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LGPD - Cookie Management

What is a cookie?

A cookie is a small text file containing information, which is saved on the hard disk of your terminal (e.g. computer, tablet or cell phone) when you visit a website with your browser software.

It is transmitted by a website server to your browser.

 

The cookie file allows its issuer to identify the terminal to which it is registered, for the duration of validity or registration of the cookie in question.

Only the issuer of a cookie can read or modify the information it contains.

Why do we use cookies?

These cookies are issued and deposited by Veripag. They have a very short lifetime, for most, the time of the session, and at most one year.

Audience measurement cookies - statistics

These cookies collect information about how visitors use a website. For example, the number of visits, the most visited pages, etc.

 

The data collected is kept for a period of twenty-four (24) months and is not transferred to third parties or used for other purposes.

How to manage cookies?

You can manage cookies. Any setting you make will likely modify your Internet browsing and your conditions of access to certain services that require the use of cookies.

You can choose at any time to express and modify your wishes regarding cookies, by the means described below.

Configuring Your Browser

You can configure your browser software so that cookies are stored on your terminal or, on the contrary, that they are rejected systematically or according to their issuer. You can also configure your browser software so that the acceptance or rejection of cookies is offered to you from time to time, before a cookie is likely to be saved on your terminal.

The configuration for each browser is different and is located in the help "menu" of your browser.

Options on our site

During your first visit to our site, we suggest that you accept the collection of your navigation data using the "Accept" button. If you object to the use of cookies, browsing the rest of our site will be impossible.

When you agree to the installation of cookies, a consent cookie is installed. Consent cookies must remain on your terminal equipment.

Please note that a cookie is based on and takes into account your choice options. If you delete all cookies stored on your terminal (via your browser), we - or our service providers - will no longer have your choices for this option.

LGPD -FAQ

Context

Law 13/709 (2018), known as the General Data Protection Law (LGPD), aims to protect personal data, privacy and the free development of the personality of the natural person, therefore imposes measures to be respected by both natural persons and public and private legal entities with regard to the processing of personal data.

 

The purpose of Veripag (a Lyra Group company), through this document, is to inform its customers, users of the Cyclopay Platform, about its obligations in the context of the LGPD, respecting what is applicable to its activity in the processing of personal data, such as: What data do we collect? For what purposes? With whom we share it, among other questions related to LGPD.

What are our responsibilities?

Veripag is a specialized technology service provider that developed and makes available the Cyclopay Platform for automating recurring payments.

We provide services exclusively to other companies, B2B market, so in the context of LGPD, Veripag is situated as an Operator, since the treatment of any personal data is limited to the management and security of the data that our customers send us within the scope of the services provided.

Thus, as the Operator, we adopt good practice technical and administrative security measures to protect the personal data provided by our customers.

What are our security measures?

For good data management and protection, Cyclopay implements the following security actions:

- PCI-DSS Certification;

- Information Security and Confidentiality Policies;

- Secure servers and data backup;

- Redundant and secure data centers;

- Firewalls;

- Encryption for file transfer;

- Protection by means of authentication;

- Headquarters with monitoring, access controls, and restricted environments;

- Regular audit;

- DPO appointment.

What personal data do we handle?

We process personal data strictly necessary for the services we provide.

We may receive personal data from different categories and by different means, such as:

- Information regarding the identity of our clients' legal representatives, necessary for the signing of contracts, such as: name, e-mail, and professional phone number;

- Identification and security authentication data, in particular during the use of the back office tool (technical records, digital evidence, security information);

- Transaction data required to provide the service and the technical analysis of these transactions (first and last name, e-mail, payment method used, shopping cart, payment amount, IP address);

- Databases provided by official agencies, such as: Internal Revenue Service, Board of Trade;

- Databases sent by our partners or service providers, always necessary for our activity;

- Third-party databases, such as business intelligence and anti-fraud services.

What are the purposes of the processing of personal data?

The main purpose is always to provide the Platform services offered by Veripag.

In addition, personal data can be used for

- Comply with our legal and regulatory obligations (responses to official requests from duly authorized public or legal authorities);

- To enable the fulfillment of our legitimate interests, including:

- Optimizing our risk management process;

- Legal defense of our interests (proof of transactions or operations);

- IT management and business continuity, including personal security;

- Fraud prevention;

- Debt recovery / litigation;

- Customization of Cyclopay's commercial offers;

- Business development.

With whom do we share personal data?

Personal data may be shared with other companies within Lyra Group or with our partners and service providers/suppliers exclusively for purposes related to the execution and fulfillment of the contract.

We take care that these third parties implement measures to ensure adequate protection of your personal information.

Data may also be shared at the request of legally authorized administrative and judicial authorities.

Your personal data is not used by us to provide third parties unnecessary for our business, we do not share data for any other purpose.

What personal data do we archive and for how long?

We take all necessary measures to ensure the security and confidentiality of your personal data in order to prevent their loss, alteration, destruction or use by unauthorized third parties.

We only store data that is essential and necessary to fulfill our responsibilities or to comply with our legal obligations.

For example, we store personal data related to credit card payments captured by our payment gateway for 15 months.

With regard to our B2B customer data, most of the information is retained during the contractual relationship and for 5 years after its termination.

Data breach notification

If Veripag becomes aware of any Personal Data breach it will notify its customers, within the due legal timeframe. The notification will be accompanied by all relevant documentation to enable the data controller to inform the competent authorities of such breach.

Privacy Policy Changes

Veripag reserves the right at any time to modify, change, add or remove portions of this Policy.

So you can always refer to the latest updated version, available on our website https://www.cyclopay.com.

If you do not agree with any provision, you should not access our Site and/or use our Services.

Contact channels

For questions or clarifications regarding the LGPD, you can contact our DPO (Data Protection Officer) by e-mail at: dpo@lyra-network.com.br

LGPD - Veripag Cyclopay Platform

The present policy formalizes our commitment to the use of your personal data and specifies the types of personal data that Veripag (a Lyra Group company) needs to collect, the purpose, the treatment and your rights, for the use of its platform called Cyclopay.

We describe how we use information during your relationship with Veripag (whether during your visit to our site, as part of our contractual relationship, when using our services, etc.) and tell you how Veripag, its partners and its subcontractors may use it.

We pay great attention to the treatment of your data and to the confidentiality of the personal information you entrust us with.

All processing of your personal data is carried out in compliance with the LGPD.

By using our Site and/or our services, you signify your agreement to all of the provisions hereof.

Veripag reserves the right at any time to modify, change, add or remove portions of this Policy.

If you do not agree with any provision, you should not access our Site and/or use our Services.

Therefore, you can always consult the latest updated version, available on our website https://www.cyclopay.com.

What personal data is collected?

The concept of "personal data" means any information relating to an identified person or a person who can be identified, directly or indirectly, through that data.

 

When Veripag collects personal data, this collection is performed with full transparency according to the terms of the contract, and our Privacy Policy, and providing the channels for clarification and contact.

 

You can also make your personal data available in different ways:

 

As a potential customer during a telephone contact or a request for access to our products and services, you may be asked for your full name, e-mail address, phone number, and other information that you voluntarily communicate to us in order to provide you with personalized service and to respond effectively to your requests;

 

As a customer, information regarding your identity and/or that of the legal representative, necessary for your contract (full name, corporate e-mail, phone number, job title, identification and authentication data, in particular in the use of your back office (technical records, computer scans, security information);

 

As the end user of our services, transaction data, necessary for the provision of the service and the technical analysis of these transactions (name, name, e-mail, encrypted card number, card expiration date, basket, amount, IP address);

 

As part of our activity through the licensing of the Cyclopay Platform, in the SaaS modality, we commit to process minimum personal information necessary for the use of the set of services provided, such as for the creation of recurring sales plans and other information related to our legal obligations.

 

Veripag also collects the data that you voluntarily declare through the contact form available on our website https://www.cyclopay.com, in particular at the time of your contact request or when you subscribe to the newsletter.

We may also collect personal data that you have voluntarily provided to us during your participation in events organized by Veripag, as well as information that appears on professional social networking accounts and pages (e.g. LINKEDIN) that you have made public.

For what purposes will your personal data be collected?

The processing of personal data of potential clients, customers, users or partners is authorized for the purposes of establishing, executing or terminating our business and contracts.

We use the personal data communicated to us to contact you, provide information about our products and services, formulate commercial proposals, establish a contractual relationship and mainly to provide the contracted services, among others.

 

This data is intended exclusively for Veripag and its partners in the execution of our services, we do not share data that is not necessary for the services provided.

Personal data may be processed and collected on paper, computer, spreadsheets, and also in any communication medium (mail or e-mail or by telephone: including SMS, MMS, etc.), and by any other electronic means via Website or application).

 

As part of the performance of our service, your personal data is required to enable us:

- Ensure the smooth running of our business relationship;

- Ensure the proper execution of the contract;

- Personalize our communication with you, based on your preferences, needs and choices;

- Customize our Services, in particular by customizing the Site according to your observed and/or stated preferences and needs;

- Perform operations related to prospecting and commercial requests;

- Customize commercial offers according to your needs;

- Develop business statistics, analysis and marketing operations;

- Manage debt collection;

- Follow your comments and evaluations on the web pages edited by us and hosted on our Social Network sites;

- Manage requests to exercise rights related to the use of your data.

 

As part of our activities related to the Cyclopay Platform, your data is also required to:

- The correct execution of services, such as maintaining payment plans;

- Provide proof of Payment Transactions and the performance of the Services;

- Manage debt collection;

- Fighting fraud;

- Process complaints and disputes in your customers' payment transactions.

With whom do we share personal data?

Personal data may be shared with our partners and subcontractors, as well as LYRA group companies or third parties in the following cases:

- For the proper execution of the contract;

- To transmit the data to the judicial authorities as required by law;

 

Veripag will not transmit your personal data to third parties who may use them for direct commercial and/or advertising purposes, without your consent.

However, as contractually agreed, Veripag may be obliged to transfer temporarily and securely to third parties (partners, subcontractors), some personal data that are necessary for the maintenance of our services, to fight fraud and more generally any prohibited activity. Our partners comply with this privacy policy by applying all appropriate security and confidentiality measures.

How long is personal data kept?

We keep your personal data for as long as necessary for the proper execution of the contract and for the required legal safekeeping time, as well as to protect Veripag's rights.

 

In this way:

- Audience measurement statistics and their raw site traffic data are not kept for more than twenty-four (24) months.

- Bank details are kept for fifteen (15) months.

- Your personal data relating to an information request (name, name, product or service, e-mail address, phone number, etc.) is kept for a period of five (5) years from the request. However, we may delete it at any time at your request.

 

However, at the end of the time periods mentioned above, including as necessary from your request for deletion, your personal data may be subject to provisional archiving in order to comply with our legal, accounting and tax obligations (such as the obligation to store invoices for a period of 5 (five) years established in Article 173 of the National Tax Code)

In the event of a dispute, including in relation to Veripag and the Cyclopay Platform, the aforementioned personal data, as well as all information and documents containing personal data tending to establish the facts susceptible to criticism or relating to non-payment (full name, date and place of birth, nationality, address, telephone numbers, e-mail address) may be kept during the procedure, which may last longer than those indicated above.

What security and confidentiality measures are in place?

For a good data management and protection, Veripag in its Cyclopay Platform implements the following security actions:

- PCI-DSS Certification;

- Information Security and Confidentiality Policies;

- Secure servers and data backup;

- Redundant and secure data centers;

- Firewalls;

- Encryption for file transfer;

- Protection by means of authentication;

- Headquarters with monitoring, access controls, and restricted environments;

- Regular audit;

- Appointment of the DPO.

What are your rights?

Within the limits of our legal obligations and when this right is applicable, the LGPD allows you the right to information about the details of your data processing.

These rights relate only to the personal data of our customers and not to that of the end users (buyers).

 

You have the right to:

- Know what personal data is processed and how it is used;

- Request your update, in case your personal data is incorrect;

- Request the deletion of personal data in accordance with applicable laws;

- Request the portability of your data;

- Request limitation of processing when you contest the accuracy of the data, when its processing is unlawful, or when you need it for the establishment, exercise or defense of your legal rights.

 

In case of opposition to the processing of personal data the services of Veripag -Platform Cyclopay can no longer be used.

To exercise these rights, you should contact our service channels.

Veripag will respond within 30 days of receipt of the request, and if necessary, this period may be extended up to 60 days given the complexity and number of requests. You will be informed of this extension and the reasons for the postponement upon receipt of the request.