Privacy Policy | Crediado
May 27, 2022
This privacy policy ("Policy") explains our policy regarding the collection, use, disclosure, and transfer of your information by DIGICASH DO BRASIL LTDA. or any of its affiliates ("we" or "us" or "our"), which operates the website https://crediado.com ("Site"), the "Crediado App" (the "App") available on the Google Play Store, iOS, and other similar platforms, and other services, including but not limited to credit/payment registration, communicating quotas/balances through the site and app, any mobile or internet-connected device or otherwise (collectively the "Crediado App Service"). This Policy is an integral part of the Terms of Use of Crediado App Services. The capitalized terms used here but undefined shall have the same meaning as attributed to them in the Terms of Use. Users (as defined below) are requested to read this Policy in conjunction with the Terms of Use.
The App/Site (i) provides an online digital ledger/book where Users can record their accounting entries with their respective customers and (ii) also allows Users to generate a payment link that can be sent to their respective customers, and the customers could use the payment link and make payment of the amount to the Users in settlement of their obligations to the Users (collectively, "Services"). Please note that "Services" includes any future services we may provide or propose to provide.
As we update, improve and expand the Crediado App Service, this Policy may change, so please refer to it periodically. By accessing the Site, App, or otherwise using the Crediado App Services, you agree to the collection, storage, and use of the personal information you provide (including any changes provided by you) for any of the services we offer.
We respect the privacy of the users of the Crediado App Services ("Users" or "you") and are committed to reasonably protecting it in all aspects. The information about the User collected by us is: (a) information provided by Users and (b) information automatically tracked while using a mobile device with the Crediado App Services enabled (collectively referred to as "Information"). By using the Crediado App Services, you agree to this Policy. If you do not agree with any term of this Policy, please do not use/take advantage of the Crediado App Services.
Information provided by users
To enjoy certain Services on the Crediado App, Users must provide certain information, which may include:
a) Name - This app optionally requires the user's name to be displayed to their customers during the money collection process.
b) Email address - The app requires the user's email to log in.
c) Phone number - This app optionally requires the user's phone number to be displayed to customers during the money collection process.
d) Business entity information - This app optionally requires the company name and logo to be displayed to the user's customers during the money collection process.
e) User account number - This app optionally requires the user's banking information to be displayed to their customers during the money collection process.
f) Camera - This app optionally requires camera access to attach a photo during the sales process.
g) Contact list - This app optionally requires contact access to easily identify a customer during the sales process.
h) GPS - This app optionally requires GPS access to find other network users while using the location filter by distance. It does not show your location at any time, only your relative distance from the user.
i) Photo library - This app optionally allows you to add an image from your library as a receipt during a sale.
j) Notification - This app sends notifications when a customer makes an online payment to you. Also, to remind you about money collection with your customers.
We may access a user's installed apps inventory and treat this data as personal or confidential data subject to this Policy, secure transmission, and prominent user disclosure requirements.
All information depends on the service, and we may use the information to provide the services, maintain, protect, and improve the Crediado app services, and develop new services.
We may also use your email address and phone number without further consent for marketing, non-marketing, or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about Crediado App Services updates, billing, etc.).
All information provided by you will not be considered personal information if it is freely available and/or accessible in the public domain or is not considered personal information under applicable law. Additionally, any reviews, comments, messages, blogs posted/uploaded/transmitted/communicated by Users in the public sections of the Site or in an app store (such as the App Store or Play Store) become published content and are not considered personal information subject to this Policy.
Should you choose to decline to submit Information on the Crediado App/Site, we may not be able to provide certain services on the App/Site to you. We will make reasonable efforts to notify you at the appropriate time. In any case, we will not be liable for the denial of certain services to you for failing to provide the necessary Information.
When you register for the Crediado App Services, we may (at our discretion) contact you from time to time about updating your information.
Information automatically tracked while using the app or site
Credit/Payment Records: We store all your credit/payment records in a cloud-based environment using third-party infrastructure service providers.
Customer Information: We store your customers' contact information. We also keep a record of all communications related to credit/payment to customers.
Demographic and related information: We may refer to other demographic and other sources of information to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track user behavior on the site.
Log File Information: Our Servers automatically collect limited information about your device's connection to the Internet, including your IP address, when you visit our Site or use the App. We receive and automatically record information from the app and/or your browser, including but not limited to IP address, device or computer name, and operating system. We may also collect log information from your device, including but not limited to your location, IP address, device name, device serial number, or unique identification number (e.g., UDID on your iOS device, Android ID or ADID on your Android device), device operating system, browser type and version, CPU speed, and connection speed, etc.
Cookies: To improve the responsiveness of our Site for our Users, we may use "cookies" or similar electronic tools to collect information to assign a unique and random User Identification (User ID) to each visitor to understand the individual interests of the user using the identified computer. By continuing to visit the Application/Site, you agree to the use of cookies and similar technologies for the purposes described in this Policy. If you prefer not to receive cookies or web beacons, please stop using the Services or refer to your third-party browsing and cookie settings. We use cookies and other technologies to analyze and optimize our sites, as well as for marketing purposes. Our partners may also assign their own cookies to your browser, a process we do not control.
Link to third-party advertisement sites/servers
The Site may include links to other sites, such as advertisers, blogs, content sponsorships, vendor services, social networks, etc. These sites are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can determine where you are by checking the URL in your browser's address bar), the use of any information you provide is governed by the privacy policy of the operator of the site you are visiting, and we make no representations or warranties about how your information is stored or used on third-party servers. This policy may be different from ours. If you cannot find the privacy policy of any of these sites through a link on the site's homepage, please contact the site directly for more information.
Information Sharing
The information (including personal information) collected may be shared with our affiliates and group companies to the extent necessary for our internal business and/or administrative purposes and/or general corporate operations, and with any third-party service providers, including marketing partners, and the User consents to the same. We will take reasonable steps to ensure that these third-party service providers are required to protect your personal information and are also subject to appropriate confidentiality/non-disclosure obligations and comply with applicable data protection laws. These entities with whom we share the information may market to you as a result of such sharing, unless you explicitly opt out.
The user explicitly consents that we may access your SMS, contacts in your directory, location, and device information and may request you to provide your PAN details and Know-Your-Customer (KYC) information to verify your eligibility for certain products/services, including but not limited to credit and payment products, etc., to enhance your experience and provide access to services offered by us, our affiliates, or other third-party service providers (including lenders).
Additionally, the User also consents to the sharing of Information (including sensitive personal information) when requested or required by law or by any court or government agency or authority to disclose, for the purpose of identity verification, or for the prevention, detection, investigation, including cyber incidents, or for prosecution and punishment of offenses. Such disclosures are made in good faith and belief that such disclosure is reasonably necessary to enforce the Terms of Use or to comply with applicable laws and regulations. No personal information of an individual user, such as name, phone number, email address, spending data, card details, etc., would be shared with any other user and/or third party unless explicitly approved by the individual user in question. We may also present information related to credit records, user spending, patterns, and user data tracked by us only in the form of aggregate statistics about data such as general application usage by date, time, balances, etc., on our application/site or to our partners.
By using the Crediado Application Services and providing information to us, Users agree and consent to the disclosure, transfer, storage, and processing of personal information (including sensitive personal information) by us in any other countries for our affiliates, group companies, and third parties. While our main motive is to protect the disclosure of personal information (except as per the provisions of this Policy) of Users, Users may note that the countries where their Information may be stored may not have data protection laws similar to the countries where they are located.
Accessing and Updating Personal Information
When Users use the Site (or any of its subsites)/Application, we make good faith efforts to provide Users, as and when requested by Users, access to their Information and will further ensure that any personal or confidential personal data or other information deemed inaccurate or incomplete is corrected or altered as possible, subject to any requirement for such personal information or confidential personal data or information to be retained by law or for legitimate business purposes. We ask individual Users to identify themselves and specify the Information requested to be accessed, corrected, or removed before processing such requests, and we may refuse to process requests that are excessively repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for example, requests regarding information residing on backup tapes) or for which access is not necessary. In any case, where we provide access and correction of information, we perform this service free of charge, except if it requires a disproportionate effort. Due to the way we maintain certain services, after you delete your information, residual copies may take some time before they are deleted from our active servers and may remain in our backup systems.
Information Security
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data, including accidental or intentional handling, loss of access by unauthorized parties. This includes internal reviews of our data collection, storage, and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All Information collected on the Crediado App is securely stored within the controlled database. Access to the servers is password-protected and strictly limited.
Our security measures are regularly reviewed and updated to reflect technological developments. Regardless of where your personal information is transferred or stored, we take all reasonably necessary steps to ensure that personal information is kept secure; however, please understand that no data transmission over the Internet or any other public network can be guaranteed to be 100% (one hundred percent) secure.
We strive to ensure compliance with the requirements of applicable data protection laws to ensure the protection and preservation of User privacy and Personal Information. We have physical, electronic, and procedural safeguards that comply with the laws of the specific jurisdiction to protect the User's Personal Information. By accepting the terms of this Policy, you agree that the standards and practices implemented by us are reasonable and sufficient for the protection of your personal information.
We will contact you about any breach of security, confidentiality, or integrity of your electronically stored unencrypted Personal Information via email or any other feasible means as promptly as possible and without undue delay, to the extent consistent with legitimate law enforcement needs, and will take all necessary steps to determine the scope of the breach and restore the reasonable integrity of the data system.
Purpose of Data Processing
We will only collect and process Personal Information about you where we have a legal basis to do so. Our primary purpose in collecting your information, including your Personal Information, is to deliver the personalized Crediado service and its various features. Please note that if you choose not to provide us with consent to collect your information, including Personal Information, we may not be able to fulfill the contract with you. When we refer to 'performing the contract,' we mean the Terms of Use applicable to your use of the Crediado Service, which means you may not be able to access certain features of the Crediado Service, or we may not be able to provide you with the Crediado Service in its entirety.
For example, we use your information when we need Personal Information to perform the contract with you (for example, to provide you with the Platform or our services) to:
Register you on our platform.
Provide you with technical or customer support, including addressing support queries related to, but not limited to, payment processing or diagnosing server issues.
Send you transactional emails/SMS or to provide information, direct marketing, online and offline advertising, and other materials related to products, services, and other offers from time to time in connection with the Crediado Service or its parent, subsidiary, and affiliated companies ("Platform Entities") and their joint ventures.
Determine your geographic location to deliver localized content, including advertisements, personalized recommendations, allow you to continue watching/using previous content at another time, and determine your Internet service provider to troubleshoot a technical issue and help us quickly and efficiently respond to queries and requests.
Provide you with a personalized service and experience; we do this by linking some or all of your personal information, such as transactions made with Crediado, with your activity on our platform across all your devices and associating and storing this information with a unique platform-generated identifier created for each user (both guest and registered user). When a guest user later registers and creates an account, the information and data related to that user's previous activities are added and associated with the registered account.
In other contexts, if the processing of your personal information is subject to the EU General Data Protection Regulation, we will use your personal information when processing is in our legitimate interest and not overridden by your fundamental rights and freedoms (for example, our direct marketing activities in line with your preferences), such as:
Displaying or targeting ads on the Platform based on your registration or profile information, location, and/or activity on the Platform across all your streaming devices (including inferred information from usage and log data) associated with your device's advertising identifier (IDFA, GAID, etc.)—this is commonly referred to as 'interest-based advertising.' We also display contextual ads on the Platform, but they are not targeted to any specific user and do not make use of any information that personally identifies or accurately locates you (contextual advertising is advertising that we target based on the content being viewed, for example, if you are watching a specific sports event, we may show ads for companies or products related to that specific sport or the most likely age group watching).
Research, analyze, and understand our audience and what content and advertising they may view, watch, or otherwise engage with to improve our service (including our user interface experiences and security features); assess your eligibility for certain types of offers, products, security); assess your eligibility for certain types of offers, products, or services and market those products or services to you; conduct analytics and perform customer research, including general market research or surveying our customers' needs and opinions on specific issues, generate sales and traffic patterns and analyze the effectiveness of advertising, both anonymously (for example, aggregating data) and on an individual basis (if legally permitted), in combination with other information collected from tracking technologies and aggregate it with information collected from other Users using our Platform, to try to provide you with the Services and a better experience on the Platform. For example, one of the ways we use this information is to count the number of times an ad or other content is viewed, as this may be the metric by which our advertisers pay us. This information is compiled and analyzed on an aggregated basis.
Allow you to participate in interactive features such as game events on the Platform, providing a relevant gaming experience, determining and declaring winners, and providing prizes.
Analyze and evaluate the effectiveness of our advertising by determining which media sources should be paid for delivering a desired action, for example, users installing our app or subscribing (also known as 'attribution'), so that we pay for demonstrated value and not overspend.
We will use your personal information with your explicit consent as follows:
When you agree to share information regarding frequently used apps on your device, we will combine this information with other information you provide us on the Crediado Service to display more relevant ads to your areas of interest.
Or otherwise whenever the law requires us to obtain your permission or when we have stated that we may seek your permission in this Privacy Notice. In some contexts, we use your personal information when we have a legal obligation to do so or to protect your vital interests or those of another person:
Prevent, detect, and investigate potentially prohibited or illegal activities, including fraud, and enforce our terms (such as determining eligibility for free trials);
Confirm your identity if you are exercising legal rights;
Notify you about changes to the Terms of Use or this Privacy Notice;
Fulfill our obligations and enforce our rights arising from any contracts entered into between you and us/our distributor.
When you access or use the Services or send us any data, queries, requests, or communications via our Support email, you understand that you are communicating with us electronically and that we may respond by electronic means, such as email.
Withdrawal of Consent
A user may withdraw their consent to the processing of their personal information at any time, with effect for the future. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal information when such collection, use, and disclosure without consent is permitted or required by applicable laws.
Organization Responsible for Data Collection
All Crediado App Services are currently provided and regulated by DIGICASH DO BRASIL LTDA, and therefore, DIGICASH DO BRASIL LTDA. is responsible for the collection, storage, and processing of Users' personal information.
Updates/Changes
We may amend our Policy from time to time to incorporate necessary changes in technology, applicable law, or any other variant. In any case, we reserve the right to amend (at any time) the terms of this Policy or the Terms of Use. Any changes we make will take effect immediately upon notice, which we may provide by posting the new policy on the Site. Your use of the Crediado App Services after such notification will be deemed acceptance of such changes. We may also make reasonable efforts to notify you by email. In any case, we recommend that you review this Policy periodically on the Site to ensure you are aware of the latest version.
Questions
If you have any complaints related to the processing of information provided by you, please contact roger@altbank.co
Disclaimer
If any personal information is shared by you with us, which has not been requested by us during registration (either mandatory or optional), we will not be responsible for any security breach or disclosure