercial use of any intellectual property of COMBAT A FRAUD by any USER without express consent is prohibited.

• COMBATE A FRAUD is the exclusive owner of those who compose and/or integrate the Service; and (ii) that this Term does not grant the other Party any copyright or industrial and/or intellectual property rights, except for the right of use, as agreed.
• The USER acknowledges that this Term and/or other agreements signed between the USER and COMBATE A FRAUD do not constitute a concession, license or authorization for any type of use of the corporate name, domain names, titles of establishment, deposited or registered trademarks, signs or advertising expressions and any other distinctive signs or intellectual property assets owned by COMBATE A FRAUD and any entities that are part of its economic group, and any use of said distinctive signs and intellectual property assets is prohibited, without prior and express authorization , in writing, from COMBATE A FRAUD, or otherwise from the guidelines and technical specifications previously provided by it.
• The functionalities that make up the services of COMBATE A FRAUD are offered as a service, not granting the USER any rights over the intellectual property rights used by COMBATE A FRAUD, its content or the computer structures that support it.

PERSONAL DATA PROTECTION

The USER and COMBATE A FRAUD undertake, during the term of this relationship, to be in accordance with the privacy and data protection laws and regulations in all locations where it operates, and, in particular, the LGPD (General Law of Protection Data, Brazilian Law No. 13,709, of August 14, 2018), and to maintain all processes, technical, operational, organizational and procedural security measures, controls and internal structures necessary to ensure this adequacy.

• The USER recognizes that it has its own Terms of Use and Privacy Policy, which are clear, transparent and up-to-date, available in a place that is easy to consult by the holders of personal data.

TERM

This Term comes into effect on the date of registration of the USER on our platform and will last as long as he remains registered or for the period set out in the Commercial Proposal, being renewed automatically.

• We may update these terms and the service-specific additional terms (1) to reflect changes to our services or the way we do business, for example, when we add new (or remove old) services, features, technologies, pricing or benefits, ( 2) for legal, regulatory, or security reasons; or (3) to prevent abuse or damage.
• If you do not follow these Terms or the Privacy Policy or additional service-specific agreements, and we do not take appropriate action immediately, this does not mean that we are giving up any rights we may have, such as taking appropriate action in the future.

TERMINATION

The USER may terminate this Term at any time, as long as there is no other contract with COMBATE A FRAUD in force, which must be terminated before the termination of this Term, upon notification by e-mail. In the event of termination of this Term, the user's registration will be terminated immediately.

• COMBATE A FRAUD reserves the right, without the need for prior notification, to resolve this Term by operation of law, preventing or interrupting the USER's access in the event of (i) COMBATE A FRAUD, for reasons beyond its control, cannot provide the services provided for in this Term, in which case the amounts effectively paid during the period in which the Platform became definitively unavailable will be refunded, and the USER, in turn, cannot claim anything else for all legal purposes; or (ii) after the specified period of use granted to the USER has ended.
• If the USER's registration is interrupted or cancelled, all pending operations on the Platform must be completed with all payments.

GENERAL PROVISIONS

COMBATE A FRAUDE is a company incorporated in Brazil and the Platform is created and maintained in strict compliance with Brazilian laws. If the USER is accessing the Platform outside of Brazil, the USER will be responsible for complying with local laws, as applicable.

• If COMBATE A FRAUD fails to exercise any right provided for in this Term, this shall not be interpreted as a waiver, abdication or revocation of the provision contained in this Term.
• If you have questions about this Term of Use, the USER may contact our team via the email address: dpo@combateafraude.com.br.
• To resolve any disputes, the Forum of the City of Rio de Janeiro/RJ is elected.

‍

Like most websites, we use cookies and similar technologies to diagnose activity on our service and store information about it.

• Cookies are files with a small amount of data that may include an anonymous unique identifier.
• Cookies are sent to your browser from a website and stored on your device.
• However, you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
• You can modify your browser setting to refuse cookies if you prefer.
• Combate a Fraude only uses cookies to improve your experience with our services.

‍

Here at CAF, we have a responsibility to take care of your data and also your privacy. We want you to have the security of having your data protected and also of exercising your rights. For this, we created a communication channel directly with us, allowing you to choose between the possibilities of requests. Click below and follow the step by step!

TALK TO THE DPO

Submit your request

PRIVACY POLICY FOR THE WEBSITE AND FRAUD FIGHTING SERVICES

COMBATEAFRAUDE TECNOLOGIA DA INFORMAÇÃO SA, a limited liability company, duly constituted and existing in accordance with the laws of Brazil, registered with the CNPJ under nº 34.102.645/0001-57, headquartered at Rua Tiradentes, nº 1077 - 5th floor - Centro, Venâncio Aires - RS, CEP 95800-000, represented in accordance with the terms of its constitutive documents.

• COMBATE A FRAUD offers, through the website (“Platform”), a Software that allows the performance of services aimed at data analysis to combat irregularities and fraud.
• We developed this Privacy Policy with the purpose of affirming our commitment and respect for the rules of privacy and protection of personal data, as well as being able to pass on the security that we are in constant improvement of the objectives outlined for the guarantee of rights over the personal data. Our privacy policy is in line with the General Law for the Protection of Personal Data. In addition, we are constantly improving internal guidelines to better serve the personal data we have.

Using our Platforms, filling out our forms and providing data, directly or indirectly, implies knowing and accepting the conditions of this Policy, the General Terms, Policies and Conditions of Use and any other specific terms, policies and conditions related to the services subscribed. When subscribing to our services, carefully read the respective terms and conditions.

THE PURPOSE OF THE PRIVACY POLICY

With this privacy policy we intend to clarify the rights and obligations involved in our relationship, as an integral part of the universe of USERS, so called the legal entities that use the COMBATE A FRAUD Platforms to carry out information queries. We want to make it clear:

• The personal data we collect;
• How and for what reasons (purposes) we use them;
• To whom we disclose them;
• Rights of Holders of Personal Data;
• Legal basis of treatment;
• How we protect your privacy and that of your USERS when you use our services or visit our platforms;
• Your responsibility when sharing third party data with COMBATE A FRAUD;
• Contact with our DPO (Personal Data Protection Officer);
• Among other information listed below.

PROCESSED PERSONAL DATA

Below is a list of some data that may appear in our databases when we carry out our searches:

• ‍When COMBATE A FRAUD carries out analyzes for the provision of services, data such as name, parental affiliation, date of birth, registration of profession, contact data (e-mail address, telephone number, postal address), data contained in public records and other necessary data so that the best possible probability can be obtained of the authenticity of the document or query requested to COMBAT FRAUD by the USER.
• The transmission of some of this data is mandatory, so if they are not provided, COMBATE A FRAUD will not be able to provide the requested product or service. In these cases, the USER will always be duly informed of the obligation to provide this data to continue the process.
• COMBATE A FRAUD may receive other personal data through partners and public websites or private websites that provide a public service. Thus, in order for us to process this data, we at COMBATE A FRAUDE use clauses in our service provision contracts so that our USERS who contract our services obtain specific consent for sharing personal data with COMBATE A FRAUDE in order to use them in our services to investigate irregularities and fraud. There may be other legal bases for us to carry out the treatment, mainly the legal basis for contractual compliance or legitimate interest of COMBATE A FRAUD.
• We request that our USERS provide in their contracts with data subjects that their personal data may be verified for the purposes mentioned here. We also ask that our USERS keep their privacy policies up to date, stating the purpose of treatment with COMBATE A FRAUD in a clear, transparent and objective manner so that holders can be properly aware of the whereabouts of their personal data.
• The description of the personal data collected depends on the services contracted and/or made available to the USER. The list of personal data that can be processed can be accessed through the link: https://docs.combateafraude.com/docs/api/secoes-validacoes/background-checking-pf/#certid%C3%A3o-de- criminal-background-pf2
• COMBATE A FRAUD does not process sensitive personal data about your racial or ethnic origin, religious conviction, political opinion, union membership or religious, philosophical or political organization, data regarding your health or your sex life.
• COMBATE A FRAUD handles sensitive biometric personal data within the scope of services, if hired by the USER.
• COMBATE A FRAUD only processes data that is strictly necessary to prevent fraud and combat irregularities.
• We are constantly improving our products and creating new ways to better serve our USERS. With this privacy policy we intend to clarify the privacy rights and obligations involved in our relationship. All COMBAT FRAUD products are added daily.

LEGAL BASIS USED

COMBAT A FRAUD has legal bases and uses them to collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, eliminate, evaluate or control information, modify, communicate, transfer, disseminate or extract personal data, according to the service provision contract and/or agreed with the USER.

• The legal bases include consent for specific sharing to FIGHT AGAINST FRAUD, contracts and preliminary contractual procedures (where processing is necessary to enter into a contract with the USER) and legitimate interest, provided that such processing does not violate rights and freedoms.
• The holder has the right to deny or withdraw the consent given to COMBATE A FRAUD and/or its USERS, when this is the legal basis for processing personal data, and COMBATE A FRAUD may terminate the performance of its services for this user in the hypothesis of occurrence of such request, EXCEPT there is a legal exception for its maintenance.
• COMBATE A FRAUD only processes Personal Data in situations where it is authorized or with the express and unequivocal consent of the owner provided by him to our USERS (consent to share data with third parties).
• Within the scope of the provision of COMBATE A FRAUD services, we use, by default, the legal basis of legitimate interest for all our services provided. It should be noted that, when COMBATE A FRAUD is the controller of personal data, it may define a legal basis different from those used by the USER accessing our Platform, since USERS may have different purposes for processing the personal data consulted. Therefore, the legal basis for the processing of legal data by COMBATE A FRAUD may have a legal basis and purposes different from those used by the USER.
• COMBATE A FRAUD does not have control mechanisms under the purposes used by USERS, as well as having knowledge if these are legitimate and in compliance with the LGPD. Therefore, it is up to the USER to use the information consulted respecting privacy and within the legal dictates. COMBATE A FRAUD is not responsible if the shared data is used illegitimately and illegally by the USER, as these are legal entities and have a legal duty and zeal to comply with the provisions of the applicable legislation.
• For the processing of personal data considered sensitive, which in the case of COMBATE A FRAUD involves the processing of biometric data, we use the legal exception for consent provided for in article 11, II, g, of Law 13.709/18, which expressly mentions that sensitive personal data may be processed without prior consent in the cases of combating fraud and others, provided for in this paragraph.

PROCESSING PERSONAL DATA

The holder's data is collected to prevent fraud, by collecting data and comparing it with his document or information sent by the USER. COMBATE A FRAUD searches its own databases or those of third-party providers in order to deliver the result of a particular query requested by the USER.

• We use data contained in external sources. Therefore, some data collected is from sources whose responsibility are third parties. COMBATE A FRAUD only uses such data to provide its services within the purpose of preventing fraud.
• COMBATE A FRAUD uses personal data in third-party services to deliver the best resolution for the demand, as well as verify the document or object that is passed to us for verification in the best possible way. Thus, we consult personal data in public and private databases, as an example - DENATRAN, SPC, Serasa, Federal Revenue of Brazil, among others.
• The personal data contained in third-party servers are not the responsibility of COMBATE A FRAUD, since we only operate/search the data contained therein to verify the veracity of the information of the objects analyzed by our services.
• The personal data shared by the USER are used within the scope of the provision and management of contracted, subscribed or reserved services, as well as for the study, improvement and adaptation of the services to their interests and needs, and to speed up the processes of FIGHTING FRAUD and validation /authentication information.
• ‍We work through some personal data provided by our USERS duly agreed in our Service Provision Agreement and/or in documents that precede it. We use the data provided by USERS to cross check with the data we have in our personal databases and partner databases only for the purpose of identifying fraud and attesting to the validity of the document or object submitted to us for analysis in accordance with the agreed services. with USER.
• ‍With each new USER, we align our contracts with updates to better comply with the legislation on the protection of personal data.
• ‍Important note: Personal data will never be shared with other companies for marketing purposes.
• ‍We also use personal data to improve our services and fulfill our administrative and commercial purposes.
• ‍The business purposes for which we use shared personal data include, but are not limited to, accounting, billing and auditing, credit card or other verification, fraud analysis, security, legal and procedural effects, statistical studies and systems development and maintenance.
• ‍Comply with our legal obligations such as the obligation to provide your personal data to the authorities and others brought by legislation.
• ‍The Legal Entities that contract with COMBATE A FRAUD provide guarantees that they are respecting the rights of the holders of personal data that are contained in their databases, requesting specific consent for the sharing of this data with us, according to legal bases, or exceptions provided for by law for sharing such data.
• ‍By sharing personal data with us, the USER ensures that the rights and obligations with the holder of the personal data have been respected to authorize the collection, treatment, use and disclosure of the same in accordance with the rules defined herein, as well as in the respective contracts signed between a FIGHT AGAINST FRAUD and the USER.
• When we identify and materialize a query, the personal data used is stored in our database so that COMBATE A FRAUD has its own solid base to use it in order to optimize and increase the assertiveness of queries made by USERS.
• The USER and COMBATE A FRAUD share the personal database with each other. We are based on the interest of cross-referencing the data in these databases with partner databases in the best possible way in order to provide the most correct service possible to combat fraud and irregularities.
• ‍COMBAT A FRAUD only stores the strictly necessary and adequate data so that it can be obtained with maximum precision if the document or object that is requested from us the information is analyzed correctly.
• ‍COMBAT A FRAUD does not keep excessive or unused data. We use all data for validation.
• ‍The data subject may notify our USERS to exercise their rights and they will notify us of such requirements so that we can process the request. We suggest that the USER inform the contact of our DPO to the data subject.‍

INFORMATION STORAGE TIME

The personal data collected are treated in compliance with the applicable legislation and kept in specific databases created for this purpose.

• ‍The period of time during which the data is stored varies depending on the purpose for which it was collected, if there is no specific legal requirement. COMBATE A FRAUD may keep your Personal Data after receiving the deletion request to guarantee the necessary deadlines to comply with legal obligations, resolve disputes, maintain security, prevent fraud and abuse and ensure compliance with contracts.
• Personal data that are stored after their elimination from the main treatment systems (Amazon Web Service) are kept in separate spaces.

PERSON RESPONSIBLE FOR PROCESSING PERSONAL DATA

COMBATE A FRAUD may treat the personal data shared as a controller, that is, come to make decisions about the purpose and for which purposes the data collected will be used internally by COMBATE A FRAUD if this is not prohibited by USERS in a way expressly and by mutual agreement.

• If requested by the USER, FIGHT AGAINST FRAUD can only assume the position of operator of personal data in relation to the data shared by its USERS.
• COMBATE A FRAUD is committed to respecting legislation on privacy protection, as well as acting ethically and in good faith. COMBATE A FRAUD is attentive to act in accordance with the legal bases and purposes of combating irregularities, thus, there is legal justification for the processing of the personal data that we have.

SHARING WITH THIRD PARTIES

COMBATE A FRAUD may disclose the Personal Data collected to third parties, in the following situations and within the limits required and authorized by law:

(i) With its USERS when necessary and/or appropriate for the provision of related services;

(ii) With COMBATE A FRAUD service providers and individuals hired to perform certain activities and services on behalf of COMBATE A FRAUD;

(iii) With suppliers and partners to provide the services contracted with COMBATE A FRAUD (such as information technology, accounting, among others);

(iv) For organizational administrative purposes such as: research, planning, service development, security and risk management;

(v) When necessary as a result of legal obligation, determination of competent authority, or court decision.

• In the event of sharing Personal Data with third parties, all subjects mentioned in items I to VI must use the shared Personal Data consistently and in accordance with the purposes for which they were collected (or with which the User previously consented) and as provided by this Privacy Policy, other website or country privacy statements, and all applicable privacy and data protection laws.

PERSONAL DATA HOLDER'S RIGHTS

The holder of personal data has the right to request from COMBATE A FRAUD, when it is in the condition of controller of the respective personal data, at any time, through DPO Tiago Borre, e-mail: dpo@combateafraude.com, the following rights:

(i)‍ confirmation of the existence of treatment;

(ii) access to data held by the controller;

(iii) the correction of incomplete, inaccurate or outdated data;

(iv) the anonymization, blocking or deletion of data, provided they are considered unnecessary, excessive or treated in breach of the provisions of the LGPD;

(v) the portability of your personal data to another service provider;

(vi) deletion of personal data when previously given consent is withdrawn;

(vii) the relationship with whom your data was shared;

(viii) the information that you can refuse consent and what its consequences are;

(xi) the revocation of consent, when this is the legal basis used.

• In no way and under no circumstances does the person transfer the condition of owner of personal data to another, since these data belong exclusively to their holders.
• The controller may keep the data necessary for the execution of the service if there is a legal basis for the continuity of the processing of personal data. The necessary data that has been deleted will no longer be processed by COMBATE A FRAUD.
• The deleted data are removed from the network used for the processing of personal data and transferred to a secondary/alternative network that were stored only to comply with legislation, regulations and court decisions for the time defined by these decisions.

CORPORATE GOVERNANCE OF PERSONAL DATA

COMBATE A FRAUD together with its legal department and DPO (person in charge of personal data) completed the preparation of its Regulations for Corporate Governance of Personal Data that bases the treatment within the internal scope of COMBATE A FRAUD. This document deals with the personal data of USERS, collaborators, partners, employees, among others who have some relationship with COMBATE A FRAUD.

• This document aims to adapt the best practices for the treatment of personal data that we have in our scope of operation to FIGHT AGAINST FRAUD. The aforementioned regulation complies with the provisions of article 50, caput, and its paragraphs, on governance and good practices in the protection of personal data.
• COMBATE A FRAUD has other policies that are analyzed together in terms of good practices and governance, such as the documents: (i) Information Security Policy; (ii) Business Continuity Plan; (iii) Regulations for Response to Information Security Incidents; (iv) Access Control; (v) Clear Screen/Desk Policy; (vi) Encryption Policy; (vii) Backup Policy; (viii) BYOD policy; (ix) Remote Access Policy; (x) Regulatory use of Acceptable Use of Information Assets; (xi) Malicious Code Protection Policy; (xii) E-mail Services Usage Policy; (xiii) other policies under development.
• COMBATE A FRAUD has an internal General Information Security Committee (CGSI) and the General Committee for the Protection of Personal Data (CGPD), which have duties in accordance with the above Personal Data Governance Regulations to better protect and respond to correct and safer processing of personal data with internal members related to the functions performed by the committees.
• COMBATE A FRAUD also has solid governance in IT (information technology) so that our professionals are educated about privacy protection when implementing and protecting our network architecture and computer services from leaks of personal data. of the Amazon Web Service (AWS) system, by itself, is already an effective mechanism for complying with good privacy and information security practices.

SAFETY MEASURES ADOPTED

COMBATE A FRAUD is committed to ensuring the confidentiality, protection and security of personal data, through the implementation of appropriate technical and organizational measures to protect them against any form of undue or illegitimate treatment and against any accidental loss or destruction thereof.

• We have systems and teams that guarantee data security, creating and constantly updating our governance, policies and procedures that prevent unauthorized access, accidental loss and/or destruction of personal data.
• ‍All Personal Data will be stored in the COMBATE A FRAUD database or in a database maintained “in the cloud” by the contracted service providers, having as its main storage base the Amazon Web Service (AWS) service, which are duly in accordance with current data legislation.
• Always committing to comply with the legislation relating to the protection of personal data shared by USERS, COMBATE A FRAUD ensures that it treats these data only for the purposes of combating fraud and irregularities, with the guarantee that they are processed with the security levels and appropriate confidentiality.
• We are aware of the importance of this fundamental right of holders of personal data, which is why we disclose this Personal Data Protection Policy and other materials to our employees, so that they are aware of their obligations in this matter.
• COMBATE A FRAUD also constantly conducts training, lectures and security measures with its employees so that they can be instructed and educated in the best possible way about the processing of personal data.
• Although COMBATE A FRAUD uses security measures and monitors its system to check for vulnerabilities and attacks to protect its Personal Data against unauthorized disclosure, misuse or alteration, the USER understands and agrees that there are no guarantees that the information will not be accessible. , disclosed, altered or destroyed for breach of any of the physical, technical or administrative safeguards.‍

TECHNIQUES USED

COMBATE A FRAUD values ​​the security and privacy of the USER and the holders of personal data in our services and applications available. We use the following security measures:

(i) Encryption;

(ii) Use of VPN;

(iii) Access control;

(iv) Procedures, management policies and training;

(v) Rules on Corporate Governance of Personal Data;

(vi) Protection Mechanisms Contained in Amazon Web Service (AWS).

• Among other technical and administrative measures.
• COMBATE A FRAUD does not anonymize personal data, since knowledge of the information is necessary for the result of the query. All data used are necessary for the correct identification and assertiveness of the query requested by the USER.
• Here at COMBATE A FRAUD, we respect and carry out the best practices in terms of security and protection of personal data, promoting actions and improving systems to effectively protect all the data that the USER makes available to us.

COOKIE STORAGE

Like most websites, we use cookies and similar technologies to diagnose activity on our service and store information about it. Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

• ‍The USER can instruct his browser to refuse all cookies or to indicate when a cookie is being sent.
• ‍The USER can modify the configuration of his browser to refuse cookies, if he prefers.
• COMBATE A FRAUD only uses cookies to improve your experience with our services.
• The USER can contact us for more information about cookies and their elimination.

SPECIFIC CLAUSES FOR PERSONAL DATA PROTECTION IN OUR CONTRACTS

We enter into a Service Provision Agreement with our USERS in which our legal department is involved to insert contractual clauses and share guarantees for the best and legal development of this service. We inform you about the General Law for the Protection of Personal Data, as well as we write clauses so that our USERS provide the necessary guarantees so that we can share personal data in order to prevent fraud.

The “terms and conditions of use” and this “Privacy Policy” made available on our website, containing more provisions on the protection of personal data, are subsidiarily applied to our service provision contract.

PERSONAL DATA PROTECTION OFFICER (DPO)

• COMBATE A FRAUD has also appointed a Data Protection Officer (DPO), to monitor compliance with applicable policies and regulations regarding the protection of personal data. Contact with the DPO will be made via email dpo@combateafraude.com.
• If COMBATE A FRAUDE updates this Privacy Policy, such changes will be published in a visible manner on the COMBATE A FRAUDE website, and it is up to the user to periodically monitor updates to this Policy on the COMBATE A FRAUDE website. This Policy is valid from questions regarding the privacy policies of the website, please contact us through the Data Protection Officer service email.
• This privacy policy is subject to the Law of the Federative Republic of Brazil and the Judicial District Court of the city of Rio de Janeiro is competent to resolve any controversy in relation to it.

‍